Articles 2 and 3 of the AP specify the State’s obligation for submitting timely declarations containing additional nuclear fuel cycle-related infor­mation. In very generic terms, Article 2 requires that the State provide the IAEA with declarations containing information on all parts of a State’s nuclear fuel cycle — including that which is not required by the State’s com­prehensive safeguards agreement such as uranium mines, nuclear-related manufacturing locations, and nuclear waste sites — as well as any location where nuclear material is or may be present. This would include, for example, information on:

• Research and development activities related to its nuclear fuel cycle[52] including those not involving nuclear material

• All buildings (permanent and temporary) on each declared nuclear site, and upon request of the IAEA, identified locations outside a site which the IAEA considers might be functionally related to the activities of that site[53]

• Locations engaged in the activities relating to the manufacture and export of sensitive nuclear-related technologies[54]

• Exports, and upon a request by the IAEA, imports of specified equip­ment and non-nuclear material[55]

• Uranium mines and concentration plants, as well as thorium concentra­tion plants

• Source material which has not reached the starting point of safeguards as defined in INFCIRC/153 (Corrected)

• Exempted nuclear material

• Processing and storage of high or intermediate level waste containing plutonium, highly enriched uranium or uranium-233 material for which safeguards have been terminated

• Long-term plans for the State’s nuclear fuel cycle development (cover­ing a 10-year period).

Whereas Article 2 defines what is to be provided, Article 3 delineates when the information is to be provided, both initially and on a routine update basis.[56] Depending on the specific Article 2 provision, the relevant update needs to be transmitted (in accordance with Article 3) either quarterly, annually, as requested by the IAEA, or as agreed with the IAEA. There are the following important practical considerations a ‘newcomer’ State may want to keep in mind regarding the provision of information.

• Factors such as the site complexity, regulatory responsibilities, leasing arrangements that include tenants that may or may not be related to the nuclear fuel cycle (e. g., private companies), the temporary existence of construction tents, level of descriptive information to provide, could all add to the complications of preparing the requisite AP declaration. Early discussions with the IAEA, and perhaps other SSACs, are likely to make the process less daunting.

• The IAEA developed guidelines in 1997 to assist in the preparation and formatting of the AP declaration. Since then, the guidelines (IAEA, 2004) have been updated and reissued, and should be considered as an additional source of helpful information.

• It should not be considered unusual if the IAEA has a need for ampli­fication or clarification of information submitted by the State pursuant to the AP. If such an occasion arises, the responsible National Authority[57] will be informed accordingly, and as experience shows, often the issue can be addressed through timely communication between the State and IAEA.

• It is a relatively more serious safeguards matter when a question or inconsistency is brought to the attention of a State. In such cases, it is to the benefit of all parties to resolve the issue(s) in a timely manner through close consultation and good cooperation between the State and the IAEA.

• Computer software[58] to help States with the submission of their AP declarations is available from the IAEA.

Complementary access (CA) is a measure which complements the access rights in the relevant Safeguards Agreement by provisioning the right of the IAEA to go to certain additional locations in a State for specific reasons as provided for in the AP. Complementary access is not an inspection, nor is it a right for the IAEA to go anywhere in a State for any reason what­soever. Its implementation is exercised by the IAEA in accordance with the relevant articles of the AP.

With reference to the provisions of Articles 5 and 9 of the Model Additional Protocol (INFCIRC/540 (Corrected)) (IAEA, 1997a), the IAEA has a right to access all places on the declared sites of facilities and locations outside facilities, all other places where nuclear material is declared located, decommissioned facilities and LOFs, locations declared by the State where other nuclear fuel cycle-related activities are conducted, and other locations (under certain circumstances).[59] When a complementary access is to be performed by the IAEA, it must always be carried out in an objective and impartial manner. Normally, it is initiated via written corre­spondence from the IAEA to the State.[60] The advance notification to the State specifies the location(s) to be accessed, along with the reasons for access and the activities to be carried out during such access. The list of the authorized activities to be performed depends on the location to be accessed. Examples of such activities, as reflected in Article 6 of the Model AP, include visual observation; collection of environmental samples; use of radiation detection and measurement devices; examination of safeguards relevant production and shipping records; examination of records relevant to the quantities, origin and disposition of material; and/or placement of seals and other identifying and tamper-indicating devices specified in Subsidiary Arrangements.[61]

Experience shows that a complementary access can be conducted effi­ciently and effectively the more technically capable the National Authority representative is (regarding the use of IAEA authorized equipment, col­lection of environmental samples, and other safeguards measures permitted under the AP). At certain times, for reasons relating to the sensitivity of information,[62] a State seeks to manage access to selected equipment, tech­nology and processes. In such cases, the State may request ‘managed access’ provision in accordance with Article 7 of the protocol. These considerations are a normal part of the conduct of a complementary access, and the IAEA inspectors are trained to consult with the designated National Authority and the operator to find appropriate alternative methods or options to achieve the objectives of the complementary access.

Depending on the needs of the State concerned, the IAEA may be able to offer other services and technical assistance, such as AP-specific training or regional workshops on safeguards implementation. In addition, several countries (such as Australia, Japan and the United States) have in the past supported outreach programmes for developing countries, including spon­sorship of regional or international seminars and training workshops, which may serve to enhance a State’s technical capability and/or readiness for implementing the AP and its related safeguards commitments. Contact through the respective government mission to the IAEA or directly through the IAEA will often provide an understanding of such possibilities.

One benefit arising from the implementation of the AP is that integrated safeguards (IS) can be implemented in a State where the IAEA has been able to draw a broader safeguards conclusion for the State.[63] IS refers to an optimized combination of all safeguards measures available to the IAEA under the CSA and AP, to maximize effectiveness and efficiency within available resources.[64] With the increased assurances of the absence of unde­clared nuclear material and activities in the State as a whole, implementa­tion of IS takes into account a reduction in the traditional level of safeguards verification effort expended on less sensitive nuclear material (e. g., low enriched, natural and depleted uranium and irradiated fuel). For States with an expanded nuclear fuel cycle, this has been shown to have a significant impact on resource utilization (i. e., shifting the focus to nuclear facilities, activities and material with higher strategic value). The same benefits are available to countries embarking on an expanded nuclear power pro­gramme; therefore, incorporation of the AP as part of a country’s safe­guards obligation should be given due consideration, if it is not already in force.

Should a NNWS decide positively on the inclusion of the AP as part of its safeguards agreement with the IAEA, the IAEA should be consulted early for the provision of advice and support to place the protocol in force. During this process, the State will need to determine which National Authority should have the responsibility for assuring that the objectives of the AP are fully achieved. As part of its options, it may consider adding the AP-related responsibilities to those of its designated SSAC. It is not a requirement, but many countries find this beneficial to both the State and the IAEA. In any case, examples of the type of AP-related responsibilities given to the National Authority include:

• Coordination and preparation for the submittal of relevant AP declarations

• Verification of declarations for correctness and completeness

• Processing and transmittal of declarations to the IAEA

• Responding to IAEA requests for additional information or clarification

• Facilitating the conduct of complementary access

• Resolving any AP-related questions and inconsistencies.