ML18101A004
| ML18101A004 | |
| Person / Time | |
|---|---|
| Issue date: | 04/11/2018 |
| From: | Hector Rodriguez-Luccioni Division of Fuel Cycle Safety, Safeguards, and Environmental Review |
| To: | |
| Duvigneaud D | |
| Shared Package | |
| ML18100B106 | List: |
| References | |
| Download: ML18101A004 (15) | |
Text
RIS 2018-XX Clarification of Export Reporting Requirements for Nuclear Facilities, Equipment, Nonnuclear Materials Hector Rodriguez-Luccioni, PhD Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Cumulative Effects of Regulation April 11, 2018
2 Agenda
- Regulatory Issue Summary
- Exports under a general and specific license
- Additional Protocol Background
- AP Quarterly Reporting Requirements
- Summary
- Point of Contacts
- Questions
3 Regulatory Issue Summary
- Regulatory Issue Summary
- Communicate and clarify NRC technical or policy positions on regulatory matters that have not been communicated to or are not broadly understood by the nuclear industry.
- Inform the nuclear industry of opportunities for regulatory relief.
- Communicate previous NRC endorsement of industry guidance on technical or regulatory matters.
- Provide guidance to applicants and licensees on the scope and detail of information that should be provided in licensing applications to facilitate NRC review.
- Request the voluntary participation of the nuclear industry in NRC sponsored pilot programs or the voluntary submittal of information which will assist the NRC in the performance of its functions.
4 RIS 2018-XX
- Purpose
- Clarification of reporting requirements under 10 CFR Part 110.
- Annual report of the export of components under a general license
- Quarterly reports of exports of components under Annex II of the Additional Protocol
- This RIS requires no action or written response on the part of licensees/exporters.
- RIS is still under NRC process, will be issued in:
- www.regulation.gov (for comments)
- www.nrc.gov
5 Export of Components Licenses
- Specific Licenses - 10 CFR 110.31 (e.g.
reactor coolant pump)
- General licenses - 10 CFR 110.26(a)
- Appendix A, 10 CFR 110
- Reactor pressure tube
- Zirconium tubes
- Reactor internals (e.g. control and rod guide tubes)
- Reactor control rods drive mechanism
- Heat exchangers
6 10 CFR 110.54(c) - Non AP Related
- Annual Export Report o Exports of components under a general license (10 CFR 110.26(a)) shipped during the previous year.
o February 1st of every year.
o Submission to U.S. NRC/Office of International Programs.
o No form required.
7 Additional Protocol Background The IAEA applies safeguards around the world, in non-nuclear weapons countries, pursuant to comprehensive safeguards agreements (CSA) in each country.
The IAEA applies safeguards in weapons countries (U.S., France, China, and Russia), pursuant to a Voluntary Offer Agreement with each country.
- United States: INFCIRC/288 or Voluntary Offer Agreement Model Additional Protocol (INFCIRC/540)
- Focuses on materials and activities, related to the nuclear fuel cycle, that were not previously covered by comprehensive safeguard agreements
- Opened for signature in 1997
8 U.S. Additional Protocol
- U.S. Additional Protocol
- Identical to the model INFCIRC/540, but with a national security exclusion
- Signed by the U.S. on June 12, 1998
- Entered into force on January 6, 2009
- Primary impacts of the U.S. Additional Protocol:
- Reporting requirements: Additional aspects of the nuclear fuel cycle and related activities (e.g. initial declaration, annual updates, and quarterly export reports)
- Annual Reports
- Quarterly Reports
9 10 CFR 110.54(a) - AP related
- Quarterly Export Reports
- Exports under a general or specific license of nuclear equipment, nuclear graphite for nuclear end use, and deuterium shipped during the previous quarter.
- January 15, April 15, July 15, and October 15 of each year.
- Submission to Department of Commerce/Bureau of Industry and Security
- Forms can be found in www.ap.gov
10 Additional Protocol Webpage (www.ap.gov)
11 Quarterly Export Reports (INFCIRC 540, Article 2.a.ix)
For licensees using NRC general or specific license authorizations for exports of specified equipment and non-nuclear material (2.a.ix),
as listed in Annex II of the Additional Protocol to the U.S. - IAEA Safeguards Agreement [INFCIRC/540 (Corrected)]
Most NRC licensees should report as a location using AP-13 found on www.AP.gov, to report directly to Department of Commerce, Bureau of Industry and Security (BIS) every quarter (forms are joint DOC/NRC forms).
Selected facilities under the U.S.-IAEA Safeguards Agreement (Framatome, Westinghouse-Columbia, Global Nuclear Fuel-Americas, and Louisiana Energy Services [URENCO-USA]) should report as sites using AP-M.
12 Additional Protocol-Annex II Example of equipment to be reported under 10 CFR 110.54(a)(1)
- Reactor Control Rods (Annex II, 1.4)
- Zirconium tubes (Annex II, 1.6)
- Reactor Primary Coolant Pump (Annex II, 1.7)
13 Summary NRC Regulation Reporting Requirement License Due Date Submission 10 CFR 110.54(a)
Quarterly report of export of equipment and non-nuclear material described in Annex II of the AP.
Specific or General January 15th, April 15th, July 15th, October 15th.
DOC/BSI 10 CFR 110.54(c)
Annual report on exports of reactor components under a general license established by 110.26(a).
General February 1st NRC/OIP Exporters should check if any of the items exported under a general license
(§110.26(a)) may also need to be reported under AP (§110.54(a))
14 Point of Contacts Please ask questions early and often!
- NRC/NMSS
- Hector Rodriguez-Luccioni hector.rodriguez-luccioni@nrc.gov
- Santiago Aguilar santiago.aguilar@nrc.gov
- NRC/OIP
- Andrea Jones andrea.jones2@nrc.gov Additional resource:
- http://www.nrc.gov/about-nrc/ip/intl-safeguards.html
Questions 15