ML21344A149
| ML21344A149 | |
| Person / Time | |
|---|---|
| Issue date: | 12/13/2021 |
| From: | Mirabelle Shoemaker NRC/NMSS/DFM/MCAB |
| To: | Nuclear Energy Institute |
| Mirabelle Shoemaker DFM/MCAB301-4157363 | |
| References | |
| Download: ML21344A149 (5) | |
Text
Meeting with the Nuclear Energy Institute, the Nuclear Fuel Industry, and Stakeholders to Discuss Foreign Obligation Reporting Requirements for Low Enriched Uranium Mirabelle Shoemaker, International Safeguards Analyst Material Control and Accounting Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 1
Instructions for Reporting Foreign Obligations NUREG/BR-0006 and -0007 provide instructions for reporting foreign obligations on special nuclear material
- Foreign obligations for enriched uranium are assigned to the U-235 isotope weight.
- The NUREGs instruct licensees to report their annual inventory holdings of enriched uranium as belonging to one of four material types:
- E1, for uranium enriched greater than normal but less than 5 percent
- E2, for uranium in enrichment of 5 percent or more but less than 20 percent
- E3, for uranium in enrichment of 20 percent or more but less than 80 percent
- E4, for uranium in enrichment of 80 percent or more
- Reporting by these material types is only necessary for Material Balance Reports (NRC/DOE Form 742) 12/10/2021 2
Reporting foreign obligations on LEU enriched between 5% and 10%
Licensees seeking to process E1 and E2 categories of LEU have requested clarification regarding foreign obligation reporting on products that require blending of E1 and E2 material.
- Appendix F of NUREG/BR-0006 identifies the like-for-like principles for tracking and exchanging foreign obligations.
- Under current reporting instructions (Page F-1 of NUREG/BR-0006),
licensees authorized to possess up to 10% enriched LEU would need to receive approval from the government for each reassignment of obligations from E1 to E2 material.
- To reduce the burden of repeatedly requesting such approvals, industry has suggested that NRC adjust the E2 definition to uranium enriched to 10% or more, but less than 20%.
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Recommendation from Interagency for Licensees seeking Prior Approval related to Foreign Obligations Tracking The NRC and government interagency recommend not redefining the E1 and E2 material types, to avoid confusion with existing guidance.
Alternatively, the interagency recommends the use of prior approval to licensees to assign foreign obligations to LEU in the E1 and E2 material types as necessary for blending.
- Licensees requesting a license amendment to possess LEU up to 10%
enrichment may submit a written request for prior approval of obligation reassignment for their licensed blending operations.
- NRC and the interagency will consider each request as received, and will have the ability to grant prior approval for obligation reassignments between E1 and E2 material.
- Licensees can then ensure that appropriate obligations are assigned to blended products in the correct material type.
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Requests for Prior Approval for Reporting Foreign Obligations on E1 and E2 material NRC-licensed facilities may submit written request to the NRC with the following information:
Proposed date to exchange obligations Quantities of the materials to be exchanged (element weight; isotope weight, if applicable)
Material type and associated obligation(s) of the materials to be exchanged Chemical and physical form of the materials to be exchanged Purpose for conducting the exchange RIS code(s) to be involved in the proposed change Written requests can be copied to Foreign.Obligations@nrc.gov.
Other special requests related to NMMSS reports of any nature can be submitted to NMMSS@nnsa.doe.gov or NMMSS.Resource@nrc.gov.
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