ML22174A282
| ML22174A282 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 06/22/2022 |
| From: | Ashkeboussi N Nuclear Energy Institute |
| To: | Office of Nuclear Material Safety and Safeguards |
| M Shoemaker NMSS/DFM/MCAB 301-415-7363 | |
| References | |
| Download: ML22174A282 (5) | |
Text
©2021 Nuclear Energy Institute Nima Ashkeboussi June 22, 2022 Updates to the Guidance on Foreign Obligation Reporting Requirements
©2021 Nuclear Energy Institute 2 Advanced LWR Fuels with LEU+
U.S. enrichment facility licensed for >5wt.%
Fuel fabricator regulatory engagement Utility pre-submittal meetings for a >5 wt.% LTA LAR Transportation packages for UF6 >5 wt.%
Category II Fuel Cycle Facility Applicants Advanced Reactor Demonstration Program and other DOE Risk Reduction Awardees utilizing HALEU up to 20 wt.%
Industrys Plan to Deploy Higher Enrichments
©2021 Nuclear Energy Institute 3 Regulatory limits on 5 wt.% enrichments 10 CFR 50.68 and 10 CFR 71.55 SRM-SECY-21-0109 - initiate rulemaking Category II MC&A NUREG-2159 Category II Security Being addressed on a case-by-case basis Staff considering options for a potential rulemaking NUREG-BR-0006/0007 An exchange of obligated material from one material type to another OR any obligation swap for material greater than 5 wt.% is not allowed unless the USG provides prior written approval Current Regulatory Framework Needs Updating
©2021 Nuclear Energy Institute 4 Blending of E1 and LEU+/HALEU E2 material will become a common daily practice at commercial facilities Pre-approval represents a significant and unnecessary burden to industry and government that would impede commerce The language to require pre-approval for any obligation swap greater than 5 wt.% is additionally problematic We appreciate the near-term option of a one-time blanket approval for the life of the facility Must accommodate enrichments up to 20%
Regulatory exceptions are not an ideal long-term solution Challenges Created with NUREG-BR-0006/0007
©2021 Nuclear Energy Institute 5 Revise the definition of E1, and eliminate E2 quantities Revise E1 to greater than natural but less than 20 wt.% and eliminate the E2 definition No indications that this revision would conflict with regulations or international treaties This change does not diminish the level of security and MC&A controls required to be in place Minimal impact and cost Largest volume of reporting is associated with nuclear fuel commerce System coding change easily edit records from E2 to E1 Training for NMMSS users Can coincide with the next planned NUREG update Long-Term Solution