ML22174A282

NEI Presentation for Public Meeting with NMMSS Users Community to Discuss Foreign Obligation Reporting Requirements for Low Enriched Uranium

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

Updates to the Guidance on Foreign Obligation Reporting Requirements Nima Ashkeboussi June 22, 2022

©2021 Nuclear Energy Institute

Industrys Plan to Deploy Higher Enrichments

• 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.%

©2021 Nuclear Energy Institute 2

Current Regulatory Framework Needs Updating

• 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

©2021 Nuclear Energy Institute 3

Challenges Created with NUREG-BR-0006/0007

• 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

©2021 Nuclear Energy Institute 4

Long-Term Solution

• 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

©2021 Nuclear Energy Institute 5