ML23133A014
| ML23133A014 | |
| Person / Time | |
|---|---|
| Site: | 11006444 |
| Issue date: | 05/17/2023 |
| From: | Sabrina Atack NRC/OIP |
| To: | Kuperman A University of Texas at Austin |
| References | |
| Download: ML23133A014 (3) | |
Text
May 17, 2023 Alan J. Kuperman Associate Professor LBJ School of Public Affairs Coordinator, Nuclear Proliferation Prevention Project University of Texas at Austin
SUBJECT:
RESPONSE TO COMMENTS ON U.S. NUCLEAR REGULATORY COMMISSION EXPORT LICENSE APPLICATION XSNM3828
Dear Dr. Kuperman:
Thank you for the comments you submitted to the U.S. Nuclear Regulatory Commission (NRC) by letter dated July 5, 2022, regarding export license application XSNM3828. This application requested to export high enriched uranium (HEU) fuel assemblies to the Belgian Research Reactor No. 2 (BR2) in Mol, Belgium.
Your letter noted your view that SCK CEN, the Belgian operator of BR2, has aggressively pursued conversion to LEU [low enriched uranium] with silicide fuel. However, you expressed that while this may satisfy the legal requirements of the Schumer Amendment to the Energy Policy Act of 1992, the Commission still must address how much HEU to approve for export, over what duration, to comply with the U.S. law and policy of minimizing HEU exports.
You further stated that the license application requests approval for export of considerably more HEU, over a much longer duration, than the reactor would need if it were converted to LEU fuel on schedule by the end of 2026. You acknowledged that any excess HEU may be intended to provide a buffer in the event of delay in the reactors conversion to LEU. Your comment letter concluded that the NRC should not permit export of more HEU than the reactor requires through the end of 2026, unless the reactor operator provides (1) proof of delays in conversion that are beyond the operators control, and (2) proof that the reactor could not operate normally in the absence of additional export of HEU.
The NRC considered your comment letter in conjunction with its review of the export license application, and largely agrees with it. The U.S. Government obtained information from SCK CEN to best determine how much HEU to approve for export and over what duration. The license application requested more HEU than necessary before projected conversion to LEU fuel because BR2 is a global producer of medical isotopes and additional HEU fuel would help ensure an uninterrupted supply of medical isotopes in the event fuel conversion encounters delays. The NRC carefully considered how to balance this potential contingency with minimizing the unnecessary export of HEU.
A. Kuperman On May 16, 2023, the NRC issued export license XSNM3828 (enclosed) with a license condition that initially limits shipments to 188 of the requested 255 fuel assemblies. This corresponds to the number of fuel assemblies projected to be needed until scheduled conversion in late 2026. To ship any of the remaining 67 fuel assemblies, the licensee must obtain justification for additional fuel assemblies from SCK CEN and submit it to the NRC. The NRC must then give written notice back to the licensee before additional fuel assemblies could be shipped. Additionally, the license was issued with an expiration date of December 31, 2028, rather than April 1, 2030, as requested on the application. This was shortened based on how long the remaining 67 fuel assemblies, if needed and adequately justified, would be projected to last.
Sincerely, Signed by Atack, Sabrina on 05/17/23 Sabrina D. Atack, Deputy Director Office of International Programs
Enclosure:
Export License XSNM3828
A. Kuperman
SUBJECT:
RESPONSE TO COMMENTS ON U.S. NUCLEAR REGULATORY COMMISSION EXPORT LICENSE APPLICATION XSNM3828 DATED MAY 17, 2023 ADAMS Accession Number: ML23133A014 OFFICE OIP/ECNP OIP/ECNP OIP/DD NAME BMiller PHabighorst SAtack DATE 05/16/2023 05/16/2023 05/17/2023 OFFICIAL RECORD COPY