Assessment of the effectiveness of the LEU Reform Rule and its implementation

Abstract

The US Nuclear Regulatory Commission (NRC) amended its material control and accounting (MC&A) requirements in 1985 for licensees possessing and using special nuclear material (SNM) of low strategic significance in quantities larger than one effective kilogram (kg). The goal of the Low-Enriched Uranium (LEU) Reform Rule (i.e., 10CFR 74.31) was to establish MC&A requirements for the LEU licensees at a level consistent with the safeguards risk associated with the relatively low strategic importance of such material. The amended requirements were written in a performance-oriented manner, rather than a prescriptive one, in an effort to allow the licensees the opportunity to choose the most cost-effective means of satisfying the requirements. The LEU Reform Rule was implemented in January 1988 and the fuel cycle facilities have had sufficient experience in implementing the rule to allow a meaningful review of its effectiveness. This document provides technical analysis and recommendations to assist the NRC in making a determination if the rule is achieving its intended purpose, and if not, to make the necessary changes to accomplish this.