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Material Control and Accounting RAIs Page 1 

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Material Control and Accounting 

MCA-1 10 CFR 40.64 details the requirements for reporting to the Nuclear Materials Management and 

Safeguards System for Part 40 licensees. Please describe how these requirements will be met and 

where adherence to these requirements will be documented. 

RESPONSE: The IIFP Facility near Hobbs, New Mexico will receive depleted uranium 

hexafluoride (DUF6), process the material and ship depleted uranium oxide to an off-site licensed 

disposal facility. The primary reporting requirements of 10 CFR 40.64(a) include providing a 

Nuclear Material Transaction Report Form 741 (Form 741) to the Nuclear Materials Management 

and Safeguards System (NMMSS) in accordance with NUREG/BR-0006 and NMMSS Report 

D-24 for receipts, transfers, and inventory adjustments of the licensed depleted uranium source 

materials (referred to as “source material”), where applicable. Further, 10 CFR 40.64(b) requires 

an annual inventory of source material as of September 30 of each year in accordance with 

NUREG/BR-0007. 

IIIFP will meet and adhere to the above requirements through the use of a documented “Source 

Material Record and Reporting (SMRR) Plan” and implementing procedures. This Plan will 

continue to be developed and refined as the IIFP Project progresses through the detailed 

engineering, construction and IIFP staffing stages and as additional specific information about the 

IIFP Facility becomes available and is confirmed. The SMRR Plan will be completely developed 

along with its implementing procedures at least four (4) months prior to receiving source material 

at the IIFP Facility. Also, IIFP will request the NMMSS Reporting Identification Symbol (RIS) 

and have the RIS in place prior to implementing the procedures and the receipt of the source 

materials. The SMRR Plan will describe source material recording and reporting relative to the 

IIFP organization, operational processes, records management, and IIFP policy implementing 

procedures. The implementing procedures will be used in managing the source material inventory 

database, training affected personnel in their respective source material recording and reporting 

duties and providing the reports required in the regulations. 

Additional information about the IIFP source materials management and how the requirements 

will be met is provided in the amendments that will be made to the IIFP License Documentation 

as shown below. 

License Documentation Impact: New paragraphs will be added to the end of Section 1.3, 

“Type, Quantity, and Form of Licensed Material” of the IIFP License Application Chapter 1 to 

read as follows: 

The IIFP Facility near Hobbs, New Mexico will receive depleted uranium hexafluoride (DUF6), 

process the material and ship depleted uranium oxide to an off-site licensed disposal facility. A 

detailed description of the IIFP processes is provided in Section 3 of the IIFP Integrated Safety 

Analysis (ISA) Summary. The 10 CFR 40.64 regulation details the requirements for reporting to 

the Nuclear Materials Management and Safeguards System (NMMSS) for Part 40 licensees. The 

primary reporting requirements of 10 CFR 40.64(a) include providing a Nuclear Material 

Transaction Report Form 741 (Form 741) to NMMSS in accordance with NUREG/BR-0006 and 

NMMSS Report D-24 for receipts, transfers, and inventory adjustments of the licensed depleted

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Material Control and Accounting RAIs Page 2 

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uranium source materials (referred to as “source materials”), where applicable. Further, 10 CFR 

40.64(b) requires an annual inventory of source material each year in accordance with 

NUREG/BR-0007. 

IIFP will meet and adhere to the above requirements through the use of a “Source Material 

Record and Reporting (SMRR) Plan” and implementing procedures. This SMRR Plan will 

continue to be developed and refined as the IIFP Facility project progresses and as additional 

specific operational information about the IIFP Facility becomes available and is confirmed. The 

SMRR Plan will be finalized and ready for implementation through its procedures at least four (4) 

months prior to receiving source material at the IIFP Facility. Also, IIFP will request the NMSSS 

Reporting Identification Symbol (RIS) and have the RIS in place prior to implementing the 

procedures and the receipt of source materials. The SMRR Plan describes source material 

recording and reporting relative to the IIFP organization, operational processes, records 

management, and IIFP policy implementing procedures. The implementing procedures will be 

used in managing the source material inventory database, training affected personnel in their 

respective source material recording and reporting duties and providing the reports required in the 

regulations. An accounting system will be used to manage the book inventory of source material.

If the Nuclear Material Transaction Report Form (Form 741) received by IIFP from shippers of 

source material to the IIFP Site, identifies the source material as subject to the terms of 

international treaties, the uranium source material will also be entered and accounted in the 

facility Inventory of Foreign Obligations. 

For those transactions requiring reports to NMMSS, the Form 741 will be prepared for transmittal 

in accordance with NUREG/BR-0006. A Form 741 will be transmitted to NMMSS for source

material received at the IIFP Facility, for the heel content of cylinders returned to the uranium 

enrichment (supplier/customer) facilities, and for depleted uranium oxide shipped from the IIFP 

Facility to an off-site licensed disposal facility.

The IIFP Chief Operations Officer will appoint a key manager at the IIFP Facility to serve as the 

Uranium Materials Manager (UMM) who also may function in other management responsibilities 

at the IIFP Facility. The Uranium Materials Manager will be appointed with appropriate authority 

for implementation of the SMRR Plan and procedures throughout the operations, accounting,

records management and security functions. 

IIFP personnel who are involved with source material transactions, accounting and reporting will 

have their functions and assignments defined once the SMRR Plan is completed. These personnel 

will have other organization roles and responsibilities (e.g., a Process Operator or Area 

Supervisor may also function as a uranium material custodian. An Accounting Clerk may also 

function as an inventory records and reporting clerk). Personnel who are involved with source

material transactions will be formally trained and appointed to their source material job tasks. The 

SMRR Plan will identify the functional organization and assignments for source material 

transactions and records management.

The SMRR Plan will include policy to establish the annual reporting period, the reference 

procedures for conducting the annual inventory, and for reporting to the agencies in accordance 

with NUREG/BR-0007. Facility material balance and the annual inventory data will be 

submitted to NMMSS on NRC Forms 742 and 742C. 

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Material Control and Accounting RAIs Page 3 

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The IIFP Facility Quality Assurance Manager will assure that audits are conducted for the source 

material records and reporting functions on an appropriate frequency as defined by respective 

procedures. Any findings of the self-assessments and audits will be entered into the facility 

tracking system for developing corrective actions. The UMM will ensure that related issues are 

followed through to resolution. 

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Material Control and Accounting RAIs Page 4 

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Material Control and Accounting 

MCA-2 Also, describe how material subject to the requirements of 10 CFR 40.64 will be tracked and 

accounted for to provide the reports required under these regulations. 

RESPONSE: As discussed in response to MCA-1, IIFP will use a "Source Material Record and 

Reporting Plan" (Plan) and its implementing procedures to address the management of the 

depleted uranium received into and shipped from the IIFP Facility and to meet the 10 CFR 40.64 

requirements. 

The IIFP Facility will have one Facility Material Balance Area (FMBA) to account for the source 

material received into the facility and the source material shipped out of the facility. Since the 

DUF6 received will be low in the U235 isotope (typically < 0.35 weight percent) and of low 

attractiveness, the assay and uranium content of DUF6 received as identified by the shipper 

measurement data will be recorded in the IIFP FMBA inventory. When a cylinder of depleted 

uranium hexafluoride (DUF6) is received from a supplier and the content weight verified, the 

elemental weight uranium and weight percent uranium-235 as reported by the supplier on Form 

741will be entered into the FMBA inventory. Likewise, the elemental uranium weight and the 

weight percent uranium-235 remaining in the emptied cylinder “heel” material after the DUF6

cylinder is emptied to the process will be determined using the data provided by the supplier on 

Form 741 and the residual weight of the heel. 

The DUF6 is de-converted in the first step of the IIFP process to DUF4 that is transferred to the 

FEP operations for use as feed material for production of fluorine products. The uranium content 

of the DUF4 is already accounted in the inventory when the amount of uranium in the received 

DUF6 is entered into the FMBA inventory. IIFP may receive pre-produced DUF4 from others to 

use in production of the fluorine products. If DUF4 is received from others, the elemental weight 

uranium and weight percent uranium-235 as reported by the supplier will be used to determine 

the uranium amount to be recorded in the FMBA inventory. 

If the shipper's Nuclear Material Transaction Report Form 741 (Form 741) identifies the uranium 

source material as subject to the terms of international treaties, the material will also be entered 

and accounted in the facility Inventory of Foreign Obligations. A computer based accounting 

system will be used to manage the book inventory of source material and account for the material 

and the Inventory of Foreign Obligations. 

In the FEP process the DUF4 is converted to gaseous fluorine products and uranium oxide. The 

depleted uranium oxide by-product of the FEP operation will be loaded into containers for 

shipment to an off-site licensed disposal facility. Because the depleted uranium de-conversion 

and subsequent fluorine extraction process will not alter the percent enrichment of uranium-235, 

the elemental weight uranium and weight percent uranium-235 that is transferred from the IIFP 

facility to the disposal facility may be determined mathematically using the weight and 

enrichment data of the depleted uranium that has been processed. A statistically significant 

sampling method (or composite sampling) and chemical analysis of the samples will be 

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Material Control and Accounting RAIs Page 5 

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conducted to verify the calculated content of uranium in the depleted uranium oxide material to 

be shipped from the facility. This data will be incorporated into the uranium inventory database 

for preparation of the Form 741 transaction report and accounting of the Inventory of Foreign 

Obligations. 

Personnel who are involved with source material transactions will be formally trained and 

appointed to their source material accounting and reporting job tasks. For any given transfer of 

source material into or out of the FMBA, the material transfer information will be submitted to 

the IIFP Uranium Inventory Clerk. The Uranium Inventory Clerk will ensure that transfer 

information is entered into the book inventory and that a Form 741 is generated and processed if 

the transaction requires reporting to NMMSS. The Uranium Inventory Clerk responsibilities and 

duties will be assigned to an Accounting Clerk in the IIFP Administration organization and who 

may perform these responsibilities and duties in addition to other responsibilities. The Uranium 

Inventory Clerk will be trained in bookkeeping relative to the FMBA and NMMSS accounting 

and reporting and in the IIFP “Source Material Record and Reporting Plan” and implementing 

procedures. 

An annual inventory of source material will be conducted at the end of each reporting year. The 

uranium material staging and storage areas will be inventoried by walk-down validating the book 

inventory of uranium containers in the areas. Process measurement and calculation procedures 

will be used for determining the inventory contents of the process equipment. 

License Documentation Impact: Additions to the IIFP License Application Section 1.3 will be 

made as described in response to RAI MCA-1. 

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