Official Response to Material Control and Accounting RAIs 

Material Control and Accounting RAIs Page 1 

Official Responses to MC&A RAIs 

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 D24 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 

uranium source materials (referred to as “source materials”), where applicable. Further, 10 CFR 
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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. 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 and 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 subject to NMMSS reporting requirements, 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 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 Facility will have one Material Balance Area (MBA) to account for incoming and 

outgoing depleted uranium source material. The DUF6 received will be low in the U235 isotope 

(typically < 0.35 weight percent) and of low attractiveness, therefore the assay and uranium 

content of DUF6 received as identified by the shipper measurement data will be recorded in the 

IIFP MBA inventory. When a cylinder of depleted DUF6 is received from a supplier and the 

content weight verified, the supplier recorded assay and uranium content are used to determine 

the mass of uranium to be entered into the MBA inventory. Likewise, when the DUF6 cylinder

content is emptied to the process, the emptied cylinder is weighed to determine the contained 

“heel” material and the recorded assay and uranium content are used to determine the mass of 

uranium to be removed from the MBA inventory when the cylinder is shipped back to the 

supplier. 

In the first step of the IIFP process the DUF6 is de-converted to DUF4 that is then transferred to 

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

content of the DUF4 is accounted for in the inventory when the recorded amount of uranium in 

the DUF6 received is entered into the MBA inventory. IIFP is capable of receiving pre-produced 

DUF4 for use in production of the fluorine products. If DUF4 is received from suppliers, its 

weight and assay and uranium content as identified by the shipper measurement data will be used

to determine the uranium amount to be recorded in the MBA inventory.

In the FEP process the DUF4 is converted to gaseous fluorine products and depleted 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. A statistically significant sampling method 
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and chemical analysis of the samples will be conducted to determine the content of uranium in the 

depleted uranium oxide material to be shipped from the facility. The measurement methods 

applied to determine the concentration of uranium in the depleted uranium oxide for disposal will 

be governed by approved written procedures. The written procedure for uranium determination

will include the sampling method and plan, acceptable quality levels, the approved analytical 

methods and steps, calibration standard requirements and procedures for calibration where 

applicable. The sampling method will be based on valid technical and statistical principles 

including estimating variance and establishing confidence limits associated with the sampling 

method. The qualified measurement methods, including the analytical accuracy, precision, 

variance and confidence limits will be demonstrated before being approved as an implementing 

procedure.

The data recorded in the MBA inventory, the net weight of the shipping containers for disposal 

and the uranium content in the uranium oxide will be used to determine the mass of uranium 

source material that will be removed from the MBA inventory. Analytical and weight data on the 

uranium content of the depleted uranium oxide will be incorporated into the uranium inventory 

database for preparation of the Form 741 shipping report and accounting of the Inventory of 

Foreign Obligations. 

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 be 

assigned 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. 

For any given transfer of source material into or out of the MBA inventory, 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 will be trained in bookkeeping relative to MBA 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 MBA. Process measurement and calculation procedures

will be used for determining the inventory contents of the process equipment.
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The SMRR Plan will include policy to establish the annual reporting period, the reference 

procedures for conducting the annual inventory, and for reporting 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. 

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 

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. A description of the how the material subject to the requirements will be tracked 

and accounted for will be added to the IIFP License Application Chapter 1 Section 1.3. This 

description is shown above in the MCA-1 response License Documentation Impact. 

License Documentation Impact: See License Documentation Impact of RAI MCA-1