SNF Verification Requirements Imposed Through 10 CFR Part 961

Article VI.B.2 of the Standard Contract for Disposal of Spent Nuclear Fuel and/or High- Level Radioactive Waste (10 CFR Part 961, Standard Contract) provides that spent nuclear fuel shall be subject to verification prior to acceptance by the Department of Energy. As part of the overall process for scheduling deliveries of spent nuclear fuel, the Standard Contract requires contract holders to submit detailed descriptions of the spent nuclear fuel they intend to deliver (Appendix F). Thus, the provision for verification in the Standard Contract allovvs the Department the opportunity to ensure that the spent nuclear fuel intended for delivery is consistent with the description provided, and that the material is properly loaded, packaged, marked, and labeled. The Department is currently evaluating the verification requirements for spent nuclear fuel that it will establish pursuant to Article VI.B.2 of the Standard Contract. The Department recognizes that there may be significant overlap between these verification requirements and the requirements established for material control and accountability (MC&A). Therefore, the Department may recommend modifications to the process established in the Standard Contract to ensure that the verification and MC&A functions and activities are fully integrated.