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Recent reports by Department of Energy National Laboratories have discussed safeguards considerations for the low enriched uranium (LEU) fueled Pebble Bed Modular Reactor (PBMR) and the need for bulk accountancy of the plutonium in used fuel. These reports fail to account effectively for the degree of plutonium dilution in the graphitized-carbon pebbles that is sufficient to meet the International Atomic Energy Agency's (IAEA's) 'provisional' guidelines for termination of safeguards on 'measured discards.' The thrust of this finding is not to terminate safeguards but to limit the need for specific accountancy of plutonium in stored used fuel. While the residual uranium in the used fuel may not be judged sufficiently diluted to meet the IAEA provisional guidelines for termination of safeguards, the estimated quantities of {sup 232}U and {sup 236}U in the used fuel at the target burn-up of {approx}91 GWD/MT exceed specification limits for reprocessed uranium (ASTM C787) and will require extensive blending with either natural uranium or uranium enrichment tails to dilute the {sup 236}U content to fall within specification thus making the PBMR used fuel less desirable for commercial reprocessing and reuse than that from light water reactors. Also the PBMR specific activity of reprocessed uranium isotopic mixture and its A{sub 2} values for effective dose limit if released in a dispersible form during a transportation accident are more limiting than the equivalent values for light water reactor spent fuel at 55 GWD/MT without accounting for the presence of the principal carry-over fission product ({sup 99}Tc) and any possible plutonium contamination that may be present from attempted covert reprocessing. Thus, the potentially recoverable uranium from PBMR used fuel carries reactivity penalties and radiological penalties likely greater than those for reprocessed uranium from light water reactors. These factors impact the economics of reprocessing, but a more significant consideration is that reprocessing technologies for coated particle fuels encased in graphitized-carbon have not progressed beyond laboratory-scale demonstrations although key equipment that has been tested in the past (such as graphite burners and electrolytic disintegration/dissolution devices) are not listed on either the 'Trigger List' or the 'Dual Use List' for mandatory export controls. Finally, if gross burn-up determined from fission product gamma ray inspection of a discharged pebble cannot be correlated acceptably with predicted plutonium content of the pebble, development and testing may be required on detector concepts for more directly measuring the plutonium content in a discharged pebble to ensure that its placement in the spent fuel storage tanks is for an acceptable 'measured discard' of diluted plutonium

Supplemental Report on Nuclear Safeguards Considerations for the Pebble Bed Modular Reactor (PBMR)