Simplified Euratom Safeguards reporting (derogation) for Small Holders of Nuclear Materials

Safeguards requirements may be applicable to small holders of nuclear material (SHNM) under Article 19 of Commission Regulation (Euratom) 302/2005. There is no rigid definition of SHNM but, as a guide, a SHNM might hold:

1. -

• 350kg of depleted uranium; or
• 200kg of thorium; or
• 100kg of natural uranium; or
• 1kg of low enriched uranium; or
• 5g of high enriched uranium; or
• 5g of plutonium

or a combination of these materials kept in the same state for long periods. Examples include:

• universities, colleges and research institutes that use nuclear material for academic studies;
• analytical laboratories that use nuclear material as reference sources; and
• manufacturers of measurement instruments that use sealed sources as standards for calibration.

2. Depleted uranium, natural uranium or thorium that is used exclusively in non-nuclear activities. Examples include:

• radiation shielding, including depleted uranium transport containers for medical or industrial radioisotopes;
• ballasts/counterweights, e.g. on aircraft or boats;
• high hardness alloys, e.g. magnesium/thorium alloys used in aerospace applications;
• catalysts for use in the chemical industry; and
• pigments used in glass.

3. Plutonium, enriched uranium or uranium-233 used in gram quantities or less as sensing components in instruments. Examples include:

• fission chamber manufacturers; and
• smoke alarm manufacturers.

4. plutonium with an isotopic concentration of plutonium-238 exceeding 80%. For example, pacemaker manufacturers.

Requesting Derogation

The European Commission will only grant derogations for nuclear material that is not stored or processed with other nuclear material for which no derogation can be granted (although, if material is co-stored or co-processed, it may be possible to create a separate material balance area specific to that material or activity that qualifies for derogation)..

A request for derogation should be made using the form provided at Annex IX of Regulation 302/05:

• Annex IX Request for Derogation [19Kb]

Operators who have been granted derogation by means of a particular safeguards provisions (PSPs) decision under Article 7 of European Commission Regulation (Euratom) 3227/76 do not have to submit a new derogation request. However, operators who have previously received less formal derogation authorisation (e.g. by letter) that enabled them to submit quarterly, semi-annual or annual ICRs are advised to submit an initial request for derogation.

Current reporting practice should continue until the European Commission has responded to the initial request for derogation. Please note however that the three year transition period for switching from reporting according to Commission Regulation (Euratom) 3227/76 to reporting under Regulation 302/2205 expires in March 2008.

Please contact HSE(UKSO) for advice on making derogation requests to the European Commission, a detailed information pack on what such derogated reporting would involve, and information on the European Commission’s interim requirements for the transition to fully derogated reporting.. HSE(UKSO) can also advise on use of the European Commission’s ENMAS (Euratom Nuclear Materials Accounting System) software package which has been developed to assist smaller users provide accountancy reports according to the requirements of the Commission Regulation (Euratom) No 302/05 [PDF].