Assessment and recommendations for fissile-material packaging exemptions and general licenses within 10 CFR Part 71

This report provides a technical and regulatory assessment of the fissile material general licenses and fissile material exemptions within Title 10 of the Code of Federal Regulations Part 71. The assessment included literature studies and calculational analyses to evaluate the technical criteria; review of current industry practice and concerns; and a detailed evaluation of the regulatory text for clarity, consistency and relevance. Recommendations for potential consideration by the Nuclear Regulatory Commission staff are provided. The recommendations call for a simplification and consolidation of the general licenses and a change in the technical criteria for the first fissile material exemptions.