13-3-3148 Purchaser Questionnaire

OMB No. 3117-0016/USITC No. 13-3-3148; Expiration Date: 6/30/2014
(No response is required if currently valid OMB control number is not displayed)

U.S. PURCHASERS’ QUESTIONNAIRE
LOW ENRICHED URANIUM FROM FRANCE

This questionnaire must be received by the Commission by no later than July 16, 2013
See page 4 of the Instruction Booklet for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its review of the antidumping duty order concerning low enriched uranium (“LEU”) from France (inv.
No. 731-TA-909 (Second Review)). The information requested in the questionnaire is requested under the authority of
the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other
order to compel the submission of records or information in your possession (19 U.S.C. § 1333(a)). Further information
on this questionnaire can be obtained from Aimee Larsen (202-205-3179, aimee.larsen@usitc.gov).

Name of firm

_________________________________________________________________

Address
City

State

Zip Code

World Wide Web address
Has your firm purchased LEU (as defined in the instruction booklet) from any source (domestic or foreign) at any
time since January 1, 2007?

NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Read the instruction booklet carefully, complete all parts of the questionnaire, and return the entire
questionnaire to the Commission so as to be received by the date indicated above)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking
on the following link: https://dropbox.usitc.gov/oinv/. (use the following PIN: LEU2)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my knowledge
and belief and understand that the information submitted is subject to audit and verification by the Commission.
By means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings or reviews
conducted by the Commission on the same or similar merchandise.
I acknowledge that information submitted in this questionnaire response and throughout this proceeding may be used by the
Commission, its employees, and contract personnel who are acting in the capacity of Commission employees, for developing or
maintaining the records of this proceeding or related proceedings for which this information is submitted, or in internal audits and
proceedings relating to the programs and operations of the Commission pursuant to 5 U.S.C. Appendix 3. I understand that all
contract personnel will sign non-disclosure agreements.

Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Email address
Fax

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

Page 2

PART I.--GENERAL QUESTIONS - Continued
The questions in this questionnaire have been reviewed with market participants to ensure that issues of
concern are adequately addressed and that data requests are sufficient, meaningful, and as limited as
possible. Public reporting burden for this questionnaire is estimated to average 40 hours per response,
including the time for reviewing instructions, searching existing data sources, gathering the data needed,
and completing and reviewing the questionnaire. Send comments regarding the accuracy of this burden
estimate or any other aspect of this collection of information, including suggestions for reducing the
burden, to the Office of Investigations, U.S. International Trade Commission, 500 E Street, SW,
Washington, DC 20436.
I-1a.

OMB statistics.--Please report the actual number of hours required and the cost to your firm of
preparing the reply to this questionnaire and completing the form.
hours

dollars

I-1b.

OMB feedback.--We are interested in any comments you may have for improving this
questionnaire in general or the clarity of specific questions. Please attach such comments to your
response or send them to the above address.

I-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire (see page 3 of the instruction booklet for reporting guidelines). If your firm is
publicly traded, please specify the stock exchange and trading symbol.

I-3.

Ownership.--Is your firm owned, in whole or in part, by any other firm?

I-4.

No

Yes--List the following information.

Firm name

Address

Extent of
ownership

Related SUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, that are engaged in importing LEU from France into the United States or that
are engaged in exporting LEU from France to the United States?
No

Yes--List the following information.

Firm name

Address

Affiliation

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

Page 3

PART I.--GENERAL QUESTIONS - Continued
I-5.

Related NONSUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, that are engaged in importing LEU from countries other than France into the
United States or that are engaged in exporting LEU from countries other than France to the
United States?
No

Yes--List the following information.

Firm name and country

I-6.

I-7.

Address

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of LEU?
No

Yes--List the following information.

Firm name

Address

Affiliation

Business plan.--Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for LEU?
No

Yes--Please provide these documents. If you are not providing the requested
documents, please explain why not.

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

Page 4

PART I.--GENERAL QUESTIONS - Continued
PLEASE ANSWER THE REMAINING QUESTIONS IN PART I ONLY IF YOUR FIRM IS A
U.S. ELECTRIC UTILITY THAT USES URANIUM AS A FUEL; OTHERWISE, SKIP TO PART
II.
I-8.

Please discuss below your electric utility’s reload cycle, explaining, as a minimum, (1) whether
you change all of the reactor’s fuel assemblies at once or some portion (identify the number
replaced out of the total number), (2) the frequency (in months) of your reload cycle, (3) the
extent to which you can extend or reduce the reload frequency, (4) the extent to which the costs of
uranium products/services affect your reload cycle, and (5) any changes that occurred in the
frequency of your reload cycle during January 2007 through March 2013 and any you anticipate
during the remainder of 2013 and 2014.

I-9.

How long does it typically take to complete a reload and is the entire facility that produces
electricity shut down during the reload?

I-10.

How does the plant meet its customers’ electricity demand during this reload-shutdown period?

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Page 5

PART I.--GENERAL QUESTIONS - Continued
I-11.

(a) Has the average enrichment level in the core designs of your nuclear fuel changed between
January 2007 and March 2013? If yes, please specify the changes and explain the reason(s) for
such changes.
No
Yes--Please explain.

(b) Please explain any costs or benefits from higher enrichment levels in the LEU and whether
higher levels are necessary and sufficient for longer reload cycles and for higher capacity factors.
Also discuss whether your reactors can accept any enrichment level of LEU, a single specific
enrichment level of LEU, or some range of enrichment levels of LEU; please explain the reasons
why.

I-12.

Do fuel assembly design specifications (other than enrichment levels) generally change at each
reload such that the quantity of uranium in a reload for each of your plant’s reactors vary? If yes,
please specify the magnitude of the changes and explain the reason(s) for such changes.
No
Yes--Please explain.

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Page 6

PART I.--GENERAL QUESTIONS - Continued
I-13.

(a) Please discuss how the following parameters have changed during 2007-12 and how these
parameters are expected to change in the foreseeable future; specify time periods and reasons for
any changes.
Capacity factor
Tails assay (percent)
Fuel design/burn up
Reactor power
Overfeeding/underfeeding
(b) Please describe the impact of these parameter changes on your firm’s production, sales, and
profitability.

I-14.

Are any of your plant’s nuclear reactors able to use mixed oxide (MOX) or convert to use MOX
as its fuel? If yes, please estimate the cost and time required to convert your fuel over to MOX
and the reasons why you might switch from uranium to MOX. In addition, please indicate any
plans your firm may have for the switch to MOX and note the time period and reasons for such a
change. Also indicate and describe regulatory requirements that need to be met in switching over
to MOX and if your firm has considered other alternatives.
No

Yes--Please explain.

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

Page 7

PART II.--PURCHASES
Contact information.-- Please identify the responsible individual and the manner by which Commission staff
may contact that individual regarding the confidential information submitted in this questionnaire.
Name
Title
Email
Telephone
Fax
Unless otherwise indicated, please answer all questions in the remainder of this questionnaire based on your
firm’s actual market experience in purchasing LEU, either via a SWU contract (purchase of enrichment) or as
enriched uranium product (EUP), during January 2007 to March 2013. If your response differs by purchase of
enrichment or EUP, by category of purchase contract, or by country of enrichment/origin, please explain in
your response or attach a separate response. Country of origin should be based on the origin as specified in the
shipping documents and not based on the location of the supplier; if the country of origin is unknown, please
report the name of the supplier. Please respond fully to the questions and attach additional discussion as
needed; identify attached responses with the question number.
NOTE: EUP is LEU that is sold or purchased where the customer does not provide any natural UF6.
NOTE: Nonsubject countries/suppliers of LEU refer to foreign countries/suppliers other than France.
Unless otherwise specified, U.S. delivery/shipment of LEU to U.S. customers, commonly U.S. electric
utilities, is normally triggered by a BOOK TRANSFER to the customer. This book transfer may occur
at the same time as the physical transport of the LEU, usually to a U.S. fuel-assembly fabricator, but
frequently occurs sometime after this physical transport (e.g., LEU is not physically transported to the
U.S. electric utility’s location). On the other hand, if your firm imports LEU and is the end user, (the
latter commonly an electric utility), such imports constitute delivery and would normally be physically
transported directly to the designated fuel-assembly fabricator. Requests for information in this
questionnaire regarding U.S. delivery/shipment of LEU to your firm refers to material that has been
book-transferred to your account (during the period requested) at a designated facility either inside or
outside the United States.
II-1.

Purchases.—
Indicate below the countries for which you are reporting based on your firm’s purchases of LEU since
January 1, 2007 from these countries and indicate whether you purchased enrichment and/or EUP from
each country
United States

Enrichment

EUP

France

Enrichment

EUP

Other (Russia)

Enrichment

EUP

Other (identify:

)

Enrichment

EUP

Other (identify:

)

Enrichment

EUP

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

Page 8

PART II.--PURCHASES - Continued
II-2.

(a) U.S. ELECTRIC UTILITY PURCHASES OF LEU VIA ENRICHMENT CONTRACTS
(PURCHASERS PROVIDED THE NATURAL UF6 FEEDSTOCK):

Report, as indicated below, the total quantity and value of LEU delivered to U.S. electric utilities during
January 2007 through March 2013 that your firm purchased on an enrichment basis from domestic production,
U.S. importers, or other sources, and that which is imported directly. Report separately by the specified country
and report only those purchases of LEU where your firm provided the natural UF6 feedstock. Report quantities
in the number of contracted SWUs and, if possible, the kgs of uranium in the LEU (if the reported data are
estimates, please mark them as such). Report the total value of the LEU and the value of the SWUs in U.S.
dollars. All reported values should be f.o.b. the U.S. fabricator. Also report, where indicated, the annual
average product and tails assays.
(Quantity in SWUs and kgs of U or enriched U and value in U.S. dollars)
Calendar years
Jan-March
Country of origin:
2007
2008
2009
2010
2011
2012
2012
2013
United States:
Quantity (SWUs)
Quantity (kgs of U)
Total value of LEU
SWU value
Product assay (percent)
Tails assay (percent)
France:
Quantity (SWUs)
Quantity (kgs of U)
Total value of LEU
SWU value
Product assay
(percent)
Tails assay (percent)
All other countries:1
Quantity (SWUs)
Quantity (kgs of U)
Total value of LEU
SWU value
Product assay
(percent)
Tails assay (percent)
1

Specify which countries:

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

Page 9

PART II.--PURCHASES - Continued
II-2.

(b) U.S. ELECTRIC UTILITY PURCHASES OF EUP:
Report, as indicated below, the total quantity and value of EUP delivered to U.S. electric utilities
during January 2002 through June 2007 that your firm purchased from domestic production, U.S.
importers, or other sources, and that which is imported directly. Report separately by the specified
country and report only those purchases of EUP. Report quantities in kgs of uranium in the EUP, and,
if possible, the number of SWUs. All reported values should be f.o.b. the U.S. fabricator. Also report,
where indicated, the annual average product and tails assays.

Country of origin:
United States:
Quantity (kgs of U)
Quantity (SWUs)
Total value of EUP
Product assay (percent)
Tails assay (percent)
France:
Quantity (kgs of U)
Quantity (SWUs)
Total value of EUP
Product assay (percent)
Tails assay (percent)
All other countries:1
Quantity (kgs of U)
Quantity (SWUs)
Total value of EUP
Product assay (percent)
Tails assay (percent)
1

Specify which countries:

(Quantity in SWUs and kgs of U and value in U.S. dollars)
Calendar years
2007
2008
2009
2010
2011
2012

Jan-March
2012
2013

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Page 10

PART II.--PURCHASES - Continued
II-2.

(c) Please enter into the table below the information requested for contracts entered into since January
1, 2007 for product from the United States, France, and all other countries as indicated. Please note if
there was more than one contract and sum all of the contracts within each category for each country of
origin.
Contracts entered into
Volume

Country of origin
United States
Natural UF6 (kg U)
Enrichment (SWU)
EUP (kg U)
France
Natural UF6 (kg U)
Enrichment (SWU)
EUP (kg U)
All other countries
Natural UF6 (kg U)
Enrichment (SWU)
EUP (kg U)

Minimum

Maximum

Price

Length

Please note that the questions in the following sections refer to domestic LEU and LEU imported from
ANY source (both France and nonsubject countries). If your response to any question differs depending
on the country of origin (based on the country specified in the shipping documents, not based on the
location of the supplier), please report separately for each country and note this in your response.
In addition, the questions in the following sections refer to LEU via enrichment and EUP. If any of your
answers differ for enrichment compared to EUP, please report separately and note this in your
response. Attach additional pages if necessary.
II-3.

Did the relative levels of your firm’s annual deliveries (physical movements and book transfers) of
LEU from different countries/sources change during January 2007 to March 2013?
No

Yes--Please explain the reasons, noting the countries of origin of the products
in your response.

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Page 11

PART II.--PURCHASES - Continued
II-4.

(a) Did your firm purchase LEU from only one country during January 2007 to March 2013, as shown
in your responses to II-2?
No

Yes--Please explain the reasons for doing so and if you expect this pattern of
single-country sourcing to continue; answer separately for purchases of
low enriched uranium via enrichment and for purchases of EUP.

(b) Did your firm purchase LEU from more than one country during January 2007 to March 2013, as
shown in your responses to II-2?
No

II-5.

Yes--Please explain the reasons for doing so and discuss any changes in the
relative levels of your firm’s annual deliveries of LEU received, as
enrichment and/or EUP, from different sources during this period. Also
discuss any expected changes in this pattern of multiple-country sourcing
to continue; answer separately for purchases of LEU via enrichment and
for purchases of EUP.

(a) Since January 1, 2007, have your firm’s deliveries of LEU received as EUP increased, decreased, or
remained about the same relative to deliveries of LEU via enrichment?
Increased

Decreased

Unchanged

(b) Please explain the reasons for your delivery pattern during this period and explain how this pattern
is expected to change in the future.

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Page 12

PART II.--PURCHASES - Continued
II-6.

Has your firm modified the terms of SWU or EUP contracts for U.S.-produced LEU, French-produced
LEU, or LEU from any other source since January 1, 2007 or replaced all or some of such contracts
with new contracts that included the obligations to meet your enrichment or EUP requirements
covered by the existing contracts?
No

Yes--For each contract, please describe the initial date of the existing contract,
the date for which the modification(s) or replacement(s) were signed,
and the specific nature of the modification(s) or replacement(s).

II-7. Report, as indicated below, information on the LEU delivered to you by domestic producers,
Areva/Cogema, or other suppliers who have supplied your firm with LEU (i.e., actual deliveries) as well
as LEU that you anticipate receiving on contracted-for requirements based on reload schedules for the
remainder of 2013 through 2016.

Year
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016

U.S. producers
U.S. origin
Other origin
Kgs of
Kgs of
SWUs
U
SWUs
U

Areva/Cogema
French origin
Other origin
Kgs of
Kgs of
SWUs
U
SWUs
U

All other
suppliers
Kgs of
SWUs
U

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Page 13

PART II.--PURCHASES - Continued
II-8. (a) Please show in the following tabulation, by categories of enrichment purchase contracts, the total
quantity (in number of SWUs and in kgs of enriched uranium) of LEU purchased by your firm on an
enrichment basis and that was delivered to your firm during January 2007 to March 2013 (if the
reported data are estimates, please mark them as such). Report separately by country of enrichment for
the United States, France, and all other nonsubject countries where indicated.
Category of enrichment purchase agreements
United States
Spot purchases
Long-term contract purchases
Other (please specify):
France
Spot purchases
Long-term contract purchases
Other (please specify):
All other nonsubject countries
Spot purchases
Long-term contract purchases
Other (please specify):

SWUs

Kgs of enriched U

(b) Please show in the following tabulation, by categories of EUP purchase contracts, the total quantity
(in number of SWUs and in kgs of enriched uranium) of LEU purchased by your firm on an EUP basis
and that was delivered to your firm during January 2007 to March 2013. Report separately by country of
enrichment for the United States, France, and all other nonsubject countries where indicated.
Category of EUP contracts
United States
Spot purchases
Long-term contract purchases
Other (please specify):
France
Spot purchases
Long-term contract purchases
Other (please specify):
All other nonsubject countries
Spot purchases
Long-term contract purchases
Other (please specify):

SWUs

Kgs of enriched U

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Page 14

PART II.--PURCHASES - Continued
II-9.

(a) Report the following information for enrichment contracts newly negotiated and entered into
since January 1, 2007 or where terms of a signed contract or accepted proposal were renegotiated on
or after January 1, 2007, where, in each case, U.S. and/or French LEU will be or has been delivered
under the contract.

Newly
negotiated

United States
Renegotiated
Pre-existing Renegotiated
terms
terms

Newly
negotiated

France
Renegotiated
Pre-existing Renegotiated
terms
terms

Total number
of contracts
Total
quantity (kgs
of U in LEU)
Total
quantity
(SWUs)
Beginning
delivery
period
Ending
delivery
period
(b) For all of the newly negotiated enrichment contracts, report the following information, if
available.
United States
Period of
delivery

Kgs of U
in LEU

Number
of SWUs

Weighted-average
net f.o.b. price (in
dollars per SWU)1

France
Kgs of U
in LEU

2007
2008
2009
2010
2011
2012
Jan-March
2013
1

Total net value f.o.b. the U.S. fabricator divided by total quantity.

Number
of SWUs

Weighted-average
net f.o.b. price (in
dollars per SWU)1

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PART II.--PURCHASES - Continued
II-9. Continued.
(c) For all of the renegotiated enrichment contracts, report the following information, if available.
United States
Period of
delivery

Kgs of U
in LEU

Number
of SWUs

Weighted-average
net f.o.b. price (in
dollars per
SWU)1

France
Kgs of U
in LEU

Number
of SWUs

Weighted-average
net f.o.b. price (in
dollars per
SWU)1

2007
2008
2009
2010
2011
2012
Jan-March
2013
1

Total net value f.o.b. the U.S. fabricator divided by total quantity.

(d) Please discuss the renegotiated enrichment contracts, including the original and renegotiated
price and quantity and reason(s) why the contract was renegotiated.

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Page 16

PART II.--PURCHASES - Continued
II-10.

(a) Report the following information for EUP contracts newly negotiated and entered into since
January 1, 2007 or where terms of a signed contract or accepted proposal were renegotiated on or
after January 1, 2007, where, in each case, U.S. and/or French LEU will be or has been delivered
under the contract.

Newly
negotiated

United States
Renegotiated
Pre-existing Renegotiated
terms
terms

Newly
negotiated

France
Renegotiated
Pre-existing Renegotiated
terms
terms

Total number
of contracts
Total
quantity (kgs
of U in EUP)
Total
quantity
(SWUs)
Beginning
delivery
period
Ending
delivery
period
(b) For all of the newly negotiated EUP contracts, report the following information, if available.
United States
Period of
delivery

Kgs of U
in EUP

Number
of SWUs

Weighted-average
net f.o.b. price (in
dollars per kg of
U in EUP)1

France
Kgs of U
in EUP

2007
2008
2009
2010
2011
2012
Jan-March
2013
1

Total net value f.o.b. the U.S. fabricator divided by total quantity.

Number
of SWUs

Weighted-average
net f.o.b. price (in
dollars per kg of
U in EUP)1

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PART II.--PURCHASES - Continued
II-10. Continued
(c) For all of the renegotiated EUP contracts, report the following information, if available.
United States

Period of
delivery

Kgs of U
in EUP

Number
of SWUs

Weighted-average
net f.o.b. price (in
dollars per kg of
U in EUP)1

France

Kgs of U
in EUP

Number
of SWUs

Weighted-average
net f.o.b. price (in
dollars per kg of
U in EUP)1

2007
2008
2009
2010
2011
2012
Jan-March
2013
1

Total net value f.o.b. the U.S. fabricator divided by total quantity.

(d) Please discuss the renegotiated EUP contracts, including the original and renegotiated price and
quantity and reason(s) why the contract was renegotiated.

II-11. Please discuss below your firm’s choices in contracting for LEU, either as enrichment or EUP, on a
spot or long-term contract basis since January 1, 2007. Include the following: use of the spot market as
an alternative to long-term contracts, options in existing contracts as an alternative to spot purchases or
long-term contracts, and whether you received any offers of LEU bundled with other products or
services.

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

Page 18

PART II.--PURCHASES - Continued
II-12. (a) Since January 1, 2007, how have spot purchases of LEU changed as a share of your firm’s total
annual purchases?
Increased

Decreased

Unchanged

(b) Please explain the reasons for these changes in your firm’s share of spot purchases. Also, identify
the country of origin that your firm tends to buy on a spot basis and explain why.

II-13. (a) What percentage of your firm’s LEU requirements (by quantity) for 2013-14 was contracted for by
December 31, 2012?

(b) What percent of your long-term contracts for LEU fall into each of these categories?
Type of long-term contract
( 1) Long-term contracts where prices are based on market
prices at the time of delivery and the contracts do not specify a
price/cost-based floor, a price ceiling, or a discount from the
market price.
( 2) Long-term contracts where prices are partially based on
market prices at the time of delivery and the contracts specify a
price/cost-based floor, a price ceiling, a discount from the
market price, or some combination of these.
( 3) Long-term contracts where prices are fixed or subject to
escalator clauses specified in the contract.
TOTAL

2007-12

2013-14

100%

100%

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

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PART II.--PURCHASES - Continued
II-14. (a) Has the use of swaps in the LEU market changed since January 1, 2007?
Increased

Decreased

Unchanged

(b) Please explain the effect this change has had on the market. Please include information for
executed contracts and contracts entered into for delivery in 2013-14. In addition, please indicate what
percentage of the LEU your firm purchased in 2012 was involved in a swap.

(b) Has the use of loans/leases in the LEU market changed since January 1, 2007?
Increased

Decreased

Unchanged

(b) Please explain the effect this change has had on the market. Please include information for
executed contracts and contracts entered into for delivery in 2013-14. In addition, please indicate what
percentage of the LEU your firm purchased in 2012 was involved in loans/leases.

II-15. Describe the ways in which any changes in your firm’s demand for fuel (e.g., fuel design, refueling
schedule, etc.) have affected your firm’s purchases of LEU since January 1, 2007. Please specify the
time period to which you are referring.

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U.S. Purchasers’ Questionnaire – LEU from France (731-TA-909 (Review))

Page 20

PART II.--PURCHASES - Continued
II-16. Please list your anticipated total purchases of LEU over the next 10 years. For each year, please provide
the total quantity of LEU that is filled by existing contracts (or committed demand), and of this committed
demand, the amount that is open origin (where the contract does not require LEU of a particular origin to be
supplied). For purposes of this question, please assume that minimum contracted quantities will be purchased
under existing contracts.

Year

Total expected demand for
LEU (in kgs of enriched U)

Total quantity of LEU
currently committed
(in kgs of enriched U)

Total quantity of committed
demand that is of open
origin (in kgs of enriched U)

2013
2014
2015
2016
2017
2018
2019
2020
2021
2022

II-17.

Since January 1, 2007, have you solicited, negotiated, signed, or been solicited to negotiate or sign
any firm or contingent contract(s) for enrichment or EUP with any supplier for the future supply of
French-produced LEU to your firm?
No

Yes--Please describe these contracts/agreements/solicitations, identifying the
nature of the contract offered (enrichment or EUP), type and quantity of
LEU, SWU (if applicable), date of commencement, and duration of the
supply commitment offered.

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PART II.--PURCHASES
II-18.

Changes in purchasing patterns.-- Please indicate how the relative levels of your firm’s purchases
of LEU from different sources (both domestic and foreign) have changed since January 1, 2007.
Source of
purchases

Did not Decreased Increased Constant Fluctuated
purchase

Explanation for
trend

United States

France

All other
countries

II-19.

Purchases from one country only.--If your firm has purchased LEU from only one country, please
explain the reasons for doing so.

II-20.

Supplier identification.-- Please list your firm’s FIVE largest suppliers for LEU since 2007. Also,
provide the share of the quantity of your firm’s total purchases of LEU that each of these suppliers
accounted for in 2012.

No.

Supplier’s name

City and state

Share of quantity of
2012 purchases

1

%

2

%

3

%

4

%

5

%

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES
III-1.

Firm type.--Which of the following best describes your firm as a purchaser of LEU (check all
that apply, noting the specific end uses if known)?
Electrical utility (
)
Nuclear fuel-assembly fabricator (
Enricher (
)
Trader/broker (
)
Other (Describe:

III-2.

)

)

Competition for sales.--If you are a trader/broker of LEU, do you compete for sales to your
customers with the manufacturers or importers from which you purchase LEU?
No

Yes--Please describe.

III-3.

Types of customers.--If your firm is a trader/broker of LEU, what are the major types of
consumers to which you sell LEU?

III-4.

End uses.--If your firm is an end user of LEU, list in order of quantity of LEU consumed, the top
3 products for which your firm purchases LEU as a component part or input. Please indicate what
percentage of the total cost is accounted for by LEU and other inputs.
Share of total cost in each of the product(s)
you produce accounted for by
Product(s) you
produce

LEU (percent)

Other inputs (percent)

Total

%

%

100%

%

%

100%

%

%

100%

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-5.

Demand for end use products.-(a)

If your firm is an end user of LEU, has the demand for your firm’s final products
incorporating LEU changed since January 1, 2007?
Increased

(b)

Decreased

Fluctuated

Has this had any effect on your firm’s demand for LEU?
No

III-6.

No change

Yes

Explain

Changes in end uses.-- Have there been any changes in the end uses of LEU since January 1,
2007? Do you anticipate any future changes?
Changes in end
uses

No

Yes

Explain

Changes since
2007
Anticipated
changes

III-7.

Substitutes.--Can other products be substituted for LEU?
No

Substitute
1.
2.
3.

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for LEU?
No Yes

Explanation

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-8.

Changes in substitutes.-- Have there been any changes in the number or types of products that
can be substituted for LEU since January 1, 2007? Do you anticipate any future changes?
Changes in
substitutes

No Yes

Explain

Changes since
2007
Anticipated
changes

III-9.

Demand trends.-- Indicate how demand within the United States and outside of the United States
(if known) for LEU has changed since January 1, 2007, and how you anticipate demand will
change in the future. Describe the principal factors that have affected, and that you anticipate will
affect, these changes in demand.

Market

No
Increase change Decrease Fluctuate

Factors

Demand since 2007
Within
the United
States
Outside
the United
States
Anticipated future demand
Within
the United
States
Outside
the United
States

III-10. Market studies.--Please provide as a separate attachment to this request any studies, surveys, etc.
that you are aware of that quantify and/or otherwise discuss LEU supply (including production
capacity and capacity utilization) and demand in (1) the United States, (2) each of the other major
producing/consuming countries, including France, and (3) the world as a whole. Of particular
interest is such data from 2007 to the present and forecasts for the future.

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-11. Changes in factors affecting supply.--Have any changes occurred in any other factors affecting
supply (e.g., changes in availability or prices of energy or labor; transportation conditions;
production capacity and/or methods of production; technology; export markets; or alternative
production opportunities) that affected the availability of U.S.-produced LEU in the U.S. market
since January 1, 2007?
No

Yes

Explain

III-12. Importance of purchasing domestic product.--Is buying a product that is produced in the
United States an important factor in your firm’s purchases of LEU (check ALL that apply)?
No
Yes-- Purchases of domestic product are required by law or regulation (for example,
government purchases under “Buy American” provisions). This involves
percent
of all our purchases of LEU.
Yes--Purchases of domestic product are not required by law or regulation, but are by our
customers. This involves
percent of all our purchases of LEU.
Yes--Purchases of domestic product are required for other reasons (please specify these
reasons below). This involves
percent of all our purchases of LEU.

III-13. Conditions of competition.-a) Is the LEU market subject to business cycles or conditions of competition (including seasonal
business) distinctive to LEU?
No (skip to question III-14.)

Yes-- Please describe and then answer part (b).

(b) If yes, have there been any changes in the business cycles or conditions of competition for
LEU since January 1, 2007?
No

Yes-- Please describe.

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-14. Decisions based on producer.--Does your firm, and to the extent that you know, do your
customers make purchasing decisions involving LEU based on the producer of the LEU you
purchase?

Always

Usually

Sometimes

Never

If at least sometimes, discuss
how your firm/customers
determine the producer and why
this information is important

Your firm
Your
customers

III-15. Decisions based on country-of-origin.--Does your firm, and to the extent that you know, do
your customers make purchasing decisions involving LEU based on the country of origin of the
LEU you purchase?

Always

Usually

Sometimes

Never

If at least sometimes, discuss
how your firm/customers
determine the source and why
this information is important

Your firm
Your
customers

III-16. Purchasing frequency.-(a)

How frequently do you make purchases of LEU (check one)?
Daily

(b)

Weekly

Monthly

Quarterly

Annually

Other

If other, specify

Do you expect this purchasing pattern to change in the next two years?
No

Yes-- How and why do you expect these changes to occur?

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-17. Number of suppliers contacted.--How many suppliers do you generally contact before making a
purchase?
firms
III-18. Supplier negotiations.-(a)

Do purchases of LEU usually involve negotiations between supplier and purchaser?
No

(b)

Yes--Please describe these negotiations, noting whether purchasers
generally quote competing prices as part of the negotiation
process.

Does your firm tend to vary its purchases from a given supplier within a specified time
period based on the price offered for that period?
No

Yes--Specify the time period.

III-19. Change in suppliers.--Have you changed suppliers since January 1, 2007?
No

Yes-- Please list the supplier(s), whether the firm was added or dropped, the
reasons for the change, and how frequently you change suppliers.

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-20. New suppliers.-(a)

Are you aware of any new suppliers, either foreign or domestic, that have entered the
market since January 1, 2007?
No

(b)

Yes--Please identify the firms and indicate how you became aware of
them.

Do you expect new LEU suppliers to enter the U.S. market?
No

Yes--Please provide details.

III-21. Supplier qualification
(a)

Do you require your suppliers to be or to become certified or qualified to sell LEU to
your firm?
No

(b)

Yes--

percent of value of purchases in 2012

Yes--all purchases

Please provide a general description of the certification or qualification process. Briefly
describe the factors that you consider when qualifying a new supplier (e.g., quality of
product, reliability of supplier, etc.).

(c) How long does it take to qualify a new supplier?

days

III-22. Failure to certify.—
(a) Since January 1, 2007, have any domestic or foreign producers failed in their attempts to
certify or qualify their LEU with your firm or have any producers lost their approved status?
No

Yes--Please identify these firms, the countries where they are located, and the
reasons why they failed the certification/qualification.

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-22. Failure to certify.— Continued
(b) Since January 1, 2007, was your firm placed on allocation by any of its suppliers of LEU,
told by any supplier that the quantity available was limited, or told by any supplier that it
would be unable to deliver the full quantity ordered as originally scheduled?
No

Yes--For each occurrence, please describe the specific allocation program,
quantity limitation, or delivery problem. Include in your discussion the
name of the supplier, the country of origin, the time period, and the
quantity involved.

(c) Was it necessary for your firm to alter its reload schedule at any time since January 1,
2007 to adjust to allocations, purchase limitations, shortfalls or delays in LEU deliveries?
No

III-23.

Yes--Please discuss how your reload schedule was altered and what impact
this had on your electricity generation operations.

(a) Since January 1, 2007, did your firm decline to accept a proposal or bid for LEU from a
potential supplier because of uncertainty about the quality of the LEU or the reliability of the
supplier?
No

Yes--Please explain and identify the supplier and country of origin.

(b) Please also discuss your firm’s concern about the ability of any specific enricher to supply
the quantity and assays of LEU that you required since January 1, 2007 and in the future.
Please specify the time period, the exact nature of any concerns, and the name(s) of the
enricher(s).

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-24.

Please discuss your firm’s evolving strategy with regard to reprocessing and recycling. Have
there been changes in this strategy since January 1, 2007? Does your firm anticipate changes
in the near future?

III-25.

Discuss below your firm’s process of choosing a supplier of LEU and the factors it considers,
including the method of establishing a transaction price. Please respond separately for
enrichment and EUP and for spot purchases and long-term contract purchases. Include
in your discussion whether you generally mention competing prices to your supplier when
negotiating a price, whether your supplier distributes price lists, the role of published LEU
prices, and the factors considered when evaluating competing bids.

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-26. Purchasing factors.--For the factors listed below, please rate each in terms of its importance in
your purchase decision for LEU.
Very
important
Availability .......................................
Delivery terms (for feed) .................
Delivery terms (for LEU) .................
Delivery time ...................................
Discounts offered ............................
Diverse source of supply .................
Escalation provisions ......................
Extension of credit...........................
Minimum qty requirements ..............
Packaging .......................................
Price ................................................
Product consistency ........................
Quality meets industry standards....
Quality exceeds industry standards
Product range..................................
Reliability of supply .........................
Tails assay option ...........................
Technical support/service ...............
U.S. transportation costs .................
Other (specify):
........
........
........

Somewhat
important

Not
important

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-27. Major purchasing factors.--Please list, in order of their importance, the three major factors
generally considered by your firm in deciding from whom to purchase LEU for any one order
(examples include availability, extension of credit, contracts, price, quality, range of supplier’s
product line, traditional supplier, etc.).
1.
2.
3.
Other factors or comments:

III-28. Quality characteristics.--What characteristics does your firm consider when determining the
quality of LEU?

III-29. Frequency of decisions based on price.--How often does your firm purchase the LEU that is
offered at the lowest evaluated price?
Always

Usually

Sometimes

Never

III-30. Price leaders.— A price leader is defined as (1) one or more firms that initiate a price change,
either upward or downward, that is followed by other firms, or (2) one or more firms that have a
significant impact on prices. A price leader is not necessarily the lowest priced supplier.
Please list the names of any firms you considered price leaders in the LEU market since 2007.
Describe how the firm(s) exhibited price leadership.

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-31. Changes in U.S. industry.-(a)

Please identify and discuss any improvements/changes in the U.S. LEU industry since
January 1, 2007 and explain the factors, including the order(s) under review, that were
responsible for each improvement/change.

(b)

Please discuss any improvements/changes that you anticipate in the future in the U.S.
LEU industry. Identify the time period and causes for these improvements/changes.

III-32. Effect of revocation.--What do you think will be the likely effects of any revocation of the
antidumping duty order on imports of LEU from France? As appropriate, please discuss any
potential effects of revocation of the antidumping duty order on (1) the future activities of your
firm and (2) the U.S. market as a whole. Please note the future time period to which you are
referring.
(1) Activities of your firm:

(2) Entire U.S. market:

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PART III.-- MARKET CHARACTERISTICS AND PURCHASING PRACTICES--Continued
III-33. Since January 1, 2007, have you solicited, negotiated, signed, or been solicited to negotiate or sign
any firm or contingent contract(s) for SWU or EUP with any supplier(s) for (i) the future supply
of French-origin LEU to your firm or (ii) the supply of LEU without limitation as to origin but
specifically conditional upon termination of the antidumping duty order on French LEU?
No

Yes--Please provide descriptions of these contracts/agreements/solicitations,
identifying the nature of the contract offered (SWU or EUP), type(s) and
quantities of LEU, SWU (if applicable), the weighted-average net f.o.b. price (in
$/SWU), date(s) of commencement, and duration of the supply commitment
offered under such contracts/agreements/ solicitations

Business Proprietary
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PART IV.-- PRODUCT COMPARISIONS
IV-1.

Country knowledge.--Please indicate the countries of origin for LEU for which your firm has
actual marketing/pricing knowledge.
United States
France
Russia
Other countries (specify

IV-2.

)

Interchangeability by country-pair.--Is LEU produced in the United States and in other
countries interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair

France

Other countries

United States
France
1

For any country-pair producing LEU which is sometimes or never interchangeable, please
explain the factors that limit or preclude interchangeable use. In your response relating to “other
countries,” if the degree of interchangeability differs for different nonsubject countries, please note
this below.

2

Please note the country/countries of origin of the LEU that are included in the “other countries”
category.

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PART IV.-- PRODUCT COMPARISIONS--Continued
IV-3.

Factors other than price.--Are differences other than price (i.e., quality, availability,
transportation network, product range, technical support, etc.) between LEU produced in the
United States and in other countries a significant factor in your firm’s purchases of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair

France

Other countries

United States
France

For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s purchases of LEU, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

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PART IV.-- PRODUCT COMPARISIONS--Continued
IV-4.

Availability of merchandise.--Are certain grades/types/sizes of LEU available from only a
single source (domestic or foreign, including both subject and nonsubject countries)?
No

IV-5.

Yes--Please identify the source and the grade/type/size.

Choice of product not based on price.--If you purchased LEU from one source although a
comparable product was available from another source at a lower evaluated price, please explain
your reasons for doing so (please specify by country, including the United States and both subject
and nonsubject foreign countries). Possibilities might include transaction characteristics such as
length of time to fill orders, minimum order size, reliability of supply, etc.

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PART IV.-- PRODUCT COMPARISIONS--Continued
IV-6. Factor country comparisons.--For the factors listed below, please rate how LEU produced in
each country you identified in your response to the first question in Part IV compares with LEU produced
in each of the other countries you identified (including the United States, France, and nonsubject foreign
countries).

Inferior

Comparable

Product from
France
compared to
product from
Nonsubject
country

Superior

Inferior

Comparable

Product from
United States
compared to
product from
Nonsubject
country

Superior

Inferior

Comparable

Superior

Product from
United States
compared to
product from
France

Availability .......................................
Delivery terms (for feed)..................
Delivery terms (for LEU)..................
Delivery time ...................................
Discounts offered ............................
Diverse source of supply .................
Escalation provisions ......................
Extension of credit...........................
Minimum qty requirements ..............
Packaging .......................................
Price1 ...............................................
Product consistency ........................
Quality meets industry standards....
Quality exceeds industry standards
Product range..................................
Reliability of supply .........................
Tails assay option ...........................
Technical support/service ...............
U.S. transportation costs .................
Other (specify):
1

.....................

A rating of superior on price and U.S. transportation costs indicates that the first country generally has
lower prices/U.S. transportation costs than the second country.

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PART IV.-- PRODUCT COMPARISIONS--Continued
IV-7.

Minimum quality.--How often does LEU from the following countries meet minimum quality
specifications for your uses or your customers’ uses?
Source

Always

Usually

Sometimes

Rarely or
never

Don’t
know

United States
France
Russia

IV-8.

Change in price.-(a)

Since January 1, 2007, has there been a change in the price of LEU? If so, has the price
of U.S.-produced LEU changed more or less than the price of imported LEU from
France?
No change in price
Prices have changed by the same amount
Price of U.S.-produced LEU has changed relative to the price of LEU from France.

(b)

If the price of U.S.-produced LEU has changed relative to the price of LEU from France,
the price of U.S.-produced LEU is now relatively
Higher

Lower – than those from France.