The Interim Staff Guidance on burnup credit for pressurized water reactor (PWR) spent nuclear fuel (SNF), issued by the United States Nuclear Regulatory Commission's (U.S. NRC) Spent Fuel Project Office, recommends the use of analyses that provide an "adequate representation of the physics" and notes particular concern with the "need to consider the more reactive actinide compositions of fuels burned with fixed absorbers or with control rods fully or partly inserted." In the absence of readily available information on the extent of control rod (CR) usage in U.S.