ML19282A039
| ML19282A039 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 05/04/1979 |
| From: | Burn R MICHIGAN, UNIV. OF, ANN ARBOR, MI |
| To: | Stello V Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7905090367 | |
| Download: ML19282A039 (1) | |
Text
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THE UNIVERSiv'.' OF MICHIGAN E..L.
PHOENIX MEMORIAL LABORATORY FORD NUCLEAR REACTOR a
Ol M ANN ARBOR, MICHIGAN 48109 M
(313) 764-6220 May 4,1979 Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Mr. Stello:
The purpose of this letter is te request that small quantities of special nuclear material be exempted under the proposed upgrude. 'e for research reactors. You have been previously contacted concerning this matter by Mr. Don Alger, University of Missouri, who is acting as chairman for the ROD Non-Power Reactor Liaison Committee.
I am writing to point out the specific and large impact to the Ford Nuclear Reactor of permitting no exemptions. At present almost all special nuclear material is stored in the reactor fuel vault. However, we routinely use two flat plate fission chambers with beam port spectrometers. Each monitor contains approximately 1 gram of U-235. A fission chamber tube is also used for routine measurements around the reactor, it contains about 1 gram of U-235. With these exemptions, the facility Controlled Access Area (as defined in the upgrade rule) is the fuel vault. Implementation of the requirements for random search and personnel trustworthiness is rathe simple. Without these exemptions, the entire reactor building becomes the Controlled Access Area. Random search and trust-worthiness verification of the many students and researchers who use the facility would be orders of magnitude more difficult.
At present,10CFR73.6 provides for a 350 gram exemption. The proposed upgrade rule allows no exemptions. In our case, even a three gram exemption would mean o great deal. I am requesting that you permit a reasonable exemption. Even the new definition of low strategic significance special nuclear material has o lower limit of 15 grams. For some reason this lower limit was not carried over into the physical protection cohgory definitions.
Sincerely, k htW D
Reed R. Burn V
Reactor Manager Ford Nuclear Reactor RRB/z cc:
W. Kerr P. Minogue G. Cook 7905090367 D. Alger