ML19289G215
| ML19289G215 | |
| Person / Time | |
|---|---|
| Issue date: | 07/05/1979 |
| From: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| Shared Package | |
| ML19289G216 | List: |
| References | |
| RULE-PRM-73-4 NUDOCS 7908030512 | |
| Download: ML19289G215 (3) | |
Text
W, PUBLIC DOCUMCNT ROOM NUCLEAR REGULATORY COMMISSION
/[ Docket No. PRM-73-4[/
Samuel H. Levine Filing of Petition for Rule Making Notice is hereby given that Dr. Samuel H. Levine, College of Engineering, the Pennsylvania State University, by letter dated February 2,1979, has filed with the Nuclear Regulatory Commission a petition for rule making to amend the Commission's regulation'" Physical Protection of Plants and Materials," 10 CFR Fart 73.
Attached to the petition is a copy of a letter dated January 31, 1979 from Dr. Levine to Dr. T. G. Williamson, University of Virginia.
The petitioner requests that 10 CFR Part 73 be revised to exempt from the requirements of Part 73 special nuclear material fuel in a fuel element which is not readily separable from other radioactive material and which has a total external radiation dose rate in excess of 0.4 rems per hour per gram of U-235 at a distance of three feet.
The petitioner also recommends that the external dose rate requirement of 100 rems per hour at three feet in air be reduced to 10 recs per hour at three feet in air.
The petitioner states that the 0.4 rems per hour per gram of U-235 would be valid for dose rates less than 10 rems per hour at three feet in air.
The petitioner states that "If NRC does not agree with the 10 rem per hour criterion, then a study should be made verifying the need for the extremely high dose rate of 100 rem per hour in view of the hardships this rule places on some cf our educaticnal institutions."
In the letter of January 31, 1979 to Dr. Williamson, the petiticner states uat:
It w:ald seem to many of us at Penn State that 10 rems per hour at a distance of three feet wculd be sufficient to exempt any fuel 2082 257 fy]
ioososo sTL
from the rule. A dose rate of 10 rems per hour per fuel element is a very high dose rate and one that would discourage anyone from trying to abscond with a few of such fuel elements. -
I believe this rule alone has had a major adverse impact on the quality of the nuclear-related academic programs conducted at yours and other institutions having over 5 kg of greater than 20!, enriched uranium fuel.
Not only does the rule require you to continually deplete your fuel, a crime in itself, just to maintain the extraor-t dinarily high dose rate, but you and members of your staff are subjected to greater and unnecessary radiation exposure.
Everyone recognizes the great importance of preventirig proliferation of nuclear bombs and every sensible (even if it is very difficult to meet) method must be used to assure significant quantities of U-235 are not stolen. But unnecessary rules which can catsse great harm to our educational institutions and their personnel should be eliminated...
4 A copy of the petition for rule making is available for public inspection in the Commission's Public Document Room,1717 H Street, N.W., Washington, D.C.
A copy of the petition may be obtained by writing to the Divisicn of Rules and Records, Office of Administration, U. S. Nuclear Regulatory Commission, Washington, D.C.
20555.
All persens who desire to submit written comments or suggestions concerning the petiticn for rule making should send their comments to the Secretary of the Cc mission, U. S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attenticn:
Dccketing and Service Branch by September 11, 1979.
2082 258
. FOR FURTHER INFORMATION CONTACT:
Gerald L. Hutton, Division of Rules and Records Office of Administration, U. S. Nuclear Regulatory Commission, Washington, DC 20555, Telephone: 301-492-7086.
Dated at Washington, D. C.
this 5th day of
- July, 1979.
For the Nuclear Regulatory Commission JohnC.Hoy[e' Acting Secretary of the Ccanission 2082 259
.