ML20003D647

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Forwards Revised Physical Security Plan for Info Only.Plan Withheld (Ref 10CFR.790)
ML20003D647
Person / Time
Site: Aerotest
Issue date: 03/23/1981
From: Newacheck R
AEROTEST OPERATIONS, INC.
To: John Miller
Office of Nuclear Reactor Regulation
References
NUDOCS 8103300071
Download: ML20003D647 (1)


Text

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e AEROTEST OPER ATIONS, INC.

4M 3455 FO$TORIA WAY . SAN RAMON. CALIFORNt A 94583 .(415) 83 4[

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G9. c' 23 March 1981 [ S(l/( ,b

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Mr. James R. Miller, Chief %r.m ** 'ISQw, n jd ' ,l001 Standardization & Special Projects Branch

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Division of Licensing , 3 s

'N Nuclear Regulatory Con: mission NJ ('

Washington, D.C. 20555 Docket No. 50-228 "

Dear Mr. Miller:

We are enclosing a copy of a revised Physical Security Plan for the Aerotest Radiography and Research Reactor (ARRR). Based on the following discussion, we are submitting this plan fur information only and not for formal review and approval.

A review of 10CFR73 indicates that prime concern is given to facilities possessing special nuclear material (SNM) enriched to more than 20% Uranium-235 and quantities greater tha 5 kg or SNM enriched to more than 10% in quantities greater than 10 kg. Enrich =ent/ quantities below these levels are spc .:ifically exempted or ignored. For example, 10CFR73.6 specifically exempts material with Uranium-235 enrichment less than 20% from the provisions of 573.20, 73.25, 73.26, 73.27, 73.45, 73.46, 73.70, and 73.72. It also exempts SNM at non-power reactors from the same provisions.

ARRR fuel is enriched to less than 20% in Uranium-235. Total possession is less than 5 kg and the fuel is not readily separable from the ::irconium hydride matrix. Baced on the enrichment and quantity constraints we feel that the ARRR facility is specifically exempted from 10CFR73 requirements for physical security and/or safeguards contingency plans. We are, therefore, supplying you with our physical security plan developed to satisfy internal requirements and request that this be treated as an informational document only.

If we can provide further clarification of our request, please contact us.

Thank you for your consideration of this matter.

We request that the attachment be withheld from public disclosure pursuant to 10CFR, Part 2, Section 2.790(d) as the information would be of assistance in planning a violation of our protective system.

Very truly yours, AER0 TEST OPERATIONS, INC.

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' Richard L'. Newacheck W &L. 'Q esMent RLN:be Encl: Security Plan ec: L.W .Ivey, NRC, Region V, Walnut Creek,CA F

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