ML20059F579
| ML20059F579 | |
| Person / Time | |
|---|---|
| Site: | 07000622 |
| Issue date: | 01/05/1994 |
| From: | Clune M ARMY, DEPT. OF, ARMAMENT RESEARCH, DEVELOPMENT & |
| To: | Keegan E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9401140075 | |
| Download: ML20059F579 (2) | |
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DEPARTMENT OF THE ARMV N!.p'g U S. ARMY ARM AMENT RESEARCH. DEVELOPMENT AND ENGINEERING CENTER M
PICATINNY ARSENAL NEW JERSEY 07806-5000 s
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January 5, 1994 "MN! Lor
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Safety, Surety, and Environmental Office Installation Safety Division Health Physics Branch
SUBJECT:
Exemption From the Requirements of 10 CFR 70.24 Ms. Elaine Keegan Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Dear Ms. Keegan:
In reference to our telephone conversation on January 3, 1994, this letter formally requests ARDEC be granted an exemption from the requirements of 10 CFR 70.24 This exemption from criticality accident requirements for the SNM-561 Special Nuclear Materials license is justified due to the following:
a.
The uranium-235 MTR fuel elements which were fabricated solely for use in the Californium Flux Multiplier (CFX) System are in long term storage in three separate drums with unique, individually numbered security seals.
This storage mode shall prevent any criticality from occurring due to the insufficient mass of fissile material in each drum.
In fact, all the uranium-235 from all three drums, if put together, is not enough fissile material for minimum dry critical mass.
The sub-critical material in each drum is also separated from the material in adjacent drums by the inherent spacer designed into each storage drum.
This assures that each sub-critical mass in each drum is kept at a certain distance from each other.
b.
The 223 uranium-235 MTR fuel plates are aluminum-clad uranium aluminum alloy containing approxi-mately 28 percent uranium, enriched to 93.27 percent in the uranium-235 isotope.
This further dilutes the uranium mass concentration in a given volume of material.
This means that it can never become critical because its surface to volume ratio is such that excessive neutron leakage shall always prevent the neutron multiplication factor from ever reaching unity.
9401140075 940105 DR ADOCK 07000622 Q.
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c.
In its present storage mode, there is no moderator or reflector material that can slow down or reflect back the neutrons to the uranium to sustain any kind of critical reaction.
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d.
The high security measures in place safeguarding i
the uranium-235 MTR fuel plates, such as the locked reinforced concrete bunker, the intrusion detection system, roving security patrols, and secret passwords will make any attempt to gain unauthorized access to the material very unlikely.
This exemption request is applicable to the current SNM-561 Special Nuclear Material license application dated August 28, 1992.
j Any questions concerning this exemption request i
should be directed to either Mr. Andy Kung, ARDEC Health 1
Physicist, at (201)724-3742, or to Mr. Richard W.
Fliszar, ARDEC RPO, at (201)724-3126.
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MI CLUNE Acting Chief, Safety, Surety, and Environmental Office Copies Furnished:
Commander, U.S. Army Material Command, ATTN: AMCSF-P (Mr. John Manfre), 5001 Eisenhower Avenue, Alexandria, i
VA 22333-0001 Commander, U.S. Army Armament Munitions and Chemical Command, ATTN: AMSMC-SFS (Ms. Betty Peterson), Rock Island, IL 61299-6000
.