ML20129A252

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Forwards Minor Rev to Proposed Rule on Highly Enriched U to Provide Improved Clarity & Small Corrections.Draft Memo to Dircks Re Development of Proposed Rule on Highly Enriched U at Domestic Research Reactors Encl
ML20129A252
Person / Time
Issue date: 02/03/1984
From: Rehm T
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Chilk S
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20127B589 List:
References
FOIA-84-784 AB60-2-317, NUDOCS 8507150255
Download: ML20129A252 (4)


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. UNITED STATES .

NUCLEAR REGULATORY COMMISSION lM

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February 3, 1984 -

m NOTE TO: Samuel J. Chilk . .' . : .

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FROM: T. A. Rehm W.i.: N f.: .: ? . i :.

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SUBJECT:

PROPOSED RULE ON HEU l .

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e2 m m ce:33 NRC-FM-ftG PC. 004 003 UNITED STATES

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MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Samuel J. Chilk Office of the Secretary

SUBJECT:

DEVELOPMENT OF PROPOSED RULE ON HEU AT DOMESTIC RESEARCH REACTOR $ AND INTERIM SECURITY MEASURES By memorandum dated June 21,1983 I reported that the Comission agreed that a proposed rule be developed to implement the Comission's policy for reduction of the use of high enriched uranium (HEU) at domestic research reactors. The Chaiman also requested that the staff brief the Comission on the matter before extensive effort was exsended in developing the proposed rule. These briefings were held on Decem>er 19, 1983 January 27, and.

February 6, 1984. You are requested to proceed expeditiously with development of the proposed rule.

A. Proposed Ru_le on HEU at Domestic Research Reactors

.In additino to the provisions set out in the memorandum of June 21, 1983, the proposed rule should, to the extent feasible, minimite the licensing burden that could result. Consideration should be given to including in the rule an automatic provision of existing licenses to cover conversion to LEU if prescribed conditions are met.

are not significantly.Those conditions should assure that present sa reduced. To this and the staff should act promptly to initiate the technical base needed to support generic findings relative to conversion. .

The Comission wishes to review (two options:

a. A rule requiring the conversion to 1.EU fuel of all licensed research and training reactors other than those exempted because of a unique purpose. Under this option, reactors that replace fuel would be required to replace such fuel with low enrichment uranium fuel as the replacement fuel is available. The schedule for such replacements shall be developed by the Director of NRR who will coordinate such actions with D0E. If a suitable replacement fuel is not expected to be available within the overall schedule for the DOE RERTR program, the rule shall provide for replacement of HEU with fuel of enrichment as close to 205 as practical. For reactors that would not othemise expect to regire the acquisition of new fuel during the term of their license, a schedule shall be developed by the Director of MRR to provide for as prompt conversion to LEU as is reasonable. The schedules for conversion shall take into account such factors as: scheduling of shipping casks, replacement fuel fabrication, financial support, and reactor usage. These schedules will be coordinated with 00E.

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b. A rule similar to the option developed above, but restricted to those reactors that expect to acquire new fuel during the term of their license should also be developed. .

On the basis of information presented at the briefing on December 19, 1983, it is anticipated that a small number of reactors may be considered as serving

" unique purposes" and be permitted to continue use of HEU.

For the purpo'ses of this rule, " unique purpose" should account for such -

' characteristics as neutron flux 1ayels and energy spectrum specifically designed to facilitate research of irradiations not readily performed elsewhere in the U.S. The Director of NRR should determine whether the reactor has a " unique purpose."

B .' Interim Security Measures' at Somestic Research Reactors Staff should also investigate physical protection requirements applicable during the int'erim preceding tie completion of conversion to LEU. Since nearly all nonpower reacters possessing high enriched fuel currently implement the Category Il physical protection requirements of 10 CFR 73.67 (a), these should be addressed before the proposed Category I nonpower.

amendments are made final. Staff should assess the impact and benefit of alternative measures to be added to the Category II requirements to increase the level of protection at these facilities ~. The alternatives should include the following: .

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1. Reduce Holdings of Fresh HEU Fuel at Nonpower Reactors

. 2. Tamper-Proof Detection Systems and Provide Line-Supervision l

3. Assure Presence of"Two-Persons During Access to Material  ;
4. Improve Connunications Capability l
5. Provide Access Barriers over the Reactor Core l o

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Staff shall also investigate whether Interim Category I requirements *

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. 1. ' To require submittal for NRC' review and approval of the specific measures that the licensee would apply to meet the requirements of 10 CFR 73.60; and

2. To require licensees which s'pply the 100 rem / hour at 3 feet exemption, to meet.cnly Category Il requirements, to

., demonstrate how they detemine that radiation levels are

. above the level stipulated in the exemption; and

. 3. To require licensees to notify the NRC at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before they expect a change in requirement category.

Upon completion of the above efforts, staff should propose a program to the Connission for the implementation of any improvements deemed necessary.

Work on the final rule for theft at Category I nonpower reactors (the permanent rule replacement to 10 CFR 73.60) shall be deferred and a schedule for completion of that effort should be included "

when staff pres'ents its

' proposals for Category II changes.

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Samuoi J. Chilk " " '

. Office of the Secretary -

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