ML20136J039
| ML20136J039 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Cranston A SENATE |
| Shared Package | |
| ML20136H905 | List: |
| References | |
| FOIA-85-379 NUDOCS 8508200591 | |
| Download: ML20136J039 (1) | |
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The Honorable Alan Cranston United States Senate Washington, D.C. 20510
Dear Senator Cranston:
I am writing to acknowledge your November 1,1984 letter to Chairman Palladino comenting on the proposed Nuclear Regulatory Comission (NRC) rule to limit the use of highly enriched uranium in domestic research and test reactors..
s The wide degree of interests and opinions on the proposed rule is reflected in the over 130 comment letters the NRC has received on the proposed rule. As you know, the proposed rule was also the. subject of a Congressional hearing, held jointly by the subcomittees on Energy Development and Applications and Energy Research and Production of the Comittee on Science and Technology.
You can be assured that the NRC will consider and evaluate all comments regarding the proposed rule and will attempt to justify its responses and final action in a reasonable and prudent manner.
Sincerely, (Signe:D William J.Dircy William J. Dircks Executive Director for Operations Distribution RAMRB R/F Shea Circ /Chron L Davis RES CentralFile G:unninghan RMingoue SECY 84-1049 Dross EDO #98 LRess FGillespie CKelber HErnst GMarino JMalaro WLahs DManson OCA WDircks JRoe TRehm OCA
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UNITED STATES d' s ,, 'g NUCLEAR REGULATORY COMMISSION 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
- W ASHINGTON, D. C. 20555
\....+/ December 21, 1984 MEMORANDUM FOR: Frank P. Gillespie, Director Division of Risk Analysis and Operations Office of Nuclear Regula ry Research FROM: Ra o rdef, utive Dire r Advisory Committee on Reactor feguards
SUBJECT:
ADDITIONAL ACRS COMMENTS REGARDING THE CONVERSION TO LEU FUEL IN NONPOWER REACTORS Your menorandum of December 4,1984 requesting clarification of ACRS views on the conversion to low enriched fuel in research and test reactors was discussed by the Comittee during its 296th meeting, December 13-15, 1984.
The Committee's coments are summarized below in response to your two inquiries.
A. Regarding your first inquiry The Committee had supposed that things like safety and accident analyses, fuel temperature limits under assumed conditions, techni-cal specifications, operating procedures, etc., would have to be s reworked and " confirmed for each different reactor design." If several reactors have the same design and facility arrangement, and have no significant site-related differences, the Comittee would agree that confirmation of the acceptability of new fuel might not have to be gone through more than once. If this is also what is meant by reactors of the same " generic class," then there is no argument.
B. Regarding your second inquiry At the time the ACRS expressed the opinion you quote, it was not cware that the position of the State Department was that steps taken in the U.S. or action by the NRC would only have "some :narginal effect on our future negotiations with foreign reactor operators on the need ... for converting their reactors." This would appear to reduce the "need for converting" to assisting the State Department in complying with U.S. Export Policy. The Comittee had not made such an assumption; and, if it should now assume that that was the proper measure of the situation, then it would see no compelling "need for action." The Comittee is, however, not fully convinced.that this is the most appropriate view.
The considerations which the Comittee had in mind -- and still supposes to be operative -- included the followino: y %
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> f Frank P. Gillespie December 21, 1984 The Committee identified hasthreat terrorist been assured thatnuclear (invelving there isfacilities no presently) in the U.S.
. Cost-benefit analysis would be of little value in this particular case.
. The public consequences of the theft (even of a comple'.ely inadequate amount) of weapons-capable material would be unpredictable, and could be large, and might well be independent of the location of the theft since such mater-f al would be readily transportable to any other location.
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. In 1978, with the Non-Froliferation Act, national policy was said to be to reduce the amount of HEU in civilian use to the maximum extent feasible on a world-wide basis.
. The cbjective of reducing civilian use and handling of HEU was to reduce the proliferation and terrorist potential provided by this material; and this was the basis of the initiative mounted by the U.S. in 1978 on an international front. This initiative -- which was discussed by Mr.
Stoiber of the State Department in his testimony, and of which he reported that " cooperation among participating governments has been outstanding" -- was certainly not presented in such terms as: there is a great need for ycg!
(foreign users) to stop using HEU, even though we (U.S.
users) may not stop.
. Few reactor operators, U.S. or foreign, would willingly go to the trouble and expense of converting (with, in many cases, at least some loss of reactor capability) without a strong and clear indication at some high political level that they must 00 so.
. The proposed NRC action would include only approximately 20% of the HEU fuel utilized in U.S. test and research reactor facilities, so that licensed reactor operators both U.S. and foreign are likely to resent having to convert if l others do not.
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. Many citizens would consider it shameful to whip up enthu- l siasm for a joint action, coerce cooperation with punitive provisions we are in a position to apply, and then fail to participate in the action we had urged. -
. The comment you refer to was to the effect that, if it is judged that there is a need for action, it would most
9 Frank P. Gillespie December 21, 1984 reasonably be based on considerations such as those indi-cated above.
. Finally, if there is a need for action, it is because the U.S. is still serious about trying to reduce the risk from proliferation and terrorist acts by cutting down on the civilian use of HEU as far as possible.
cc:
Chairman Palladino W. J. Dircks, ED0 H. Denton, NRR S. Chilk, SEC) .
J. R. Shea, IP J. G. Davis, NMSS
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