ML20136J048

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Requests Clarification of ACRS Congressional Testimony & How Staff Should Interpret Comments on Proposed Rule Re Use of Highly Enriched U in Light of Recently Stated Position of DOS
ML20136J048
Person / Time
Issue date: 12/04/1984
From: Gillespie F
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To: Fraley R
Advisory Committee on Reactor Safeguards
Shared Package
ML20136H905 List:
References
FOIA-85-379, FRN-49FR27769 AB60-2-114, AB61-2-114, NUDOCS 8508200595
Download: ML20136J048 (11)


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UNITED STATES  ;

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KEMORANDUM FOR:

Raymond F. Fraley, Executive Director Advisory Comittee on Reactor Safeguards h .k.fNs FROM:

Frank P. Gillespie. Director l Division of Risk Analysis and Operations l Office of Nuclear Regulatory Research

SUBJECT:

REQUEST FOR CLARIFICATION OF ACRS CONGRESSIONAL TESTIMONY The purpose of this memorandum is to request your assistance in two matters relating to the proposed rule to limit the use of highly enriched ura research and test reactors.

of ACRS Congressional testimony which you have previously dis William Lahs of my staff.should interpret ACRS coments on the proposed rule stated position of the Department of State.

On the first matter, you are probably aware that the staff, in assessing the values and impacts of the proposed rule, made several critical assumptions.

One of these assumptions was that certain licensing costs could be minimiz the safety analyses, required to achieve replacerent o With this approach, it was believed that proper

' classes of research reactors.

protection of public health and safety could be achieved whi licensee's costs.

staff as a distinct possibility.

With this background, you can appreciate our concern 25,regarding possible intsr 1984. Spec.if-pretations of the ACRS Congressional testimony on Sept was made, "We do not suppose that safe operation will be jeopardized sort of fuel changes proposed; but this will have to be confirm different reactor design." confirmation by generic clats of reactor design 4 potentially vi nle licensing approach.

The second matter involves the ACRS coment that "...it is more appropriate to base the need for requiring owners of research and of 1978 than to tie it to an unidentified threat." Congressional hea September 25, 1984 7

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AFTERCO85-379 PDR

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l f i Raymond F. Fraley 2 g p, 4g (enclosed) on the proposed NRC actions was that they "...can be expected r tol l have some marginal effect on future negotiations with foreign cperators...."

In considering our options on any final rule, we have been directed to address alternatives including retention of the status quo, promulgationAt of this the proposed rule, or an upgrading in security in lieu of HEU removal.

point in time, the staff is attempting to judge what alternatives are viable for consideration. As an example, the reduction of inventories of fresh fuel at licensee sites to minimal levels might be considered a safeguards alterna-/ <

tive.

What would be extremely helpful in this selection process is the ACRS view on "need for action" assuming the marginal Your international assistance implications in obtaining such an implied by the Department of State.

interpretation would be appreciated and, if the staff or I can be of assis-tance, please give me a call, r JA M 0' W / '

rank P. Gillespie, Director Division of Risk Analysis & Operations Office of Nuclear Regulatory Research

Enclosure:

As stated

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t STATEMENT OF CARLTON R. STOIBER DIRECTOR, OFFICE OF NUCLEAR EXPORT CONTROL U.S. DEPARTMENT OF STATE l

BEFORE THE FOR THE SUB00!!MITTEE ON ENERGY RESEARCH AND PRODUCTION A::D THE HOUSE 201!MITTEE ON SCIE!:0E AND TECHNOLOGY SEPTE!! DER 25, 1964 J

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Madam Chairman I am Carlton Stoiber, Director, Office of Nuclear Export Control, Department of State. I am pleased to be here today to present the State Department's views on the foreign policy aspects of the Nuclear Regulatory Commission's proposed rule for conversion of domestic research reactors to low enriched uranium. In particular, I will sJdress the relationship aerween sucn conversions and the Administration's nuclear non-proliferction goals.

The Office of Nuclear Export Control is responsible for making reconneacat ions to t..c Nuclear Regulatory Conmission for the state Department on various export license applications involving highly enriched uranium (HEU). Related to this, we are also respcnsible f or working with the Department of Energy on the neuueed Enrichment for Research and Test Reactor (RERTR) program, a DOE program oriented toward reducing HEU exports.

The RCRTR program was st&rted in 1978 to support a U.S.

initiative to reduce the proliferation potential and the threat of auclear terrorism associated with international commerce in highly enriched uranium. The program goal is to develop the technology needed for coaversion of research and test reactors to the use of low enriched f uels (at levels of less than 20 percent). Most of the work is carried on at the Argonne National Laboratory under DOE's aegis. Since 1978, similar 1

I programs for development of reduced enrichment fuel have also been established in a number of countries including France, the FRG, JuPan, Canada, and the United Kingdom. Programs for studying reactor conversions are in progress in 19 other countries. The Int ernational At or..ic Energy Agency (I AEA) has estaa41sned a small program, whose purpose is to coordinate and

- promote ed;cational activities relcred to the overall reduced enrichment effort, particularly for developing countries.

Cooperotlor, among participating governments has been outstanding. The t ecnnical program t o develop and demonstrate high densitj low-enriched fuels for research reactors is going very sell. Aluminide, oxide, and silicide plate-type fuels have caen developed by DOE with fabrication capabilities demonstratea by the commercial manufacturers NUKEM, Federal Repuolic of Germany, CERCA, France and Babcock & Wilcox in the U.S. In the United Stetes zirconium hydride rod-type fuels

'l have beea weveloped bj GA Technologies, and Babcock & Wilcox  ;

l has estaulished a commercial capability to manufacture f I

plate-r,pe fue; elements. Canada, Argent ina, Denmark, the  ;

U.K., Japan, and the USSR are also developing and evaluating LEU fuels technology. The development of high uranium density, 20% enriched silicide fuel may permit most U.S.-supplied foreign research and test reactors to convert to such fuel, without a change in the geometry of the fuel elements, and wit hout .ignificant penalty in test capability.

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, j An important aspect of the U.S. RERTR program is Argonne's l involvement with operators of foreign research reactors through  !

the development and demonstration phase to examine the possibility of timely conversion to use of lower enrichment fuels ana with oper-tors of U.S. reactors in testing and evaluating the technology. A whole-core demonstration in the Ford Nac; car Reactor at the University of Michigan is nearly cumplet e and a second whole-core demonstration with high density silicide fuel is Lei..g planned in DOE's ORR reactor at Oak Ridge. Joint studies on conversion feasibility are on-goiag between Ar goane anJ reuetor operators in Aust ria, J4 pan, Romania, Sweden, Netherlands, Argentina, Australia, Chile, Turkey, Greece, U.K., and Denmark.

Also, the following countries are testing, or will rest in toe near future, prototype LEU fuel elements in their reectors: Argentina, Austria, Brazil, Canada, Denmark, France, t..e Federal Republic of Germany, Greece, Japan, United Kingdom, Netherlands, Romania, Sweden, Switzerland, Turkey and the United States.

International meetings attended by some 50 representatives of over 17 countrics are sponsored annually by the IAEA, the U.S., and other host countries, for information exchange on the statuo Of R&D within the RERTR and related programs, and on research reactor operation and use. The most recent was near

'.'oAyo in October 1983.

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Only The program is still largely in the testing phase.

two reactors in the non-communist world actually have a full replacement core of low enriched fuel and have been licensed to use it. These are the Osiris reactor in France and the Ford Naclear Reactor in the United States. Further tests of LEU wit h high uranium density, including a f ull-core demonst ration ait h silicide f uel, ar e required. n addition, safety analyses are required and related licensing issues need to be resolved

' Lef ore coaversica candidates can plan to use LEU f uels.

  • Tr.o availability of reprocessing service for silicide and or!.er LEU fuci, a very inportant issue for LEU conversions, also needs to be resolved. For example, in the major user cuuarries, license amendment will not be issued to reactor operators for use of new fuel alternatives unless there is documenteri evidence that tae reactor operator can dispose of the spent LEU fuel outside the host nation, as has been done to r ot 6r ning spe..t IIEU f acis to the U.S. for "--receipt date b, and settlemeat- .* Credit for recovered uranium is an important economic concideratica for the reactor operator since half of the original fissile material remains in the spent fuel. Experiments on reprocessing advanced LEU fuels within DOE facilities have been completed successfully at Savannah River, and DOE ia currently ascessing the overall LEU reprocessing issue. .

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l The testing phase needs to continue and most of the new low enriched fuels will not be ready for commercial applications antil the 1987-33 time frame. During that period, we should see the new LEU fuels being accepted routinely as a substitute for the carrant HEU reloads--the ultimate goal of the program.

This uringc me to an important characteristic of the RERTR program that : mer.tloned a few minutes ago but which merits i further elaboration because I believe it has been a critical j

' facto: In t he developmeat and testing phases of the program.

This is the spirit of willing cooperation that has prevailed t .ir oug hout the course of the program. I believe that it is most impor t a;.t that this cooperative spirit be maintained as we approsca the reactor conversion stage. A number of factors have f est ered t his cooper at ive atmosphere, not the least of which has uee.. the outstanaing efforts of the Argonne program manLgers, scientists and technicians. Another key contributing Za'ctor has bee.. tne commitmer.t of the United States to be a reliable supplier of HEU in the period prior to conversion to u e of LEU. We have pursued a afstem of voluntary cooperation witnout arbitrary deadlines. Our processing of HEU license All applications has been apceded up cver the last four years.

of the trading partners to whom we can export HEU under the Nuclear Non-Proliferation Act regulations have obtained .

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udequate and timely supplies. With the cooperation of the NRC, we t rust, we will continue this approach. In return, we expect continael cooperction o.. conversion studies, and timely conversion when feasible.

With respect to U.S. HEU export policy in general, there is unanimous agreement amung foreign governments and programs that reJuced t rade flows in HEU cculd help reduce the risks of nuclear proliferation. However, their support for reducing commerce in HEU is conditioned by the obvious necessity that t..e new fuel s;.oald not significantly affect the safety, performance, licensability and economics of the research ro ctors. With adeguate and continued U.S. commitment to meet fuel development and demonstration schedules, including fu21-core teuting, resolution of the LEU reprocessing issue, and continued international participation, and with no undue

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deiaj ia licensing pr ocedures, the RERTR program should allow k'

for conversion of most recearch reactors to use of LEU fuel by t..e on cf this decade. The concerns and purposes behind our program abroad, of course, are linked to our overall l non-proliferation efforts, and this effort will continue l whatever the decision may be in respect to the domestic program.

! As the period for actual conversion approaches, a few foreign reactor operators have expressed an interest in whether ti.e U.S. is applying the same guidelinea domestically, and have

l a.ked what steps the U.S. is taking to convert domestic

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research reactors. The actions of the NRC on this matter can .p' be expected to have some marginal effect on our future s '.

negotiations with f oreign reactor operators on the need and timing for converting their reactors.

In considering measures which will encourage conversion of t esearc. react ors, our itat ernerional experience with RERTR participants has underscored the importance of being sensitive to lice. sing cn3 funding issues.

U.S. conversion of domestic research reactors to low ec.riched !cc14 ic 3ust or.c of mer y f actors which, in our judgment, is important for shaping the attitudes of foreign perticipaars in the RERTR program toward couversion of research reactors. Among the other considerations are:

(1) the establishment of saf e (the most important factor) and viable LEU fucis and its commercial availability; (2) the specific resetor geometry and mission of the

- particular facility being converted (e.g., whether cv.4 version. would require major or minor fuel or core reconfigurations); j (3) the economics of conversion--a matter which actually ha; several aspects, including the cost of altering the r eact or ! syst ems , the incremental cost of new fuels, the incremeatal cost of revising research e::periments or tests

' using the new fuels, and the costs of obtaining an amended I

operating license, if that should prove necessary (4) the regulatory steps which must be taken to re-license l

or approve operation of a converted facility from the i

. health, safety and environmental perspective; (5) the availability of reprocessing services or back-end of the fuel cycle solutions for new fuels (This is likely to Le a very Ley f actor);

(6) whether other nations, including close neighbors, will also be evn.erting t.ielt fucilities, concurrently; the perception of other governments that use of LEU I

! (7) fuel is 11. their best interests from a physical security viewpoint (i.e., less attractive targer and because it is less costly and difficult to protect LEU than to protect weapons-usable material); and (8) the justifiable availability of HEU for operating react ors until the LEU f uels are ready for the conversion proceas.

This cone.udes my prepared remarks. I will be happy to answer your questions at the appropriate tin 2.

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