ML20138N830

Comments on Commission 850927 Order to Show Cause Re Removal of High Enriched U from Nonpower Reactor Facilities. Natl Organization of Test,Research & Training Reactors Agrees W/Removing Excess Fuel to Secure Facilities

ML20138N830
Person / Time
Site:	Rhode Island Atomic Energy Commission
Issue date:	10/22/1985
From:	Dimeglio A NATIONAL ORGANIZATION OF TEST, RESEARCH & TRAINING, RHODE ISLAND, STATE OF
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 8511060055
Download: ML20138N830 (3)

Text

Cartification #P 645 196 977 To - L *13 STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS RHODE ISLAND ATOMIC ENERGY COMMISSION

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Nuclear Science Center South Ferry Road Narragansett, R.I. 02882-1197 3

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October 22, 1985 g

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e Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555

Dear Sir:

The National Organization of Test, Research and Training Reactors (TRTR) membership will be affected by the show cause order issued by the Com-mission on September 27, 1985 concerning removal of excess high enriched uranium fuel from non-power reactor facilities.

TRTR agrees with the Commission on the advisability for removing all excess HEU fuel from non-power reactors to secure facilities away from the reactor site. Further, TRTR believes that since removal of this excess fuel has already been substantially accomplished by the non-power reactor community, there is time available to insure that the wording of the order is clear.

TRTR is concerned that the paragraph labeled (2) on page 111 of the order is ambiguous in two respects and restrictive in one area as follows:

1.

TRTR believes that " amount of fuel depleted" should be changed to "the amount of fuel or the number of fuel elements depleted" since depleted fuel may usually only be replaced in increments of whole fuel elements containing more than the depleted fuel.

2.

TRTR believes that " normal operation" should be changed to

" equivalent full power operation." The suggested wording will minimize the possibility of problems during inspection when a facility with an HEU inventory sufficient for full power opern-tion, has been operating at reduced power or not at all because of operational problems.

8511060055 851022 PDR ADOCK 05000193 P

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Secretary of the Commission October 22, 1985 Page 2 3.

TRTR believes that the 90 day period, while appropriate for many facilities, may be inappropriate at others and may actually lead to an increase in the safeguards threat. For example, a facility with an operating cycle slightly longer than 90 days may require, to meet the 90 day condition, twice the number of fuel shipments normally made thus increasing the safeguards exposure during shipments. TRTR believes that this is a good cause for some relaxation of the 90 day requirement, and, that a balance should be made between the time period and and number of shipments.

TRTR also believes that in addition to the element (s) for replacement of one failed element, facilities should be allowed an unirradiate element for special purposes.such as flux plotting.

Thank you for your consideration.

Very truly yours,

,/k A. Francis DiMeglio Chairman, TRTR AFD:cd cc: Executive Legal Director, NRC

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,' i CORRESPONDENCE CONTROL TfCKET A. Francis DiMeglio SECY NUMSER:

85-912 LOGGING DATE 10/29/85 0FFICE OF THE SECRETARY Davis f/approp action i

EDO Cys: Denton ACTION OFFICE:

Taylor A. Francis DiMeglio

• Minogue AUTHOR:

Region I Rhode Island Atomic Energy Commission GCunningham/SBurns AFFILIATION:

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10/22/85 LETTER DATE:

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SECY ADDRESSEE:

Views concerning 9/27/85 show cause order re removal of excess.

SUBJECT *.

HEU fuel fm non-power reactor fac Appropriate ACTION:

DISTRIBUTION:

SPECIAL HANDLING:

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