ML20138N914

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Consents to 850927 Order to Show Cause,Contingent Upon Listed Interpretations.Min Inventory of Unirradiated Fuel Maintained.Inventory of Irradiated Fuel Larger than Necessary Due to Delays in Shipping Cask Licensing
ML20138N914
Person / Time
Site: MIT Nuclear Research Reactor
Issue date: 10/25/1985
From: Lisa Clark
MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 8511060145
Download: ML20138N914 (3)


Text

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MASSACHUSETTS INSTITUTE OF TECHNOLOGY O.K. HARLING 138 Albany Street Cambndge Mass. 02139 L. CLARK, JR Director (617)253- 4202 Director of Reactor Operations October 25, 1985 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Show Cause Order of September 27, 1985, Docket No. 50/20

Dear Sir:

As provided in 10 CFR 2.202(d), the Massachusetts Institute of Technology consents to the entry of an order in substantially the form proposed in the Commission's Order to Show Cause dated September 27, 1985 and addressed to the Institute as holder of Facility Operating License No. R-37 and to other non power reactors licensed by NRC and using high enrichment uranium (HEU) fuel.

It has been MIT's policy for some time to maintain a minimum inventory of unirradiated fuel. That inventory is currently in compliance with the Order, and it will remain so. However, our inventory of spent (irradiated) fuel, although highly self protecting, is larger than necessary because of the protracted delays in the licensing of the Department of Energy HM-1A shipping cask. Problems causing further delays in the availability of this cask should be resolved at the earliest possible date.

MIT's consent is contingent upon interpretation of the Order as follows:

1) In determining the number of replacement elements that may be maintained in inventory, it is our interpretation that "the amount of fuel depleted in a 90-day period" may be rounded upward to the next whole number of elements.
2) Even with the above assumption, some refuelings will become complicated, and a request for relaxation of the require-ments may be necessary. It is our further interpretation that paragraph II(3) provides for the filing of such i requests after the Order becomes effective and not neces-sarily beforehand.

8511060145 051025 PDR ADOCK 05000020 P PDR

A final and very important point is that HEU inventories at non power reactors subject to the Order will be so small and dispersed that the Commission's proposed requirement of July 6,1984 (49 FR 27769) for conversion of HEU fuel to low enrichment fuel becomes entirely unnecessary and should be withdrawn.

Sincerely, L. 'AGJ/

Lincoln Clark, Jr.

Director of Reactor Operations LC/crh ,

cc: J. Bernard O. Harling D. Lanning W. Milne .

l Y

Lincoln Clark

  • CORRESPONDENCE CONTROL TICKET SECY NUM ER: 85-924 LOGGING DATE 10/30/85 0FFICE OF THE SECRETARY Davis f/approp action ACTION OFFICE: EDO Cys: Denton Taylor .

AUTHOR:

Lincoln Clark Region I GCunningham/SBurns AFFILIATION: Nuclear Reactor Lab--Mass Pat Anderson LETTER DATE: 10/25/85 W'

FILE CODE ADDRESSEE:

Chilk Show cause order of 9/27/85--unirradiated fuel in non-power SU8 JECT:

reactors Appropriate ACTION:

DISTRIBUTION:

None SPECIAL HANDLING:

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