ML20154C690
| ML20154C690 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/1998 |
| From: | Hodges M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Shankman S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9810060365 | |
| Download: ML20154C690 (1) | |
Text
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L October 1, 1998 MEMORANDUM TO:
Susan F. Shankman, Deputy Director Licensing and inspection Directorate Spent Fuel Project Office, NMSS FROM:
M. Wayne Hodges, Deputy Director Technical Review Directorate l
Spent Fuel Project Office, NMSS l
SU8 JECT:
URGENT RULEMAKING FOR PART 71 i
. The 10 CFR Part 71 rule that became effective on April 1,1996, is based upon lAEA regulations. Like IAEA regulations,'the Part 71 rule specifies A values for U (natural); U 2
(enriched 5% or less); U (enriched more than 5%); and U (depleted). However, IAEA
- Safety Series 6,1985 Edition (As Amended 1990) has a footnote for each of these j
materials, which was omitted from the NRC and DOT rules adopted in 1995. The footnote i
in IAEA regulations states that the A values for uranium do not apply to reprocessed 2
We have discussed this with Mr. Michael Wangler, who was the cognizant DOT official at the time NRC and DOT regulations were published for comment. Mr. Wangler is certain that there was no intent that the A values in NRC and DOT rules should be applied to 2
reprocessed uranium.
We request that rulemaking be immediately initiated to correct this omission. The need for the correction is urgent, in that, without the explanatory footnote, the regulations are unnecessarily ambiguous, and apparently have been misinterpreted by some licensees. We i
request that the rulemaking be conducted on an expedited basis, and, if possible, as an administrative rule change.
Distribution:
NMSS r/f SFPO r/f WFKane EPEaston DHTiktinsky
'PUBUCT2MNRC' File' Center 239
- C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure 'N' = No copy OFC N G S/SFPO E
NMSS/SFPO N
NMSS/SFPO 6
NMSS/SFPO l
NAME LOsgood ERZiegler M C b ppell Hodges (D
j DATE
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OFFICIAL RECORD COPY 050099 Ly ln m X
3 b ~ l~3 9810060365 981001
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