ML20198A914
| ML20198A914 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Washington State University |
| Issue date: | 12/22/1983 |
| From: | Nyman C WASHINGTON STATE UNIV., PULLMAN, WA |
| To: | Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20155J110 | List: |
| References | |
| FRN-49FR27769, RULE-PR-50 AB60-2-068, AB60-2-68, AB61-2-68, NUDOCS 8605210348 | |
| Download: ML20198A914 (3) | |
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WASHINGTON STATE UNIVERSITY N
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THE CRADUATE SCHOOL (509) 3353535 l
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December 22, 1983 Dr. Nunzio J.
Palladino, Chairman U. S. Nuclear Regulatory Commission i
Washington, DC 20555
Dear Dr. Palladino:
Thank you for your letter of December 2, 1983 concerning highly-enriched uranium (HEU) fuel at Washington State University's research reactor.
Unfortunately, your letter did not arrive at WSU until December 12, 1983.
This did not provide sufficient time for a response to be prepared prior to the December 19, 1983 hearing on HEU fuel.
Dr. Royston H. Filby, Di.ector of the Nuclear Radiation Center, also received a letter from you; this letter represents the Washington State University response.
The letter that I received from Commissioner Gilinsky indicating that the fuel in the WSU TRIGA reactor "is a nuclear explosive" is quite disturbing. After consulting with the staff who operate the WSU TRIGA reactor, I find that this statement is very misleading and ill advised.
The WSU TRIGA reactor is fueled with FLIP fuel rods which are a mixture of uranium and zirconium hydride that is essentially a ceramic-type material clad in stainless steel. The uranium in the fuel is enriched in the uranium isotope U-235 to 70% but only 8.5% by weight of the fuel is uranium. Furthermore, the fuel also contains a burnable poison, erbium, such that the FLIP fuel exhibits the same nuclear characteristics as fuel with a 20% enrichment.
1 I am told that the fuel from any TRIGA reactor cannot be directly used to construct a cland<.stine nuclear weapon. The highly radioa.:tive fuel reaterial would need to be dissolved and the uranium extracted.
It is my 1
understanding that this has never been done on a large scale for the ZrH type TRIGA fuel.
Thus a considerable amount of research and development work would need to be done to develop an extraction plant.
f It has been estimated that it would take of the order of 20 Kg of 70%
enriched uranium from TRIGA FLIP fuel to construct a crude weapon.
If we assume a high uranium extraction efficiency of say 75% for the clandestine extraction plant, TRIGA FLIP fuel containing of the order of 30 Kg of I
uranium would be needed for the project. This amounts to about two complete FLIP TRIGA reactor cores. Realistically, TRIGA FIdP fuel is not a very attractive material to construct a clandestine weapon.
8605210348 860514 PDR PR 50 49FR27769 PDR 1
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i Dr. Kunzio J. Palltdino I
December 22, 1983 Page 2 I understand that in 1978, while you were a Dean at the Pennsylvania State University, that you chaired the morning session of the "Non-Power Reactor Licensee's Conference" held in Ann Arbor, Michigan on the subject of security. At that time, as a member of the academic community, you were well aware of the impact of Federal Regulatory activities upon academic l
institutions. I am also sure that you are aware of the fact that many in the nuclear research community consider that academic nuclear research in is waning relative to that of other countries and that this is the U.S.
due, in part, to onerous federal regulations and lack of federal support.
The policy statement in the NRC staff position paper on the question of reduced enrichment of domestic "Research and Test Reactors" states:
"Because of the high cost of construction and operation and relatively low student enrollment in the nuclear departments of universities, the staf f does not expect to receive any new license applications for research reactors in the near future. Following the issuance of
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F the present backlog of 20 license renewal applications, there will be 1 to 4 renewals processed annually with renewals issued typically for 20 year 1 Most of the
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research reactors are not refueled often due to low usage and consequently low burn-up.
At these current rates j
many licensees expect to use their present cores for the rest of this century."
one wonders if the Commission in its zeal to regulate is not overreacting.
If you " kill the goose (universities) that lays the golden egg" (research and training students) the nation is in serious trouble.
It appears that in the reactor research area, the United States is rapidly becoming a second-rate nation.
I am further told that the technical and cost aspects of conversion from HEU to LEU have been adequately covered in reports by the NRC staff and the Non-Power Reactor Users Groups. However, it must be clear that if WSU is forced to convert to LEU, that 100% of the associated costs must be borne by the federal government. In addition to the estimated $250,000 cost per reactor, the research programs at WSU would be significantly impaired during the year, or so, that it would take for the actual There would be a significant loss of productivity during the conversion.
2-to 3-year period when the reactor staff would be preparing for the conversion rather than devoting their time to more constructive activities.
The WSU TRIGA reactor facility currently has on hand sufficient TRIGA FLIP I
fuel to operate for the next 10 to 15 years. Approximately 5 man-years of effort were expended during the past 10 years to shift from 20% standard TRIGA fuel to 70% TRIGA FLIP fuel. This conversion was prompted and funded l
The licensing backlog includes research and test reactors which use either 1
There are 66 non-licensed research and test reactors.
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' Dr. Nunzio J. P311cdino December 22, 1983 Page 3 by the federal government.
It is extremely troubling that we are now being told that the federal government wishes to reverse this process.
The uncertainty reflected in this process is a major reason for the poor state of nuclear research in the United States.
Dr. Filby and the Reactor Staff will be happy to provide a more detailed analysis of the effects of the reactor fuel conversion.
Sincerely yours, 0
W C. J.
n Dean and Associate Provost for Research CJN:jo cc Senator Evans R. H. Filby Representative Foley Senator Gorton j& $/~.k 'c' POL GA Technologies Inc. P o. Box 81608 $,$s[ 7 m u2m 21 November *1983 Mr. Harold Denton Director Office of Nuclear Reactor Regulation I U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Denton:
As a participant in the Test Research and Training Reactor (TRTR) Confer-ence recently at MIT I want to express appreciation that you and your colleagues could take time from your Washington schedule to meet with us. As you are well aware, many problems threaten the research reactor commun-ity. Some of these problems arise from sources - such as'the activists' attacks on license renewals - that are mainly beyond the control of our community. On the other hand, several of our problems have been and are being created by the Commission, especially as a result of its responses to political pressure. The research reactor consnunity members are well aware of the need to pre-vent uncontrolled proliferation of nuclear weapons and weapons materials. At the same time we are also aware, as you must be, that the research re-actor facilities in the United States have never been a source of supply for nuclear fuel for clandestine purposes and surely are unlikely future sources. The NRC at times seems unaware, or insensitive, or both, to the great value of the scientific and technical research that our research re-actor community provides. The inestimable value of the resulting medi-cal, biological, high technology advances, research in so many areas, and training not only for reactor operators but also for the future cadre of researchers must be weighed against the potentially prohibitive costs of the proposed Security and Safeguards programs. Several of us at the recent TRTR meeting viewed with interest the LEU conversion program you and your NRC colleagues outlined. As one par-I ticipant, I viewed your proposed program with sympathy for your goals but with alarm for its single minded attention heavily slanted to the needs of the owners of university reactors. i q K\\ o-
-a. < = - - -~ w-a -.: w:- y i J l_ l J Harold Denton-11/21/83 The LEU Conversion Program
- discussed:
1. No new research reactors licensed with REU fuel. J 2. All refueling of existing research reactors shall be with LEU l provided: (a) DOE will bear all costs to university reactor owners, and (b) Purpose of reactor shall not be jeopardized by use of LEU. (' paraphrased in the writer's words.) i The thrust of this approach ignores important non-power reactors that are privately owned and for which private funds (not DOE funds) must bear the costs of mandated LEU conversion. Why is this national imperative being ] j considered only if it is at no cost to university and DOE reactors? i To avoid unwarranted and unseemly preferential treatment of the univer-sity reactors at the expense of the few (two or three) privately owned reactors presently using HEU fuel, the Commission need only provide for i reasonable. site dependent, alternatives in any solution to be mandated. In view of the Galinsky presentations (letter to university officials in October,1983 and the lecture he delivered at the November LEU conversion symposium in Japan in November,1983), we view with heightened concern the future Safeguards and Security regulations that may be initiated with J l the rashness of the Galinsky approach and which may force members of the j private sector's research reactors out of business. In addition, if the Galinsky approach should prevail and LEU is mandated (solely in the in-terest of removing HEU fuel from use) then several HEU users with small reactors would have to ship HEU for disposal that would normally reside in the reactor for many years - even for the lifetime of.the reactor in several cases. Instead of reducing the transport and handling of HEU fuel, this approach would have the undesirable effect in several reactors l of increasing the transport and handling of HEU. Your sympathetic and effective attention to the legitimate needs of the private sector of the research reactor community is respectfully antici-l pated. For your convenience, we have also enclosed herewith a copy of d i l k
-.. - _. _.. _.. _ _ = _ - - - -. - - - - Harold Denton 11/21/83 the official response we are submitting to the recently proposed safe-guards upgrade program offered for public comment. Yours sincerely, kF' W. L. Whittemore, Ph.D. Senior Scientific Advisor WLW:he cc: w/ enclosure N. J. Palladino, Chairman, NRC Cecil Thomas, Chief, S&SP Br., Div.of Licensing, NRC cc: w/o enclosure W. Richards, Chairman, ANS-15 Robert S. Carter, NBS, Chairman N17 Lincoln Clark, Jr., Chairman TRTR (1983) S L l
..-. - -,-~ ..w m. . a.. -wy u .sv y \\ .V ( kuGr' a.,-..,, In Reply Refer To: ARL-5061 GA Technoiogies Inc. 'ONNAuroac sms 22 November 1983 s i6199 455-3000 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch.
Subject:
Comments on NRC's Non-Power Reactor Physical Protection Rule.
Dear Sir:
The NRC published, in the Federr.1 Register dated July 27, 1983, a pro-posed rule for physical protection of SNM in non-power reactors possess-ing a formula quantity of strategic SNM (SSNM). This letter contains the comments from GA Technologies Inc. on the pending matter. In brief, our comments relate to two basic problem areas involving: (1) the application of self protection criteria to each removable fueled component without regard to quantity of SSNM and (2) the continued references to unprotected formula quantity of SSNM which then require application of 10 CFR 25 & 95 regulations for protection of related information. These two troublesome areas could easily be avoided if, as in IAEA Infcire 225, the self protection criteria could be applied to a quantity of fuel rather than each removable component such as fission chambers, fuel foil assembly, fuel plate or in the case of TRIGA reactors a single element containing slightly over 1/10 of the upper limit for unirradiated SSNM of low strategic significance. We have previously suggested that self protection should be required for a quantity of SSNM of approximately 1 kg. A quantity between 500 gm to 1 kg would be acceptable. This would assure that any significant quantity f of material stolen would have substantial radiation associated with it and that any formula quantity of SSNM would be several times the self pro-tecting dose rates. In fact the stolen assemblage of a formula quantity [ would have a lethal dose giving capacity. It would also avoid the prob-les associated with small qu' ntities of SNM which can't be irradiated to a the self protection level. It should be noted that for TRIGA reactors, especially those most significantly impacted by the rule, a formula quan-l tity constitutes approximately 1/3 of its roughly 110 elements with each element containing the order of 100-130 grams of SSNM uniformly distribu-ted in about 3 kg of zirconiue metal alloy. Y i U% q n, 3 ge \\y a
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~ w-- i Secretary, NRC ARL-5061 We support the Commission's position that each licensee must not have a formula quantity of materials that is not self protecting. We, as a re-sponsible member of the research community, also support reasonable phy-sical protection requirements which will assure that no significant (neither moderate nor formula) quantity of SSNM can be successfully stolen from a reactor. We believe that our proposal above will assure attainment of that goal. Our more detailed coimeents are provided below. 1. 10 CFR 73.6 - As written this section along with 73.67(b)(0) seem to preclude non-power reactor licensees from utilizing the laboratory exemptions of 73.6(c) or 73 67(b)(1)(1). This is but one example of the illogical bias against non-power reactor licensees who are un-fortunate enough to possess a formula quantity of SSNM and cannot reasonably keep each small quantity of such material at the "self- [ protecting" level. I 2. 10 CFR 73.6 - As written this section imposes needless additional record keeping. Most non-power reactor licensees have very few in-dividuals authorized to access the reactor room or the reactor's = controls. Other regulatory requirements require the logging of visitors, issuance of monitoring equipment as applicable, surveil-lance and control of visitors to assure their safety as well as pre-vent unauthorized activity. The added 10 CFR 73.70 record-keeping for movements within facility subspaces is unwarranted, particularly since 10 CFR 73.67(a) & (d) require controlled access areas to be locked and alarmed or attendeq by authorized individuals. Note also the required 73.67(d)(7) escort requirement. With these procedures the 73 70 record-keeping reference should be deleted. 3 10 CFR 73.6(e) - The phrase "and any licensee subject to 10 CFR 73.67(e) is not exempted from 10 CFR 73.72 of this part" is in-correct and is unnecessarily biased against non-power reactors. Perhaps the intended reading should have been "...10 CFR 73.67(h). We believe the phrase is not needed. If 10 CFR 73.67(e) was in-tended, then it should be changed to require any 73 72 advance notices. In this way the bias for NPRs would be removed. 4. 10 CFR 73.67(b)(2) - This section is redundant and is inappro-priately inserted here. 10 CFR 73 50 is a separate section pre-scribing the physical protection requirements for a formula quantity of self-protected SNM in other than operating reactors. t 5. 10 CFR 73.67(b)(3) - could be clarified by replacing "above those of special nuclear material of moderate strategic significance" with "of 10 CFR CFR 73.67(h)." In addition this section is the most logical section to incorporate the accepted quantity of SNM which l must be self-protecting. Suggested word. changes are as follows: 1 i l'
m Secretary, NRC ARL-5061 a. Insert after possesses the words "1 kg of" b. delete the word "other" and optionally insert "its" in lieu thereof 10 CFR 73.67(b)(3) with suggested word changes is stated below for clarity. "(3) A non-power reactor licensee who possesses a formula quantity is exempt from the additional requirements of 10 CFR 73.67(h) to the extent that it possesses 1 kg of special nuclear material which is not readily separable from radioactive material which has a total external radiation dose rate in excess of 100 Rems per hour at a distance of 3 ft from any accessible surface without intervening shielding." Such wording would assure that each such quantity would have a min-imum radiation level and any theft of material would be accompanied by a proportional amount of unseparable radiation. Please note the suggested value.is less than a quantity of moderate strategic signif-icance established for unirradiated material and is a small fraction of a formula quantity likewise established for unirradiated mater-ial. Adoption of this approach would supplant the staff's method of using weighted averages over a core with radiation from no element less than a specified level. The staff's suggestion of averaging over the whole core to demonstrate the self protection with no element less than 50 R/hr is helpful. However, substantial but intermittent operations will not assure that the Bisproportionately large number of elements on the periphery of the core can achieve the criteria. Dose averaging over the core is very sensitive to this large segment of the core experiencing a relatively lower power density. Lowering the individual value permitted in the staff's suggestion to about 15 R/hr would be satisfactory for most affected NPRs. You will note that our suggestion above of a 1 kg quantity that gives 100 R/hr at l 3 ft is essentially equivalent, since the renoval of a 1 kg quantity involves at least eight time consuming operations and eight of the elements taken from the periphery will approximate 120 R/hr at 3 ft. I 6. 10 CFR 73.67(b)(4) - We believe this section is inappropriate here under a section of exemptions. It appropriately belongs as a con-ditional statement in 73.67(h). 5 i 7. 10 CFR 73.67(b)(5) - From the safeguards point of view we have no objection. Note, however, that this is in conflict with IAEA Infcire 225 precedent wherein a material quantity relative to. its strategic significance is established presuming no irridation. Then j if this quantity is not readily separable fran its radioactivity and it has a radiation level in excess of 100 R/hr at 3 ft the level of i
. u- = =- .a; -g _ a .__a u -~.. e Secretary, NRC ARL-5061 physical protection may be reduced by one category. We believe the Commission's best interests are served by allowing its rules to move i toward compatibility with those of the international community. 6. 10 CFR 73 67(b)(6). The abhorrent special denial for non-power reactors must be removed. There is no logical basis why a uni-i versity's laboratories supporting its nuclear program should be denied opportunities afforded any other non-power reactor or SNM licensee. 9. 10 CFR 73.67(c)(3) requires submission of new physical protection plans. All facilities now have physical protection plans which are afforded protection under 2.790d, 73 21 or 10 CFR 95. One can con-i clude tne new plans are to be protected under 10 CFR 73 21. The objections to this part are (1) fees will be levied to only three known facilities to pay for rather minor plan upgrading and (2) that the rule is silent about the need to protect suen plans under 10 CFR i 95, 25, and 11. Though unstated, we suspect the staff will impose costly and burdensome procedures on the classification of such NPR l physical protection plans. Imposing NRC access clearances upon in-l dividuals working in NPR research facilities for the marginal bene'- fit added to the facility safeguards is unwarranted in our view. Note that in bulk, 10 CFR 95 Appendix A, has no relevance to re-i search reactor operations. There will likely be no formula quantity i receipt of fuel. Material accounting ID & LEIDs are irrelevant, j Spent fuel shipments will be made under 10 CFP 73 37 or its super-l seding rule. Fuel movements are infrequent so knowledge of fuel j whereabouts in the facility has no safeguards significance; it is i presumed to be in the core or related pool storage. The layouts of I each facility are already in the public possession througn NRC's i public document room. For these cad a variety of other reasons, the I Commission should not require NPR to safeguard their physical protec-I tion plans under procedures of 10 CFR 95, 25 or 11. i t i 10. 10 CFR 73.67(h) - As mentioned above, we believe the thoughts em-t bodied in 73.67(b)(4) could be included here by (1) revising the i lead paragraph to insert the words "notwithstanding (h)(4) below," 3 before the second sentence lead word "Each," and (2) moving words j from 73.67(b)(4) to 73.67(h)(4). Otherwise we have no objection to 1 the requirements of 10 CFR 73.67(h). ( 4 11. 10 CFR 73 70 - There is no need for change to 73 70 for reasons } given above. Ij 12. In addition to our comments on the rule as written, we wish to j comment upon the apparent lack of previously available safeguards .i credit given to certain reactor fuel types where small quantities of i SSNM are contained in zirconium hydride erbium alloy. For the TRIGA j FLIP FUEL (70% enriched U) the U-235 is uniformly dispersed in 1.85 g ratio within the aforementioned alloy. We presume some safeguards credit will continue to be given for fuels of this type,
w. _ - - -m :- :, -- - a. l a Secretary. NRC ARL-5061 We hope the consients provided above have been useful.in your development of a final physical protection rule for NPRs. We are hopef61 that such a rule clearly divests itself of connotations that formula quantities of SSNM are in NPR without adequate protections because protections of 10 CFR 73 20. 73 45, 10 CFR 95. etc.. are not implemented. Should you have any questions, we would be happy to discuss them with you. My telephone number is (619) 455-2823. Very truly yours. W William R. Mowry Licensing Administrator WRM:he .}}