ML20198B106

Responds to NRC Requesting SNM Inventory Justification.Justification of 45-kg Allotment & Info Re Inventories for Proposed Fuel Design Change Encl

ML20198B106
Person / Time
Site:	05000000, University of Wisconsin, University of Missouri-Columbia
Issue date:	09/14/1979
From:	Alger D, Mcginty D MISSOURI, UNIV. OF, COLUMBIA, MO
To:	Reid R Office of Nuclear Reactor Regulation
Shared Package
ML20155J110	List: ML20198A914 ML20198A942 ML20198A968 ML20198B004 ML20198B021 ML20198B027 ML20198B033 ML20198B075 ML20198B086 ML20198B106 ML20198B837
References
FRN-49FR27769, RULE-PR-50 AB60-2-101, AB61-2-101, NUDOCS 8605210528
Download: ML20198B106 (8)

Text

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I Research Reactor Facility M

p.,,,,en p.,x UNIVERSITY OF MISSOURI Columbia MHtsouri 65201 meste m4) ss2 42n September 14, 1979 Hr. Robert W. Reid, Chief Division of Operating Reactors Nuclear Regulatory Commission Washington, D. C.

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Reference:

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Docket 50-186 2.

NRC letter dated 30 July 1979 re-questing SNM inventory justification.

Dear Sir:

~ The dotal amount of Special Nuclear Material-(SNM) required for'operatiori of our

- research reactor is, present1.y 45kg. The justification of this amount is presented in

. Tabli 'I which 'al'so contains 'information on ~ inventories for'a proposed fuel design

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-change..

The 45kg inventory limit is based on a one-year fuel cycle. This basis may need to be changed to a modified two-year fuel cycle, since operating inventories are presently controlled by various external factors over which our facility has little cr.no control.

Several of these external. factors have been brought to our attention in recent months and we would like to relate briefly their effects on our SNM in-ventory. These factors will be treated according to the following categories:

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Licensing of Spent Fuel Shipping Cask.

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Security regulations concerning Spent Fuel Shipments.

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New regulations on Un-irradiated Fuel Shipments.

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Non-regulation uncertainties, The difficulty and lack of timeliness in licensing of the spent fuel shipping 3

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casks has caused MURR to stretch the inventory limit to its maximum. -

1) Our recent experience indicates that the licensing of a spent fuel shipping cask can take from six months to a year or more. This time is not included in our inventory analysis, but should be when one considers the fact that our present Certificate of Compliance for G. E. Model 700 Shipping Cask was issued with an t

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Hr. Robert W. Reid September 14, 1979 Page 2 expiration date of only about ten months from the date it was issued. Another i

factor we have experienced and increases the fuel cycle is the cancellation of a shipping cask license without an adequate time for adjusting fuel inventories or getting a new cask licensed (as shown in Table II).

2)

In our recent fuel cycle experience, the security regulations related to spent fuel shipping have necessitated a D.ge inventory limit.

Inventory level at our facility reached 44.6kg one week before we received permission for the first fuel shipment in June of this year.

If any part of NUREG-0561 on spent fuel shipments had been implemented at this time, this shipment would not have been accomplished.

This would have resulted in curtailed research until either the fuel shipment had been accomplished or the inventory limit was increased to allow continued operation of the research facility.

Our fourth fuel ship-mer.t of this set of shipments has been delayed over two months as shown in Table II. As yet no firm shipping date has been reached.

These uncertainties in a fuel cycle dictate an increase in the storage capability and inventory requirements beyond our present limits.

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~ 3).New security r.egulations.regarding un-irradiated fuel shipments when.imple-m

.mented will result in delays for the delivery of new fuel.

How much of,a delay is uncertain but this will need.to be considered.in determining SNM inventories.

If the delay is in the order of several months; the number of

' fuel elements ~ in the active cycle will have to be increased from 24 to 32 for our facility, necessitating an inventory limit increase of 6kg.

4)~ ~ Non-regulatory uncertainties cover the area of transportation (trucker's strike), weather, quality control, and facility operational schedule and these can cause interruptions in the fuel cycle.

These interruptions to a normal fuel cycle are usually minor since their durations are very short.

1 Our present inventory limits are just sufficient to absorbe these effects when they are minor but any reduct. ion in the fuel inventory would present

j problems.

New fuel designs under consideration at HURR will make an increase in our power level possible and increase the research potential by 50% while decreasing the SNM requirements of an associated fuel cycle and decreasing the cost per HWD for making neutrons.

Depending upon ultimate design, inventory requirements might be reduced 4

by a minimum of Skg.

However a transition period for converting to a new fuel design j

will dictate a temporary increase in our SNM inventory limit.

The time involved for the phase in/out of different core designs would take approximately a year after license approval. Our facility can not financially afford the insnediate conversion to a different fuel design.

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Mr. Robert H. Reid September 14, 1979 Page 3 Once the impact of the new regulations for irradiated and un-irradiated fuel is clearly understood, a proposal to increase our present inventory limit may need to be considered.

This problem will be evaluated more closely once all the new regulations are in effect, Sincerely, Bst mW David McGinty Reactor Physicist Endorsement:

Reviewed and Approved:

I DA Donald M Alger

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Table I TOTAL AMOUNT OF SNM REQUIRED FOR OPERATION of UNIVERSITY OF MISSOURI RESEARCH REACTOR Category Present Proposed

• Exempt Minimum of 24 elements Minimum of 24 elements in active fuel cycle in active fuel cycle Core - 8 elements 6.2 kg Core - 8 elements 7.96 kg Pool - 16 elements 12.4 kg Pool - 16 elements 15.92 kg 10.6 kg 23.88 kg Exempt Storage (awaiting shipment)

Storage (awaiting shipment) 24 elements 14.4 kg 12 elements 7.2 kg Exempt Elements awaiting proper Elements awaiting proper decay decay time **

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10 elements 6.0 kg 5 elements 3.0 kg Non:xempt Vault Vault 6 elements 4.65 kg 4 elements 3.98 kg TOTAL t

64 elements 43.65 kg 50 elements 38.06 kg Miscellaneous

< 350 kg

<.350 kG E

44.0 kg

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The proposed fuel design will allow a 50% increase in power level and research potential while decreasing the amount of material in the fuel cycle.

This increase in productivity j

allows the more efficient use of special nuclear material and reduces the safeguards i

threats.

Recent restrictions imposed by NRC certificate of compliance for our shipping cask has increased this number from 8 to 10.

I ote: On a regular basis, fuel will be transferred from the vault to the core as part of the N

fuel cycle. During this period of transition from a nonexempt to an exempt status, the core access area will be attended by an authorized individual.

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Fuel shipments from the University of Missouri Research Reactor (MURR) have been completed in a routine manner in previous years. The only major uncontrolled variables effectingspent fuel shipments were weather conditions.

This effect was compensated for, since fuel shipments were controlled largely by our staff.

The following chronological event listing shows that fuel shipments can no longer be r

completed in a routine cycle and will require an inventory increase to ensure normal

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operation of our facility.

Table II CHRONOLOGICAL EVENTS FOR FUEL SHIPIENTS 1979 September 6,1977 Received letter from NRC stating expiration date for NL cask certification changed from December 31, 1977 to April 28, 1978.

December 5,1977 Shipped 14 elements in NL cask.

. January 4,1978 MURR letter requesting extension to September 30, 1978, of NL cask certification.

March 13,jl978

.NRC letter denies extension.'

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.~" Possibility.of oth'er ship;iing' cask investigated..In order.to

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~ ~7e?the Shipping' Cask Analysis' was-undertaken in a joint effort-r 4

with the Nuclear Enginee' ring Department. Three theses were l

completed on this analysis at the Master's level.

January 10, 1979 Safety Analysis for shipping cask. submitted.

Ahil 18,1979 Additional information requested by NRC.

t May 22,1979 Supplemental information provided to NRC.

June 12,1979*

License granted for MURR use of G.E. Model 700 shipping' cask.

(Initiated shipping plans on receipt of telecopy of license.)

I June 25,1979 Processed first fuel shipment. Trucker's strike in progress results in no other cask being processed at Savannah River j

Plant therefore turnaround time minimum.

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June 27,1979 Received license in mail - dated 21 June 1979.

July 2,1979 Processed second fuel shipment.

Approximately 3 days involved for turnaround of cask since Savannah River Plant at normal operating schedule due to truck strike being resolved.

July 9,1979 Third shipment rescheduled due to delay in return of cask.

4 Shipment planned for midweek causing an additional shutdown to be scheduled.

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License granted 12 June 1979 with an expiration date of April 30, 1980.

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o Table 11 - continued July 12,1979 Processed third fuel shipment.

July 12,1979 Submitted route approval to NRC in compliance with new regulations NUREG-0561 with planned shipping date of 30 July 1979.

July 30,1979 Cancelled fourth shipment due to route approval not received from NRC.

Further scheduling of fourth fuel shipment delay until route approval received.

August 15, 1979 Received route approval from NRC in letter dated 10 August 1979.

Primary route was disapproved as not meeting regulations.

though the route had been used by MURR for over ten years in shipment of spent fuel.

Proposed alternate route was approved with an alternate

. reconnended for a section under construction.. Planned 3

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August 17,1979 ' {.: Route submitted to Tri-State by phone and mail..

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August 24, 1979

- Notified that three segments of secondary route unsatisfactory to Tri-State.

They judged route to be unsafe for truck route.

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Cancelled fourth shipment planned for 27 August 1979.

August 28, 1979 Tri-State commencing additional survey to find route that meets their safety requirements.

i August 30, 1979

. Received route from Tri-State that meets their safety con-siderations.

NRC notified of route by phone and letter.

Fourth shipment is planned for 10 September 1979 pending route approval by NRC.

September 5,1979 Informed by HRC that the route survey cannot be accomplished until the end of September.

Cancelled fourth shipment planned for 10 September.

Our fourth and fifth shipments will cost an additional $2,500 each because of delays due to new regulations.

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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS RHODE ISLAND ATOMIC ENERGY COMMISSION Nuclear Science Center i

South I'erry Road Narragansett, R. I. 02882 September 13, 1983l l

i Dr. Harold H. Young, Chief Laboratory Programs Branch Division of University and Industry Programs Dapartment of Energy Washington, DC 20585

Dear Dr. Young:

This letter is in response to your request for information concerning the consequences of converting to LEU fuel elements all at once. We presently have 61 HEU fuel elements with varying amounts of burnup, all requiring disposal as spent fuel. If shipments were made using the BMI-1 cask, 3 trips to the reprocessing plant would be necessary. This assumes that we trim the end boxes allowing for 24 elements per trip.

For delivery to Savannah River, the cost per trip would be about $15,000 c

for cask rental and $8,300 for transportation for a total of $23,300 per trip. For delivery to Idaho Falls, the cost per trip would be about $16,000 j

for cask rental and $13,780 for transportation for a total of $29,780 per trip.

We have an additional 42 HEU fuel elements which have not been used. These would require shipment to a cold scrap recovery plant in 11 containers.

I cannot provide a cost estimate for this because we have never disposed of new elements.

It would, nevertheless, not be insignificant.

We appreciate the concerns of the safeguards community and, while not agreeing entirely with their estimates of the magnitude of the threat, we accept the fact that we can convert the Rhode Island reactor to the use of LEU fuel without appreciably degrading specifications. To this end, we will soon begin the preparation of a safety analysis report for submission to the Nuclear Regulatory Commission for a license modification permitting the use of LEU.

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. T Dr. Harold H. Young, Chief September 13, 1983 Page 2 In the meantime, we believe that a prudent approach would allow the normal

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utilization of existing fuel with all new fuel fabrication being LEU.

Using this approach, we would be utilizing LEU elements sometime in 1986.

We will be pleased to provide additional information if necessary.

Very truly yours,

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MAY 251984 MEMORANDUM FOR:

R. M. Bernero, Director Division of Risk Analysis and Operations Office of Nuclear Regulatory Research FROM:

W. R. Lahs Regulatory Analysis and Materials Risk Branch Division of Risk Analysis and Operations Office of Nuclear Regulatory Research

SUBJECT:

PROPOSED INFORMATION PAPER ON RESEARCH REACTOR FUEL CONVERSION DEVELOPMENTS AND RELATED ISSUES This memorandum responds to IP's May 22, 1984 request for comments on the sub-ject paper (attached).

i The identified shortfall in the FY 1985 RERTR program funding as proposed by the House Comittee on Science and Technology certainly warrants Comission attention.

Any delay in the RERTR program, as indicated, could be expected to have a direct impact upon the timing of any Comission-directed conversions of NRC-licensed research and test reactors.

In this regard, a request for Comis-sion guidance on appropriate staff action would be more appropriate than the suggested supporting action which presumes a " fait accompli" specific Comis-sion conversion program.

The sumary of the meeting with European Officials could further contrast the DOE vs. NRC conversion actions by highlighting the respective amounts of total HEU in each Agency's research reactors.

The concern expressed "...over unfair practices if European reactor operators, in competition with U.S. operators, l

were placed in an unequal cost position through forced conversions when the U.S. operators enjoy the advantages of non-conversion," should note that this j<

statement probably applies to only one or two NRC licensees at most.

These licensees could also be exempted from conversion under the " unique purpose" provisions of the proposed rule.

To provide a point of reference, the contrast between THTR (pebble bed) reactor annual requirement for 150 to 200 kg of HEU per year and the total NRC licensee requirement of 50 Kg. could be indicated.

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Finally, the stated conflict with the Department of State's position could be subject to interpretation as to whether their position refers to overall domes-tic conversion (for which conflict may exist) or only NRC's efforts (for which no conflict should exist).

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APR 4 1984 MEMORANDUM FOR: Robert B. Minogue, Director Office of Nuclear Regulatory Research FROM:

John G. Davis, Director Office of Nuclear Material Safety and Safeguards

SUBJECT:

0FFICE CONCURRENCE REQUEST:

PROPOSED PART 50 AMENDMENT TO LIMIT THE USE OF HIGH ENRICHED URANIUM (HEU) IN NON-POWER REACTORS This is to confirm the telephone conversations on March 30 and April 2,1984, between Mr. Robert J. Dube and Mr. William R. Lahs. NMSS concurs in the subject paper subject to the following revisions:

1.

Either change the number of licensed HEU nonpower reactors to 30 or insert a footnote thet the number 31 assumes that the General Electric GETR reactor will be licensed for future operations.

It is our under-standing from NRR that the GETR cannot resume operations without sub-mitting and having approved an Operational Readiness Plan, and that GE has sold their fuel and is negotiating for sale of their targets.

2.

On page 10 of the Regulatory Analysis, change the beginning of the paragraph on " Reduced Safeguards Costs" to read as follows:

"For most reactors conversion from HEU to LEU would permit a facility to enploy a lower classification of safeguards requirements. The savings in safeguards costs by conversion to LEU would be even greater compared to the costs of the additional safeguards measures for HEU being pursued by staff in response to the February 23, 1984 memorandum from the Commission. The financial benefit...."

3.

On page 4 of the Environmental Assessment, delete the paragraph on the environmental impact of increased security measures, since this proposed rule does not address security measures.

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i POLICY ISSUE May 30,1984 (lnfOrmatiOn)

SECY-84-220 For:

The Comissioners From:

William J. Dircks Executive Director for Operations

Subject:

RESEARCH REACTOR FUEL CONVERSION DEVELOPMENTS AND RELATED ISSUES purpose:

To infom the Comission of (1) recent developments in the Reduced Enrichment in Research and Test Reactor (RERTR) program which may affect current reactor LEU fuel conversion schedules and (2) a recent meeting with European officials on European research reactor fuel requirements.

t RERTR Budoet:

Under current schedules, the DOE /Argonne RERTR program projects that the bulk of the testing and evaluation requirements for proving the proposed new 20% enriched LEU silicide reactor fuels would be completed by 1987.*

l Assuming resolution of funding and licensing issues, this schedule would enable initial conversion of candidate U.S. and foreign research reactors to LEU fuel usage by 1988.

However, this tentative conversion schedule is heavily contingent upon continuation of adequate DOE funding support for the RERTR test and evaluation programs.

The staff has learned recently that the House Comittee l

on Science and Technology has proposed a FY 1985 funding level for the RERTR program of $4.932 million.

Argonne officials have informally advised the staff j

that this amount would cause a $700K shortage, which would preclude the procurement of the LEU fuel for the full-core demonstration and will force a probable one-year delay in completing necessary test and j

evaluation programs.

This delay would extend eventual

Contact:

Marvin R. Peterson l

Office of International Programs

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492-4599 I

• Approximately 6-8 of the 31 HRC, licensed, reactors would be likely candidates l

for utilizing these silicide fuels.

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The Commissioners 2

Discussion:

achievement of the program's objectives into the (Continued) 1990's. The staff is monitoring these developments closely and is also attempting to obtain a more official DOE assessment of the impact of the croposed FY 85 RERTR budget.*

Meeting With As a related matter, on May 14 the staff attended a European meeting between U.S. and European officials to discuss Of ficials :

European research and test reactor fuel requirements.

The European delegation was headed by Juergen Jaspert, Principal Administrator, EURATOM Supply Agency.

It was disclosed at the meeting that activities to convert European reactors to LEU fuel were progressing adequately. However, interim HEU fuel exports would be necessary for the next few years until the new LEU fuels were available.

Horst Hassell from NUKEM, the West German fuel fabrication company, noted that the obligation to study conversion to LEU fuel also applies to the U.S. and that, in particular, DOE's research reactors, except for the Oak Ridge Research Reactor (ORR), continued to be conspicuously absent from any participation in reactor fuel conversion studies and possible identification as candidates for conversion.

While the European side did not explicitly threaten to reduce cooperation in conversion activities if efforts to convert DOE's reactors were not more forthcoming, it was clear that any failure by the U.S. to cooperate fully in the conversion effort would eventually have a significant impact on the Europeans' approach to the entire matter. Mr. Jaspert voiced concern over unfair

• As this paper was being dispatched, NRC received a copy of a letter dated i

May 22,1984 (Appendix A) from DOE (Laughon) to State (Malone) which J

confirms that the current proposed budget will probably cause delays in the RERTR program and suggests the possibility of supplementary budget i

support from other agencies (perhaps including NRC).

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Discussion:

practices if European reactor operators, in competition (Continued) with U.S. operators, are placed in an unequal cost position through forced conversions when the U.S.

operators enjoy the advantages of non-conversion. The Europeans also expressed serious concerns regarding the 4

still unresolved issue of DOE's policy on the return of spent LEU research reactor fuel to the U.S. for reprocessing or storage.

Resolution of this issue is critical to the long-range spent fuel disposition plans of European research reactor operators. As noted by j

the official from the Petten research center in the Netherlands, LEU fuel cycle costs are expected to l

exceed HEU fuel cycle costs by approximately 25% and any increase in DOE spent fuel disposition costs may widen this cost differential. The Euratom delegation stated that at least four European reactors are candidates for immediate conversion from HEU to LEU but are prevented from doing so by the lack of a U.S.

l decision on the return and reprocessing of sper.t LEU fuels.

As a final matter, Mr. Jaspert also noted that it would be necessary to obtain peaceful end-use assurances fr a the U.S. Government regarding any future spent LEU research reactor fuel returned to the U.S. from Europe.

This new requirement was necessitated by the fact that significant quantities of plutonium would be contained in LEU spent fuel and European officials were not willing to pennit the possible use of such produced i

plutonium in U.S. military programs.

In sumary, the staff noted an increased sensitivity on the part of the Europeans regarding the reciprocal obligations on all parties to explore seriously reactor fuel conversion possibilities in all civil L

research and test reactors.

It shoul'd be noted, h,owever, that the State Department's position is that U.S. domestic 1

reactor conversion efforts will have only a " marginal" impact on foreign conversion programs.

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William J. Dircks

i Executive Director for Operations i!

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Appendix:

A.

Ltr from Klaughon, DOE to 4

!l JMalone, DOS, dtd. 5/22/84

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3RS REcovts USNRC I

'84 liAY 25 A7:33 Department of Energy Washington, D.C. 20545 YAY 2 21984 mf[ reb!,R PR8GP.A5 Mr. James J. Malone Assistant Secretary for Oceans and International Environmental and Scientific Affairs U.S. Department of State Washington, DC 20520

Dear Mr. Malone:

This is in response to your letter of May 4,1984, to Assistant Secretary Brewer regarding the level of funding proposed for the Reduced Enrichment for Research and Test Rectors (RERTR) Program in FY 1985. As you are aware, the Presidential request level of $4.8 million was defined by the Arms Control and Disarmament Agency (ACDA) budget submission and, based on congressional actions to date, it appears that funds for the RERTR Program will be. included in the Department of Energy's (DOE) Nuclear Energy (NE) budget as has been the case in previous years.

Federal budgets for FY 1985 are very tight as you know, and funding priorities have been carefully prepared for the DOE programs. Within the current DOE-NE budget fo-FY 1985, planned support for the RERTR Program will very likely be limited to the funding level appropriated by Congress.

As you may know, $4.93 million is presently included in the proposed House Energy and Water Development Appropriations Bill for FY 1985. We are coordinating with other offices of DOE but are not optimistic that these efforts will produce the supplemental support needed to initiate the planned full-core demonstration in the Oak Ridge Research Reactor (ORR) in FY 1985.

DOE would welcome any supplemental funding that the Department of State (DOS), ACDA, or other Federal agencies can make available to the RERTR l

Program. As currently structured, the program contains tasks to evaluate highly enriched uranium export requests, as well as efforts to implement 4

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2 These tasks' are important but only the RERTR Program results.

peripherially related to the principal DOE RERTR mission of fuels technology development and demonstration. Accordingly, DOS, ACDA, or the Nuclear Regulatory Commission (NRC)- funding might be used for these activities thereby freeing existing funds for ORR fuel procurement.

We would be pleased to discuss this matter further if you so desire.

Sincerely, W

<Kermit O. Laughon Director Office of Spent Fuel Management and Reprocessing Systems Office of Nuclear Energy cc:

Kp neth L. Adelman, Director, ACDA Aames R. Shea, Director, Office of International Programs, NRC t

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Bill Dircks M '"

(ltwe.h rev.lu. hasT PROPOSED RULE FOR LIMITING THE USE OF HEU IN RESEARCH REACTORS somed C.== W8M I have looked at the RES proposed amendment to 10 CFR Part 50 to " Limit the Use of High Enriched Uranium (HEU) in Nonpower Reactors" requested by the Commission. The proposed rule requires timely conversion of low enriched fuel unless continued use of HEU can be justified. About 31 NRC licensed nonpower reactors (including the GE Test Reactor and the UCLA reactor) could be affected by the proposed rule. Of these, 25 are owned and operated by universities, some are owned by private business and one is owned oy an agency of the Federal Government.

My concerns are (1) Rule impacts such as changes to reactor fuel and configurations, procedures and staffing (potentially significan[t lic sing i es need more work.to demonstrate practicality (2) Safety (public and occupational) impacts resulting from changes to reactors and reactor operations need to be identified and considered. 7 (3) Safety and safeguards risks associated with refueling (including jh transportation) need to be identified and cons'idered.

(4) As noted in the enclosed letter from Congressman Volkmer, the rule could cause scientific and financial difficulties" for nonpower ye reactor licensees.

(5) The rule provides for exemption - continued use of HEU. Since each nonpower reactor is uniquely used, I would expect 31 letters like the one from Congressman Volkmer.

If these exemptions are granted, the rule would have little if any effect concerning conversion from HEU to LEU. 4 Md s GW

-J (6) The cost benefit analysis is weak. Apparently, the Comission has made AA the judgment that the proposed rule is needed. %,1/

The proposed rule is not within the purview of the CRGR unless you request that the CRGR review the proposed rule.

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MU4 POL MM IM MEMORANDUM FOR:

R. Carter Standardization and Special Projects Branch Division of Licensing Office of Nuclear Reactor Regulation FROM:

William R. Lahs Regulatory Analysis and Materials Risk Branch Division of Risk Analysis Office of Nuclear Regulatory Research

SUBJECT:

PROPOSED RULE TO LIMIT USE OF HEU IN RESEARCH AND TEST REACTORS The following represent some preliminary thoughts on the basic implementation provisions of the subject rule. Establishing the criteria for " acceptability" of replacement fuel under these basic implementation provisions certainly ap-pears to be the major task.

UNIQUE PURPOSE The first licensee action required by the proposed rule (within 6 months of effective date) is an optional request for a determination that a licensee's reactor has a " unique purpose." " Unique purpose" is defined in general tems in the rule; however more specific guidance will probably be required. The most specific provisions of the " unique purpose" rule definition are (b)(3)(iv) and i

(b)(3)(iii)

"A reactor core of special design that could not perfonn its.in-tended function without using HEU fuel and - Research projects based on neutron flux levels or spectra only attainable with HEU fuel." The preamble to the rule states that technical feasibility of conversion is dependent on the continued success of the RERTR program. The preamble also suggests that conversion, in its simplest fonn external dimension, consists of replacing HEU with LEU fuel without changing the l

s.of the element or significantly changing the ther-mal-hydraulic characteristics of the core.

If a licensee can demonstrate that the achieved or projected increases in the uranium density of LEU fuel under i

development in the RERTR program, do not permit a conversion which is techni-cally feasiblg a case for unique purpose could be made. Under this approach

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the NBS, UCC, GETR(?), MURR and MITR would be potential candidates for a unique purpose determination. Considering the rule's tie-in with the RERTR program, three other reactors may be considered unique on an interim basis pending a DOE /NRC commitment to replace fuel of unusual design. These reactors include GE-NTR, WNTR, and MCZPR. Alternative conversion possibilities could be studied for these facilities.

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f PROPOSED CONVERSION SCHEDULE i

The second action required by the proposed rule (within 12 mo of effective date) is the submission of a conversion schedule by all 31 licensees. Those reactors determined to be " unique purpose" facilities could tie their conver-j sion schedules to potential development of replacement fuel acceptable to NRC.

Based on NRC decision, DOE would have to be lobbied to include development of suitable fuel in their RERTR program. The remaining reactors fall into two classes:

(1)thosewhichcouldutilizeUAlxfuel3P ates for which full core l

demonstrations have been achieved (FNR - 2.39 /cm ) and (2) those which require fuel types in which individual element or full core demonstrations are yet to be accomplished.

In the first class, conversion hinges sequentially on (1) a detennination by the NRC that the fuel as demonstrated is acceptable and (2) the procurement of 4

j such fuel through D0E. The licensee, in the schedule submitted, also could opt for a change to other fuel types if such fuels are expected to be available in a reasonable time frame. NRC would still have to evaluate the acceptability of l

this proposed fuel.

1 In the second class, the licensee with DOE assistance, could propose a conver-

}

sion schedule tied to technically feasible replacement fuel being developed under the RERTR program or at GA. The schedules, in these cases, would be somewhat speculative and would recognize the time needed for NRC to determine i

the acceptability of the conversion fuel type as well as the time required for i

DOE procurement. Based on a review of the progress being made in the develop-ment of candidate fuel types, NRC could accept these proposals and attempt to i

influence DOE accordingly. As an alternative, NRC could require conversions

?

which necessitate minor change in core design. Such a decision might suggest some redirection of DOE's RERTR program.

i i

If I can assist you in any other way, give me a call.

oRIGlhA1. SIGNED BT i

3 William R. Lahs

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Regulatory Analysis and Materials Risk Branch Division of Risk Analysis 3

Office of Nuclear Regulatory Research cc: R. Bernero j

J. Malaro f

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i IEMORAIERM FOR: James C. Malare Regulatory Analysis and Materials Risk Branch Divistem of Risk Analysts and Operatleas, RES I

FROM:

William R. Laks Regulatory Analysis and Materials Risk Branch Division of Risk Analysis and Operettoms. RES

SUBJECT:

TRIP REPORT - ARS MEETIls AND MEDHD BRIEFIIS i

l From W June 4 to Wednesday June 6, I attended the American Nuclear Society's CARS) meeting in New Orleans. Da Monday afternoon, at the levitation of Dr. Paul Turinsky, I made a presentattee to the Euclear Engineering Department Meads' Organizaties (NEDHD) and en Wednesday afternoon, at the invitation of D. R. Brodnick of Florida Peuer and Light, I presented a paper at the ARS sessten en Nuclear Maste Trans-1 portation Issues and Techselogy.

MEDHD Meeting Dr. Paul Turinsh, Chairman of REDO, had asked if I would make a presentation uhtch would (1) saunarize IstC activity se the ed rule to limit the use of NEU in research and test reacters, aummarize related IRC activity en proposed upgraded security requirements, and (3) relate the highlights of the Commission meeting ubich had takes place en May 31 en both the above subjects.

-l The basis of my presentaties se item (1) uns several of the vugraphs i

from the Commission presentation which described the proposed rule i

requirements, tuplancataties features and the related cost /henefit considerations. For item (2), I used four vupraphs from BISS's Comunissten presentattes uhtch portrayed the status of the threat and I

the proposed upgrade previstoms for CAT I and CAT II licensees and l

l for transportation of IEU.

Two potentially important comments were made by the audience of about 15-20. First, the apparently enanimous aplaten seemed to be that the

• generic limutag" approach broadly referred to la the proposed rule uns a " pip 2 dream." Several empressed the optates that interveners would l

challempe any licensee ceswersten based as a Generic===ama===t and that protracted and aestly hearings usuld result. Others believed there useld r

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l be mag facilities which a4y not fall within av specifically defined generic envelop. Second, mag believed that an additional real or perceived safeguards er conversica costs associated with the proposed NRC l

actions would definitely lead to a decision to decommission a significant fraction of the licensed facilities since almost all are not self-supporting entities.

I stated that comments dealing with the specifics of these concerns should be semitted to IRC for consideraties since they could have a significant impact en the regulatory analysis.

Immediately following this meeting, a panel discussion was held to discuss the proposed conversion and upgrade issues. Attendance was about 30. Panel members included Don Harris, a member of the LEU Study Group sponsored by IRC; Frank DiMeglio, head of the Test, Research, and Training Reactor (TRTR) organization, and Ed Zebrowski of EPRI. The latter two are scheduled for presentations at the June 12 ACRS subcomittee meeting. Major points discussed included (1) a summary of the LEU Study Group report (IRlREG/CR-3666),

(2) the evaluation of the conversion requirements and questioning of its lustification, and (3) a discussion of relative attractiveness of adversary targets for HEU er weapon attaiment as a function of required adversary capabilities. This last discussion focused on the extremely small amounts of HEU at most licensees compared to export traffic, foreign inventories and DOE inventory and traffic. The open discussion focused on how to influence the NRC to implement reduction is HEU use in a prudent manner.

AMS Presentation The presentation at the ARS discussed both NRC and DOE's sabotage source term program and its related regulatory impacts and the current direction of the " Modal Study." The paper was apparently well received by the audience of about 20. Other papers at this session indicated a high degree of preparation by the authors and all were well presented.

ORIGINAL SIGED ET i

William R. Lahs Regulatory Analysis and Materials Risk Branch Division of Risk Analysis and Operations Office of Nuclear Regulatory Research cc:

R. Minogue, RES Distribution C. Kelber, RES RAMRB/r/f/

i R. Bernero, RES DCS M. Ernst, RES Subj/Chron/ Circ R. Carter, M R CBelote C. Withee, MSS Wlahs

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