ML20205F004
| ML20205F004 | |
| Person / Time | |
|---|---|
| Issue date: | 07/24/1985 |
| From: | Peterson M NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| To: | Delabarre R STATE, DEPT. OF, BUREAU OF OCEANS & INTL. ENVIRONMENT |
| Shared Package | |
| ML19301D852 | List: |
| References | |
| RULE-PR-110 AC25-2-20, NUDOCS 8608190060 | |
| Download: ML20205F004 (2) | |
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JUL 241985 Mr. Robin DeLaBarre U.S. Department of State OES/NEC Room 820 Washington, DC 20520
Dear Mr. DeLaBarre:
NRC agrees with the change to NRC's general license for tritium contained in luminescent light sources (10 CFR Part 110.23(a)(2)) proposed by you. We believe, however, the revision in NRC's regulations should be in a new, separate paragraph under 5110.23 and not as a paragraph of 5110.23(a),since the other NRC general licenses with export restrictions to both 5110.28 and 5110.29 destinations are in separate paragraphs. Thus, the general license should read:
5110.23(d) A general license is issued to any person to export tritium in luminescent light sources containing 10 curies or less of tritium per source in individual shipments of 10,000 curies or less to any country not listed in s110.28 or s110.29.
c Since the primary means for reducing proliferation risk in the proposed revised general license is the 10 curies per source limitation, the Executive Branch may wish to consider deletion of the 10,000 curie individual shipment limit. Alternatively, if the 10,000 curie limit is determined to be necessary, there should also be a limit on the total amount of curies an exportercouldshipperyear(e.g., 100.000 or 200,000 curies per person per year),
i Upon mceipt of the Executive Branch's final recomumdation, NRC is prepared
! to revise Part 110 as quickly as possible in accordance with standard procedures for proposed rulemaking actions.
Sincerely,
! Marvin R. Peterson
! Acting Assistant Director l Export / Import and Intemational Safeguards i Office of International Programs I
81 060 860813 110 MISC PDR
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Mr. James R. Shea Director of International Programs United States Nuclear Regulatory Commission Washington, D.C.
Dear Mr. Shea:
I refer to ths recently completed review by the Subgroup on Nuclear Export Coordination (SNEC) of tritium export controls.
The SNEC with NRC concurrence concluded, inter alia,that changesato y recently revised general license provisions for tritium under 10 CFR Part 110.23, Export of byproduct material, should be con-sidered.
During the SNEC review and consultations with other governments on tritium controls, it became increasingly evident that the prcvi-sion for export under general license of tritium in luminescent light sources in individual shipments of 10,000 curies or less (Purt 110.23 (a)(2) was too generous and could possibly be abused, Sincer.the time when the tritium general license provisions were first proposed the maximum size and tritium content of the larger light sources has significantly increased. Now light panels for remote airfields;for exmple, contain five sixty curie light sources for a total of 300 curies of tritiun per panel. In View of the foregoing the following changes are proposed for Part 110. 2 3 (a) (2) :
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"(2) Tritium in luminescent light sources not to exceed 10 curies per source in individual shipments of 10,000 curies or less to any country not listed in (110.29."
The proposed changes would limit the export of light sources under general license to countries not listed under " Restricted destinations" and would preclude export under general license of the very large light sources from which the contained tritium might conceivably be extracted and utilized for other purposes. ;
The Executive Branch recommends that the proposed change to 10 CFR 110.23(a)(2) be implemented by the Nuclear Regulatroy Commission as soon as possible. {
Sincerely, 7/9/85 James B. Devine Deputy Assistant Secretary
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