ML20211Q610

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Discusses Interpretation of 850927 Show Cause Orders. Licensee Understanding of Terminology of Orders Provided. Facility in Compliance W/Nrc Orders
ML20211Q610
Person / Time
Site: University of Virginia
Issue date: 10/21/1985
From: Mulder R
VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To: Hoyle J
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20211Q606 List:
References
FOIA-85-738 NUDOCS 8607250172
Download: ML20211Q610 (3)
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UNIVERSITY OF VIRGINIA F ,A, 1 DEPARTMENT OF NUCLEAR ENGINEERING AND ENGINEERING PIIYSICS NUCLEAR REACTOR FACILITY

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) SCHOOL OF ENGINEERING AND APPLIED SCIENCE I i  ; CHARLOTTESVILLE, VA 22901 I October 21, 1985 Telephme: 804 924-7136 Mr. John C. Hoyle E ' m- . , _

Acting Secretary of the Commissien . g..

U.S. Nuclear Regulatory Commission ,.

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Washington, DC 20555 .g ~.w ( l

Subject:

U.S. NRC Orders to Show Cause, issued on Sept. 27,1985 for CAVALIER reactor license R-123 (Docket No. 50-396) and UVAR reactor license R-66 (Docket No. 50-62), held by the Reactor Facility of the University of Virginia

Dear Sir:

The purpose of this letter is not to officially answer the above orders, as provided for in 10 CFR 272'U2(d). Rather, this written statement is meant to inform the Conaission of our interpretation of the orders and of our understanding that this Facility is presently in compliance with the orders' requirements. This step is taken to preclude possible misunderstandings based on some undefined terminology which has been used in the text of the orders referenced above.

We note, in particular, possible misinterpretatior.s of several terms, such as " adverse consequences", " normal operations", "all excess... unirradiated HEU fuel", " operational needs", "each different type element in core". Since this licensee is no longer covered by a licensed mass limit of U-235 which may be possessed on-site, this terminology appears critical in determining compliance with NRC regulations.

We have interpreted " adverse consequences" to mean threat of HEU f6el diversion; " normal operations" to be based on fuel utilization averaged over the last five years of operation; "unirradiated PEU fuel" to be fuel in the form of reactor fuel elements or element plates which are " cold" or "not irradiated", i.e. not self-protecting and which do not represent a radjological hazard significantly different from freshly fabricated reactor fuel; "all excess" tu mean reactor fuel elements and element plates in excess of the numbers defined in Section III, provisions (1) and (2) of page 2 of the orders; "each different type element in core" to allow a distinction to be made between partial (1/2 load), experimental (permitting insertion or withdrawal of individual fuel plates), regular (full) and control rod elements, in addition to allowing for the interchange of straight and curved plate cores.

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".T Therefore, we have concluded that the orders permit the U.Va.

Reactor Facility to possess on-site the followir.9 amounts of HEU cold reactor fuel elements in dry protected storage (with M curved element plates E 1 curved plate element and H straight element plates a 1 straight plate element):

A) For the UVAR, where both straight plate element and curved plate element cores are licensed (and stored in the reactor pool):

1 partial curved plate element 1 partial straight plate element 1 experimental curved plate fuel i experimental straight plate element element I regular curved plate element I regular straight plate exp. element 1 curved plate ~ control rod element 1 straight plate control rod element B) For the CAVALIER, where only curved plate elements will be used in the future:

1 partial curved plate element *1 experimental curved plate element I regular curved plate element I curved plate control rod element It is also our understanding that these orders do not affect the quantities of U-235 we have in protected dry storage in forms other than reactor fuel elements or fuct element plates, since permissible quantities for these were not addressed by the orders. Example of these forms are fission plates, fission chambers, powdered uranium oxide, and uranium foils meant for use in experiments.

The opportunity is taken to remind the Commission that this Facility completed a shipment of its on-site excess fuel to the Babcock and Wilcox Co. (secure facility), Lynchburg, Virginia on September 24, 1985. In total, 12 elements with a combined isotope weight of 1534.67 g and element weight of 1647.60 g were transferred, as a Fissile Class I, Type A quantity.

To accommodate future fuel burnup, we presently have remaining in our protected dry storage (Fuel Storage Room) a single complete fuel element (194.73 g U-235), 8 curved fuel element plates (85.599 U-235),

and 3 flat fuel element plates (41.22 g U-235). Also in storage, the Facility continues to possess a "small" fission plate (73.84 g U-235),

a "large" fission plate (181.00 g U-235), a fission chamber #692602 (1.68 g U-235), and a fission chamber #83506 (1.72 g U-235). The above items and amounts have been and are covered by the R-66 license.

In addition, under the Broad License 45-00034-26, the Facility possesses on-site in storage a bottle of uranium dioxide powder and powder deposited on mylar (96.89 g U-235) and metal uranium foils (31.00 l g U-235). -

i In all, the Facility presently stores 707.67 g of U-235 in its protected Fuel Storage Room.

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In conclusion, we believc that this Facility is presently in compliance with the recent NRC orders. Should the U.S. NRC have need for further information, I, or Mr. Pres Farrar (reactor supervisor), can be reached at (804) 924-7136.

You s r ly, ,

,1 1. 1 ,

Robert U. Mulder, Director U.Va. Reactor facility and Res. Asst. Prof. of Nuc. Eng.

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