ML20237J642
| ML20237J642 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 03/03/1981 |
| From: | Fonner R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | John Miller Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20237H679 | List: |
| References | |
| FOIA-85-196 NUDOCS 8709040029 | |
| Download: ML20237J642 (1) | |
Text
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March 3, 1981 1
h00MNDlN FOR:
James R. Miller, Chief Standardization and Special Projects Branch Division of Licensing, MIR FBCM:
Robert L. Fonner, At torney Regulations Division Office of the Executive Legal Director SURTECT:
NJN POWER REACIOR SPENI FUEL SHIPhENIS In your note of February 3,1981 you asked what regulations apply to shipments of SN4 (non power reactor fuel) in a quantity exceeding 350 grams, but less than 1 kg., and with a total external radiation dose rate less than 100 ran per hour at a distance of three feet. You question pertains to UCLA research reactor spent fuel.
It is clear frcrn your description of the quantity involved that 10 CFR 55 73.20, 73.25, and 73.27 do not apply because the quantity is less than a form 21a quantity, regardless of any enrichment.
10 CFR $ 73.37 does not apply because the radiation dose rate is less than 100 ran per hour at three feet. The requirernent that dose rate exceed 100 ren for application of Section 73.37 is now explicitly stated in paragraph 73.37(a)(1). That sane requirement was inplied, in the prior version, by the referral in paragraph 73.37(a) to anterial that is exenpt frcrn transportation safeguards in Sections 73.25, 26, and 27 by virtue of Section 73.6.
That leaves for application the transportation safeguards requirement of 10 GR $ 73.67 (which paragraph applies would depend upon whether the SMd is of noderate or low strategic significance). Section 73.6 does not provide any exerption frcrn Section 73.67 for any class of naterial to which Section 73.67 applies.
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Robert L. Fonner cc:
R. Tedesco S. Treby C. Woodhead D. Carlson G. McPeek H. Bernard G. Cunninghmn 8709040029 870901 PDR FOIA AFTERGOB5-196 PDR; g