NRC Generic Letter 1986-12

NRC Generic Letter 1986-012: Criteria for Unique Purpose Exemption from Conversion from the Use of HEU Fuel

ML031150243
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Washington Public Power Supply System, Shoreham, Satsop, Trojan, Clinch River
Issue date:	07/03/1986
From:	Miraglia F Office of Nuclear Reactor Regulation
To:
References
GL-86-012, NUDOCS 8607030269
Download: ML031150243 (3)

°> UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555 July 3, 1986 TO: ALL NON-POWER REACTOR LICENSEES AUTHORIZED TO USE HEU FUEL

SUBJECT: CRITERIA FOR UNIQUE

PURPOSE

EXEMPTION FROM CONVERSION FROM THE

USE OF HEU FUEL (GENERIC LETTER 86-12)

from

10 CFR 50.64 (51 FR 6514) provides for a "unique purpose" exemption (HEU) fuel, the requirement to convert from the use of high enriched uranium that is accepted by the provided the licensee presents a Justification acceptable Commission. Amended 10 CFR 50.2 gives broad definitions for for those unique purposes. This letter provides more specific guidance licensees who believe they might qualify for such an exemption.

or The definition states that a unique purpose means a project, program, the use commercial activity that cannot be reasonably accomplished without of the following four purposes:

of HEU fuel, and may include one or more

1) A specific experiment, program, or commercial activity (typicallyand long-term) that significantly serves the U.S. national interest cannot be accomplished without the use of HEU fuel;

of

2) Reactor physics or reactor development based explicitly on the use HEU fuels;

3) Research projects based on neutron flux levels or spectra attainable only with HEU fuel; or intended

4) A reactor core of special design that could not perform its function without using HEU fuel.

might qualify The definition provides guidance to licensees who believe they that best for a unique purpose exemption to develop a basis for exemption that the fits each unique situation, and which would provide a Justification necessarily Commission could find acceptable. These four purposes are notexemption.

the only ones that might form the basis for a unique purpose 10 CFR

However, the following discussion relates to the four given in the

50.2 definition.

Purpose

number 1 is intended to relate primarily to technical activities preeminence closely coupled to the national interest, which might include of some supply in a specific field of research or assurance of a domestic in the definition essential product of reactor operation. This was included (NRC)

of "unique purpose" to help provide the Nuclear Regulatory Commission wide latitude of discretion like the standards in 10 CFR 50.41.

ZA

8607030269 D7I

LTIZ

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Of the four purposes identified, it is intended that numbers (2) and

(4) provide opportunity to perform new reactor projects whose objectives were to learn about or develop reactor concepts for which parameters of HEU were a necessary component. Examples might be a unique compact reactor heat source, a compact pulsing reactor with minimal distortion of fast neutron spectra, or a comparison of HEU and low enriched uranium (LEU) operating cores for assessing the potential for conversions of non-power reactor cores.

Purpose

number 3 is intended to provide the opportunity to continue using HEU fuel if converting to available LEU fuel would change neutron flux densities or spectra, or other essential radiation parameters, so that the fundamental reason for conducting the reactor-based program would be lost, or irreparably compromised.

Purpose

number 4 might also pertain to a non-power reactor that was designed and is operated to take maximum advantage of the unique characteristics of HEU fuel and where the substitution of any available LEU

fuel could not be made without major facility modification to accommodate such things as a larger core, different coolant systems, or major changes in its primary mode of operation. An example would be a core with specific physical size limits that currently uses near-maximum uranium density in its fuel.

An application for exemption from conversion from HEU fuel must be submitted to the Director, Office of Nuclear Reactor Regulation, in accordance with the schedule given in the published regulation. The application should specify the date when acceptable LEU or medium enriched uranium (MEU) fuel is expected to be available, and a conversion schedule provided where appropriate. The NRC expects that only very few licensees will qualify for exemption. The following are examples of items which should be considered and developed in detail, as appropriate, in any application for exemption:

(1) Identification and outline of the program

(2) Explanation of the value of the program and any special experiments to the U.S. national interests

(3) Discussion of how the achievement of significant and competitive results is dependent on such factors as the following:

(a neutron fluence (e.g., power level and operating schedule)

b neutron flux density (e.g., power level, core size)

c neutron spectra d signal-to-noise ratio in the experimental results e) operating and refueling schedule for the reactor f) operating costs (g) waste management

(4) Discussion of program accomplishment with available LEU fuels, and specification of LEU fuel characteristics required to permit continuation of the programs with no significant decrement in accomplishment.

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This letter is for guidance only in interpreting 10 CFR 50.64. No response or action is necessary other than that required by the regulation to apply for a unique purpose exemption.

Questions should be addressed to Mr. Robert E. Carter at (301) 492-8206.

Original signed by Prank J, Kiregl8A

Frank J. Miraglia, Director Division of PWR Licensing-B

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