ML20136J127

Responds to Re 850927 Show Cause Order.Amount of Fuel Depleted in 90-day Period May Be Rounded Upward to Next Whole Number of Elements Needed for Normal Operation.No Time Limits Associated W/Relaxation of Requirements of Order

ML20136J127
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	11/19/1985
From:	Mccorkle G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Lisa Clark MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
References
NUDOCS 8511250287
Download: ML20136J127 (1)

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SBurns JKopeck Region I NOV 191985 Docket File SGRT:DMC PDR w/ enclosure-CThomas 50-20 Case File PStarcher DCarlson Massachusetts Institute of Technology DKasun Nuclear Reactor Laboratory NMSS r/f ATTN: Dr. Lincoln Clark, Jr. SGRT r/f Director of Reactor Operations 138 Albany Street Cambridge, Massachusetts 02139 Gentlemen:

This refers to your letter dated October 25, 1985 concerning the Septegeber 27, 1985 Show Cause Order and to your telephone convers&tions with Mr. D. Carlson of this office on November 12, 1985.

We have reviewed your interpretation of the Order and agree that the amount of fuel depleted in a ninety (90) day period may be rounded upward to the next whole number of elements needed for normal operation. It is our understanding that two (2) elements are now normally used in a 90 day period and that one (1) extra element is retained as a spare.

In regard to the relaxation of the requirements of the Order by the Commission under Section III (3), there are no time limits associated with such a request.

Sincerely, l lit /

l George W. McCorkle, Chief Safeguards Reactor and Transportation Licensing Branch l Division of Safeguards, NMSS l

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O.K. HARLING 138 Abany Street Cambridge, Mass. 02139 L CLARK, JR.

Director (617)251 4202 D"ect r of Reactor Operations October 25, 1985 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Show Cause Order of September 27, 1985, Docket No. 50/20

Dear Sir:

As provided in 10 CFR 2.202(d), the Massachusetts Institute of Technology consents to the entry of an order in substantially the form proposed in the Commission's Order to Show Cause dated September 27, 1985 and addressed to the Institute as holder of Facility Operating License No. R-37 and to other non power reactors licensed by NRC and using high enrichment uranium (llEU) fuel.

It has been MIT's policy for some time to maintain a minimum inventory of unirradiated fuel. That inventory is currently in compliance with the Order, and it will remain so. However, our inventory of spent (irradiated) fuel, although highly self-protecting, is larger than necessary because of the protracted delays in the licensing of the Department of Energy HM-1A shipping cask. Problems causing further delays in the availability of this cask should be resolved at the earliest possible date.

MIT's consent is contingent upon interpretation of the Order as follows:

1) In determining the number of replacement elements that may be maintained in inventory, it is our interpretation that "the amount of fuel depleted in a 90-day period" may be rounded upward to the next whole number of elements.

2) Even with the above assumption, sone refuelings will become complicated, and a request for relaxation of the require-ments may be necessary. It is our further interpretation that paragraph II(3)' provides for the filing of such requests after the Order becomes '

effective and not neces-sarily beforehand.

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A final and very important point is that HEU inventories at non power reactors subject to the Order will be so small and dispersed that the Commission's proposed requirement of July 6, 1984 (49 FR 27769) for conversion of HEU fuel to low enrichment fuel becomes entirely unnecessary and should be withdecwn.

Sincerely, b, -[h Lincoln Clark, Jr.

Director of Reactor Operations LC/crh cc: J. Bernard O. Harling D. Lanning W. Milne I * '

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