ML20138F651

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Speech Entitled, Technical Solution to Difficult Problem, Presented at 1984 Intl Meeting on Reduced Enrichment for Research & Test Reactors on 841017
ML20138F651
Person / Time
Issue date: 10/17/1984
From: Asselstine J
NRC COMMISSION (OCM)
To:
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ML20138F577 List:
References
FOIA-85-379, FRN-49FR27769 AB60-2-113, AB61-2-113, NUDOCS 8512160145
Download: ML20138F651 (7)


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Remarks by James K. Asselstine Comissioner, U. S. Nuclear Regulatory Commission at the 1984 International Meeting on Reduced Enrichment for Research and Test Reactors Argonne National Laboratory October 17, 1984 A TECHNICAL SOLUTION TO A DIFFICULT PROBLEM It is a pleasure to be here tonight at the 1984 International Meeting on Reduced Enrichment for Research and Test Reactors. I would especially like to thank Dr. Travelli and the organivers of this meeting for inviting me to speak.

We are here today to discuss the progress of various programs to reduce the use

- of highly enriched uranium in research reactors. It is my understanding that aside from reactor operators themselves there are representatives here nom various licensing bodies and from organizations which develop and fabrierte reactor fuels. I am glad to see such a varied turn out. It no dot.bt reflects the growing maturity of our efforts to move away from fuels that are potential i

nuclear explosive materials towards conversion to low-enriched uranium fuels.

I would like to give you a view on this matter from my perspective as a nuclear regulator. As Victor Gilinsky reported to you last year during your meeting in Japan, the U. S. Nuclear Regulatory Comission was about to issue a proposal to i

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limit the use of highly enriched uranium in domestic reactors. This has happened. A proposed rule was published in July for public comment. The proposed rule would require that new non-power domestic nuclear reactors use low eniched uranium fuel and that existing domestic research and test reactors replace their HEU fuel with LEU fuel when it is available. While we believe that currently licensed non-power reactors using HEU fuel are operated without undue risk to the public health and safety, the proposed rule is intended to further reduce the risk of theft and diversion of HEU fuel used at such reactors. We are now awaiting public comments on this proposal.

As you know, originally under the Atoms for Peace program, only LEU fuel was meant to be exported for use in research reactors. In the late 1960's HEU became available and the fuel of choice in order to meet certain experimental needs. In the 1970's various events heightened our concern about proliferation and U. S. nuclear export policy turned to encouraging the reduction of U. S.

supplied HEU inventories for fueling research and test reactors abroad. Against this background, of course, the RERTR program was established in 1978.

A goal of U. S. policy is to minimize the trade in highly enriched uranium. A way of accomplishing this is by developing and demonstrating new high density uranium fuels to permit conversion of reactors to the use of low-enriched uranium with mininal impact on reactor performance and economics. This is the effort that many of you are now embarked on. I understand that the response to this initiative to reduce the use of HEU has been very positive. I urge you to continue your support of this worthwhile program.

As ycu are aware, the Nuclear Regulatory Commission has certain responsibilities under the Non-Proliferation Act with respect to licensing exports. In connection with this responsibility the Commission issued a policy statenent in 1982 noting the widespread use of HEU fuel and the fact that the use of such fuel involves a large number of domestic and international fuel shiprents which increases the risks of proliferation through theft and diversion. Therefore, the policy statement concluded, efforts should be made to reduce HEU inventories on the assumption that any reduction in the potential for access to these inventories would constitute a reduction in proliferation risk. The policy statement supported the RERTR program, which we continue to do today, and went on to say that we would take steps to encourage the elimination of HEU inventories at domestic reactors. Most recently, the Commission restated its support for full funding of the RERTR program at hearings before two subcommittees of the House Committee on Science and Technology.

There is another reason for converting our facilities to LEU. We have been pursuing security improvements at non-power reactor facilities over the last several years. While some improvements have been made, as long as high enriched uranium exists at non-power reactors, some residual risk of malevolent use exists. While we have no indication of a specific threat at a domestic facility, recent acts by terrorists abroad have shown that a threat can naterialize without sufficient warning. Therefore, we believe that it is prudert to consider additional measures to increase protection of HEU naterial s. One approach of course is the removal of such material. But we are aise considering additional security measures.

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The NRC is responsible for the health and safety of the public. At the same time, we do not intend to shut down the industry. So we must consider the impact of our regulations on the licensees. The potential impact of ths rule on the licensees, as we see it today, can be broken down into two parts. For those seeking a construction permit for a new reactor requiring HEU fuel, the proposed rule would require that applicants demonstrate that the reactor would have a " unique" purpose. Unique purpose is defined in our rule as a project or program which cannot reasonably be accomplished without the use of HEU fuel in the reactor. If the applicant cannot meet the uniqueness test, we will not issue a license. On the other hand, we believe there is sufficient flexibility in the rule through the unique purpose test to permit legitimate research using HEU fuel where that is the only feasible alternative.

The other part of the proposed rule affects existing research reactors and could have a greater impact on current licensees. Unless the licensee can meet the unique purpose test, the proposed rule would prohibit the licensee from acquiring additional HEU fuel if LEU fuel is available and such fuel meets the Commission's health and safety criteria. In addition, the rule would require each licensee to replace all fuel in its possession with the available LEU fuel in accordance with a schedule based upon the availability of that fusi and the consideration of other factors. These other factors include the availability of shipping casks, reactor usage, and financial support. The final schedule would be based on discussions with our licensing staff.

l The process we envision for accomplishing conversion of existing reactors is that if the replacement of HEU fuel by LEU fuel does not change the technical l l

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specifications incorporated in the license or involve an unreviewed safety issue as defined in our regulations, the licensee will be permitted to replace l HEU with LEU withcut amendment to his license. Information availab.le to date suggests that the conversion of many licensed domestic non-power reactors from HEU to LEU is technically feasible. And, if the goals of the RERTR program are succesfully achieved over the next five years, conversion will be technically feasible for most of the remaining reactors.

Comments we have received indicate that academic institutions which operate most of the U. S. research reactors are particularly concerned about the costs of conversion. They are concerned about the cost of the new LEU fuel as well as the costs of removing, transporting, and reprocessing their present HEU cores. They are also concerned that it would be expensive and time consuming to meet NRC requirements for relicensing the reactors once they become subject to conversion, especially if relicensing process were subject to public hearings.

We intend to consider carefully the public comments on this proposal, to proceed judiciously toward adopting a final rule which is appropriate given the circumstances, and to implement the final rule in a careful manner. We are sensitive to the cost concerns regardir.g conversion to LEU fuel that have been expressed by many of our current licensees, and we realize that additional funding ray be a particular problem for the academic institutions. In an attempt to address these concerns, the Commission has supported efforts to obtain Federal fundirg through the Department of Energy to cover the cost of the new LEU fuel. In addition, we will attempt to epply a generic licensing 9

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approach to conversion in order to minimize or eliminate licensee administrative costs and avoid disruption of ongoing research and educational programs. If the RERTR program succeeds in attaining its goals over the next few years, the likelihood of applying a generic approach for most reactors will no doubt increase and thus help reduce costs by minimizing the procedural steps that would be required to achieve conversion. These measures to reduce procedural costs and to obtain Federal funding for new LEU fuel should do much to address the concerns about the proposed rule that have been expressed by many of our licensees.

While the costs of conversion to LEU fuel are a legitmate concern, I think it is fair to point out that a failure to proceed with conversion to LEU fuel will also entail added costs. As I mentioned earlier, I expect that the continued use of HEU fuel in domestic research reactors is likely to lead to enhanced physical security measures, particularly if there is an actual attempt to steal or divert this naterial or to sabotage one of these facilities. It is worth noting that, unlike most of the cost of conversion to LEU fuel, the cost of

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these enhanced physical security measures will be borne by the licensee rather than by the Federal government. Quite apart from cost considerations, I suspect that a serious security incident at one of these facilities could well cause many academic institutions to reevaluate their research reactor prograris.

This cculd lead to the loss to the country of these valuable educational and research tools.

There are many politically complex and technically difficult issues involved in non-proliferation. The use of highly enriched weapons grade uranium as fuel in

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civilian research reactors stands out as one problem which has a straight forward technical solution. We should take advantage of that. Research results, as evidenced by the whole-core demonstration at the Ford Nuclear Reactor at the University of Michigan, have shown that the operating characteristics are essentially unchanged with the LEU fuel. This result should encourage us in believing that in the near future many reactors will be able to convert and a proliferation and security concern will at last be solved. Thank you.

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