ML20129A529
| ML20129A529 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Volkmer H HOUSE OF REP. |
| Shared Package | |
| ML20127B589 | List:
|
| References | |
| FOIA-84-784 NUDOCS 8507150318 | |
| Download: ML20129A529 (3) | |
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. APR 971984 The Honorable Harold L. Volkmer United States House of Representatives Washington, D.C. 20515
Dear Congressman Volkmer:
This letter is in response to your letter of March 23, 1984 to Chairman Palladino. Your letter correctly presumes that the Nuclear Regulatory Commis-sion is considering a proposed rule to limit the use of high-enriched uranium (HEU) in research and test reactors. The intent of the proposed rule is to ' reduce the risk of theft or diversion of HEU from these facilities. The re-duction in domestic use of HEU fuel is also iraended to encourage similar ac-tion by foreign research reactor operators. The Comission is acutely aware of the potential impacts of the proposed rule on specific facilities such as the University of Missouri at Columbia. Provisions of the proposed rule are attempting to minimize thesh impacts by: (1) , recognizing that certain projects or programs cannot be reasonably accom-plished without the use of HEU fuel and, therefore, may require exemption; and _ (2) considering HEU fuel replacement schedules which would minimize facility design and operational impacts as well as the financial. burdens associated with conversion. _ The Commission also has directed its Advisory Committee on Reactor Safeguards to review and coment on the proposed rule prior to a final decision regarding publication. As you may be aware, the publication of a proposed rule will allow a coment period - typically 60 days. The Comission is specifically soliciting outside views, including those of its licensees, on the extent of the impacts you have raised. l I have directed that a copy of the proposed rule be sent to you when it is published in the Federal Register. The proposed rule will also be sent to all potentially affected NRC licensees including Dr. Brugger, as director, of the University reactor facility. i Sincerely, j (Signed) William J.Dircki BfNb [uNSCH84-784 PDR William J. Dircks Executive Director for Operations , l Distribution
,RES Central File C. Kelber, RES M. Ernst, RES DIR:RES ED0
'CHRON W. Dircks, EDO B. Buchbinder, RES DORA Subject File R. Minogue, RES J. Malaro, RES ABMi m M ircks H. Denton, NRR D. Ross, RES C. Belote, RES gf fg4 gj fg R. Carter, NRR R. Bernero, RES p hs, RES ^
- See previous record copy THR8/DRA/RES TMR8/DRA/RES TMRS/DRA/RES RAS /DRA/RES DD:DRA/RES DIR:DRA/RES DO:RES
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The Honorable Harold L. Volkmer
~ United States House of Representatives Washington, D.C. 20515
Dear Congressman Volkmer:
This letter is in response to your letter of March 23, 1984 to Chairman Palladino. Your letter correctly presumes that the Nuclear Regulatory Comis-sion is considering a proposed rule to limit the use of high-enriched uranium (HEU) in research and test reactors. The intent of the proposed rule is to reduce the risk of theft or diversion of HEU from these facilities. The re-duction in domestic use of HEU fuel is also intended to encourage similar ac-tion by foreign research reactor operators. The Comis'sion is acutely aware of the potential impacts of the proposed rule on specific facilities such as the University of Missouri at Columbia. Provisions of the proposed rule are attempting to minimize these impacts by: (1) recognizing that certain projects or programs cannot be reasonably accom-plished without the use of HEU fuel and, therefore, may require exemption; and (2) considering HEU fuel replacement schedules which would minimize facility design and operational impacts as well as the financial burdens associated with conversion. The Commission also has directed its Advisory Comittee on Reactor Safeguards to review and comment on the proposed rule prior to a final decision regarding publication. As you may be aware, the publication of a proposed rule will allow a comment period - typically 60 days. The 'Comission is specifically soliciting outside views, i.ncluding those of its licensees, on the extent of the impacts you have raised. I have directed that a copy of the proposed rule be sent to you when it is published in the Federal Pe.ister. The proposed rule will also be sent to all potentially affected NR' licensees including Dr. Brugger, as director of the University reactor faci'.ity. . Sincerely, (Sip t M .T!? n .' 5 9 William J. Dircks '
. Executive Director for Operations Distribution RES Central File C. Kelber, RES M. Ernst, RES sih DIR':RES EDO CHRON W. Dircks, EDO B. Buchbinder, RES RBMinogue WJDircks DORA Subject File R. Minogue, RES J. Malaro, RES 04/gg/8404/ /84 H. Denton, NRR D. Ross, RES C. Belote, RES R. Carter, NRR R. Bernero, RES W. Lahs, RES OFFICIAL RECORD COPY
- See previous record copy TMRB/DRA/RES TMRB/DRA/RES TMRB/DRA/RES RAS /DRA/RES DD:DRA/RES DIR:DRA/RES DD:RES cWP,Lahs:mir *JCBelote *DBuchbinder *JCMalaro *MLErnst *RMBernero *DFRoss
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e ( ComlTTEE ON SCIENCE AND TECHNOLOGY U.S. HOUSE OF REPRESENTATIVES WASHINGTON, D.C. 20515 S W COMMITTEE ON ENERGY DEVELOPMENT AND APPLICATIONS t SWCOWITEE ON ENERGY RESEARCH AND PRODUCTION Hearing on Conversion of Research and Test Reactors to Low-Enriched Uranium (LEU) Fuel Tuesday, September 25, 1984 2:00 - 5:00 P.M. Room 2318 Rayburn House Of fice Bullding
. Witness LLS1 Penet 12, IL.L. Nucl ear Recul storv Comm t ss ten ,(,EC)_
Honorabl e Frederick Bernthal Acting Chairman Accompanied by: - Honorable James Asselstine Commissioner fJLES.I. 21. HEC Adviserv Committee ,qq Reactor Safecuerds (ACRS) M Others Jesse Ebersole, Chairman Edwin'L. Zebrosky NRC ACRS
' Electric Power Research Institute Accompanied by:
J. Carson Mark, Chairman Subcommittee on Safeguards and Security i l
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April 9,1984 CHAIRMAN The lionorable' Alan Simpson, Chairman Subcommittee on Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, D. C. 20510
Dear Mr. Chairman:
This' is in response to your letter of March 18, 1984. While the Commission has. asked the staff to prepare a proposed rule for converting research reactors that now use high enriched uranium (EEU) to low enriched uranium (LEU), that rule would be premised on Congress authorizing the Department of Energy to fund the conversion program. (Our directive to the staff is enclosed for your information.) There are no
;. - > NRC funds budgeted for such a purpose.
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\. . In our opinion, it would be more appropriate for another Federal agency, such as DOE, to provide funding assistance.
for conversion of HEU to LEU rather than to fund this as an NRC research project. However, the Commission agrees?that Federal funding of the conversion effort is justified because the. government played a signiff.f ant role in the establishmerit of these rese, arch reactors for the national interest. Sincerely, e , I G.0 ) "
- Nunzio J. Palladino
Enclosure:
As Stated , cc: Senator Gary Hart h e n,4 , Js ,#f . ~ ;l _ y'
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ApM1 9, 1984 CHAIRMAN The Honorable Mark Hatfield, Chairman Subcommittee on Energy and Water Development Committee on Appropriations United States Senate Washington, D. C. 20510
Dear Mr. Chairman:
This is to, follow-up Commissioner Gilinsky's March 2, 1984 letter to you. While~the Commission has asked the staff to prepare a proposed rule for converting research reactors that now use.high enriched uranium (HEU) to low enriched uranium (LEU), that rule would be premised on Congress
, authorizing the Department of Energy to fund the conversion program. (Our directive to the staff is enclosed for your information.) There are no NRC funds budgeted for such a purpose. ,
In our opinion, it would be more appropriate for another Federal agency, such as DOE, to provide funding assistance for conversion of HEU to LEU rather than to fund this as an NRC research project. However, the Commission agrees that
. Federal funding of the conversion effort is justified because the government played a si'gnificant role in the establishment
, of these research reactors for the national interest.
Sincerely,
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0 Nunzio J. Palladino
.. Enclosure- - -
As Stated cc: Senator J. Bennett Johnston
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k April 9,1984 CHAIRMAN The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives War:ihington, D. C. 20515-
Dear Mr. Chairman:
This is to follow-up Commissioner Gilinsky's March 2, 1984 letter to you. While the Commission has asked the staff to prepare a proposed rule for converting research reactors that now use high enriched uranium (HEU) to low enriched uranium (LEU), that rule would be. premised on Congress . authorizing the Department of Energy to fund. the conversion 7 program. (Our directive to the staff is enclosed for your [ information.) There are no NRC funds budgeted for such a purpose. . In our opinion, it would be more appropriate for another Federal agency, such as DOE, to provide funding assistance" for conversion of HEU to LEU rather than to fund this as an NRC.research project. However, the Commission agrees that Federal funding of the conversion effort is justified because the government played a significant role in the-establishment ~ of these research' reactors for the national interest. Sincerely, t- ~~/ s ,5Lb*r ' Nunzio J. alladin)
Enclosure:
As Stated cc: Rep. Manuel Lujan
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e 8 q UNITED STATES E' y 3 g NUCLEAR REGULATORY COMMISSION gg ,jg wAsmNGTON, D, C. 20555 Qca / ***** April 9,1984 CHAIRMAN - The Honorable Tom Bevill, Chairman Subcommittee on Energy and Water Development Committee on Appropriations United States House of Representatives Washington, D. C. 20515
Dear Mr. Chairman:
This is to follow-up Commissioner Gilinsky's March 2, 1984 letter to you. .While the Commission has asked the staff to prepare a proposed rule for converting research reactors that now use high enriched uranium (EEU) to low enriched uranium (LEU), that rule would be premised on Congress authorizing the Department of Energy to fund the conversion
, program. (Our directive to the staff is enclosed for your
/ information.) There are no NRC funds budgeted for such a
\ purpose. .
In our' opinion, it would be more appropriate for another , .
. Federal agency, such as DOE, to provide funding assistance for conversion of HEU to LEU rather than to fund this as an NRC research project. However, the Commission agrees that Federal funding of the conversion effort is justified because the government played a significant role in the establishment of these research reactors: for the national interest.
Sincerely, u .- E . M .E_ _ Nunzio J. Palladino
Enclosure:
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April 9, 1984 CHAIRMAN The Honorable Richard L. Ottinger, Chairman Subcommittee on Energy Conservation and Power Committee on Energy and Commerce United States House of Representatives Washington, D. C. 20515
Dear Mr. Chairman:
This is to follow-up. Commissioner Gilinsky's March 2, 1984 letter to you. While the Commission has asked the staff to prepare a proposed rule for converting res'earch reactors that now use high enriched uranium (HEU) to low enriched uranium (LEU), that rule would be premised on Congress authorizing the Departnient of Energy to fund the c'onversion e program. (Our direc.tive to the staff is enclosed for your
., information.) There are no NRC funds budgeted for such a
. purpose. -
In our opinion, it would be more appropriate for another Federal agency, such as DOE, to provide funding assistance for conversion of HEU to LEU rather than to fund this as an NRC research project. However, the Commission agrees that Federal fundi,ng of the conversion effort is justified because the government played a significant role in.the establishment of these research reactors for the national interest. Sincerely, fA- o / A & {< & Nunzio J. Palladino
Enclosure:
As Stated cc: Rep. Carlos Moorhead Y l .
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I(I N RT)L Y // NOTE T0: Bill Dircks PROPOSED RULE FOR LIMITING THE USE OF HEU IN RESEARCH REACTORS I have looked at the RES proposed amendment to 10 CFR Part 50 to " Limit the Use of High Enriched Uranium (HEU) in Nonpower Reactors" requested by the Comission. The proposed rule requires timely conversion of low enriched fuel unless continued use of HEU can be justified. About 31 NRC licensed nonpower reactors (including the GE Test Reactor and the UCLA reactor) could be affected by the proposed rule. Of these, 25 are owned and operated by universities, some are owned by private business and one is owned by an agency of the Federal Government. . My concerns are - (1) Rule impacts such as changes to reactor fuel and configurations, procedures and staffing (potentially significant licensing issues) need more work to demonstrate practicality. (2) Safety (public and occupational) impacts resulting from changes to reactors and reactor operations need to be identified and considered. (3) Safety and safeguards risks associated with refueling (including transportation) need to be identified and considered. (4) As noted in the enclosed letter from Congressman Volkmer, the rule
...could cause scientific and financial difficulties" for nonpower reactor licensees.
(5) The rule provides for exemption - continued use of HEU. Since each nonpower reactor is uniquely used, I would expect 31 letters like the one from Congressman Volkmer. If these exemptions are granted, the rule would have little if any effect concerning conversion from HEU to LEU. (6) The cost benefit analysis is weak. Apparently, the Commission has made the judgment that the proposed rule is needed. The proposed rule is not within the purview of the CRGR unless you request that the CRGR review the proposed rule. l Vic Stello d g 7
June-12, 1984 Mr. John C. McKinley Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Comission . Washington, DC 20555
Dear Mr. McKinley_:
In. regard to the Advisory Committee on Reactor Safeguards June 12 meeting to review the low-enriched uranium proposed rule for the conversion of research reactors if " technically feasible," and if fuels are "available" and " acceptable," I am concerned that the emphasis placed on related safeguard measures for Category II to provide interim protection of our HEU will produce a far greater problem for research reactors than the conversion to LEU. I have been told that NMSS has indicated to the Comission that the research reactor community had no strong feeling about the interim requirements and a voluntary program was acceptable. That is far from the case. At the TRIGA Owners Conference of March 1984, that group informed Mr. Dube of NMSS that we prefer to " negotiate" these proposed requirements as a reactor type and as a group rather than a site-specific requirement. This was our reply when offered the option of " voluntary license condition," "being ordered to modify our licenses" or " negotiating for rule changes." I caution overreaction to safeguards requirements and the resulting harm done when university research reactors become " locked-up" and can not provide their intended function of research, teach.ing, and training. We will be taking these drastic measures which will result in consideration Just look at the UCLA by our administrators to close our facilities. hearings and their impact on the Northrop reactor. That reactor will be shut down within the next six months in part due to administrative reaction
- to the UCLA hearings.
Sincerely, Donald E. Feltz, Director Nuclear Science Center
- Texas AfJ4 University System F. E. Box 89 College Station, Texas 77843 (409) 845-7551 Dictated by telephone from Mr. Feltz to Joan Kirkland, June 12, 1984, 10:15 AM 634-1413 a , L;P- p 2b 4
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