ML20244D914
| ML20244D914 | |
| Person / Time | |
|---|---|
| Site: | 05000262 |
| Issue date: | 06/12/1989 |
| From: | Stohlton J Brigham Young University, PROVO, UT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20244D918 | List: |
| References | |
| NUDOCS 8906200056 | |
| Download: ML20244D914 (2) | |
Text
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9 BRIGHAM YOUNG UNIVERSITY lonsa m,ntios inn. oi m o' ooo 1AIO 71VIt rlitLSlill.NI 1% IN1 t Lt.lGI ACi June 12, 1989 Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Nuclear Regulatory Commission:
Brigham Young University requests that it be granted an exemption from the requirements for an emergency plan as specified in 10 CFR 50. 54 (q) . We also request that the current Physical Security Plan which was instituted pursuant to the requirements of 10 CFR 73.67 be dropped. In addition to the exemption requests we are submitting revised technical specifications in support of our request for " possession only" status.
Rationale for the exemption to 10 CFR 50.54 (c) .
10 CFR 50.12 (a) (2) (ii) states that the Commission may grant exemption to the requirements if " Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." The underlying purpose of this rule is to assure "that adequate protective measures can and will be taken in the event of a radiological emergency." [10 CFR 50.47(a) (1))
In this case the reactor in question is an L-77 research reactor which has been defueled prior to decommissioning. The fuel has been returned to the Department of Energy. The major source of radiation source.
left in the reactor facility is the plutonium-beryllium This source has a total isotope weight of 7 grams.
There is no reasonably foreseeable incident in which this material would be released to the environment or pose a threat to persons outside the confines of the nuclear facility; further-more, since the entry of emergency personnel into the facility is covered by extant emergency procedures, it seems prudent to maintain plan.
the reactor in it's present status without an emergency Rationale for droppina the Physical Security Plan.
Our current fixed site Physical Security Plan was instigated under the provisions of 10 CFR 73.67. However, there has been no fuel on our facility since May of 1987. Due to the fact that the u msn gd l 8906200056 890612 PDR ADOCK 050002621
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Nuclear Regulatory Commission June 12, 1989 Page 2.
only special nuclear material associated with the reactor is the Pu/Be source we would fall under the provisions of 10 CFR
- 73. 67 (b) (1) (ii) "A licensee is exempt from the requirements of this section to the extent that he possesses, uses, or I transports... sealed plutonium-beryllium neutron sources totaling 500 grams or less contained plutonium at any one site or con-tiguous sites." The building in question currently houses 7 grams of plutonium contained in a Pu/Be sealed source, which is of course less than the 15 grams of plutonium which would con-stitute "special nuclear material of low strategic significance" (10 CFR 73.2).
We appreciate your consideration of this matter.
Sincerely, (o e ni _
Jo t ton
/Execu ive Vice-President s1 l STATE OF UTAH )
l ss:
l COUNTY OF UTAH On this 12th day of June 1989 Public in and for the State of Utah, personally County appeared of L tah, before me, John B. Stohlton, thea Notary Executive Vice President of Br ham Young University, and signed the forer,oin ' clear Re latory Commission.
7, 8
? a=m KARIN K. JORDAN
> AfD4Ls Public Notan'ission Comm Expires: 7490 i I
(* ovu Prg T A-as7 AGB Residing in Provo, Utah We or -@ i
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