ML19330C625

Requests Temporary Exemption Until Dec 1980 from Code Requirements Requiring Upgraded Physical Protection of Pu Inventory.Transfer of Pu Inventory & Fuel Fabricating Equipment to DOE Is Under Consideration.Related Ltrs Encl

ML19330C625
Person / Time
Site:	Framatome ANP Richland
Issue date:	05/06/1980
From:	Nilson R SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
To:	Dircks W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
16361, NUDOCS 8008110084
Download: ML19330C625 (10)

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E(ON' NUCLEAR COMPANY,inco

, RESEARCH AND TECHNOLOGY CENTER r

Mis George Wasmogion Way, RdLand. WasNngton 99"l$2 P HON E: (5C9) 943-7100

. mEiVED 1 Applicant. f.Y:.T..I.'", d[..x -

Check No..10S.'.. g.

May 6, 1980 Am:unt/ Fem Cat:3:q. //?. T!- -

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Mr. William J. Dircks, dip- -

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Office of Material Safety and Safeguardt f i-G D c y -

U.S. Nuclear Regulatory Cc= mission Washingten, D.C.

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Ref.: 1)

License No. SNw.-1227 2

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Docket No. 70-1257 q

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I,etter, R. Nilson to R. A. Brightsen, c

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May 4, 1976.

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Iatter, E. R. Astley to R. K. Tieusser, dated g_.,a CA March 19, 1980.

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Ietter, R. K. Eeusser to E. R. Astley, dated N

April 10, 1980.

Dear Mr. Dircks:

In May 1976 the Exxen Nuclear Ceepany ceased cperations involving the fabrication of mixed Puo -UO fuel ele =ents as a result f the govern-2 mental policy which proh bits cor. ercial use of IWR recycle plutenius fuels. Special protective measures were taksn (see Reference 3) to adegately assure the security of the ra-mining =aterial while mini--4 ing the associated security system cost i= pact.

Notwithstanding those measures, actual accured security related costs for stcrage of the material have been significant.

Since no change of gover== ental policy is anticipated in the foreseeable future, the centinued storage of plutenium fuel and the associated cost burden are not warrented.

It is enr intention, therefere, to arrange for appropriate disposition of cur plutenium inventory and subsevent decc J.ssiening of cur =ixed exide fuel fabrication facility.

In February and March 19S0 Exxen Nuclear Ceepany, in eccperatica with the Rochester Gas and Electric Wry (RG&E), det.micaded twelve (12) j mixed exide fuel rods cwned by RG&E and repackaged and transported the

=aterial to DCE facilities in Richland, Washington fer storage and l

potential futura use. Cn March 7,1960 Censu=ers Pcwer Cmy schnitted a request to DCE for a similar transfer of their pluteni.=2, currently stored by the Exxon Nuclear Cc=pany, to DCE facilities. 'That =aterial l

represents approximately 70% of the Exxon Nuclear Cc=pany plutenic=

inventory and owners of the ra,aining 30% have indicated that they are i

receptive to the idea of transferring ownership and centrcl of their l

= *a-ial to DCE.

Accordingly, en March 19, 1920 (see Reference 4, l

THIS DOCUMENT CONTAINS POOR QUAUTY PAGES 4636*d i

AN AFFILIATE oF EXXON CORPORATION e

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0 Mr. W. J. Dircks May 6, 1980 I

attached) Exxon Nuclear equested that the DOE consider acceptance of our total plutenium inventory along the lines of the Censu=ers Power proposal. Furthermore, a willingness was expressed to =ake available for DCE use, at no cost, all or part of the Exxon Nuclear owned fuel fabrication equip =ent after dispositien of the existing plutenium inven-tory.

On April 10,1980 (see Reference 5, attached) Mr. Heusser indicated that a decision with respect to the proposed transfer of plutenium in possessica of Exxcn Nuclear would be =ade in about ninety (90) days.

In anticipatica of a favorable response, an unsolicited proposal is c=rently being prepared by Exxon Nuclear for submittal to DCE to provide for decm-4 =sien-ing of our mixed PuO -CO fuel fabricatien facility as a feasibility 2

2 de=cnstration.

On Nove=her 28, 1979 final physical protection system upgrade rules were published by the NRC with a specified effective date of March 25, 1980.

These rules require submittal of a ravised fixed site physical protect-ion plan 150 days after the effective date and full ccepliance by March 25, 1981. Cn March 5, 1980, final rules were published with respect +w access and protection of national security information and restricted data specifying an effective date of May 19, 1980. Cn that date all required personnel clearances are to be requested and a plan for protecting classified information is to be submitted. Full ec=pliance is expected by about Septe=ber 1, 1980. Since we anticipate transfer of our plutonium invent =ry wi-M n a short time period fellowing the above noted implemen-tation dates, the prepeation and actuat i=plementation of security plans to satisfy the physical protection system upgrade rules and the rules regarding access and protectica of natienal security information and restricted data is considered to be unnecessary.

As a consevaence of the above, and in accordance with the provisiens of 10 CFR 25.11, 95.11, and 73.5, te=pora:f exe=ptions are regaested from the requirements of 10 CFR 25, 95 and 73.20.

The te=pora f exe=ptiens are initially being regaested for a peried of about six (6) months from the effective date of 10 CFR 25 and 95 (i.e., until Decenher 1, 1980).

Continuation of the exemptions after Dece=ber 1, 1980 will be contingent upon DCE's willingness to accept plutenit= stored at INC's facilities sufficient to reduce the inventory to less than 2 kg.

After Exxcn l

Nuclear's proposal, or suitable alternative, is accepted by DCE, but not later than December 1980, Exxon Nuclear will provide NRC with a schedule i

for transferring the plutonium to DCE..

If the schedule is accep*able to NEC, the exemptions would be extended until the material transfer is acec=plished.

If the proposed transfer of material is not accapted by DCE the exe=ptiens should continue until i=plementation of Exxon Nuclear's plan is acccmplished in accordance with the following paragraph.

If the DCE response to cur request is negative, actions would be tahre to permit suhaittal of a revised security plan required by 10 CFR 73.20 l

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d Mr. W. J. Dircko May 6, 1980 (c) (1) and of information and plans required by 10 CFR 25 and 95 by December 31, 1980. Full compliance with the requirements of 10 CFR 25 and 95 could then be anticipated about April 1981 and compliance with the requirements of the physical protection upgrade rule could be achieved by abcut September 1981, assucing timely approval of the submitted plans.

During the time period of the exemption, the existing physical protection system and document control practices and procedures would remain in

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force. Exxon Nuclear would remain abreast of on-going classification activities to facilitate rapid implementation of 10 CFR 25 cnd 95 requirements, if necessary. In addition, all internal copies of the Exxon Nuclear Company Physical Protection Plan, Contingency Plan, Guard Training Plan and all security system design and installation drawings would be stored in GSA approved security containers, access to which would be under the control of personnel with existing DCE clearances.

Your prompt review and approval of this application for temporary exemp-tions from the recently revised and new regulations as described above is requested. The total program as outlined herein is believed to be consistent with government non-proliferation objectives. We believe the requested exemptions are authorized by law and would not constitute an undue risk to the common defense and security. We reiterate our belief that the Exxon Nuclear plutonium inventory can be expeditiously reduced to less than 2 kg and, as a consequence, additional expenditures of funds to implement or preprare for implementation of system changes responsive to 10 CFR 25, 95 and 73 is not warranted due to the limited time between required implementation and the anticipated inventory reduction. Furthermore, we are confident that the program for decommis-sioning which we are proposing to undertake with DOE participation would lead to the gathering of a substantial body of useful knowledge.

If you have any questions with regard to this request or if you desire additional information please contact me on (509) 375-7286 or Mr. L. E.

l Hansen on (509) 375-7288. We would also be pleased to discuss these matters with you and your staff at your convenience.

i Sincerely, R. Nilson, Manager Corporate Licensing and Compliance RN: sir i

cc:

Robert F. Burnett, Director, Divisiva of Safeguards

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Department of Energy

[y Washington, D.C. 20545 APR 101980 Mr. E. R. Astley Vice President and Executive-in-Charge Fuels Manufacturing Department Exxon Nuclear Company, Inc.

2101 Horn Rapids Road P. O. Box 130 Richland, Washington 99352

Dear Mr. Astley:

It was a pleasure to receive your March 19, 1980, letter regrading plutonium materials stored at Exxon Nuclear Company's Richland, Washington, facilities.

In your letter, you indicated support of the Censumers power Company ('s March 7 1980, proposal to offer.their plutonium to the Department of Energy DOE)at no cost.

As I indicated in my March 21,1980, letter to Mr. Curran, of your staff, in limited circumstances, DOE may have a program need for the quality of plutonium contained in Exxon inventories. We are reviewing the listing of the plutonium contained in your letter. We plan to have a position regarding the plutonium inventory in about ninety days.

I appreciate your assistance in contacting the owners of the material and their receptiveness to the proposal.

Sincerely, R. K. Heusser ctor Division of Maper is Processing Office of Nuclear aterials Production RECEIVED APR 161980 R. CURRAN

'[.,.'f' ERON NUCLEAR COMPANY,Inc.

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• Y 2101 Morn RJpods Road P. O. Bon 120. Rentand. Washor'gtors.09252 Phone- ($C9) 37b.8100 Tctra 15 2870 E RA,80- 81 March 19, 1980 s

Mr. Roger K. lleusser, Director Division of Materials Processing Office of Nuricar Materials Production Department of Energy Washington, 4).C. 20545 Rc[crenec:

1.et ter f rom it. J. Odlevak of Consumers Power Company to R. K. licusser of ICE dated March 7,1980 I) car Hr. licusser:

In the referenced letter, Consumers Power Company has proposed that the Department of Energy take titic to the Connumers Power Company ownoi pintonium oxide and mixed oxide fuel materials that are presently S;nred in Exxon Nucicar Company's facility in Richland, Washington. The Consumers Power Company material makes up approximately 70% of the total plutonium inventnry of 70,'i85 grams now stored at this site. Because of the increaslun~ costs' to meet new Hncicar Regulatory Commission security re<1uirenents and because of prevent nnvernment policy that prohibits the commercial use of plutonium fuel in the foreseeable future, the continued stnranc of plutonion fuci has become a sinnificant cost burden to the industry. Therefore, it'is our intention to arrange for proper disposal of nur total inventory of plutoninm f net and eventually, tor the decommissioning of our mixed oxide facility.

Accordingly, we support the Consumers Power Company proposal and rertnest that the Department of Energy consider acecpt.inre of nus; total inventory. along the lines of the Censumers Power Company proposal. Attachments i and it are listings of. our total-inven-tory of plutonium oxide powder and mixed exide fuel naterials by form. isotope and owner.

Ex:wn Nuclear Company is prepared to package all the materini in accordance with apprepriate DOE spec i f ica tions for vault or 20 year temporary steranc and to arranne for shipment to a designated government facility. I!c have been in contact with the other ewner of the material in our inventory and they are receptive to this approach.

REC:NED PAR 2 41980 AN AFFitlATE oF t XXON conPOR A TION

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Hr. Roger K. IIeusser -

M.irch 19,1980 There has also been some interest in y.xxon Nucle.1r Company owned mixed oxide fabrication equipment indicated by the Ucstinghouse llanford company. Should the Department of Energy be interested in all or part of the mixed oxide equipment for use in nevernment prograns, Exxon Nuclear Company will siake it avallnhlc to them at no cost, once disposition of the existing plutonium inventory is complete.

'It is our belief that this preposal is in keepisu. ylth government non-proliferation concerns and apparent desire to place all plutonium and mixed oxide fuci under direct nuvernment control.

Very truly yours.

Exxon Nacicar Caapany, incorporated

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$$$5 E. R. A:stj ey, g r V. President & Executive-in-Charge Fucis fianufacturing Department

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cc ER Van lloof, Consumers Power Company he:

R. C. Corran R. Nilson R. K. Robinson I.J. Samaritano 4

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a owner lit. ( m l'ti) 2 Fissile 2 l'ity.e 7 Pu Cican Plutonium 0xide Consumers Power Co.

134 80.38 16.8 86.66 198 82.76 14.8 86.30 34 81.81 15.4 86.88 50 82.00 15.7 85.86 121 81.88 16.0 86.71 58 80.08 L9.2 87.05 88 82.10 16.3 87.09 L7 MO.96 17.1 87.22 54 79.39 18.L 87.27 86 80.n3

19. 1 37.20 244 78.27 19.6 87.45 21 79.00 19.7 87.45 101 79.30 19.8 87.37 1206 Plutonium oxide Dirty 18 80.33 16.3 86.66 1601 81.25 16.L 74.39 242 79.39 18.1 37.21 12 78.27 19.6 37.45 1873 Cican Plutenlun Dr.ide General Public Utilit.tes 33 81.32 16.4 35.30 203 82.26 16.4 87.14 a

1 Portal Monitor 16.4 35.30 237

":atunium Oxide Dirty 3

16.4 87.14 39t 82.35 16.4 63.80 394 e

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% Fis: lle 2 Pile,o 2 PU Cic.,n Plutonium Oxide.,

Kernkraftwerk, Lingen 133 80.45 19.2 87.05 Electric Power Re8earch Inst.

6 79.39 18.1 57.47 9

78.77 L9.6 87.45 1}..

Total l'tlo; 3858 4

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% PU Consumers Power Co.

Fuct I:ods 31,528 4.6 - 4.8 Sintered Pellets 3,439 Green Scrap 778 Sintered Scrap 8,780 Powder 1,L19 Sintered Powder 2,470 (Swarf) n Samples 1

48,117 General Public l' L11 tics Fuel Rods 4,332 1.9 - 2.7 Sintered Pellets 785 Green Scrap 34 Sintered Scrap 1, ">J 3 cican Powdce 3

Dirty Powder

'll Sint.' red Powder 124 (Swarf) 7,33 l e

Kernkraf twerk,1,Inr.cn Fuel Asscmhiles 5.39:1 1.4 - 2.3 Fuel Hods 6 '. 3 Sintered Pc11 cts 327 Green Scrap 247 Sintered Scrap 1,673 Clean Powdce l 's Dirty Powder 52 Sintered Powdce 174 (Swarf)

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Ownce form k't. (gm Ptt)

_21U Electric Powe'r filxed Oxicd 115 3.1 - 4.8-Research Institute Exxon Nuc1 car Cimpany Fuel Rods 192 2.5 Sintered Pellets 182 2.5 Green Scrap 6

1.4 Sintered Scrap 2,519 -

2.5 Cican Powder 87 2'.5 - 5.0 Sample 2,

3.'3 2_.2 13 Total PU as P!O 67.66h Total Ptl as Pl!O

~1,313 Total PU 71,518 -'1976 inventory basis Total PU

/O',533 - 1930 liasis corrected l'or decay.

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