Re: Nuclear Reactor Fuel Rods are Radioactive Sealed Sources,

[David W Lee <lee_david_w@lanl.gov>]

At 07:57 AM 27-11-96 -0600, you wrote:
>David Lee questioned the classsification of reactor fuel rods and other
items as "sealed
>sources."  At this point, I can only respond with another question, i.e.:
what is the problem?
>
>If, because of these definitions,  you are being hit with requirements that
seem unreasonable, 
>get back to the NRC.  The NRC (only) is empowered to interpret its regulations.
>
>If, on the other hand, this is a quibble about terminology in the
regulations, I suggest dropping
>the issue.  There are countless imperfections in the regulations.  This is
inevitable as each
>regulation is years in development and is revised many times by many people
before
>publication.  Then it may be on the books for decades.  If a regulation is
seriously defective, it
>seems appropriate to utilize the provisions for initiating a rule change.  
>
>Charlie Willis
>
>
>
>
>       As to Charlie's attempting to reply to the original posting merely
by asking 'what is the problem,' part of the magnitude of any problem
concerning fuel rods is whether or not fuel rod manufactures certify their
rods as being 'sealed sources' under ANSI N43.6, Radioactive Sealed Sources,
Classification.  I do not know whether or not such manufacturers routinely
certify reactor fuel rods under N43.6 as meeting the various tests
recommended for sealed sources under this standard.  Table 4 of this
standard does not list a 'typical' sealed source use as being a nuclear
reactor fuel rod.  Perhaps some other Radsafer could clarify this point.
IF, however, reactor fuel rods are NOT routinely certified by the
manufacturer as meeting N43.6, then the 'problem,' becomes 'does it then
make any sense for the NRC to include such fuel rods under its definition of
a 'sealed source' if indeed, manufacturers of such rods are not regarding or
certifying them as 'sealed sources' to begin with"?

        Also, all replies to the original posting have so far chosen to
dodge the issue of whether or not fission chambers and RTG's are regarded by
the NRC as being 'sealed sources.'  On this issue, again in response to
Charlie's rhetorical question 'what is the problem'?, the potential
'problem' is knowing what the NRC expects in terms of how these items are
operationally kept track of.  Fission chambers are sometimes used inside
nuclear reactor cores during operations.  If such chambers are 'sealed
sources' under the present NRC definition of same, then does the NRC expect
them to be inventoried quarterly, individually wipe tested semiannually,
etc., as other traditional 'sealed sources'?

REGARDS

David W. Lee
Radiation Protection Policy & Program Analysis Group, ESH-12
Los Alamos National Laboratory
PO Box 1663, MS K483
Los Alamos, NM  87545
(505) 667-8085
FAX (505) 667-9726
David W. Lee
Radiation Protection Policy
& Programs Analysis Group (ESH-12)
Los Alamos National Laboratory
PO Box 1663, MS K483
Los Alamos, NM  87545
Ph:  (505) 667-8085
FAX: (505) 667-9726