ML19275A114

Responds to 790730 Request for Info Re Implementation of New Portions of 10CFR73.No Addl Const Features Will Be Required at Facility.Provides Info on Budget,Facility, Students,Experiments & Radiation Levels

ML19275A114
Person / Time
Site:	University of Wisconsin
Issue date:	08/09/1979
From:	Cashwell R WISCONSIN, UNIV. OF, MADISON, WI
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 7908310298
Download: ML19275A114 (4)

Text

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Regulatory Commission 7 l Washington, D. C. 20555 i , L- l

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Attention: Assistant Director for Site and Safeguards  ;

Re: Docket 50-156, License R-74

Dear Sir:

This letter is submitted in response to your letter of July 30, 1979, request-ing information on implementation of the requirements of the newly published portion of 10 CFR Part 73 with associated changes in Parts 50 and 70.

This letter is drafted based on both the Federal Register Notice and the copy of Proposed Regulatory Guide 5.XX which was supplied to us in January,1979. At this time, our facility has not had the benefit of a visit from NRC personnel to discuss the guide and its interpretation. Finally, the requested response time on-ly allowed nine days from receipt of the mailing until the information is to be sub-mitted so in depth answers to all questions can not be attempted, particularly in instances where cost information would have been obtained from outside groups.

The format of the following is a numbered response to exn of the 16 numbered questions contained in the July 30th letter.

1. We do not believe any additional constructed features will be required at our facility.

2. We expect the total cost to upgrade hardware will be approximately

$5,000, primarily improvements to the intrusion alarm system.

3. We believe we will be exempted from the requirerents for protection of material of high strategic significance by virtue of maintaining the fuel in the cc - at sel f- protecting levels. We believe the main-tenance of facilit as and procedures appropriate to materials of

, moderate strategic significance is essentially equivalent to the level SV , of protection supplied at our facility presently, with only a slight

\ incremental cost of approximately $2,000 per year for increased sur-ve111ance activities.

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_[ / Ne further believe it would not be possible to accomplish our in-

,1 ' structional mission if we are required to meet more stringent re- g quirements for safeguards. For this reason, we expect the univer- t sity would seek to terminate the operation of the facility if re-quired to protect beyond the " moderate strategic si nificance" levels indicated in Regulatory Guide 5.XX.

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7908310 #i6

U. S. Nuclear Regulatory Commission '

August 9, 1979

4. The cost of shutting down the facil ty would be based, primarily, on the cost of shipping all fuel to another facility plus decontamina-tion costs. Our last irradiated fuel shipment took place more than ten years ago so our estimate for fuel shipment is likely to be in great error because of cost escalation since that time and increased requirements on shipment of special nuclear materials. We believe at least four shipments of fuel would be necessary if we were to use a cask similar to the cask used in our previous fuel shipment. The cost of shipping the fuel based on the previous shipment and with the price adjusted at a 6% increase per year would be $100,000. The cost of remaining facility decontamination and disposal of activated components is estimated at $50,000.

5. The cost of maintaining possession only status is likely to be as great as operating the facility, or greater, since the fuel would cease to be self protecting and would require the fuel security re-gime of the Upgrade Rule. We expect the additional guard force per-sonnel plus maintaining surveillance of the reactor to entail about the same total cost, or a greater cost, although we have no basis for cost prediction in this area.

6. .In a typical year we will have about thirty students (primarily seniors and graduate students in nuclear engineering) complete our two laboratory courses which utilize the reactor. An additional forty or so students (typically engineering sophomores) become ac-quainted with reactor operating characteristics through our intro-ductory nuclear engineering course which utilizes one 3-hour ses-sion in the reactor laboratory. Students from a number of our other departments (perhaps two hundred total in any year) will be visiting our facility for a single laboratory session appropriate to the.f r field of study.

We expect to provide training for twenty-four to twenty-six utility operator trainees during the next year compared with only twelve during the previous year.

7. We currently hoe three groups using our facility for isotope pro-duction for primarily medical uses. A far greater loss would be the elimination of the neutron activation analysis capability on campus which analyzed approximately 4,000 samples during the past year in pursuit of environmental, agricultural, metallurgical, medical,and industrial studies. Most of this work would be impos-sible without a local reactor facility. In short, our primary re-search use is not production of radiopharmaceuticals, but neutron activation analysis.

8. The cost of rewriting new security and contingency plans for meet-ing the requirements of Regulatory Guide 5.XX is estimated at

$2,000. Should we be required to meet the full requirements of the Upgrade Rule assuming that we did not maintain self-protecting levels, we have no good basis for the estimate of costs without further opportunity for careful study of changes in the regulations under the Upgrade Rule.

9. The cost of implementing plans for material of moderate strategic significance is within our capability. Security requirements be-yond those of Regulatory Guide 5.XX are beyond our budgetary level but, more importantly, will so seriously interfere with our train-ing mission that it would be unlikely that the university would 2033 237

U. S. Nuclear Regulatary Commission August 9, 1979

. continue teaching in the fission area of nuclear engineering by use of the reactor facility, thus it is unlikely that we could continue to operate the facility should we be required to meet the full requirements of the Upgrade Rule for greater than formula quantities of SNM.

10. Although it is possible to offer graduate and undergraduate degrees in nuclear engineering without the teaching capability involved with a campus reactor and associated laboratories (in the beginning days of our nuclear engineering program, we did not have a reactor on campus but were able to use facilities at Argonne National Laboratory for the essential laboratory courses), it is unlikely that we would continue to offer our courses in fission reactor subjects that constitute most of our undergraduate courses. The fusion activities within the department would continue. The overall program of the Gradu-ate School would be weakened by the loss of the facility, al-so. More than thirty graduate students from fields outside the Nuclear Engineering Department used our facilities in their research last year. This could be as important to the nation in the long run as the loss of the NE students receiving BS degrees through our program.

11. The facility is staffed by seven full-time equivalent person-nel . Staffing level would certainly be cut if the reactor were to be shut down, probably to two individuals plus addi-tional guard personnel.

12. The number of students in formal classes is indicated under item 6. The students would certainly be given the opportuni-ty to complete their degrees if the reactor were to be shut down.

13. The number of graduate students making use of the facility (all outside nuclear engineering) is indicated under item 10.

The students would be able to complete their degrees, although loss of the local facility for neutron activation analysis, in many cases, would require redirection of their thesis re-search.

14. The annual operating budget for our reactor facility is approx-imately $128,000 exclusive of overhead costs (which are highly unlikely to change whether the reactor is operated or not) and fuel support which has previously been entirely by the Depart-ment of Energy.

15. We believe we can maintain the 100 rem /hr at three feet criteria in such c manner that we will never have a formula quantity of material zbove 20% enrichment which does not meet the criteria.

This requires additional full power operation which would not be scheduled based on experimental work load. It will also (1) a u to the activity released to the environment (2) result in acc -

mulation of larger amounts of solid radioactive wastes (3) make scheduling of some instruction much more difficult (4) result in some second shift operation during extensive utility opera-tor training programs (5) increase the radiation exposure of our personnel, and (6) add a great deal of difficulty to our maintenance activities. Items 3, 5, and 6 just listed are more 2035 238

U. S. Nuclear Regulatory Commission August 9, 1979 important than the increased financial cost of the operation which will only amount to around $10,000 annually. Experiments such as critical experiment and reactivity measurements req dre a xenon-free core and as low a gamma-ray environment for detectort. as possible.

Definite problems in this area have already been encountered in main-taining the core at self-protecting levels. Inspection and measure-ment,of fuel control elements and other in-pool components of the reactor were fomerly scheduled after shut down periods of a week or more but maintaining the exemption level of rcdiation will no longer allow this type of scheduling. Integrating operation for self pro-tection with making the reactor available for special low-level ex-periments will require that, occassionally, the reactor core will approach non-self-protecting levels. It is entirely possible that equipment failure at such a time might make it possible for the fa-cility to temporarily cease to be in self-protecting level for a short period.

In summary, maintenance of self-protecting levels and fuel radiation level is diametrically opposed to "as low as reasonably achievable" doses and to safety considerations involving consequences of acci-dents leading to core damage. Maintaining self-protection levels will not significantly affect our fuel replacement costs since we are presently operating with a FLIP core which will probably be limited as much by corrosion of the cladding as by fuel burnup.

All of the foregoing is based on the assumption that self protec-tion must be maintained for a fuel bundle. Our fuel consists of four TRIGA-type fuel elements assembled into bottom and top adap-ter units which fit into our grid box. It is possible to disas-semble our fuel bundles with remote handling tools, but it requires special tools and procedures and ir slow and tedious work. It is actually more difficult than would t;e chopping or cutting single elements and, therefore, we expect the interpretation will remain that fuel bundles as a whole must maintain self-protecting levels.

16. Response to the question on what courses utilize the facility is indicated above under item 6.

Very truly yours, Manager, Nuclear Reactor Laboratories RJC:mid XC Reactor Safety Committee Reactor Director Department Chaiman 2033 239

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