ML19276H055

Responds to 790730 Ltr.Upgrade of Rule Security Requirements Are Not Necessary.Requirements of 10CFR73.47 Will Apply in Lieu of Rule.Major Changes to Facility Are to Be Undertaken If Compliance W/Rule Is Deemed Necessary

ML19276H055
Person / Time
Site:	University of Virginia
Issue date:	08/15/1979
From:	Shriver B VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:	John Miller Office of Nuclear Reactor Regulation
References
NUDOCS 7908310547
Download: ML19276H055 (6)

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UNIVERSITY OF VIRGINIA SCHOOL OF ENGINEERING AND APPLIED SCIENCE s v C H ARLOTTESVILLE. 22901 D EP ARTM ENT OF NUCLEAR ENGINEERING AND ENGIN EERING PHYSICS TELEP HO N E: 804-914 7136 REACTOR FACILITY August 15, 1979 p u q ,. g _

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Mr. James R. Stiller Acting Assistant Director for Site and Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Miller:

This letter responds to your letter dated July 30, 1970 which requested information concerning the impact that implementation of the increased phy.;ical safeguards intended to protect special nuclear material would have on the University of Virginia Reactor Facility.

Your letter implies that since our present reactor licenses (R-66 and R-123) allow us to possess and use more than a formula quantity of special nuclear material, as defined in 10 CFR part 73, that we will be required to meet the physical security requirements of the " upgrade rule". Specific re-quirements of the " upgrade rule" are contained in 10 CFR parts 73.20 and 73.46 and include training and maintenance of several armed guards and extensive requirements for protective barriers, intrusion alarms, searches on packages entering and leaving the facility, etc.

It is our intent to ensure that we do not possess a formula quantity of special nuclear material at the Reactor Facility. We have provided the NRC with written statements to that effect along with identification of the specific actions we are taking to ensure that we do not possess a formula quantity in letters dated September 13, 1978, September 28, 1978, November 7, 1978 and December 1, 1978.

In addition, in a letter to the U. S. NRC dated March 9, 1979, we re-commended changes to our present reactor licenses which would specifically re-quire that less than a formula quantity of special nuclear material be possessed at the Reactor Facility.

Based on these actions we do not believe that the security requirements of the " upgrade rule" apply to the University of Virginia. Instead the re-quirements of the 10 CFR part 73.47 which was recently issued will apply. We believe that we are essentially in compliance with those requirements now.

This will be discussed with the NRC representatives which visit our Facility as identified in your letter.

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However, if for any reason the NRC concludes that we may possess a formula quantity of special nuclear material the requirements of the "up-grade rule" will apply. If we were to comply with this rule many changes to the Facility would be required. Since you requested our response by August 15, 1979 and since we do not consider that the upgrade rule applies to us we have not yet p trformed a comprehensive evaluation of the Facility changes which would be required. However, an initial assessment of the ex-pected impact on the Facility and associated educational and research pro-grams is provided in this letter.

Briefly, we believe that the upgrade rule would require that the size of the full time staff be increased by at least a factor of two or three.

This would be necessary to provide the full time guard force, provide access control and meet the search requirements of the " upgrade rule".

In addition,many changes to the building and surrounding area would be required. For example, our present isolation area does not meet all of the

" upgrade rule" requirements. To meet these requirements fully, over 2000 feet of new fence and a new parking lot would be required since we allow parking within our isolation area. Many changes to the security alarm system would be required including the installation of an automatic, auxiliary power system to provide power for the alarm system in the event that normal power was lost. In addition,a bullet-resisting central alarm station and access control stations would be required. Other specific changes which would be required will be provided at the August 27, 1979 meeting.

While we have not performed specific cost estimates on the proposed changes, I believe that over $1,000,000 would be required to upgrade the facility and that the annual operating state supported budget would increase from its present level of about $140,000 per year to .cout $500,000 per year.

In addition to the cost of these changes the severe restrictions on access to the Facility by students and researchers would greatly degrade the educational program associated with the operation of the two reactors. For example, this summer we have sixteen fourth year and graduate students training to become reactor operators. It appears that the cost associated with the NRC or DOT material access authorization which would be required by the "up-grade rule" would preclude this valuable training program and the use of qualified, screened students as reactor operators.

While no formal position or recommendation has been established by the University of Virginia, I believe that it is likely that the Reactor Facility would be closed if we were required to meet all of the requirements of the

" upgrade rule". However, as noted above, we consider that this should not bc required since we possess less than a formula quantity of special nuclear material.

The initial dollar cost of permanently shutting down the Reactor Facility is estimated to be about $160,000 The basis for this cost estimate was pro-vided in a letter to the NRC dated December 18, 1978.

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- ' Letter to James R. Miller Page 3 The state supported annual operating budget is about $140,000 of which $120,000 is for personnel. Supported on this budget are part of the salary of the director, the full salary of the reactor supervisor, three full time reactor operators, two technicians and a secretary. If the reactor were not operating nearly all of these positions would disappear. This would be particularly tragic for the reactor operators who are ex-navy enlisted men working toward bachelor's degrees in engineering.

His path to earning their degrees has been used by numerous men during the life of the facility.

In addition to the state budget approximately another $150,000 is earned by operation of the facility. This money is primarily used to support students, both graduate and undergraduate. This important educational com-penent, which is discussed below, would be lost without reactor operation.

The importance of reactors to nuclear engineering education is illustrated by the number of schools with reactors. Bere are presently about 61 univer-sities in the United States which have least a limited program in nuclear en-gineering. Of this list, about 14 have no graduate programs or are other engineering disciplines with a nuclear interest. That leaves about 47 active nuclear engineering programs. Presently there are about 36 research reactors and 12 laboratory reactors at U. S. universities. The fact that there are more university reactors than activa nuclear engineering departments in-dicates that reactors are required for a viable educational and research pro-gram in nuclear engineering.

The reasons that a viable nuclear engineering program requires the use of a reactor can be appraised by considering the three required classes using the reactors in our undergraduate program. Two of these courses cover practical applications of the basic principles of reactor design such as measurement of reactor response to changes in reactivity, measurement of neutron fluxes and spectral variations in materials,and provide practical experience in neutron activation analysis. The other. course emphasi::es reactor operation. In this class, the students gain a better perspective of the actions, systems, and ad-ministrative controls required to operate and maintain a reactor. This includes an understanding of the safety systems, licensing requirements, and how reactor instrumentation can be used to detect abnormal conditions before they affect reactor safety. We believe that a graduate engineer who has only a " textbook" knowledge of these items would be much less qualified to design, operate or regulate commercial nuclear reactors than our graduates who take these classes.

The above discussion concerning the educational benefits of the reactor also apply at the graduate level. However, a major benefit of the reactor at the graduate level is in the research opportunities it provides. Research at our reactor has included measurements of basic reactor physics parameters, shielding effectiveness of laminated shields, shielding and dosimetry of high energy photons, penetration of. radiation through thick shields, neutron spectrum measurements and materials damage studies. The latest major project, presently supported by EPRI, is concerned with the prospects of thermally annealing neutron damage in reactor vessel steels and will be extended to crack growth arrest studies in steel.

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• Page 4 The nuclear engineering department at the University of Virginia has granted 203 bachelor's degrees, 205 master's degrees and 42 Ph.D's between its inception in the late fifties and the end of 1978. There are presently about 50 undergraduate students who use the reactor in the three required undergraduate classes discussed above. There will be approximately 40 graduate students in the program for the 1979-80 academic year. Probably all of the students would graduate without the reactor but the quality of their education would be drastically cheapened since they would miss much of the practical experience necessary to understand reactor design and operation.

As noted below, the impact on future enrollments may be much greater.

The use of the reactor for educational purposes is not limited to students in nuclear engineering. For example the University of Virginia Chemistry Department regularly uses the reactor for neutron activation analysis. In addition, during the present academic year 77 students and seven faculty members from seven area coaeges have used the reactor for experiments, such as neutron activation analysis, under the DOE Reactor Sharing Program.

These students were able to do experiments which would not be possible at their colleges which do not have reactors. This type of educational exposure would not be possible if the reactor were not operating.

Although the effect of closing reses.rch reactors can be quantified in terms of numbers of students involved or research programs terminated, the most important effect may be the psychological effect on the industry. The act of closing university reactors would be a clear signal to prospective engineering students that nuclear engineering as a profession is not healthy. We are al-ready seeing signs of this. For example at our university the number of graduate students in the Nuclear Engineering Program has dropped from 60 in tne 1977-78 session to about 40 for the 1979-80 academic year. The prospects for growth in the graduate program is not bright becaus the undergraduate en-rollment is weak--30 in the senior class,12 in the junior class and 12 in the sophomore class. The situation is anomalous because the job market has never been better and there are ample-sources of financial support for the graduate students. The action of closing university reactors, which are the hallmarks of quality educational programs, could have a fatal impact.

The status of the job market deserves further comment. Hardly a week goes by that we do not get a phone call from someone seeking our graduates. The calls come from the utilities, the vendors, consultants and, more frequently, from regulators. This is a problem for the graduate program because salaries for bachelor's degrees are so high that it is difficult to convince the student to stay for the master's degree. There is no lack of market for our graduates; quite the contrary, there is a crying need. Thus, although there is a clear need to continue to design, build and operate new commercial power plants, it is likely that closure of university reactors such as those at the University of Virginia may have a significant long term effect on our .bility to accomplish this due to reductions in qualified personnel.

The effect on the commercial nuclear industry of the research conducted at university reactors is significant. Power reactors simply cannot be operated as research devices and yet there is a continual need for basic engineering studies, such as those listed above. These studies are needed to support fu-ture reactor designs and assure continued safe operation of the present nuclear power plants. For example, the ability to anneal irradiated reactor vessels W6 306

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'. Page 5 is required by 10 CFR 50 Appendix G. However, the actual benefit of this process is only now being confirmed in a EPRI supported program being con-ducted by Westinghouse and the University of Virginia. This program would not be practical without the irradiation of specimens in a research reactor such as ours.

In addition to the items discussed above your letter requested information concerning the impact of the exemption of fuel which is maintained at radiation dose rates of 100 R/hr or greater. The fuel in the UVAR can be maintained at the 100 R/hr as specified; the fuel in the CAVALIER reactor cannot. However, there are some situations in which some UVAR fuel may not be maintained at "self-protecting" levels. These cases include:

1) Delays in shipment of expended fuel. The possibility exists that a spent fuel shipping cask could not be scheduled before the fuel decays below the self-protecting levels. The availability of shipping casks is at best, uncertain. If there is any reactivity remaining in the fuel, it could be re-loaded and reoperated. This procedure would take about three weeks which would interrupt on going research programs and entail a loss of revenue to the ',

facility of about $20,000. The additional handling of the fuel introduces the -

possibility of a mishap which may lead to additional radioactive exposure to operating personnel. t

2) Imperfect fuel elements. Some fuel elements develop fission product leaks which prevent their further operation in the core. When these elements decay below self-protecting levels, they cannot be reirradiated. To ship even a single element away from a reactor requires a shipping cask and associated security measures at an estimated cost of about $20,000.

3) Lightly loaded elements. Some fuel elements have lower uranium loadings than others. For example, the control rod fuel elements contain only half as much uranium as the normal elements. These elements will decay below the self-protection levels sooner than the rest of the core. This is a particularly serious problem because the process of connecting and disconnecting the control rod follower to the fuel is complicated and involves a considerable manipulation of the fuel. The operation increases the possibility of radiation exposure to personnel and violates the ALARA philosophy.

4) Receipt of new fuel. Receipt of new fuel may be more limiting than the availability of a :, hipping cask for fuel shipments. The CAVALIER reactor has a loading greater than 2kg of unprotected fuel. If a new core with more than 3kg were delivered we would exceed the formula quanity until the new core were irradiated. It should be noted that CAVALIER fuel and UVAR fuel will not normally be interchangable. The CAVALIER is fueled with the older flat plate elements and new UVAR fuel contains curved plates. Thus, we cannot make the CAVALIER fuel self-protecting by moving it to the UVAR.

We would also like to note that the notice requesting this response by August 15, 1979 and informing us of the meeting on August 27, 1979 was not issued until July 30, 1979. We appreciate the opportunity to comment on the impact these regulations would have on the research reactor community, the nuclear industry and on nuclear engineering education. Unfortunately the timing is such that the NRC may not get an adequate and representative response from t'.e affected facilities. August is typically a time of vacation for universit faculty members.

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We are particularly concerned about the smaller facilities, those which may be most directly affected by the order and may not be able to respond in a timely manner. Without the response of these facilities the NRC will not have a representative sampling from the reactor community which is necessary to provtde an accurate evaluation of impact of the " upgrade rule" on research reactors. >

In summary, we believe that the " upgrade rule" does not apply to the University of Virginia Reactor Facility since we have less than a formula quantity. However, we consider that its implementation at the University of Virginia or other universities would likely result in closure of the affected facilities. This will have a significant adverse effect on this countries ability to meet the energy requirements necessary to maintain our country's standard of living and position of world leadership.

Sincerely, t.L B.lu. Shriver, Director Reactor Facility BLS:ph cc: Dr. T. G. Williamson

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