ML20042C096
| ML20042C096 | |
| Person / Time | |
|---|---|
| Site: | 05000134 |
| Issue date: | 03/24/1982 |
| From: | Wilbur L WORCESTER POLYTECHNIC INSTITUTE, WORCESTER, MA |
| To: | John Miller Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8203300193 | |
| Download: ML20042C096 (2) | |
Text
..
~
WORCESTER Worcester POLYTECHNIC Massachusetts 01609 I
_~
INSTITUTE (617)793-5000 March 24, 1982
- /
9
(/\\
s e
,x Mr. James R. Miller, Chief "t
2, Standardization and Special Projects Branch Division of Licensing E
89 7g i
United States Nuclear Regulatory Commission
@g 8:/
Washington, DC 20555 1,'
x hs
'g/
l
Dear Mr. Miller:
J
\\
\\p i
Your letter of March 8,1982 has been discussed with Worcester Polytechnic Institute officials. We have some misgivings concerning your suggestion that we revise our pending license renewal request, dated September 25, 1975, to confonn to the recent draft release of ANS-15.1.
i Our concern with adopting ANS-15.1 's that "Research Reactors" is a broad and somewhat arbitrary category, with small training reactors, used entirely for educational purposes, at one end of the spectrum. According to TID 8200-R38 there are only five 10 kw pool reactors in the United States, j
the most recent of which was completed in the 1960's. There appears no i
chance that more reactors of this class will be built. These 5 reactors i
thus constitute a unique set of educational devices which should not pose i
a s ubstantial regulatory problem to the NRC. We feel it is not only unnecessary, but counterproductive to efficient management, to categorize a pool reactor such as ours with complex megawatt size or pulsed reactors.
The effect of using a uniform format could well be to submerge the differ-ences and lose sight of the individualistic operation of our small educa-i tional reactor.
t Your letter states that our adoption of ANS-15.1 "will facilitate the hand-l ling of Technical Specifications by those not intimately familiar with each t
reactor facility." This is precisely our concern.
If the WPI 10 kw reactor i
is classed with large research reactors and regulated by people who do not i
appreciate our unique problems and' capabilities, ratcheting requirements to conform to research reactor standards could bring about unnecessary restric-tions and prohibitive costs.
i j
About 50 undergraduate engineering students are exposed to nuclear fundamen-tals and safety concepts at our facility each year.
Our graduates who have gone on to nuclear graduate school or into the nuclear profession are placed 1
throughout the industry, and we believe they contribute significantly to.
public safety, in part because of their training at the WPI.0 pen Pool Reactor Facility.
The Forward to ANS-15.1 says, among other things, o
l-
"We affinn, further, that the use of any standard of perfonnance.
5 j
conduct or excellence is volitional. The decision to use a f
standard is a management matter, presumably on technical-
/ O i-advisement."
p I
8203300193 820324 PDR ADOCK 05000134 l
P PDR l
~.
o Mr. James R. Miller 2
It is our opinion that it is not in the best interest of WPI or the public safety to participate in actions which will tend to destroy our identity, thereby jeopardizing our continued useful existence. We therefore request that you process our application as submitted. Naturally, if any further technical information is required by the Code of Federal Regulations we will attempt to supply it promptly.
Sincerely, C. WA L. C. Wilbur, Professor of l
Mechanical Engineering and Director, Nuclear Reactor Facility LCW/ns cc:
Donald N. Zwiep Dean Ray E. Bolz j
Raymond Goloskie l
i l
.-