ML20064K039
| ML20064K039 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 01/12/1983 |
| From: | Aftergood S COMMITTEE TO BRIDGE THE GAP |
| To: | |
| Shared Package | |
| ML20064K001 | List: |
| References | |
| NUDOCS 8301180283 | |
| Download: ML20064K039 (17) | |
Text
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UNITED STATES CF AMERICA NUCLEAR REGUIATCRY COMMISSICN
~
BEFORE THE ATCMIC SAFETY AND LICENSING BCARD g O ka (gCo $
In the Matter of -
Docket No. 5@A2 ON y7 THE REGENTS & THE UNIVERSITY , Ogg ,
& CALIFORNIA (Propssed Re Facility Lic j'p*..
(UCLA Research Reactor) ro DECLAPATION Cl STEVEN Ar ueGCCD AS "OL CCNTENTICN I I, Steven Af tergood, do declare as follows:
- 1. I am a researcher with the Committee to Bridge the Gap and a member of the Southern California Federation of Scientists. A statement of professional qualificatio"s is attached.
2 I have reviewed UCLA records related to reactor use. These records included the reactor supervisor's legs, the operating lc6s, and annual reports. Based on this review, it is my conclusion that the statement on page 5 of the application regarding the educational and research uses fer which the reactor will be used is materially false. I further conclude that th'e chart on page II/1-6 of the amended Application, detailing supposed current instructional use of the. reactor, is likewise materially false.
- 3. Fy review indicates that the original purposes for which the reactor was licensed and constructed--instruction in nuclear engineering and related sciences and research at the M.S. and Ph.D. levels--has lon6 since ceased to be a primary or even substantial portion of the activity of the reactor.
The use of the facility for these licensed purposes has very markedly declined over the license period to date. In their place, activity unrelated to the licensed purpose of the facility, in particular, commercial activity, has gradually increased to cecome by far the largest single category of reacter use.
Furthernere, the Applicant has acted repeatedly to obscure this fact.
- h. The current application states at page 5:
The reactor and its supporting lateratories will be used for the educati^on of senior undergraduate and graduate students in nuclear engineering an:1 related sciences. In addition to formal courses and demonstrations, the reactor will te used to support research at the E.S. and Ph.D. levels.
Without so indicating, the Applicant in its current application cerely copied virtually verbatin the sane statenent of purpose fren its 1960 applicatien. However, the statenent, which night have been true in 1960, was no longer true in 19e0.
8301100283 830112
{DRADOCK 05000142 PDR
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5 A review of the early operating logs compared against the most recent ones indicates a steady decline in both the instructional and research uses of the reactor. As the NEL internal Annual Report for 1976 (not the version sent to the NRC) states at page 3. "The reactor is no lenger new, and reactor physics research projects with the UCLA reacter have become non-existent."
However, that change remained obscured in the use data reported by NEL to the NRC.
- 6. NEL continued to report its activities in three categories of use--
instruction, research, and maintenance. In 1980, in reviewing the application for license renewal, the NRC noted that classroon instruction acccunted for only 8% of usage in 1979 and requested a breakdown of the categories. In Dr. Wegst's Fay 13, 1980, reply, we see for the first time that what had been reported for years as "research" was primarily commercial activity. Dr. Wegst's table is reprinted below.
REACTOR USAGE 4
ACTIVITY HOURS PER YEAR 1976 1977 1978 1979 AVG.
Engineering Classes, 17 83 52 3}, . 46 NEL Experiments 4 31 9. 1 11 i
Maintenance 23 14. - 34 1 18 UCLA Users 109 106 105 91 1 03 Colleges & Universities 45 47% 37 53 46 Demonstrations 10 6 7 5 7
~
Commercial 1 5 95 264 91 Total Port-Hours
- 208 290 340 446 3 21 Actual Run Time _
184 238 271 372 278 Equiv. Full Power Hours 131 159 203 294 197
- 7. As is readily seen, instruction and research by the Nuclear Energy Iab represents a very small fraction of the actual use of the reactor, less than 20%.
The steady increase in commercial usage is noteucrthy. So is the admirably frank definition of commercial use (see Attachment A, p. 3), which includes get coloration and mineral assaying for private firms.
- 8. '41th the passage of time, this frankness disappeared. The history of CEG's interrogatories to UCIA requesting data as to ccmmercial usage of the facility, and UCLA's repeated denial that such data existed, along the with Enard's three Orders conpelling truthful answers, as well as a "show cause" order threatening sanctions, need not te detailed here. Ecuever, the lack of frankness has continued, as is seen in the tables belou, taken from the 10P1 NEL Annual Report. Similar tables have now been included in the amended Application. The Annual Report sections are included as Attachment 3.
l Tabic 1 _.
t' Reactor Usage (Operating Hours) l CATEGORY 1977 1978 1979 1980 1981 CLASSROOM INSTRUCTION SI $2 31 46 61 j DEMONSTRATIONS 6 7 $ 2 3 RESEARCH. 135 178 335 295 284 MAINTENANCE
- 14 34 1 38 16 TOTAL OPERATING HOURS 238 271 372 381 364 EQUIVALENT FULL POWER HOURS 159 203 294 283 239 MEGAWATT-HOURS 15.9 20.3 29.4 28.9 23.9
~ _ _ _ _ _ _ _
Research Usage * (Port Hours)
USER CATEGORY 1977 1978 1979 1980 1981 UCLA ACADEMIC USERS 106 105 91 101 67 OTHER UNIVERSITIES C COLLEGES 47 37 53 20 38 '
OTHER EXTRAMURAL USERS 5 95 264 360 211 NEL STAFF 31 9 1 27 113 TOTAL PORT HOURS 189 246 409 508 429 9 Note that the figures categorized as commercial in the 1980 letter have -
now been redesignated as "research" once again, and this time subcategorized as "other extramural users." In response to C3G interrogatories, UCLA on September 18, 1981, admitted that all " extramural users" to date had been conmercial firms. Furthermore, the "NEL Staff" category under "Research Usage" is vastly inflated for 1981, with 82 of the reported 113 hours0.00131 days <br />0.0314 hours <br />1.868386e-4 weeks <br />4.29965e-5 months <br /> actually an effort to reduce Argon-41 measurements as part of the relicensing effort.
Corrected for this miscategorization, 61% of the so-called "research" services provided in 1981 were for ccmaercial mining assayers and gem colorers.
Note also the return to the less-than-frank definitions (e.g., "research")
in Attachment 3.
_4_
- 10. Classroom instruction, on the other hand, accounts for only 7 to 12%
of the total port hours for the most recent three years. Apparently in an effort to portray classroom instruction as something other than a peripheral function of the reactor, in the light of the mere 10-20 hours of operation per quarter for instructional purposes, the NEL staff has contrived a rather elaborate accounting scheme. This approach yields thousands of " student reacter hours." I used the word " contrived" advisedly, since the figures on which the accounting is based are tremendously inflated, as I will show.
- 11. The Applicant's tables of " Class Use of UCLA Reactor" for the school years 1980-1981 (Attachment C) and 1981-1982 (Attachment D) are attached hereto.
I compared these supposed summaries of instructional use against the actual reactor logs for the same period. Those logs list every reactor run, including the user's name, purpose of run, and length of run. When used for a class, the course number is listed.
- 12. I went through those logs and added up the length of time the reactor had been used for each class. The results are listed below, alongside the hours claimed by the NEL staff in its presentations to the NRC (taken from Attachments C and D):
1980-81 Annual Reactor Hours, Class Use Course Number Hours Claimed by NEL Actual Use Engr 135AL 9 3.3 Engr 135BL 9 3.45 Engr 135F >100 33.63 Engr 139A 12 4.5 Phys 180A 4 1.3 Chem 184 12 1.6 Chem 221K -
10 0.0 l ESS 298 6 3 l Engr X497.17 3 2 1
1981-82 Annual Reactor Hours, Class Use Course Number Hours Claimed by NEL Actual Use Engr 135AL 40 5.37 40 l Engr 135BL 1.7 Engr 135F _
40 7.7 Engr 139A 60 7.6 Chem 184A 10 3 E & SS 298 __ ..
48 _ _0 Phys 180A 24 0.24 Engr X497.17 30 1.7 l
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- 13. In its 1980-1981 table (Attachment C), I!EL claimed 172-190 students per year. In its 1981-1982 table (Attachment D), they claimed 138 students over the course of the year. So it is interesting to note that as of August 1979, UCLA claimed only thirty students per quarter or ninety per year. (. letter, Brown to Miller, answer #12, Attachment E). liote also that UCLA indicates in that letter that only about a dozen graduate students are in facility-related programs, and that reactor shutdown would not directly affect them (answer #13).
14 Thus, based on its own unreported records, Applicants thousands of
" annual student-reactor hours" are seen to be grossly inflated. They reduce in reality to just a few tens of ordinary hours. And, as noted above, these amount to a mere 7 to 12% of total reactor port hours, which are devoted primarily to commercial activities.
I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief.
f a
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Steven Aftergoed f/ f Executed at Ios Angeles, California, this 12th day of JantIary,1982 1
Statement of Professional Qualifications STEVEN AFTERGOOD Uy name is Steven Aftergood. I am an environmental researcher on the staff of the Committee to Bridge the Gap. I am also a member of the Southern California Federation of Scientists.
I received :ny Bachelor of Science degree, cum laude, from the School of E. gineering at the University of California at Los Angeles in 1977 In 1977 I was also elected to Tau deta Pi.
In 1978 I was employed by Meret Opto-Electronics, a fiber optics fim, as an applications engineer.. In 1980 I was employed as a research physicist at the Technion, in Haifa, Israel, working on the development of photovoltaics from amorphous silicon. In early 1981 I joined the staff of the Committee to Bridge the Gap.
My responsibilities at the Committee to Bridge the Gap include research into local errri nmental issues and, in particular, coordination of the technical review of the UCLA reactor license application.
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CFTICE OF ENV!BO.NM*TAL HEALTN AND SAFETY ruz czursa rOn TxE azALrn sc:xNcas LOS ANCELES. CALIFORNIA 90024 May 13, 1980 ROS C1510 Robert W. Reid, Chief Operating Reactors Branch #4 United States Nuclear Regulatory Commission Washington, D.C. 20555 Dear Mr. Reid';
f RE: DOCKET MO. 50-142
- Enclosed is the additional infor=ation you requested in your letter of April 17, 1980, regarding the application for the license renewal of the UCLA reactor. The information
provided your letter.
is clearly keyed to the fifteen (15) items posed in The enclosed information_has been reviewed by various
- members of UCLA's Radiation Use Committee and by myself. If you need further details concerning these, or other points, please le.t me know.
Very truly yours, ,
/$ k Walter F. Wegst Director, Research
& Occupational Safety WFW/lc Enclosure
cy Lj' Tabic. I11/1-3 ptovides Itants/ycar of reactor opeAttian for .tescatch, class insttuction, and mainte. nance. Class hatweHnn accoun.cs fon.
anly n of the. totcL hours of opeution. . vscase pavide.1 on.eart.aown in Il0urs/yenz uf Mbjpts o g stesearen pMgrama CQnduct2d 0nd thC, .Cypth i
0f custumCns for witCm .this service. WGA. Strf03,med.
Table III/l-3 will be retitied REACTOR USAGE and will be replaced <
with the table and explanations which follow here Detailed figures for years prior to 1976 are.not,available.
REACTORUbGE d
ACTIVITY HOURS PER YEAR 1976 1977 1978 1979 AVG.
Engineering. C1 asses, 17 83 52 131.. 46 4 31 - 9J . 1 11 NEL Experiments:-
Maintenance 23 14 . 0 34 c.[ l 18 109 106 105 91 103 UCLA Users Colleges & Universities 45 47 % 37 53 46 s
Demonstrations 10 6 7 ,_5; . 7 Commercial 1 5 95 s 264 91 208 290 340 446 3 21 Total Port-Hours * .
184 238 271 372 278 Actual Run Time' Equiv. Full Power Hours 131 159 203 2 94 197
, i-
- Port-Hours are a measure of user demand, two concurrent users for one hour contribute two port hours. Instructional and maintenance j
hours are- counted as one part-hour per hour.
Enoineerine Classes include both graduate and undergraduate laboratory work wnich includes basic counting, activation analysis, reactor parameter determinations and operator training and requalification.
NEL Exoeriments are conducted by the reactor staff and include seed irradiations, gem coloring experiments, activation analysis, tracer studies, isotope production using the N-P reaction.
UCLA Users include the Chemistry, Geology, Geophysics, Meterology, and Nuclear Medicine Departments. The types of experiments include activation analysis , tracer studies, delayed neutron counting.
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ornia institutiFUT Te ,
Los Angeles, California State University - Nortt. ridge, Harvey Mudd Cc1Hg2, Mt. San Antonio College, Pierce College, University of California - Santa
- Barbara and tiniversity of' California - San- Diego.' The typs of experiments performed are activation ~ analysis, fission track counting, tracer studies, reactor parameter detenninations,' reactor' operating characteristics, reactor operations, shielding, '^"studies Au . and health physics trainino. , .: -
Demonstrations were actual' reactor runs in which the reactor was taken critical to demonstrate reactor parameters, characteristics, or operation. Tours in which the reactor was shut down are not included.
High schools, Pierce College, the press, Southern California Edison Co.
and the University of California Extension were' r :recipients
.m of reheter de pmoions. ........-:.___....._ _
f Commericial Users include geochemists, gem dealers and engineering- .
firms.
Mineral assay through activation analysis and delayed neutron counting, gem color alterations, and radiation. shielding studies -
- _ _..../
s'.4Xpify the types of' experiments performed.. . _ _ _ .
NOTE: Total Port-Hours,_ Actual Run Time and Equiv. Full power Hours are includea in this table. -Deviations between the reported port-hours. and the Total Port-Hours,are due to ,ung'offerrors.
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Table 1 ANdM b Reactor Usage (Operating Hours) 1977 1973 1979 1980 1981 CATEGORY 83 52 31 46 61 CLASSROOM INSTRUCTION 6 7 5 2 3 DEMONSTRATIONS 135 178 335 295 284 RESEARCH.
14 34 1 38 16 MAINTENANCE
- 238 271 372 381 364 TOTAL OPERATING HOURS 159 203 294 289 239 EQUIVALENT FULL POWER HOURS 15.9 20.3 29.4 28.9 23.9 MEGAWATT-HOURS .
CLASSROOM INSTRUCTTON COMPRISES USE OF THE REACTOR IN SUPPORT OF UCLA UNDERGRADUATE AND GRADUATE LABORATORY WORK INVOLVING BASIC COUNTING, '
ACTIVATION ANALYSIS, REACTOR PARAMETER OETERMINATIONS, AND OPERATOR HOURS TRAINING. OPERATOR REQUALIFICATION IS INCLUDED IN THIS CATEGORY.
ARE REACTOR OPERATING HOURS IN SUPPORT OF CLASS INSTRUCTION.
DEMONSTR ATTONS ARE OF VARIOUS KINDS; THEY ARE PERFORMED FOR EDUCATIONAL . .
GROUPS AND OTHER TOUR GROUPS.
RESEARCH IS A BROAD CATEGORY DOMINATED BY SERVICE I,RRADIATIONS IN WNICH THE REACTOR IS USED AS A TOOL WITHOUT REFERENCE TO REACTOR THEORY OR OPERATIONAL PROPERTIES. (SEE TABLE II). ,
MAINTENANCE REPRESENTS THE HOURS FOR WHICH THE REACTOR IS OPERATED FOR CALIBRATION PURPOSES,, AND DOES NOT IMPLY TOTAL MA!!!TENANCE HOURS.
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Table II Research Usage * (Port Hours)
USER CATEGORY 1977 1978 1979 1980 1981 UCLA ACADEHIC USERS 106 105 91 101 67 53 20 (
OTHER UNIVERSITIES & COLLEGES 47 37 38 -
OTHER EXTRAMURAL USERS 5 95 264 360 211 NEL STAFF 31 9 1 27 113 TOTAL PORT HOURS 189 246 409 508 429 --
xRESEARCH USAGE OF THE REACTOR IS DOMINATED BY SAMPLIL IRRADI ATIONS. CERTAIN NEL STAFF RESEARCH DOES NOT INVOLVE SAMPLE IRRADIATI'ONS.
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- First Offering (1980-1981)
(-)=Per Student basis when class is subdivided CLASS USE OF UCLA REACTOR Student Studen:s Reactor Hrs
, Reactor Hrs Student Reactor Instrumentation Student Instrumentation Offe Class Units per qt. per yr Per Quarter Per Year Hours / Year 11 urs/ Class , Hours / Year Per Yi Engineeri ng 135AL 2 4-12 4-12 9 9 36-108 2 8 24 1 Engineering 135BL 2 4-12 4-12 9 9 36-108 4 16-48 1 Engineering 135F 2 4-6 4-6 >100 >100 200-300 N/A N/A 1 Engineering . (1) (1) (12) 139A 4 25 75 4 12 75 48 900 3 Physics 180A 4 10 20 2 4 40 12 240 2 Chem 184 4 20 40 6 12 240 16 640 2
- Chem 221K 4 10 10 10 10 100 18 180 1
- ESS 298 2 5 5 6 6 30 22 110 1 Engineering X 497.17 4 10 10 3 3 30 N/A N/A 1 Engineering 1398 See C-1
! Uni ts 172 -
TOTALS ,
offered 190 -
>l65 787-1031 - 2094-2142 11
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IM W UCLA NUCLEAR ENERGY LABORATORY 1981 - 1982 Academic Year Table of Class Use of UCLA Reactor
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CE Sm T@3 EN) ;i 3% ; E C'^55 Ea "VE SEE "21 21 40 320 1 320 9 3 29 ENGR 2 5 135 AL 40 320 1 320 9 4 27
" 2 8 4* 200 1 200 28 0 12 ENGR 2 5 I3I .(100N 20 500 3 1500 1 12 7 4 25 f 8 160 2 to 160 1 1 7 EM 4 16 48 288 1 288 1 32 15 5 4 6 g
0 240 11 24 240 1 5 10 1 12 4
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- 4 10 3 497.17 3328 TOTAL: l ANNUAL STUDENT MOURS OF REACTOR DEPENCENT INSTRUCTION ..
FOR THE INSTRUCTION OF UCLA STUDENTS IN TT I CLASSES LISTED ARE THOSE AND THE WHICH USE THEOF DEPARTMENTS REACTOR CHEMISTRY, EARTH AND SPACE SCIENCE, AND SCHOOL OF ENGINEERING, ACTIVATION PHYSICS ]N REACTOR CHARACTERISTICS, 80TM FUNDAMENTAL AND OPERATIONAL, AN ALY S I S , AND REACTOR OPERATIONS. THE TABLE 00E5 NOT INCLUDE CLASSES FROM OTHER USE THE REACTOR. STUDENT ENROLLMENT IN THESE COURSES COLLEGES AND UNIVER$1 TIES WHICH VARIES FROM ACADEMIC QUARTER TO ACADEMIC QUARTER.
AND THE SPECIFIC COURSE CONTENT THE COURSE THE TABULATED ENTRIES REPRESENT.TNE CURRENT TYPICAL USAGE AS ESTIMA INSTRUCTOR $. TO 2 R!ACTCR ACADEMIC MOUR$ = INCLUDES OPERATING MOURS "AT-POWE 135 F.
THE NRC A5 WELL A5 "NON-POWER" MOURS SUCN IN THE OPERATOR TRAINING COURSE ENGR IN ENGR 135 AL AND THE PRE-START CHECK-OFF IN THE PRODUCTION OF
- RECOGNIZE 5 THE USE OF THE REACTOR ILA80RATORY ANALv515 NOUR5 SUS 57ANCE5 WHICH SUB5EQUENTLY ARE SUBJECTED TO RAY VARIOU5 RADICACTIVE MATERIALS OR EXAMPLE, TO PRODUCE MATERIALS USED IN GANMA LA00RATORY ANALYSIS SY STUDENTS, FOR SPECTROSCOPY.
4LA809ATORY LECTURE AND ptE*ARATION HOURS - RECOGNIZE 5 THE STUDENT INSTRUC l
c OCCUR $ IN CONMECTION WITM THE OPERATION OPERATIONS, REACTOR INSTRUMENTATION, EXPERIMENTAL PROCEDURES ANDOF THE TECHN! QUES, REACTOR IN REAC l
MEASUREMEN! TECHNIQUES, AND METHOD 5 OF DATA REDUCTION.
OPERATOR LICENSING, 5 INCLUDES Appa0XIMATELT 100 Aco!TIONAL TRAINING MOURS REQUIRED FOR WITM OTHER REACTOR OPERATIONS.
THE TRAINING TAKING PLACE CONCURRENTLY 6OFFERED GENERALLY TWO COURSES WITM DIFFERENT COURSE CONTENT BUT W ANNUALLY, ONLY ONE OF WHICM REQUIRES THE USE OF THE REACTOR.
Prepared by UCLA NUCLEAR ENERGY LABORATORY
m - , _ -
a NUCLEAR REGULATORY COMMISSION -
{.a I vensumavam.a.c.ansas g., .
/ MhJ~* C Univ:rsity of California a 30 M ,
ATTN: Mr. Harold B. Brown Environmental Health & Safety .
Officer Los Angeles, California 90024 Gentlemen:
Bgckground ,
Your reactor facility license authorizes you to possess. special nuclear material (SNM) of types and amounts that exceed the " threshold" quantity defined by 10 CFR Part 73, g73.l(b). Authorization limits will establish physical protection requirements under 10 CFR 37 3.47 and the Safeguards Upgrade Rule. The maximum possession limit will mandate that you comply with the requirements of the proposed safeguards. upgrade rule (see enclosure A) which will be issued in the Federal Register within the next few days and. will be implemented 120 days from its effective date. All nonpower reactor facilities have been deferred from the implementation of the upgrade rule for 120 days. During this 120 day period the staff has been directed to detennine for the affected facilities (1) the status of physical protection at each, (2) the impact of closure of some or all as applicable, (3) what plans are being taken to implement the upgrade rule. After acouisition of this data the staff must report to the Conmission with appropriate recommendations.
Reauirements The purpose of this notice is to inform you of our program to comply with the Consission's directive (see enclosure B) and to request certain information from you.
l i program July 27,1979 Issue this Notice August 15, 1979 Licensees to provide requested data August 27, 1979 Meeting of all affected nonpower licensees with NRC staff representatives at NRC Region III headquarters. Agenda will be provided separately.
August - ,
September 1979 Visit facilities not previcusly visited October 5,1979 First draft of Report Infomation Reauired Information is required that only you can provide to develop the aforementioned report. Therefore, provide the following as a minimum. This list is by no 1
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2-means complete and additional data from you is solicited.
- 1. What additional features will be constructed walls, vaults CAS, protected area and costs associated with these.
- 2. Wha't is the expected total cost to upgrade hardware? - one time-cost - alarms, CCTV, guns,. uniforms, badges, detectors.
- 3. What is the expected cost annually - guards, material, screening, two man rule - for an upgraded physical security plan - manpower
- and hardware?
l 4. What is. the cost of shutting down the facility?
( What is thi annual cost of maintaining possession only stat.us?
l 5'.
l 6. Effect of loss of program on US industry - (i.e.) engineers and operators for U.S Nuclear Power Plants.
! 7. Effect of loss on medical researett, medical treatment.
- 8. Cost of new clans - security, contingency, guard training.
- 9. Considering the impact of implementing the Safeguards Upgrade Rule will you continue to operate your facility?
- 10. Describe the impact of closing the facility on the educational program at your facility (school) - Loss of program and courses.
l 11. What is the size of the facility staff? - Will it be cut?
- 12. How many students are in the- classes? - Will they finish their degrees?
- 13. How many graduate students. are in facility -- related programs? -
Will they be able to finish?
- 14. What is the typical annual operating budget?
l
- 15. With 100 r/hr at 3 feet exemption criteria, can you meet and maintain the SNM at such a level continuously? What would the impact be on current financial and operating resources? How would it maintain the self-protection criteria affect fuel replacement and costs therefore?
- 16. How many courses utilize the facility - will they be cut?
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- Sincerely,
,/ .,t #
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James R. Miller, Acting Assistant Director for Site and Safeguards N
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,JNIVERSITY OF CALIFORNLA LOS ANGELES
~-
- -. .mnn .un - .anamme. - ===. - - - (. , wri- --- . =ri cum THE FACTS AND FIGURES IN THIS DOC MENT ARE NO LONGER T1MELY OR ACCURATE. THEY SHOULD BE CONSIDERED ONLJ g,_ m IN A HISTORICAL CONTEXP. m es,rms,oe rux xxu.m -
umancxus.cumaan A 9aam Augusc 15,. 1979 EHS: C1251 James R. Miller So-2A+
Accing Assistant Director for Site and Saf eguards IT . S . Nuclear Regulatory Commission Washington, D.C. 20555 Dear Mr. Miller-Due to the sensitive nature of the contents of this letter, we request that this document be withheld from oublic disclosure oursuant e, Section 2.790 of 10 CFR Parr 2. Ihis letter is.our responsa to your letter dated July 30, 1979 It is not our intencion to possess greater than a. f ormula. quantity of non-exempe SSNE because grescer amounts would encall financial costs, manpower requirements , and restriccians which could not be met a c chis-facility. Our Argonaut Reactor concains approximately 3.6 Igs of SSNM.
We also have 0.7 Kg of irradiated SSNM in the process of being shipped to the Idaho Chemical Reprocessing Planc and ano ther 4.6 Ig of non-irradiated fuel in. scorage. We ha.ve three alt e rnative s .
- a. Ask for a variance on the 3.6 Kgs of SSNM in the core of the reaccoe due to the dif ficulty in re trieving it frun the reactor,
- b. Score che 4.6 Kgs of non-irradiated SSNM elsewhere off-site.
- c. Remove all.the irradiated.fue*1 from the reactor and send it to IC2P for reprocessing and place che non-teradiaced fuel in che reactor.
With the above comments in mind, the following are our responses to your sixteen questions answered in the same order as submitted in your letter:
- 1. None planned.
- 2. None except change of locks, keys, and comb',ardans in the near future. C OEU$ MNk
- 3. Uncertain, depends upon alternatives. g g~r ;ty \
4 Approximately S500,000 to S1,000,000.
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- 5. Aporoxin telv S25,000 to $35,000.
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- 6. Uncertain, but would result in a reduction in theOur number of reactor also graduate nuclear engineers entering industry.
supports uranium assay work related to the search for uranium COsources.
I. None.
- 8. None planned. '
e
- 9. Yos, conditionally.
The reaccor serves as a major part of five laboratory courses 10.
offered by the School of Engineering and Applied Science. Closing the f acility will, cost UCT.A at leas t three job openings, five classes, and several research. programs.here and at other Univer-cities. Closure would diminish not only our catal educational other schools pro gram,. but would. dimin.ish. educational programs at of the Reactor Sharing Program of DOE.
becausa our reaccor is a part
- 11. Seven Tes. W will have to cut approximacely three people.
- 12. Approximacal 30 ee quarter Tes.
)
- 13. Approximacely a. dozen. Keactor shutdown would not directly affect t h ,e m .
- 14. $120,000.
- 15. It does noe seem possible ta meet the 100 r/s at l' at all times for the reactor fuel. The impact of the upgrade enie would result in prohibicive costs if unf avorably interpreced in our case.
- 16. There are five courses which utilize che reactor, and two courses on reactor licensing (on a one-time-only basis) are beginning this fall. .
We hope that the answers ce chas e- quescions neet with your approval.
Sincerely, l
&arols.
n 7. f htn" Brown, Dr. P.H.
Environmental Heal:h and l Safety Officer l
HV3/jac f cc: Charles E. Ashbaugh Ivan Caccon John Evraets l
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