ML20246J429
| ML20246J429 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/1989 |
| From: | Alexander Adams Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8907170367 | |
| Download: ML20246J429 (10) | |
Text
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o UNITED STATES g
NUCLEAR REGULATORY COMMISSION I
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WASHINGTON, D. C. 206"5 June 19, 1989
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PARTICIPANT:
THE ORGANIZATION OF TEST, RESEARCH, AND TRAINING REACTORS (TRTR)
SUBJECT:
Sul9tARY OF MEETING TO DISCUSS REGULATORY ISSUES CONCERNING NON-POWER REACTORS (NPRs) l On June 1,1989, representatives of TRTR and NRC staff met at NRC headquarters in Rockville, Maryland to discuss current issues of concern to the non-power reactor community. Enclosure 1 is a list of attendees. Enclosure 2 are hand outs provided by TRTR at the meeting.
TRTR opened the meeting by stating that the mission of NRC licensed NPRs is education, the conduct of research, and to provide public service. TRTR also stated that the foremost goal of the community is the protection of the health and safety of the public and the environment and that NPRs strive for excellence in their operations. TRTR believes that except for licensing, the NRC staff does not recognize and appreciate the difference between NPRs and power reactors. TRTR believes that the regulatory climate has contributed to the decision of some NPRs to decommission. A summary of TRTR's concerns and suggestions presented at the meeting are summarized below:
1.
TRTR believes that the staff does not keep in mind that the Atomic Energy Act treats research reactors differently than power reactors.
and recent regulations The inspection program, enforcement policy,lation upon the licensees are not imposing the minimum amount of regu as the Comission finds will permit the Comission to fulfill its obligations under the Act.
2.
TRTR stated that there is a " power reactor mindset" in NRC's inspection program. The result of this is inspectors that do not understand the difference in design, construction, operation, risk and regulation between power reactors and NPRs. Concern was expressed about inspectors pushing for increased written procedures and paper trails for all tasks, the use of inspection reports as a forum for making policy, and the use of team inspections at NPRs. TRTR suggested that the NPR inspection program be centralized at headquarters with a staff of NPR experts such as exists for NPR licensing.
3.
1RTR believes that enforcement conferences, civil penalties, and the negative public interest that results from enforcement does not enhance safety, but detracts from safety by diverting manpower and resources away from solving problems and improving safety. TRTR can identify no instance where a NPR licensee has ignored a notice of violation or where
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a civil penalty was required to insure compliance. TRTR suggested that consideration be given to modifying the enforcement policy for NPRs.
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TRTR agreed to submit examples of NPR violations that they feel are appropriate for the various Supplements and Severity Levels.
It is felt that the present severity level system does not recognize the reduced safety and environmental significance of specific types of violations at NPRs as compared to power reactors. A two tier enforcement system was also suggested by TRTR. The first tier would allow a NPR to correct problems with assistance from the community trithout a notice of violation. If first tier action could not solve the problem, the second tier would consist of NRC taking enforcement action. TRTR believes that this system would result in a positive approach to enforcement. The staff requested and TRTR agreed to provide additional detail about this suggestion.
4.
TRTR reiterated their opinion that NRC administered requalification examinations are not required to maintain operator proficiency at NPRs. Small operating staffs that are involved in all aspects of operation and performance based requalification programs make NRC testing unnecessary. NRC can achieve the same level of cefiden.:e in NPR requalification programs by conducting inspections and audits which would consume less NRC staff resources. TRTR indicated that they will request that the Commission reconsider the necessity of these examinations.
5.
Concern was expressed by TRTR about uncertainties concerning future fitness for duty programs.
The staff thanked TRTR for their views and indicated that they would give careful consideration to the suggestions and concerns put forth by the community.
0a Alexander Adams, Jr., Proje Manager Standardization and Ngn-Po er
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Reactor Project Dire ate Division of Reactor Projects - III, IV, V bnd Special Projects
Enclosures:
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i June 19, 1989 l
TRTR agreed to submit examples of NPR violations that they feel are appropriate for the various Supplements and Severity Levels.
It is felt that the present severity level system does not recognize the reduced safety and environmental significance of specific types of violations at NPRs as compared to power reactors. A two tier enforcement system was also suggested by TRTR. The first tier would allow a NPR to correct problems with ass Stance from the community without a notice of violation.
If first tier action could not solve i
the problem, the second tier would consist of NRC taking enforcement action. TRTR believes that this system would result in a positive approach to enforcement. The staff requested and TRTR agreed to provide additional detail about this suggestion.
4.
TRTR retterated their opinion that NRC administered requalification examinations are not required to maintain operator proficiency at NPRs. Small operating staffs that are involved in all aspects of operation and performance based requalification programs make NRC testing unnecessary.
NRC can achieve the same level of confidence in NPR requalification programs by conducting inspections and audits which would consume less NRC stafi resources. TRTR indicated that they will request that the Commissdon reconsider the necessity of these examinations.
1 5.
Concern was expressed by TKTR about uncertainties concerning future fitness for duty programs.
The staff thanked TRTR for their views and indicated that they would give careful consideration to the suggestions and concerns put forth by the community.
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Alexander Adams, J:., Pr ect Manager Standardization anj Not Power Reactor Project Di ctorate Division of Reactor Projects - III, IV, V and Special Projects
Enclosures:
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ENCLOSURE 1 MEETING BETWEEN TRTR AND THE NRC STAFF
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ENCLOSURE 2 i
THE ATOMIC ENERGY ACT OF 1954 CHAPTER 1. DECLARATION, FINDINGS, AND PURPOSE bection 3. Purpose.--it is the purpose of this Act to effectuate the policies set forth above by providing for --
- a. a program. of conducting, assisting, and fostering research and development in order to encourage i
maximum scientific and industrial. progress; CHAPTER 10. ATOMIC ENERGY LICENSES Section 103. Commercial Licenses.--
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- a. The Commission is authorized to issue licenses...
Such license shall be issued in accordance with the provisions of chapter 16 and subject to such conditions as the Commission may by rule or regulation establish to effectuate the purposes and provisions of this Act.
Section 104. Medical Therapy and Research and Development.--
- c. The Commission is authorized to issue licenses... The Commission is directed to impose only such minimum amount of regulation of the licensee as the Commission finds will permit the Commission to fulfill its obligations under this Act to promote the common defense and l
security and to protect the health and safety of the public I
l and will permit the conduct of widespread and diverse I
research and development.
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l University Research Reactors in the United States -
their ' Role and Value e
Prepared by the Committee on University Research Reactors Energy Engineering Board Commission on Engineering and Tecimical Systems NationalResearch Council NATIONAL ACADEMY PRESS Washington, DC 1988
1 EXECUTIVE SUMM.ARY THE NATURE OF THE PROBLEM Over the past two decades the number of nuclear To formulate such policies,the Committee addressed reactors used for research and education on the following questions:
university campuses has declined from about 76 to Whatnationalinteresta(scientific,echnical,
- 40. Moreover, while some universities continue to maintain and even upgrade their reactors, further medical and educational) are served by m-reductions are expected. The reasons for this melude g,
7 competition for limited university funds, poor external funding prospects, lack of growth in the What academic values derive from nuclear power industry, and, in some cases, university reactors?
prolonged hearings and litigation associated with licensing procedures. In effect a vicious circle has Is federal financial support necessary or developed in which red v,cd support leads to lower faculty and student interess, Much leads to under-desirable to arrest current trends and assure utilization, which leads to lower motivation for the retention of an adequate population of continued support and so on.
university research reactors?
It was a premise of this study that, given the What levels and types of federal support,if traming, research, manpower development and other any, should be provided?
needs in the nuclear field, this trend should not be Pclicies that will limit permitted to[o too far. encourage modernization of a What guidance can be offereil to universities closures an sustainabic subset of existing reactors, sufficient in and to the federal government pursuant to numbers and types to meet national and academic reasonable and prudent licensing of needs for re search, education and service am clearly university research reactors?
in the nationalinterest.
PRINCIPAL FINDINGS Deficiencies at U.S. university research reactors, Pursuant to the NationalInterest stemmmF tn part from inadequata financial support, heralresearch eguipment include inadequate perigd sources,andradiographic The natio.nalinterests served by university research suchasspectrometers,co reactus imItidc:
equipment. The effects of these deficiencies would be reduced by better access for university-based
- developmenterhightechnologyapplicationstnfields researchers to ma or national facilities which are such as matenals sciences, fluid dynamics, and ed ut opportunities for such access biomedical mesences, usmg reactars as sounes of better eguipfequ.
are nowina ate.
neutrons; The Committee is concerned that a failure to correct
- resean h contdbuting to the future of nuclear power these deficiencies, coupled with a continuation of reactors, including the scientific basis for new thp trend in reactor closures, will serve to widen an concepts, for safeguards, and safety; existmg gap of U.S. neutron science capabilities.
- education of personnel needed to operate, maintain TheCommittee.is also concerned thatfuture national and improve reactors and other facilities associated needs for nuclear engineers and scientists trained with national defense and nuclear power activities.
in the neutron sciences may notbe metif the current The Committee finds that the existing population of negative trends continue.
university research reactors, as a whole, does not However, selective reduction in the number of 1
adequately fulfill these national interests, particularly with respect to the use of neutrons in university research reactors will not of itself damage the development of high technology. Moreover,in the national interest, provided that a healthy core of several important research areas the U.S. is not on-campus and off. campus research and educational currently on a par with Europe and Japan.
reactor facilities is retained.
7 l
a Pursuant to AcademicValues The Committee finds that on-campus research faculty and students to commercial applications of reactors contribute to academic values through the nuclear sciences, and earn revenues to help research and education at the university, and support reactor programs (See Chapter 4).
through service to off-campus user constituencies:
The Committee finds that U.S. university research Research: University research reactors are the reactor facilities must be upgraded and provided focus of multi-disciplinary research with with modern equipment if they are to meet their contributions to physics, chemistry, biology, intended objectives and become world-class research medicine, epidemiology, environmental neiences, and educational facilities. Needs include modern material sciences, fluid mechanics, geology, instrumentation, low temperature irradiation archaeology, paleontology, forensic sciences, and facilities, cold neutron capabilities, modern other fields in addition to nuclear engineering spectrometers, radiographic equipment, increased research and reactor physics. The three principal power and neutron flur and other enhancements.
reactor research techniques are neutron activation analysis, neutron scattering, and neutron University administrators,in weighing the future radiography. The latter two are largely confined to of on-campus reactor programs take into account reactors of one megawatt and higher power.
the fonowing factors:
Research reactors in the United States constitute unique and essential research tools in several
- academic benefits in terms of researrh, education, aspects: structural determinations of materials and senice including superconductors and biological, ultrasensitive analysis for t. races of elements'
- costs of achieving theae benefits including the costs of radiological display of physical phenomena, and safety and safeguards as well as dealing with legal introduction ofradioisotopes for medical diagnostics d n8 and Pmtesta and research (See Chapter 2).
- 'h* "*"II"bilit7 "I'** "'*** f'"" I'd*'*I ""d *th" Education: On-campus reactors have been a a urms to defray these costs traditionalfocus ofeducationalprogramsfor nuclear engineers. In addition, on-campus reactors are
- c n1Pedd nfmmother n<*mPusresearchfacilities increasingly used as laboratories by students in the I 'II*I**d II"""'I"I ""d th* " ** "#**
non nuclear fields listed above. Educational uses are made of even the sinallest fractional watt on.
The academic benefits associated with university campus reactors. Beneficianes melude graduate research reactor programs are summarized above and undergraduate students, nuclear power plant and are discussed m detailin Chapters 2,3 and 4.
operators, secondary schools and the general public On site reactors clearly enhance the educational through outreach programs (See Chapter 3).
and research missions of a umversity. Properly equipped and managed on-campus reactors offer Scavice: University reactors,particularly those of unique advantages in terms of hands-on education one megawatt and larger, serve a range of off-and research experience in running small scale campus constituencies: the medical community, crperiments which would not be practical at larger industrial organizations, and government agencies.
off-campus reactors. However,it eannotbe concluded These clients use irradiated materials, materials that every on-campus research reactor is essential analysis, trace element detection and radiographic to these missions. This depends on the particulars analysis ofobjects and processes. By providing such of the educational program, and on the nature of services, managers of university research reactors access to off-campus research reactors.
establish beneficiallinks to off-campu s users, crpo se
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Pursuant to Procedums for Safety and Safeguards The Committee observes that the safety and safety and safeguards at university reactors can safeguard records ofon-campus reactors have been resultin costs out ofproportion to the improvement achieved. Aparticularconcernisthatrelicensink excellent. Nevertheless a growin concern for reactor safety as well as the potentia for sabotage procedures associated with reactor safety an and for theft of nuclear materials have led the safeguard upgrades can in some cases Nuclear Regulatory Commission to upgrade the unnecessarily expose the universities to costly requirements for the protection ofall reactors from hearings and litigation.
Committee is also the large 3500 MW(thermal) electric power facilities concerned that existing rules and procedures for down to the smallest university reactor. Committee the licensing of university research reactors have does not take issue with the Commission with at times lent themselves to abuse by intervenor respecito these concerns. However,the Committee group who use the opportunity to assert their finds that some of the procedures of the Nuclear larger political opposition to nuclear power and Regulatory Co mmis sion associated with impn.-ing defense activities (See Chapter 6).
PRINCIPAL RECOMMENDATIONS The federal government,in partnership with the
- study in detail the approaches of other advanced universities and the national laboratones, should countries to operating reseanh reactor networks such as that of hnking the major facility at Grenoble develop and implement a national research reactor with smaller mactor research centers in Europe (ese strategy, the elements of which should include:
Chapter 5)
- development of university and nationallaboratory
- establish and support such a network, adapted to centere of excellence in specitle areas of the neutrun US#'da sciences and reactor technology for world. class research as well as for education
- make up to $20 million available annually (as a pnhminay estimate to be modiSed as impmved e anticipation that as some university reactors are data become available) to universities through the upgraded and a user's networkis created (see below)'
designated fedeml agency, speciScany for operational
- th'" are likel to el***
support and facility upgrades of university reseanh Y
and educational reactors (see Chapter 7)
- mechanisms to assure that such closures do not go so far as to damage the national interest related to review mechanism to assist the
- create a hncyin makinggrants touniversities, research and educational capabilities in the nuclear designate sciences and engmeenng The Nuclear Regulatory Commission,should rt of a reactor network to examine its current approach to the beensmg and a development and subration and productivity [ of reglation of university research reactors in term s bmvide enhanced uE. reseanh reactors involving researchers mm of e foHowing issues.
universities with and without on<ampus reactors, and from the nationallaboratories.
- the small nuclear materials inventories and low reseanbreactors,which power densities ofuniversitkto safety and safeguards To m.mplement the above strategy:
resultinriskfactorarelate considerably lower than commercial power reactors e a single federal agency should be designated to (see Chapter 6) administer programs in support of the national research reactor programs a avoiding unnecessary exposure of small university
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reactor operators to costly hearing and litigation
- the federal government should create a standing proceduns as a condition for licensing upgrades and advisory etructure to advise on a continuingbasis on impmvements.
all aspects of this program.
Finally,the Nuclear Regulatory Commission should In pursuit of this strategy the Federal government consider grants of toch mcal and financial assistance should:
to help university reacter operators to comply with upgraded safet and safe ard requirements,
- adopt the goals of meeting U.S. research reactor including and continuing yond tae current needs, and regaining a position competitive with program of assisting with the conversion to low-Europe and Japan in the neutron-based sciences ennched fuels.
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