ML20195B709

Discusses Results of Review of Reactor Fuel Status Re self-protection Criterion of 10CFR73.5,b.Lock Procurement to Implement Stage 1 Implemented Immediately

ML20195B709
Person / Time
Site:	05000142
Issue date:	08/17/1978
From:	Catton I CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:	Case E, Sinisgalli Office of Nuclear Reactor Regulation
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References
FOIA-85-196 NUDOCS 8806210489
Download: ML20195B709 (2)

Text

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L UhlVERSITY OF CALIFOR.oA, LOS ANGELES scumuy . avu . mer . Los ocrus . menser se mzco su runcuco[  ! sam unam.54m cm

$d SCHOOL OF ENCLNEERING AND APPUED SCIENCE cos actus. cAuronm ,om r c. -

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'. h August 17, 1978 Mr. Edson G. Case (Attn: Mr. Sinisgalli) ~

Office of Nuclear Reactor Regulation . '

U.S. Nuclear Regulatbry Comission Washington, D.C. 20555 Docket 50-142

Dear Mr. Case:

Due to the sensitive nature of the contents of this letter, we

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reauest that this occument be withhelf from public disclosure pursuant to Section 2.790 of 10CFR Part 2.

We have reviewed the status of our reactor fuel in regard to the self-protection criterion of Part 73.6,b (100 rems /hr. at 3 feet).

That criterion does not specify an elemental quantity .(fuel plate, bundle, or entire core loading),'nor do the words "readily separable" and "accessible surface"' convey a very clear picture of the intent of the self-protecting provision.

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If a fuel bundle'of'll plates.is regarded as the elemental quantity, our calculations indicat6)that the radiation field around an equivalent isolated point source would. fall to less than 100 rems /hr. (at 3 feet) within a day after reinovd from the re' actor. l

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Considering the p.hysical difficulties of removing a fuel bundle, and the radiation field attendant to that operation, it isn't clear to me that a single bundle is "readtly lseparjble". from..the remainder of the core loading. If the "accessable. area".fs inteYpreted as the top of the core after renoval of two strield. bioi*s'.',f o approximately 10 tons eacn, then the remaining surrounding shiddaa'nd;structu.re are radiation sources contribut'ing to the 100 rems /hr. at 3' f t'.hcH terfon. ~

Core entries of the UCLA' Argonaut reactor are infreouent, our last entry was in the fall of 1974 A nortnal core entry is made af ter suspending reactor operations for a period of three weeks. A minimum of 5 shield blocks are removed to reduce local radiation levels, provide work space, and to simplify normal or emergency egress from the high radiation area of the fuel box region. To control personnel exposures, no personnel are permitted in the vicinity of an ocen fuel box unless the transfer cask is mounted over the fuel box.

8806210489 880603 PDR FOIA

a. x E. ERGY L ORATuRY  ; VAN CATTON, Director

e' Case, Edson, G. August 17, 1978 I mention these facts to show that radiation measurements made during our prudent and conservative maintenance procedures are hardly indicative of the radiation exposures that would attend a well-planned but rapid clandestine entry. The only other possibly relevant measurements consist of lowering a dosimeter into a vertical sample port. I am told that

, the lowest level ever observed was 1500 R/hr. The geometry is complex and it is difficult to relate these observations to unshielded exposures at 3 feet.

As you will perceive, we are uncertain about the interpretation of Part 73.6, b and also uncertain about the radiction level attendant to an imprudent core entry. These uncertainties pertain only to the fuel loading within the core and not to the fuel in hot storage. The latter material, consisting of 5 fuel bundles, if regarded either individually or as an entity are unlikely candidates for exemption by self protection.

We are proceeding with plans to remove this material from our site.

We propose the following two stage program for the further protection of our fuel,

l. The hot storage pits are declared to be a material access area, I covered by a single slab of concrete movable only with the i bridge crane. This area is located in the reactor room, a l protected area, as are the crane control circuits. Control of I the crane will be effected by implementing a multiple lock system with no individual possessing all of the hardware or '

knowledge to activate and operate the crane.

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2. The fuel within the reactor is tentatively regarded as se' f-protecting by virtue of the complexity of removing any or all of that fuel, and the substantial probability that individuals participating in a clandestine coeration would be exposed to radiation in excess of the self-protecting criterion.

We have initiated the lock procurement to implement stage 1 innediately. ,

If effect, the procedure will deny individual use of the crane for any purpose what-so-ever, and the in-situ re.tctor fuel will be so protected.

However, we do leave open the possibility that the in-situ reactor fuel is self-protecting, and that restraints upon usage of the crane may be re- ,

laxable when the other hot fuel is removed from our site. We will continue to review this situation, and will welcome any assistance you can provide in interpreting 73.6, b in the context of our rituation.

Sinarely, I. Catton, Director Nuclear Energy Laboratory IC/NCO/af Oc: C.E. Ashbaugh, NEL Security Officer

a l'NIVEllSITY OF CALIFORNIA. LOS ANGELES 4

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• b g N S KgNCisCO ff g g % f g n g hu g h g a sg si g a et t SCHOOL OF ENCINEEPING AND APPLIED SLIENCE LOS ANGELEJ, C ALIFORNI A 90024 Boelter Hall 2567 September 6, 1978 Mr. Larry Akers, Chief Campus Programs Branch ,

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Department of Energy p/ gi +4 /7 '/

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400 First Street, N.W.

Room 307 Washington, D.C. 90545

Dear Mr. Akers:

Due to the implementation of the proposed amendments to 10CFR73 by the beginning of 1979, we hereby request permission to ship five irradiated fuel bundles (containing three dunmy fuel plates) and three irradiated fuel plates to the Idaho Chemical Reprocessing Plant.

The amount of fissile material to be shipped will be approximately 785 grams of 93% enriched uranium. The shipping date is expected to be toward the middle of December,1978.

We hereby wish to notify you that a request for funds from DOE to accomplish this task pursuant to the AEC Reactor Fuel Cycle Assis- I tance Contract No. AT(04-3)-34 project agreement #192, section A-II (b)(2)(iii) will be made after the fuel transfer.

A cost estimate to date is as follows:

G.E. Model 700 Shipping Container:

Preparation Charge *

$925.00 Lease rate 0 $185 per day for 3 days 555.00 Tri-State Motor Transit Company:

G.E. to UCLA 319.06 i UCLA to Idaho 1176.35 Idaho to G.E. 675.06 Dual, Drivers @ .15 mile for 2126 miles 318.90 Total $3969.37 Possible extra charges could be added to the above total if delays occur during loading or unloading of the container. The charges would accum-ulate at the rate of $17.50 per hour for the truck and drivers, $?70.00 per day if the container is returned after the expiration date of the contracted period, and some unknown amount for special rigging if some problems develop during the fuel transfer at UCLA.

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- September 6, 1978-Page Two r

i We hope .that these requests ' meet with your approval and we will keep you informed on the status of the operation.

Sincerely,

.'. .. - - t. s. - .'

Ivan Catton, Director Nuclear Energy Laboratory CEA/NC0/IC/li  !

cc: David G. McIntosh D.0.E., San Francisco Operations Office G

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/  %, UNITED STATES e" 74 NUCLEAR REGULATORY COMMISslON f 1 ,

W ASHING TON, D. C. 20555 September 22, 1978 k..v... f Docket ho.: '50-142 University of California at Los Angeles ATTN: Mr. Harold B. Brown Environmental Health and Safety Officer Los Angeles, California 90024 Gentl emen:

By letter dated Parch 10, 1978, you requested amendment to the security plan for the University of California at Los Angeles (UCLA) research reactor. As a result of our review and subsequent discussions between our rescective staffs, you proposed certain facility modifications relative to the reactor controls which should be reflected in the facility security plan. These modifications were described in the letter from Dr. Catton to Mr. Case dated July 3,1978. This letter, i however, did not indicate whether the proposed modifications had been reviened and found acceptable by the Radiation Use Committee.

Therefore, if you have not already done so, you should refer the pro-posed modifications to the Radiation Use Comittee to determine if an arent :ent of the facility license or technical specifications is re-quired or if the modifications constitute an unreviewed safety question pursuant to 10 CFR 50.59. If the determination is affirmative, details of the proposed modifications should be suomitted for our review and approval prior to implementation. If the determination is negative, prior NRC approval is not required. In this case, you are requested to ,

submit by December 1, 1978, an amended security plan incorporating the modifications described in Dr. Catton's letter. You should also indicate in your submittal your comitment to implement the proposed modifications and the amended security plan by March 31, 1979.

Sincerely, h/

Robert W. Reid, Chief JY Operating Reactors Branch #4 Division of Operating Reactors cc: See next page.

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University of California at Los Angeles cc

Attorney General 555 Capitol Mall Sacramento, California 95814 Energy Resources Conservation and i Development Comnission ATTri: Librarian lill Howe Avenue Sacramento, California 95825 Director Energy Facilities Siting Division -

Energy Resources Conservation &

Development Commission ,

1111 Howe Avenue l Sacraner.:c, California 95325 California :erart ent of Health ATTi: Chiaf, Environnental l Radia:icn Control Unit l Radiologic Health Section 714 P Strqet, Rocn 493 Sacrarento, California 95814 l

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IlNIVERSITY OF CALIFORNIA, LOS ANGELES ,

1. 1 f k, I sonruv . mis tmst Los ascetts nivraser uN meco six ru3C:sCo  ? ) sava siu m .u m w SCHOOL OF ENCINEEPINC 4ND APPLIED SCIENCE Los ANCELt.5. CAL!roPNIA 90o: 4 Boelter Hall 2367 November 30, 1978 Mr. Harold R. Denton Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

Docket 50-142

\

Due to the sensitive nature of the contents of this letter, we request  ;

that this docu ent be withheld from public disclosure pursuant to Section l 2.790 of 10CFR Part 2.  !

Due to recene events, the text and Appendix of The Security Plan dated January 20, 1977 must be updated by A=endment #4 Two copies of each page are submitted. Please replace pages 1, 2, 3, 5, 9, and 11 of text and pages l 6, 7, and 9 of the Appendix.

On October.3, 1978, the Radiation Use Co=mittee met and reviewed the proposed modification of the rod drives (see I.C.l.c) in the context of I 10CFR50.59. P.aving reviewed this question, it was decided that a lock-out relay en the up-drive circuitry would not affect the drive-down circuitry 1 and hence would not influence reactor safety. I=plementation of the =odifi-cation will occur prior to March 31, 1979.

' 1 Planning continues for the shipment of 0.7 kg of irradiated fuel asse:- I blies to the Idaho Chemical Reprocessing Plant. The working of the proposed )

a=end:ent assu=es this to be an accomplished fact. The shipment should be effected in January or February, 1979, and the effective date of the proposed amend =ent should not predate the actual shipment. We will notify you of the shipping date when that date is fixed.

We hope that this amendment meets with , r al.

1 SincepC y

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. Ivan Catton, Director ,

Nuclear Energy 1.aboratory '

l IC/CE.A/NCO/li l

Enclosures:

Two copies of pages 1, 2, 3, 5, 9, 11 of text Two copies of pages 6, 7, 9 of Appendix n_m ir s , m, eny+ e e ^'

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