ML19275A128

Ack Receipt of 790730 Ltr Re Impact of Safeguards Upgrade Rule.Provides Info Re Costs for Shutdown,Hardware & Security Upgrade,Annual Maint Costs,Effect of Loss on Us Industry, Medical Research & Treatment & Educational Program

ML19275A128
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	08/20/1979
From:	Lisa Clark MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
To:	John Miller Office of Nuclear Reactor Regulation
References
NUDOCS 7908310402
Download: ML19275A128 (9)

Text

_ _ . _

f ), .,m y N 3

. . .. _ac).

g* >.

NUCLEAR REACTOR LABORATORY i g', ,1

, z ---:

MASSACHUSETTS INSTITUTE CF TECHNOLCGY m .w '

. - A p . < a. r, t 38 A bany Stree' Cartrdge *. tass C213) e im M

. - ,61n 253. 4202 cm , . a.x ~ c:.ws August 20, 1979 powcr 50-23 Mr. James R. Miller, Acting Assistant Director for Site and Safeguards U. S. Nuclear Regulatory Commission Division of Operating Reactors Washington, D. C. 20555

Subject:

Impact of Safeguards Upgrade Rule

Dear Mr. Miller:

Massachusetts Institute of Technology furnishes in the attachment to this letter the information requested by your letter of July 30, 1979 with regard to the impact of the Safeguards Upgrade Rule.

Please note that MIT is subject to 10CFR 73.40 but exempt from paragraphs 73.50, 73.55, 73.60 and 73.70 by virtue of the exemption in paragraph 73.6 (b). It appears that the exemntion is not changed by the Safeguards Upgrade Rule. Even though Facility License R-37 for the MIT Reactor authorizes possession of uranium -235 in excess of formula quantities, it has been MIT's practice and remains MIT's intention to maintain its inventory of non-exempt SNM at less than a formula quantity.

It is our understanding, based on another NRC letter of July 30, 1979, from Robert W. Reid, Chief, Branch #4, Division of Operating Reactors, that MIT License #R-37 and incorporated Technical Specifications are to be amended to clarify that SNM not exempted by the self-protection criterion must remain at less than a formula quantity. This MIT is prepared to do.

In view of the above situation, it is not at all clear why MIT has been requested to furnish information with respect to the impact of a regulation that will not apply to the Institute. Nevertheless, M08 310g 2035 331

Mr. James R. Miller August 20, 1979 Impact of Safeguards Upgrade Rule as the result of discussion with your staff, MIT is providing the requested information.

Due to the short time available in which to reply and due to

- other demands on the MITR staff, it should be understood that the cost data provided are only very rough and approximate estimates.

Sincerely, b

LC/pk Lincoln Clark, Jr.

Enc.

cc: 0. Harling T. Jones N. Rasmussen 2035 532

Information Requested by NRC on Impact of Safeguards Upgrade Rule

1. What additional features will be constructed walls, vaults, CAS, protected area and costs associated with these.

2. What 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?

During the short time available in which to develop the requested information, it is impossible to provide a meaningful total estimate of cost, much less the breakdown requested for the above three areas.

It is noted that the NRC Staff has prepared an estimate that is contained on page 8 of " Report Justification - Physical Protection of Plants and Materials", Enclosure C to SECY-79-187, dated March 16, 1979, to the Commissioners. The Staff has estimated

$780,000 as the average additional capital cost per facility, which represents an increase over present expenditures of 197%. Present plus additional capital costs would then be $1,176,000. For annual costs, the Staff estimate is $588,000 per facility, an increase of 87% over present costs, giving a total of $1,264,000 per year.

A study of the Safeguards Upgrade Rule indicates that MIT's ex-isting capital facilities, hardware and program that would contribute to meeting the requirements of the Rule represent only a very small fraction of the totel requirements. Hence, the additional costs for MIT can be expected to approximate the total costs given above, assuming that the Staff's estimates are accurate and applicable to MIT. We have no basis for believing otherwise. Even if the estimates are wrong by a factor of two or three or more (and assuming that MIT were to be subject to the Upgrade Rule), the implications for MIT uld be no different than those indicated below in some of the following questions.

4. What is the cost of shutting down the facility?

a) Shutting down the facility (shipping all fuel, disassembling and shipping all radioactive materials, dismantling the containment and making the site available for other use) is estimated very roughly to cost in the vicinity of $1,500,000, b) Mothballing the site (shipping all fuel, sealing radioactive systems, providing for surveillance, relicensing) might cost in the vicinity of $500,000.

2U35 333

Mr. James R. Miller, Acting August 20, 1979 Assistant Director for Site and Safeguards Impact of Safeguards Upgrade Rule

5. What is the annual cost of maintaining possession only status' It is assumed that possession only status would entail radiation protection, surveillance, inspections, insurance, heating and venti-lation, security, etc.. The cost is estimated at $50,000 per year.

It is believed, however, that mothballing the facility would serve no useful purpose. The interruption of programs, loss of personnel, and loss of contract research would constitute such a negative impact that MIT, in all likelihood, would decide to shut the facility down permanently.

6. Effect of loss of program on US industry - (i.e.) engineers and operators for U.S. Nuclear Power Plants.

The MIT Reactor does not presently conduct any operator train-ing courses. It does provide financial support to future nuclear engineers who serve as operatoro and supervisors on either a part-time or full-time basis. Presently three are licensed, and three more are in training. Others gain valuable experience doing research on the reactor and some serving a s teaching assistants for courses using the reactor. One or two grtduates per year, who have had significant experience on the MIT Reactor, go on to power plants, other utility positions, architect-engineering firms, or the Nuclear Regulatory Commission.

7. Effect of loss on medical research, medical treatment.

Medical research utilizing the MITR is conducted in the following areas: very short-lived radioisotope generator, cancer therapy by boron neutron capture 3 radiation synovectomy with dysprosium, neutron activation analy sis studies for: trace element bioavailability kidney mineralization lung clearance of trace elements source recognition for combustion Medical therapy is performed at six Boston-area hospitals by use of gold seeds activated at the MITR for cancer implants. Pre-sumably these could be obtained from another source. The MITR medical room beneath the reactor, however, is a unique facility that has potential for providing the boron neutron capture therapy needed by brain cancer (glioblastoma multiforme) victims. Research continues in this area, spurred on by successes with this method reported from Japan.

8. Cost of new plans - security, contingency, guard training.

The costs would be included in the figures given under Questions #1-3.

035 534

August 20, 1979 Mr. James R. Miller, Acting Assistant Director for Site and Safeguards Impact of Safeguards Upgrade Rule

9. Considering the impact of implementing the Safeguards Upgrade Rule will you continue to operate your facility?

An authoritative answer to this question can be given only by the MIT Administration. Since the Upgrade Rule will not apply to MIT, which makes the question a hypothetical one, it is not appro-priate to request that top officials spend their time reviewing the subject. However, given the apparent costs, my recommendation to the Administration would be to shut down the reactor permanently.

I believe that they would then study the situation and undoubtedly come to the same conclusion.

10. Describe the impact of closing the facility on the educational pro-gram at your facility (school) - Loss of program and courses.

The impact may be summarized as follows (based on data from Rgport of Educational and Research Activities, MIT Nuclear Reactor Labo rato ry, Report No. MITNRL-001, December 1978):

a) Research programs:

Annual utilization by students 56 Annual utilization by faculty and staff 39 MIT departments and laboratories 15 Annual theses, papers and reports 59 (over 1000 in 20 years)

Research activities, current and recent include the following topics:

Neutron Activation' Analysis in Areas of Nutrition and Health, Chemical Engineering and Coal Research, Marine Sciences, Environmental Disciplines, Materials Sciences, Coastal Engineering, and Other Physical Sciences Radiation Effects in Stainless Steel Irradiation of Reactor Pressure Vessel Steels Particle Track Etch Method for Pu Assay In-Core Fatigue Testing of Fusion Reactor Materials Computer Control of Reactor Operation Advanced Alloys for Fusion Reactors 2033 335

Mr. James R. Miller, Acting August 20, 1979 Assistant Director for Site and Safeguards Impact of Safeguards Upgrade Rule Radioactive Corrosion Products in L W s Experimental Fast Reactor Physics Fast Reactor Analysis iteutron Spectrometry and Molecular Dynamics in Solids and Fluids Calcium Metabolism by. Thermal Neutron Activation Analysis Cancer Therapy by Boron Neutron Capture Very Short-Lived Radioisotope Generator Radiation Synovectomy with Dysprosium 4 Design Studies for the MIT Reactor Modification Study of the Cu-Fe Kondo Alloy Polarized Neutron Techniques for the Observation of Ferromagnetic Domains Electron Distribution in Hydrocarbons Pendellosung Fringe Studies with Perfect Crystals of Germanium Installation of Superconduct.21g Magnet for Producing High Magnetic Fields Diamagnetic Scattering of Net.trons by Bismuth Search for deHaas-vanAlphen Neutron scattering by Copper Polarized Neutron Scattering by Nuclearly-Polarized LiF Phase Transformation and Superconductivity of ZrV 3

2033 336

August 20, 1979 Mr. James R. Miller, Acting Assistant Director for Site and Safeguards Impact of Safeguards Upgrade Rule Dynamical Diffraction Experiments with Perfect Copper Crystals Neutron Flight-Time Transm.ssion Measurements on Pyrolytic Graphite Ferromagnetic Domain Topography in Co-Fe Alloy Pendellosung Fringe Structure in Silicon Neutron Interferometry Experiments Atomic Ordering in Amorphous and Liquid Materials Petrologic and Trace Element Study of Basalts Cored in the Deep Sea Drilling Program Petrological and Geochemical Studies of Atlantic Ocean Floor Dredged Basalts and Gabbros Origin of Basalts Petrology and Geochemistry of Ultramafic Rocks Origin of Andesites Geochemical and Petrological Study of the Bay of Islands Ophiolite, Newfoundland Field, Petrological and Geochemical Studies of a Felsic Volcanic-Plutonic Complex (Mt. Katahdin - Traveler Mtn) in Maine Field, Petrological and Geochemical Studies of Three Plutons in Huntington Quadrangle, Sierra Nevada, California Geochemistry of Europium Experimental Laboratory Studies of Trace Element Distribution Between Coexisting Phases 2035 337

Mr. James R. Miller, Acting August 20, 1979 Assistant Director for Site and Safeguards Imnact of Safeguards Upgrade Rule b) Educational use:

. Courses using reactor 9 Enrollment 119 Course titles:

Introductory Nuclear Measurements Laboratory Nuclear Measurements Laboratory Nuclear Reactor Operations and Safety Biological and Medical Applications of Radiation anc Radioisotopes-I Biological and Medical Applications of Radiation and Radioisotopes-II Principles of Nuclear Medicine Analysis of Geological Materials Undergraduate Seminar in Nuclear Engineering Independent Activities Period (mini-courses)

11. What is the size of the facility staff? - Will it be cut?

A total of 29 individuals are required for reactor operation, maintenance, health physics and administration. These jobs would all be eliminated. Another 10 individuals are sufficiently involved in research utilization so that loss of the facility would mean loss of those jobs. Other users enumerated above are not on the facility staff and would not be cut.

12. How many students are in the classes? - Will they finish their degrees?

Enrollment was given in Question #10. Loss of reactor utilization in those courses would not prevent attainment of their degrees.

13. How many graduate students are in facility - related programs? -

Will they be able to finish?

The 56 students listed in Question #10 are mostly graduate students. They would probably finish, but in many cases would find it necessary to re-orient their thesis research.

14. What is the typical annual operating budget?

The operating budget is $600,000/ year, not including health physics and building maintenance, which are budgeted in other divisioa but amount to another $150,000/ year, approximately. The total budget for research projects which are dependent on the MITR for their programs amount to $1,700,00Csyear.

b Ib

. 5 ,

Mr. James R. Miller, Acting August 20, 1979 Assistant Director for Site and Safeguards Impact of Safeguards Upgrade Rule

15. With 100 r/hr at 3 feet excmption criteria, can you meet and maintain the SNM at such a level continuously? What would the impact be on current finsacial and operating resources? How would it maintain the self-protection criteria affect fuel replacement and costs therefore?

It is estimated that fuel operated at 5 MW for 2-3 years at about 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per week should meet the self-protection criterion continuously until shipped for reprocessing. The impact on financial and operating resources and on fuel replacement and costs should be minimal.

16. How many courses utilize the facility - will they be cut?

The courses listed in Question #10 would continue, but would suffer from the loss of segments that depend on use of the MITR.

17. Other information:

a) Fuel is now being fabricated for the MITR by Atomics International under contract to the Department of Energy at a cost reportedly in the range of $500,000- 700,000.

b) The MIT Reactor is utilized by a number of non-MIT organizations and individuals:

Average Annual Other educational and research institutions 12 Hospitals 6 Industry 8 School group tours 30 Total visitors 1500

) jj9

_ _ _