ML101310203

University of Massachusetts at Lowell - Request for Additional Information Regarding the Application for Special Nuclear Material Possession Limit Increase

ML101310203
Person / Time
Site:	University of Lowell
Issue date:	05/07/2010
From:	Kegel G Univ of Massachusetts - Lowell
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD8109
Download: ML101310203 (4)

Text

Pinanski Building Gunter H.R.Kegel, Ph.D.

One University Avenue Co-Director,Radiation Laboratory Lowell, Massachusetts 01854 tel: 978.934.3280 University of fax. 978.459.6561 A IJ Massachusetts e-mail: GunterKegel@uml.edu UMASS Lowell RADIATION LABORATORY May 7, 2010 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: UNIVERSITY OF MASSACHUSETTS AT LOWELL REQUEST FOR ADDITIONAL INFORMATION REGARDING THE APPLICATION FOR SPECIAL NUCLEAR MATERIAL POSSESSION LIMIT INCREASE (TAC NO. MD8109)

FACILITY OPERATING LICENSE R-125, DOCKET NO. 50-223 In response to your letter dated May 4, 2010, The University of Massachusetts Lowell hereby submits the following additional information.

Item 1:

In a letter and report to the NRC dated April 9, 2001, the University of Massachusetts Lowell Research Reactor (UMLRR) detailed the successful conversion of the UMLRR from HEU to LEU fuel, completed on August 4, 2000. Despite the error in wording in the current license amendment issued by NRC on July 31, 1997, the UMLRR is fueled with Low Enriched Uranium as defined in 10 CFR Part 50.2.

We propose the following wording for license condition 2.B.(2):

Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material," to receive, possess, and use at any one time up to 6.0 kilograms of contained uranium-235 at enrichment less than 20 percent in the form of material test reactor (MTR) type reactor fuel.

Item 2:

We have completed a review of the UMLRR license technical specifications. Only TS 5.1.1 references a specified percentage in conjunction with the term LEU. In order to be consistent with license condition 2.B.(2) and 10 CFR Part 50.2, we propose adding the symbol for less than (i.e., <) prior to the stated percentage. The proposed modified page (TS-40) is enclosed with this letter.

Ao;c)

Item 3:

An error in wording in the current license amendment issued by NRC on July 31, 1997 provides a license condition 2.B.(2) for special nuclear material authorizing Am-Be and Sb-Be neutron sources. We propose the following wording for license condition 2.B.(3) to possess these sources under 10 CFR Part 30:

Pursuant to the Act and 10 CFR 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operations of the reactor, and to receive, possess, and use up to 5 Ci Am-Be and 10 Ci Sb-Be neutron sources in connection with operation of the reactor, and to receive, possess, use and transfer byproduct materials activated in other reactors other than the University of Massachusetts Lowell reactor, in the form of Cobalt-60, in quantities not to exceed 1,500,000 curies at any time.

The proposed change in Item 1 removes these sources from license condition 2.B.(2).

Item 4:

All irradiated HEU fuel was shipped from the UMLRR on August 17, 2004 and all un-irradiated HEU fuel was shipped from the UMLRR on December 13, 2004. License condition 2.B.(4) can be removed from the license.

Item 5:

We propose the following wording for a license condition to allow receipt and possession but not use of the Worcester Polytechnic Institute (WPI) LEU fuel:

Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material," to receive and possess, but not use, up to 5.0 kilograms of contained uranium-235 enriched to less than 20 percent in the form of Worcester Polytechnic Institute MTR-type reactor fuel.

Item 6:

The WPI LEU MTR-type fuel consists of 21 irradiated full-fuel elements, one (1) irradiated removable-plate fuel element containing 6 plates, four (4) unirradiated full-fuel elements, one (1) unirradiated removable-plate fuel element, and 12 unirradiated fuel plates (for use in a removable-plate fuel element). The total number of WPI LEU fuel elements is 27. Each of the WPI LEU fuel elements is designed to have less than 170g U-235 per element. The total U-235 content for the WPI LEU fuel is 5 kg when rounded up to the nearest kilogram. The requested combined U-235 possession limit for the UMLRR 11 kg.

The UMLRR MTR-type fuel consists of 27 full-fuel elements and two'(2) partial-fuel elements for a total of 29 fuel elements. The UMLRR possesses and maintains nine (9) underwater fuel storage racks having nine (9) positions in each rack to accept fuel. A detailed description of the fuel storage racks may be found in the UMLRR Final Safety Analysis Report (1984) section 6.1 and as evaluated in section 9.1 of NUREG-1 139 (SER Related to the Renewal of the Operating License for the Training and Research Reactor at the University of Lowell - November 1985) and as evaluated in section 2.4 of the safety evaluation for facility 2

license R-125, amendment 12. Currently, eight (8) of the racks are unused, providing 72 available positions to store fuel. The combined number of WPI and UMLRR fuel elements is 56.

Therefore, all the WPI LEU fuel elements and all UMLRR LEU fuel elements can be safely and completely stored in the UMLRR fuel racks, with 16 rack positions remaining available.

Please feel free to direct questions or concerns regarding this additional information to:

Mr. Leo Bobek, Reactor Supervisor Radiation Laboratory University of Massachusetts Lowell One University Avenue Lowell, MA 01854 I declare under penalty of perjury that the foregoing is true and correct.

Sincerely, Gunter H. R. Kegel Director, Radiation Laboratory Cc: Mr. Al Adams NRR/ADRO USNRC Enclosure 3

TECHNICAL SPECIFICATIONS 5.0 DESIGN FEATURES 5.1 REACTOR FUEL The reactor fuel shall be as follows:

1. Standard fuel element: the fuel elements shall be flat plate MTR-type elements. The plates shall be fueled with low enrichment (<20% U-235)

U 3 Si 2 , clad with aluminum. There shall be 18 plates per element with 16 containing fuel and two outside plates of aluminum. There shall be 200 +

5.6 grams of Uranium-235 per element.

2. Half-element: same as a standard fuel element except each plate has one half the uranium loading.

3. Variable-load element: same as Specification 1 above, but internal plates are removable.

5.2 REACTOR CORE

1. The reactor core consists of a 9 x 7 array of 3-inch square modules with the four comers occupied by posts. The reference core for these Technical Specifications consists of 20 standard fuel elements in a 5 X 5 array with comers removed and the central location filled with a graphite-water aluminum clad flux trap element, as shown in Figure 2.6 of the FSAR Supplement for Conversion to LEU Fuel.

2. Cores from 16 standard elements to 28 elements may be used, and cores from 16 elements to 28 elements may contain 2 half-loaded elements.

TS-40