ML102080021

Armed Forces Radiobiology Research Institute-- Request for Additional Information License Amendment, Separation of Byproduct Material

ML102080021
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	08/04/2010
From:	Alexander Adams Research and Test Reactors Licensing Branch
To:	Miller S US Dept of Defense, Armed Forces Radiobiology Research Institute
ADAMS A, NRC/NRR/ADRA/DPR/PRTA 415-1127
References
TAC ME4117
Download: ML102080021 (5)

Text

August 4, 2010 Mr. Stephen I. Miller, Reactor Facility Director Armed Forces Radiobiology Research Institute 8901 Wisconsin Avenue Bethesda, MD 20889-5603

SUBJECT:

ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE C REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT, SEPARATION OF BYPRODUCT MATERIAL (TAC NO. ME4117)

Dear Mr. Miller:

We are continuing our review of your amendment request for Facility Operating License No. R-84 for the Armed Forces Radiobiology Research Institute Reactor Facility which you submitted on June 16, 2010. During our review of your amendment request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 20 days of the date of this letter. In accordance with Title 10 of the Code of Federal Regulations (CFR) Section 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your renewal request.

If you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely,

/RA/

Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-170

Enclosure:

As stated cc w/encl:

See next page

Armed Forces Radiobiology Research Docket No. 50-170 cc:

Director, Maryland Office of Planning 301 West Preston Street Baltimore, MD 21201 Montgomery County Executive 101 Monroe Street, 2nd Floor Rockville, MD 20850 Mr. Stephen I. Miller Reactor Facility Director Armed Force Radiobiology Research Institute 8901 Wisconsin Avenue Bethesda, MD 20889-5603 Environmental Program Manager III Radiological Health Program Air & Radiation Management Adm.

Maryland Dept of the Environment 1800 Washington Blvd.,Suite 750 Baltimore, MD 21230-1724 Rich McLean, Manager Nuclear Programs Maryland Department of Natural Resources Tawes B-3 Annapolis, MD 21401 Director Air & Radiation Management Adm.

Maryland Dept of the Environment 1800 Washington Blvd., Suite 710 Baltimore, MD 21230 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

August 4, 2010 Mr. Stephen I. Miller, Reactor Facility Director Armed Forces Radiobiology Research Institute 8901 Wisconsin Avenue Bethesda, MD 20889-5603

SUBJECT:

ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE C REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT, SEPARATION OF BYPRODUCT MATERIAL (TAC NO. ME4117)

Dear Mr. Miller:

We are continuing our review of your amendment request for Facility Operating License No. R-84 for the Armed Forces Radiobiology Research Institute Reactor Facility which you submitted on June 16, 2010. During our review of your amendment request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 20 days of the date of this letter. In accordance with Title 10 of the Code of Federal Regulations (CFR) Section 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your renewal request.

If you have any questions regarding this review, please contact me at (301) 415-1127.

Sincerely,

/RA/

Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-170

Enclosure:

As stated cc w/encl:

See next page DISTRIBUTION:

Public RidsNrrDpr RidsNrrDprPrta AAdams RTR r/f RidsNrrDprPrtb GLappert ADAMS Accession No: ML102080021 NRR-088 OFFICE PRLB:PM PRLB:LA PRLB:BC PRLB:PM NAME AAdams aa GLappert gkl JQuichocho jq AAdams aa DATE 8/2/10 7/29/10 8/3/10 8/4/10 Official Record Copy

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR THE ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE LICENSE NO. R-84; DOCKET NO. 50-170

1. Your license condition 2.B.(3) is an old version of the license condition that does not specifically allow for use of byproduct material produced by operation of the reactor.

Please propose wording to clarify that use of byproduct material produced by operation of the reactor is authorized.

2. Your proposed license condition 2.B.(4) and changes to license condition 2.B.(3) would allow separation on a laboratory scale. The first exception in the third part of the definition of production facility states laboratory scale facilities designed or used for experimental or analytical purposes. Your proposed license condition does not restrict use to experimental or analytical purposes but states that the separations are needed for the development of a system for the production of molybdenum-99 from low-enriched uranium. Discuss why the research you plan to conduct is for experimental or analytical purposes. Please clarify your proposed license condition as to design or use for experimental or analytical purposes. Please discuss what is considered laboratory scale and why your proposed research is laboratory scale.

3. Your proposed license condition 2.B.(4) states that such separation will take place at the Armed Forces Radiobiology Research Institute (AFRRI) facility in Bethesda, MD, will not be in batch mode, and will involve no more than 100 grams of uranium enriched in the isotope uranium-235 per experiment.

Please verify that the separations proposed in your application will be conducted under the authority of the reactor license and that the Radiation Chemistry Laboratory is within the area of the AFFRI complex under the authority of the reactor license. If the Radiation Chemistry Laboratory is under the reactor license, explain why the proposed license condition states that separations will take place at the AFFRI facility or remove this statement from the proposed license condition. A more specific license condition that reflects your application is that separations will take place in the Radiation Chemistry Laboratory of the AFFRI facility.

It appears that you are proposing to meet the first exception of part 3 of the definition of production facility. Given that, why does your proposed license condition also refer to parts of the third exception of part 3 of the definition of production facility? Please justify this wording or remove it from your proposed license condition.

4. Technical Specification (TS) 3.6 b. controls the conduct of fueled experiments to limit doses if an experiment fails. You are proposing no changes to the TS as part of your

request to perform separation of byproduct material in fueled experiments. Your application states that the consequences of an accidental release are not increased as a result of your application to conduct separation experiments. While the inventories of radioactive material will not change as a result of your amendment request, it is not clear if the doses from accidental release of the inventory will remain the same. Please discuss the assumptions for the dose calculations (staff and public) and the results of the calculations that are the bases for TS 3.6 b. How do these assumptions and results compare to accidents during separation activities? For example, releases that form the bases for TS 3.6 b. and releases from separation activities may have different initiating points (reactor pool vs. laboratory hood), ventilation paths, release points to the environment, etc.

5. The purpose of TS 3.6 b. is to help ensure that the consequences of the accidental release of the fission product inventory of a fueled experiment is acceptable. While the consequences are acceptable, it is assumed that the failure of a fueled experiment will be a very rare occurrence. Likewise, the accidental release of the fission product inventory of a sample undergoing experiment or analysis as a separation experiment should also be a very rare occurrence. Your application states that laboratory scale experiments do not increase the frequency of an accidental release of radioactive material. Please discuss the features of separation experiment design that will help ensure that a failure that would release radioactive material from the experiment will be a rare occurrence.

6. Your application discusses some features of the Radiation Chemistry Laboratory. Some of these features appear to function as engineered safety features to limit the consequences if a separation experiment were to fail. It is not clear if the radiation area monitors discussed in your application are required by the TSs. Please address. If not, please propose TS limiting conditions for operation and surveillance requirements.

Please provide details on the ventilation system of the Radiation Chemistry Laboratory and its fume hoods. Discuss TS requirements to help ensure operation of equipment when required (e.g., ventilation fans, dampers and filters) and surveillances to help ensure equipment will be operable when needed. Your application states that the laboratory is maintained under negative pressure and contains alarms. Should this be a TS requirement when separation experiments are being performed? Please discuss.

How would experiment failures be detected and releases controlled?