ML12024A397

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University of Texas at Austin - Requested Change to Facility Operating License
ML12024A397
Person / Time
Site: University of Texas at Austin
Issue date: 01/09/2012
From: Whaley P
University of Texas at Austin
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12024A397 (14)
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Text

0r Department of Mechanical Engineering THE UNIVERSITY OF TEXAS AT AUSTIN NuclearEngineering TeachingLaboratory Austin, Texas 78758 512-232-5370" FAX 512-471-4589 http://www. me. utexas.edu/- net/I January 9, 2012 Nuclear Regulatory Commission Attn: Document Control Desk Washington D.C., 20555-0001

Subject:

Requested Change to Facility Operating License for the University of Texas at Austin Ref: (1) Letter of March 25, 2008 (ML080920755) Docket 50-602 (2) Letter of March 4, 2010 (ML101250168) Docket 50-602 (3) Letter of September 1, 2010 (ML102560381) Docket 50-602 Madame or Sir:

On March 4, 2010, a proposal (Ref. 2) was submitted for a change to the University of Texas at Austin Facility License R-129. The proposed change would have permitted authorization of byproduct material in new categories, related to the reactor operations or reactor-based research; the proposal was revised and transmitted on September 1, 2010 (Ref. 3) to identify specific isotopes and form. This transmittal replaces the previous submission.

Changes from the previous submission include (1) listing major license sections separately, (2) including special nuclear material masses for quantities listed in 2.B(2)(a)(vi), (2) clarifying incidental usage of the special nuclear or byproduct material, (3) adding the word "material" in 2B(3)(a)(viii), and (4) expanding justification for the proposed change.

Current License 2.B(2):

2.13(2) Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material," in connection with operation of the facility:

(a) to receive, possess and use:

(i) up to 9.5 kilograms of contained uranium-235 enriched to less than 20 percent in the isotope uranium-235 in the form of TRIGA reactor fuel; (ii) up to 20 grams of contained uranium-235 of any enrichment in the form of fission chambers; (iii) up to 1.0 gram of uranium-233, 1.0 gram of contained uranium-235 of any enrichment, 1.0 gram of plutonium-240, 1.0 gram of plutonium-239, and 1.0 gram of plutonium-241 in the form of foils; 140r-

(iv) 1.0 gram of plutonium-239, and 10 grams of contained uranium-235 of any enrichment in the form of reference materials; (v) 150 grams of plutonium as mixed oxide pellets contained in stainless steel pins for experimental purposes; (b) to receive, possess, and use, but not separate, any amount of special nuclear material produced by the operation of other facilities, contained in TRIGA fuel transferred from other facilities, and (c) to possess, use, but not separate, such special nuclear material as may be produced by the operation of the facility.

Proposed Change to 2.B(2):

2.B(2) Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material," in connection with operation of the facility:

(a) to receive, possess and use:

(i) up to 9.5 kilograms of contained uranium-235 enriched to less than 20 percent in the isotope uranium-235 in the form of TRIGA reactor fuel; (ii) up to 20 grams of contained uranium-235 of any enrichment in the form of fission chambers; (iii) up to 1.0 gram of uranium-233, 1.0 gram of contained uranium-235 of any enrichment, 1.0 gram of plutonium-240, 1.0 gram of plutonium-239, and 1.0 gram of plutonium-241 in the form of foils; (iv) 1.0 gram of plutonium-239, and 10 grams of contained uranium-235 of any enrichment in the form of reference materials; (v) 150 grams of plutonium as mixed oxide pellets contained in stainless steel pins for experimental purposes; (vi) special nuclear material in reactor-based experiments, calibration of radiation detectors, and reference sources for reactor based programs, including:

- sealed sources up to 0.1 mCi each of Pu-239 (1.6 mg), Pu-240 (0.43 mg), Pu-241 (I jig) and up to 85 mCi of Pu-238 (0.5 nmg);

- liquid sources up to 0.1 mCi each of Pu-238 (5.9 jtg), Pu-239 (1.6 mg), Pu-240 (0.43 mg), and Pu-241 (1 jig);

NOTE Although these sources have primary purposes supporting reactor-programs such as neutron activation analysis or the Radiation Protection Program, they may be used in other experiment or education programs where utilization (1) does not prevent supporting reactor-programs and (2) does not require relocation outside the control of the approved Radiation Protection Program or applicable sections of the Physical Security Plan.

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(b) to receive, possess, and use, but not separate, any amount of special nuclear material produced by the operation of other facilities, contained in TRIGA fuel transferred from other facilities, and (c) to possess, use, but not separate, such special nuclear material as may be produced by the operation of the facility.

Current License 2B(3):

2B(3) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material," in connection with operation of the facility:

(a) to receive, possess, and use:

(i) a 6-curie sealed polonium-beryllium neutron source; (ii) a 2-curie sealed americium-beryllium neutron source; (iii) 1200 micrograms of californium-252 encapsulated in stainless steel; (iv) 10 kilocuries of cobalt-60 in the form of sealed stainless steel pins; (v) 500 mCi of Cobalt 60 in the form of sealed sources (vi) up to 0.1 curie of byproduct material, atomic number 3-83, in the form of reactor components transferred from Facility Operating License No. R-92; (vii) byproduct material which is to be irradiated in the reactor within 3 1 days of receipt; (b) to receive, possess, and use, but not separate, any amount of byproduct material produced by the operation of other facilities, contained in TRIGA fuel transferred from other facilities; (c) to possess and use any byproduct material produced by operation of the reactor except for byproduct material in TRIGA fuel elements; and (d) to possess and use, but not separate, such byproduct material in TRIGA fuel elements as may be produced by operation of the facility Proposed Change to 2.B(3):

2B(3) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material," in connection with operation of the facility:

(a) to receive, possess, and use:

(i) a 6-curie sealed polonium-beryllium neutron source, (ii) a 2-curie sealed americium-beryllium neutron source; (iii) 1200 micrograms of californium-252 encapsulated in stainless steel; Page 3

(iv) 10 kilocuries of cobalt-60 in the form of sealed stainless steel pins; (v) 500 mCi of Cobalt 60 in the form of sealed sources (vi) up to 0.1 curie of byproduct material, atomic number 3-83, in the form of reactor components transferred from Facility Operating License No. R-92; (vii) byproduct material which is to be irradiated in the reactor within 31 days of receipt; (viii) byproduct material used in reactor-based experiments, calibration of radiation detectors, and reference sources for use in reactor based analytic techniques 2 including:

sealed sources up to:

0.1 mCi each of C-14, CI-36, Cr-51, Fe-55, Fe-59, Co-57, Mn-54, Ni-63, Zn-65, Sr-85, Y-88, Sr-90, Tc-99, Cd-109, Sn- 113, Sb-125, 1-129, Pm-147, Eu-155, TI-204, Bi-207, Pb-210, Po-210, Bi-210, Ba-133, Th-230, Np-237, and 500 mCi of cobalt-60, 1.0 mCi each of Cf-252, Cm 244 and Eu-152, 2.0 mCi of Ra-226, 5.0 mCi of Na-22, 2.5 Ci of Cs-137, and

- 1.0 Ci of Am-241; and in liquid form up to 0.1 mCi each of Cr-51, Mn-54, Co-57, Co-60, Zn-65, Sr-85, Sr-90, Y-88, Cd-109, Sn-I 13, Ba-133, Cs-137, Ce-139, Ce-141, Pm-147, Eu-152, Eu-154, Eu-155, Hg-203, Bi-207, Po-209, Np-237, Am-241, Cm-244 and 0.5 mCi of Pb-210 (b) to receive, possess, and use, but not separate, any amount of byproduct material produced by the operation of other facilities, contained in TRIGA fuel transferred from other facilities; (c) to possess and use any byproduct material produced by operation of the reactor except for byproduct material in TRIGA fuel elements; and (d) to possess and use, but not separate, such byproduct material in TRIGA fuel elements as may be produced by operation of the facility.

2 See previous Note I.

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Justification:

This proposed change is consistent with the description in Section 9.1.6 of the Safety Analysis Report, University of Texas at Austin, which states:

Other materialsthat are to be identifiedand controlledby identification and location are encapsulatedisotopic radiationsources, radiochemicalsource materialsandprocess equipment ...Activity levels of encapsulatedand radiochemicalsources are expected to vary widely as will handlingand storageprecautions.

Activities using these sources fall under the facility operating license. The approved USNRC Radiation Protection Program currently provides radiological protection, monitoring, and surveillances associated with use of all radioactive material at the facility, including the listed sources; therefore, there will be no changes to the current safe use of the sources and no changes required for the approved Radiation Protection Program. The proposed change does not require any changes to the approved Physical Security Plan.

Each of the sources listed in 2.B(2)(a)(vi) currently exists at UT-A specifically to support calibrations and/or performance checks of instruments used in alpha and/or gamma spectroscopy, neutron activation analysis and/or facility health physics as indicated in Table 1. A Pu-238 sealed source also currently supports an experimental program (not reactor-related), but the usage does not interfere with the reactor-program purpose. The total mass of sources listed in Table I is less than 5 mg, and does not change the category of the facility as defined in IOCFR73; therefore, the proposed change does not require any change to the approved Physical Security Plan.

Table 1: Special Nuclear Material Sources Gamma or Neutron Current SOURCES Alpha Spec. Activation Instruments Incidental Cal./Inst. Checks Analysis Usage Pu-239 sealed source X X Pu-240 sealed source X X Pu-241 sealed source X X Pu-238 sealed source X X X Pu-238 liquid source X X Pu-239 liquid source X Pu-240 liquid source X Pu-241 liquid source X Each of the sources listed in 2.B(3)(a)(viii) exists at UT-A to support calibrations and/or instrument checks of instruments used in neutron activation analysis, health physics instruments, and/or development of reactor facilities as indicated in Table 2. Currently there are two types of incidental utilization, material irradiation and teaching applications. One Co-60 sealed source supports a material irradiation program, with the remainder of the sources listed in the Table 2, 'Current Incidental Usage" column used in standard nuclear engineering laboratory exercises.

Table 2: Byproduct Material Sources Gamma or Alpha Health Positron Current SOURCES Spec. Cal./inst. Physics Source Incidental Checks Instruments Development Usage C-14, 1.0 mCi sealed source X X Page 5

Table 2: Byproduct Material Sources Gamma or Alpha Health Positron Current SOURCES Spec. Cal./Inst. Physics Source Incidental Checks Instruments Development Usage CI-36, 1.0 mCi sealed source x x Cr-51, 1.0 mCi sealed source x x x Fe-55, 1.0 mCi sealed source x x x Fe-59, 1.0 mCi sealed source x x x Co-57, 1.0 mCi sealed source x x x Mn-54, 1.0 mCi sealed source x x x Ni-63, 1L0 mCi sealed source x x Zn-65, 1.0 mCi sealed source x x x Sr-85, 1.0 mCi sealed source x x x Y-88, 1.0 mCi sealed source x x x Sr-90, 1.0 mCi sealed source x x Tc-99, 1.0 mCi sealed source x x Cd-109, 1.0 mCi sealed source x x x Sn-I 13, 1.0 mCi sealed source x x x Sb-125, 1.0 mCi sealed source x x 1-129, 1.0 mCi sealed source x Pm-147, 1.0 mCi sealed source x Eu-155, 1.0 mCi sealed source x TI-204, 1.0 mCi sealed source x Bi-207, 1.0 mCi sealed source x Pb-2 10, 1.0 mCi sealed source x Po-2 10, 1.0 mCi sealed source x x Bi-2 10, 1.0 mCi sealed source x Ba-133, 1.0 mCi sealed source x Th-230, 1.0 mCi sealed source x Np-237, 1.0 mCi sealed source x Co-60, 500 mCi sealed source x x x Cf-252, 1.0 mCi sealed source x x Cm 244, 1.0 mCi sealed source x Eu-152, 1.0 mCi sealed source x Ra-226, 2.0 mCi sealed source x x Na-22, 5.0 mCi sealed source x Cs-137, 2.5 Ci sealed source x x x Am-241, 1.0 Ci sealed source x x x Cr-51, 0.1 mCi liquid x x x Mn-54, 0.1 mCi liquid x Co-57, 0.1 mCi liquid x Co-60, 0.1 mCi liquid x Zn-65, 0.1 mCi liquid x Sr-85, 0.1 mCi liquid x Sr-90, 0.1 mCi liquid x Y-88, 0.1 mCi liquid x Cd-109, 0.1 mCi liquid x Sn-I 13, 0.1 mCi liquid x Ba-133, 0.1 mCi liquid x x Cs-137, 0.1 mCi liquid x x Ce-139, 0.1 mCi liquid x Ce-141, 0.1 mCi liquid x Pm-147, 0.1 mCi liquid x Page 6

Table 2: Byproduct Material Sources Gamma or Alpha Health Positron Current SOURCES Spec. Cal./Inst. Physics Source Incidental Checks Instruments Development Usage Eu-152, 0.1 mCi liquid X Eu-154, 0.1 mCi liquid X Eu-155, 0.1 mCi liquid X Hg-203, 0.1 mCi liquid X Bi-207, 0.1 mCi liquid X Po-209, 0.1 mCi liquid X Np-237, 0.1 mCi liquid X Am-241, 0.1 mCi liquid X Cm-244, 0.1 mCi liquid X X Pb-210, 0.5 mCi liquid X X Although possession and use of the sources listed in Table I and Table 2 are authorized via different licenses, radiological protection and usage for all listed source is controlled by the reactor Radiation Protection Program and applicable sections of the Physical Security Plan, The proposed change is administrative in nature, moving authorization for sources used in reactor-programs onto the reactor license, with no effect on the practices required by the license basis as implemented in facility procedures.

Under the proposed revision, if a source supporting reactor-based programs is suitable for use in a non-reactor program then the source may be used as an alternative to acquiring additional radioactive material.

If the use of the radioactive material conflicts with reactor-programs or removes the radioactive material from areas governed by the reactor Radiation Protection Program or applicable sections of the Physical Security Plan, the radioactive material will be transferred to the appropriate license.

Safety Analysis As indicated in the (University of Texas at Austin) Safety Analysis Report, the reactor facility possesses a number of special nuclear material and byproduct material sources that are controlled under the Radiation Protection Program and protected by applicable sections of the Physical Security Plan. Some of these sources are currently under separate licenses; we are requesting that authorization for possession and use of these sources be incorporated in the appropriate sections of the reactor facility operating license.

No change is required to the Safety Analysis Report, Radiation Protection Program, Physical Security Plan, or facility procedures in order to implement the proposed license change. The Safety Analysis Report, Radiation Protection Program, and Physical Security Plan are part of the basis used to evaluate the safety of the facility in order to issue a facility operating license. Periodic USNRC inspections show facility operations to be in compliance with the license basis:

" IR-05-201 ADAMS Accession ML053490224

" IR-07-201 ADAMS Accession ML073180316

" IR-09-201 ADAMS Accession ML092730002 Page 7

Access to the reactor building and the laboratory wing (offices and laboratory spaces) of the Nuclear Engineering Teaching Labortory (NETL) is controlled electronically. Access to NETL laboratories where radioactive materials are used is controlled with locks that cannot be left in an unlocked condition, and/or by intrusion alarms. The reactor license basis includes a USNRC approved Radiation Protection Program providing radiological controls for radioactive sources at NETL. Exposures for the previous three years are provided as demonstration that the Radiation Protection Program is effective. The high 2007 doses are associated with disposal of an irradiator source assembly, and were less than 80% of the dose calculated in the ALARA review.

ANNUAL EXPOSURE PERMANENTLY ASSIGNED MONITORS 9

0 2009 N 2008 2007 LU z 7 z

0

~ 5.

4, 1:0 3, z 2 zo 66ýU 16 6 Al Annual Dose (mnremn)

All personnel entering restricted areas at the NEIL are required to be monitored by personal dosimeters.

Personnel with unescorted access to restricted areas are provided training in radiological protection (with a biennial refresher course). Visitors are provided a safety briefing, and escorted. Annual occupational dose limits under the NEIL ALARA program are set at I rem TEDE, with the sum of the deep dose equivalent and the committed effective dose I rem. Annual eye dose equivalent limit is 1.5 rem, with a skin dose limit of 5 rem. Radioactive material storage rooms are posted; if storage occurs within a room, the storage area is segregated and posted.

The level of safety is therefore not affected by the change which assures that activities conducted under the proposed change can be conducted (1) without endangering the health and safety of the public, and (2) in compliance with the regulations of the Commission.

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The complete text of the license as amended is attached.

Please contact me by phone (512-232-5373) or email (whalevy(,mail.utexas.edu) if you require clarification or further information.

P. Michael Whaley Associate Director Nuclear Engineering Teaching Laboratory The University of Texas at Austin 512-232-5373 I declare under penalty of perjury that the foregoing is true and correct Steven R. Biegalski NETL Director cc: S. Biegalski, Director H. Liljestrand, Reactor Oversight Committee Chair P. Torres, Project Manager, NRC

0. E. Font, Relicense Project Manager att: Proposed License Text Page 9

i;-A UNITED STATES c NUCLEAR REGULATORY COMMvISSION Washington, D.C. 20555 FACILITY OPERATING LICENSE DOCKET NO. 50-602 UNIVERSITY OF TEXAS AT AUSTIN Amendment No. 7 License No. R- 129 The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for license, filed by University of Texas at Austin, on November 9, 1984, as supplemented, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. Construction of the facility was completed in substantial conformity with Construction Permit No. CPRR-123, of June 4, 1985, the provisions of the Act, and the rules and regulations of the Commission; C. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; D. There is reasonable assurance (i) that the activities authorized by this license can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted in compliance with the Commission's regulations; E. The licensee is technically and financially qualified to engage in the activities authorized by this operating license in accordance with the regulations of the Commission; F. The licensee is a nonprofit educational institution and will use the facility for conducting educational activities, and has satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; G. The issuance of this license will not be inimical to the common defense and security or to the health and safety of the public; H. The issuance of this license is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied; and

License No. R-129 The receipt, possession, and use of the byproduct and special nuclear materials as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30 and 70, including Sections 30.33, 70.23 and 70.31.

2. Facility License No. R-129 is hereby issued to the University of Texas at Austin as follows:

A. The license applies to the TRIGA Mark II nuclear reactor (the facility) owned by the University of Texas at Austin (the licensee). The facility is located on the licensee's site in Austin, Texas, and is described in the licensee's application for license of November 9, 1984, as supplemented.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the University of Texas at Austin:

(1) Pursuant to Section 104c of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," to possess, use, and operate the facility at the designated location in Austin, Texas, in accordance with the procedures and limitations set forth in this license; (2) Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material," in connection with operation of the facility:

(a) to receive, possess and use:

(i) up to 9.5 kilograms of contained uranium-235 enriched to less than 20 percent in the isotope uranium-235 in the form of TRIGA reactor fuel; (ii) up to 20 grams of contained uranium-235 of any enrichment in the form of fission chambers; (iii) up to 1.0 gram of uranium-233, 1.0 gram of contained uranium-235 of any enrichment, 1.0 gram of plutonium-240, 1.0 gram of plutonium-239, and 1.0 grain of plutonium-241 in the form of foils; (iv) 1.0 gram of plutonium-239, and 10 grams of contained uranium-235 of any enrichment in the form of reference materials; (v) 150 grams of plutonium as mixed oxide pellets contained in stainless steel pins for experimental purposes; (vi) special nuclear material in reactor-based experiments, calibration of radiation detectors, and reference sources for reactor based analytic techniques including:

sealed sources up to 0.1 mCi of Pu-239, Pu-240, Pu-241 and up to 85 mCi of Pu-238; Page 2

License No. R-129 liquid sources up to 0.1 mCi of Pu-238,. Pu-239, Pu-240, and Pu-241; (b) to receive, possess, and use, but not separate, any amount of special nuclear material produced by the operation of other facilities, contained in TRIGA fuel transferred from other facilities, and (c) to possess, use, but not separate, such special nuclear material as may be produced by the operation of the facility.

(3) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material," in connection with operation of the facility:

(a) to receive, possess, and use:

(i) a 6-curie sealed polonium-beryllium neutron source; (ii) a 2-curie sealed americium-beryllium neutron source; (iii) 1200 micrograms of californium-252 encapsulated in stainless steel; (iv) 10 kilocuries of cobalt-60 in the form of sealed stainless steel pins; (v) 500 mCi of Cobalt 60 in the form of sealed sources (vi) up to 0.1 curie of byproduct material, atomic number 3-83, in the form of reactor components transferred from Facility Operating License No. R-92; (vii) byproduct material which is to be irradiated in the reactor within 31 days of receipt; (viii) byproduct used in reactor-based experiments, calibration of radiation detectors, and reference sources for use in reactor based analytic techniques including:

sealed sources up to:

0.1 mCi each of C-14, CI-36, Cr-51, Fe-55, Fe-59, Co-57, Mn-54, Ni-63, Zn-65, Sr-85, Y-88, Sr-90, Tc-99, Cd-109, Sn-113, Sb-125, 1-129, Pmn-147, Eu-155, TI-204, Bi-207, Pb-210, Po-210, Bi-210, Ba-133, Th-230, Np-237, and 500 mCi of cobalt-60, 1.0 mCi each of Cf-252, Cm 244 and Eu-152, Page 3

License No. R- 129 2.0 mCi of Ra-226 5.0 mCi of Na-22, 2.5 Ci of Cs-137, and 1.0 Ci of Am-241; and in liquid form up to 0.1 mCi each of Mn-54, Cr-51, Co-57, Co-60, Zn-65, Sr-85, Sr-90, Y-88, Cd-109, Sn- 113, Ba-133, Cs-137, Ce-139, Ce-141, Pm-147, Eu-152, Eu-154, Eu-155, Hg-203, Bi-207, Po-209, Np-237, Am-241, Crn-244 and 0.5 mCi of Pb-210 (b) to receive, possess, and use, but not separate, any amount of byproduct material produced by the operation of other facilities, contained in TRIGA fuel transferred from other facilities; (c) to possess and use any byproduct material produced by operation of the reactor except for byproduct material in TRIGA fuel elements; and (d) (d) to possess and use, but not separate, such byproduct material in TRIGA fuel elements as may be produced by operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in Parts 20, 30, 50, 51, 55, 70, and 73 of 10 CFR Chapter I, to all applicable provisions of the Act, and to the rules, regulations, and orders of the Commission now or hereafter in effect and to the additional conditions specified below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady-state power levels not in excess of 1100 kilowatts (thermal) and in the pulse mode with reactivity insertions not to exceed 2.2 percent 4k/k.

(2) Technical Specifications The Technical Specifications contained in Appendix A are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Physical Security Plan The licensee shall fully implement and maintain in effect all provisions of the physical security plan approved by the Commission and all amendments and changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.5 4 (p).

The approved plan, which is exempt from public disclosure pursuant to the provisions of 10 CFR 2.790(d), is entitled "Physical Security Plan for the UT

[University of Texas] TRIGA Mark 11 Reactor Facility," Revision 1, dated August 1990.

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License No. R- 129 D. This license is effective as of the date of issuance and shall expire twenty years from its date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Date of Issuance:

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