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Texas A&M University - Request for Amendment to License No. R-83 and Technical Specification Associated with Receiving and Storing Special Nuclear Material Currently Located in the Tamu AGN-201M Reactor
	ML15287A148
Person / Time
Site:	05000128
Issue date:	10/14/2015
From:	Mcdeavitt S; Texas A&M Univ
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	2015-0041
	Download: ML15287A148 (20)
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NUCLEAR SCIENCE CENTER Dr. Sean M. McDeavitt Director, TEES Nuclear Science Center Texas A&M University Texas A&M Engineering Experiment Station 1095 Nuclear Science Road, M/S 3575 College Station, TX 77843-3575 October 14, 2015 2015-0041 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Ref: 10 CFR 50.90

SUBJECT:

Texas A & M Engineering Experiment Station [TEES] is seeking to modify the License and Technical Specification associated with receiving and storing Special Nuclear Material currently located in the TAMU AGN-201M Reactor. The Proposed Changes are contained in the Attached Amendment Request, Docket Number 50-128, Facility License R-83, to receive and store in the Nuclear Science Center [NSC] Fuel Storage Vault, Special Nuclear Material currently located in the AGN-201M Mr. William Dean, Office Director Office of Nuclear Reactor Regulation:

This Amendment request affects Texas A&M University [TAMU] in actively developing plans to construct a new building adjacent to the Nuclear Science Center [NSC] site near the NSC reactor to support the relocation, reconstruction and operation of its AGN-201M reactor currently licensed for use in the Zachry Engineering Center. This will consolidate the University's reactor operations onto two adjacent sites.

Texas A&M University has pressing needs for the space currently occupied by the AGN-201M reactor and proposes to establish an interim storage plan to enable the timely removal of the AGN-201M from its current location while permitting a thorough design phase, regulatory approval, permitting, and construction of the new building without delaying the unrelated expansion of the Zachry Engineering Center. The proposed storage does not present any foreseeable adverse radiological impacts for the public or TAMU/TEES operating staff. The amendment request represents one part of a two-pronged plan. The first request is TAMU/TEES requesting approval to amend the License and Technical Specification of license R-83 for the NSC reactor to enable the receipt and safe storage of the AGN-201M SNM while the new facility is being established. A companion Amendment requesting approval is to enable the disassembly and relocation of the AGN-201M Reactor [license [R-23] to the NSC site to Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 1 Tel. [979] 845-7551

enable release of the current AGN-201M site. Taken together, these requests will set the stage for further future communication with the Nuclear Regulatory Commission as the plans for transportation, construction, and reassembly the AGN-201M for operation proceed; these items are not covered in detail here.

Relocation of a nuclear reactor is considered a rare occurrence. To assist in our preparations, TAMU/TEES has reviewed a similar storage approval requested and granted to Oregon State University [OSU] facility for storage of its AGN-201 fuel in their TRIGA Reactor Fuel Storage Vault [ref 4]. The planned activity comprises the transfer of the AGN-201M special nuclear material [SNM] to the NSC Fuel Storage Vault, which requires approval of the attached Amendment. The duration of this storage in the NSC Fuel Storage Vault will be about 3-5 years to allow for the completion of construction of a new building adjacent to the NSC site.

Once completed, pending the receipt of Commission authorization, the AGN-201M will be assembled in its new location and the AGN-201M SNM will be transferred from storage to the installed, fully constructed reactor. This will all be pursuant to the noted future communications with the NRC after construction is complete.

In addition to the information reviewed from OSU, it is germane to review information from the previous relocation of the subject TAMU AGN-201M reactor in the early 1970s. For the interim period, TAMU has proposed that the defueled, drained and disassembled AGN-201M and supporting equipment will be appropriately packaged for storage within the Restricted Area at the NSC site. Similar activities associated with the disassembly, handling, packaging, moving, storing and transport were addressed in the early 1970s via the amendment process associated with a previous relocation of the AGN-201M from the Mechanical Engineering Shop area to the Zachry Engineering Center. These like activities are addressed in the parallel request for amendment to the AGN-201M license.

This document is exclusively focused on amending the NSC reactor license to enable the beginning of this multi-step process. Three specific new authorizations to be incorporated in the NSC license are requested, as described below.

235

1. A new possession authorization to receive and store approximately 665 grams of U in the AGN-201M fuel containing uranium enriched to less than 20% 235U.

2. A specific possession authorization to receive and store the nominal 1-curie Plutonium-Beryllium [239PuBe] neutron start-up source containing 16 grams of 239Pu.

3. An additional possession authorization for storage of byproduct material in the form of AGN-201M components, potentially activated or contaminated to low levels, within the NSC Restricted Area.

In addition, the new possession authorization must also be addressed in Technical Specification 5.6, Fuel Storage, for the NSC facility (Nuclear Regulatory Commission, 2015).

In accordance with the provisions of 10 CFR 50.90, TEES is submitting this License and Technical Specification Change Request seeking to modify the TEES NSC license, Facility License R-83, Docket Number 50-128 (Nuclear Regulatory Commission, 2015). A License and Technical Specification Change Request for the NSC reactor are contained in Attachment 1 to this letter. Attachment 1 also contains recommended replacement pages for the proposed License Change and Technical Specifications affected [as noted above, the requested Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 2 Tel. [979] 845-7551

cc:

William Dean, Office Director, Duane Hardesty, Project Manager Office of Nuclear Reactor Office of Nuclear Reactor Regulation Regulation United States Nuclear Regulatory United States Nuclear Regulatory Commission Commission Patrick Boyle, Project Manager, Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 4 Tel. [979] 845-7551

Attachment Texas A & M Engineering Experiment Station [TEES] is seeking to modify the License and Technical Specification associated with receiving and storing Special Nuclear Material currently located in the TAMU AGN-201M Reactor. The Proposed Changes are contained in the following Amendment Request, Docket Number 50-128, Facility License R-83, to receive and store in the Nuclear Science Center [NSC] Fuel Storage Vault, Special Nuclear Material currently located in the AGN-201M October 14, 2015 License and Technical Specification changes are being requested by the Texas A&M Engineering Experiment Station [TEES]. TEES is seeking approval from the United States Nuclear Regulatory Commission [NRC] to receive and store special nuclear material [SNM] in the Nuclear Science Center [NSC] Fuel Storage Vault. The SNM is used in the AGN-201M reactor located in the Zachry Engineering Center. The defueled, drained, and emptied AGN-201M reactor and support equipment will also be stored in a licensed area within the NSC site.

Three very specific new authorizations in the NSC license are requested, as described below.

235

1. A new possession authorization to receive and store approximately 665 grams of U in the AGN-201M fuel containing uranium enriched to less than 20% 235U.

2. A specific possession authorization to receive and store the nominal 1-curie Plutonium-Beryllium [239PuBe] neutron start-up source containing 16 grams of 239Pu.

3. An additional possession authorization for storage of byproduct material in the form of AGN-201M components, potentially activated or contaminated to low levels, within the NSC Restricted Area.

TEES is requesting authorization to possess SNM from the AGN-201M Reactor and therefore the NSC facility Technical Specification 5.6, Fuel Storage (Nuclear Regulatory Commission, 2015), must be modified.

TAMU1 will observe all applicable Rules and Regulations associated with handling, packaging, and transport of the AGN-201M reactor and support equipment to successfully relocate from the present location in the Zachry Engineering Center to the NSC site. The proposed relocation is the second move for this particular reactor system. The AGN-201M was originally located in the Mechanical Engineering Shop area and was subsequently disassembled, moved, and reconstructed in the early 1970s in the Zachry Engineering Center. This License Change request seeks to obtain authorization under the TEES NSC facility license R-83 to receive and store the AGN-201M SNM, reactor components and support equipment on the NSC site. In addition, TEES Technical Specification 5.6, Fuel Storage, is required to be modified to reflect this change; recommended language is attached as Enclosure 2a. Justification for the proposed changes follows.

1 It is important to note that TAMU and TEES are distinct organizations, yet the principal personnel associated with the AGN-201M relocation often perform roles within both organizations. TAMU and TEES function together to achieve their distinct academic and research objectives, respectively. TAMU holds the AGN-201M license [R-23] and desires to relocate the reactor in an orderly and timely manner. TEES holds the license for the NSC reactor [R-83] and will be supporting the relocation activities.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 5 Tel. [979] 845-7551

The SNM inventory to be stored includes approximately 665 grams of 235U contained in uranium fuel enriched to less than 20% and a nominal 16 grams of 239Pu in the 239PuBe neutron start-up source. To facilitate periodic inventory, enhance contamination control, and to minimize potential personnel exposure, TEES will store the AGN-201M fuel plates in the NSC fuel storage vault in multiple bolted-ring containers with tamper seals affixed. The start-up source will be stored in an existing source well within the fuel storage vault or in another source shield, as approved by site Radiation Protection staff.

1.0

SUMMARY

DESCRIPTION The NSC is currently authorized to receive, store and use only SNM to be used for NSC reactor operations. Thus, TEES is seeking to amend the NSC reactor License and Technical Specifications to receive and store the AGN-201M fuel and neutron start-up source until a new building is constructed and licensed for receipt and operation of AGN-201M reactor. TEES understands that the construction of a new building to house the reconstructed AGN-201M reactor requires that TAMU obtain a Construction Permit from the NRC pursuant to 10 CFR 50.45.

License and Technical Specification changes are being requested by the TEES to enable storing AGN-201M fuel plates, fueled control rods, and 239PuBe neutron start-up source in the NSC Fuel Storage Vault. To simplify inventory, provide robust contamination control, and reduce potential personnel exposure, the AGN-201M fuel will be stored in 5-gallon drums [2 drums, each containing approximately half of the fuel inventory]. The defueled, drained, and empty AGN-201M components will be stored in a licensed area within the NSC site along with the remaining support equipment. The proposed relocation is similar to the move of the AGN-201M Reactor undertaken in the early 1970s, as approved by the U.S. Atomic Energy Commission [USAEC] (Atomic Energy Commission, 1972) except that a longer period of storage will be required [hence this request] while a new facility location is prepared. This present SNM storage request also closely mirrors the possession and storage authorization approved for the Oregon State University's storage of its AGN-201 fuel in its TRIGA facility.

Refer to the Safety Analysis Report (Oregon State University, 2008a) and Facility Operating License (Oregon State University, 2008b). It is noteworthy that the Oregon State University AGN-201 fuel inventory has been safely stored at OSU in the core tank overpacked in a single steel drum for over 30 years.

Land owned and controlled by Texas A&M University and Easterwood Airport surrounds the NSC site where the AGN-201M fuel and components will be stored. A chain-link steel fence around the perimeter restricts access to the site. The main entrance into the site is through an electrically operated chain-link steel gate at the east end of the site. The entire area inside the perimeter fence of the NSC is a "Restricted Area." Located within the boundaries of the site are the reactor confinement building, reception room, laboratory building, mechanical equipment room, cooling system equipment, liquid effluent holding tanks, and other storage and support buildings.

Security has been addressed in the past as it relates to the NSC site and no changes are warranted as the existing Restricted Area will be used for storage of the defueled and drained reactor and other support equipment. The SNM associated with the AGN-201M Reactor will be moved from the Zachry Engineering Center and will add 665 fissile grams to the current NSC site inventory. This will not affect the licensed limit and authorized fuel SNM inventory [15 Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 6 Tel. [979] 845-7551

kilograms] for the NSC facility. TEES will continue to ensure requirements pursuant to 10 CFR 73 are met and will comply with the NSC Security Plan.

The AGN-201M reactor and NSC reactor are operated by TAMU and TEES, respectively, and are located on the campus at College Station, Texas. The AGN-201M reactor is currently located in room 61 of the Zachry Engineering Center and has been in this location since its last relocation in the early 1970s. The NSC reactor is located approximately five miles away and its location is N30°35', W96°23'. TAMU has been operating the AGN-201M reactor on its campus since the late 1950s. This reactor is licensed to operate at up to 5 watts under License Number R-23 and Docket Number 50-59. Since its installation, the AGN-201M reactor has been used primarily for reactor operator training and student laboratory experiments.

Upon receipt of Commission approval, the SNM will be removed and transferred for storage in the NSC fuel storage vault, followed by the complete disassembly of the AGN-201M reactor.

Over the following weeks, relocation of the defueled, drained, and empty reactor core tank, water shield tank, and the remaining support equipment will take place. All equipment will be stored within the Restricted Area at the NSC site.

The AGN-201M reactor contains approximately 665 fissile grams of 235U in uranium enriched to less than 20 percent. The fuel matrix is UO2 embedded in radiation-stabilized polyethylene. In addition to the fuel plates and fueled control rods, the SNM inventory includes 16 grams of 239Pu in the form of a sealed 239PuBe neutron start-up source. Thus, the total mass of SNM to be moved is 665 fissile grams of 235U in uranium enriched to less than 20 percent and 16 grams of 239 Pu to be stored in the NSC Fuel Storage Vault.

It is notable that the NSC fuel storage vault currently contains no special nuclear materials. The array of storage bins in the fuel storage vault is designed for storage of fresh fuel for the NSC reactor. It was not used in 2006-7 when the NSC reactor was refueled to LEU fuel rods. In fact, it has not been used for SNM storage for decades but the capability exists and is maintained.

Given the current NSC facility SNM inventory of approximately 12 kilograms, the NSC TRIGA reactor licensed limit of 15 kilograms of contained 235U in connection with operation of the reactor will not be exceeded by storage of the AGN-201M reactor fuel. The NSC Technical Specification 5.6, Fuel Storage, must, however, be changed to identify the AGN-201M reactor SNM as a separate possession authorization for storage [but not use] in the NSC fuel storage vault. The AGN-201M non-fuel components and support equipment will be surveyed, appropriately packaged, transported, and stored on the NSC site [not in the fuel storage vault].

Fuel Storage restrictions in Technical Specification 5.6 [Enclosures 2 and 2a] for the NSC reactor are applicable to storage of reactor fuel at times when it is not in the reactor core (Nuclear Regulatory Commission, 2015). The objective is to ensure that fuel that is being stored cannot become critical and cannot reach an unsafe temperature. Current requirements for the storage of NSC reactor fuel are:

1) All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.

2) Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 7 Tel. [979] 845-7551

The NSC SAR [Section 9.2.2.1, Fuel Storage Vault] notes a very conservative model was used to evaluate unirradiated fuel storage. Summarizing, for new LEU 30/20, self-moderating NSC reactor fuel, the criticality safety model included the aluminum tubes with a four-rod cluster inside, but without the cadmium sleeve and polyethylene sleeve. A concrete wall was added on five sides to simulate the storage room. The storage configuration was evaluated with air in the fuel storage vault, and again with the fuel storage vault flooded. Calculated results:

1. Storage of LEU 30/20 in air: keff = 0.12994 +/- 0.00024

2. Storage of LEU 30/20 flooded: keff = 0.45526 +/- 0.00043 The proposed storage of the AGN-201M fuel and the associated neutron start-up source will not impact the existing restrictions on fuel storage or challenge established Nuclear Safety margins as the total amount of fuel to be stored in the NSC fuel storage vault remains well below the licensed limit. The proposed storage does not introduce new risks.

2.0 BACKGROUND

DESCRIPTION OF AGN-201M REACTOR The AGN-201M polyethylene fuel plates and fueled control elements contain approximately 665 grams of contained 235U. The fuel itself is in a plate-type configuration and is homogeneously mixed powder of polyethylene and uranium dioxide in the form of 20 micron diameter particles.

The core discs have been formed by pressing, under high pressure, the homogeneously mixed powder. Thus, the materials of concern are the uranium dioxide embedded in radiation-stabilized polyethylene, plus 16 grams of 239Pu in the form of a sealed 239PuBe neutron start-up source. This is the SNM to be transported and stored in the NSC Fuel Storage Vault.

The reactor core of the AGN-201M reactor consists of nine separate fuel plates which are stacked into a right circular cylinder. The final core configuration is 10.15 inches [25.8 cm] in diameter and 9.34 inches [23.75 cm] in height.

The AGN-201M reactor core also contains four fueled control and safety rods. Three of these rods: Safety Rods 1 & 2 and the Coarse Control Rod are constructed in a similar manner while the Fine Control Rod is half the diameter. The fuel contained in these rods is of the same type as the fuel plates. The fissile content of the fueled control rods is included in the 665 grams 235U core inventory (Texas A&M University, 2010).

Of note is the previous movement of the AGN-201M reactor from the Mechanical Engineering Shops area to the Zachry Engineering Center in the early 1970s. This Commission-approved activity involved the disassembly, packaging, transport, and reconstruction of the AGN-201M reactor in the Zachry Engineering Center. The packaging and temporary storage of the SNM was in Type A containers while movement and reconstruction activities were underway.

Similarly, Oregon State University received approval from the NRC to store their AGN-201 fuel in their TRIGA reactor facility in the early 1980s. This fuel has been successfully stored for over 30 years.

3.0 REGULATORY EVALUATION

The NSC reactor facility is licensed to possess up to 15 kilograms of SNM in the form of low enriched uranium fuel [less than 20% enriched] for NSC reactor operations. To ensure no Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 8 Tel. [979] 845-7551

impacts on nuclear safety considerations, the total inventory of fuel SNM [including the requested possession and storage-only provision for the AGN-201M SNM] located at the NSC will remain below the current 15 kilograms license limit [i.e., a sum-of-fractions rule will be applied]. In addition, a possession authorization is needed to possess and store, but not use, the 16 grams of 239Pu contained in the AGN-201M 239PuBe neutron start-up source. This is the primary information to be incorporated in the changed License. [See Enclosure 1a, Proposed License Change]. This information is also important to add to the Technical Specifications and, as such, is incorporated in Enclosure 2a, Proposed Technical Specification Change.

3.1 Applicable Regulatory Requirements/Criteria TEES has evaluated the regulatory requirements and criteria applicable to the proposed License Change Request and Technical Specification Request. A similar request was approved for the Oregon State University facility (Oregon State University, 2008b).

3.2 Precedent In the early 1970's, the USAEC authorized TAMU to relocate the AGN-201M reactor about 1400 feet; While the current plan differs because the distance of the move is approximately 5 miles, many of the practical aspects of the previous move such as disassembly, storage, and reassembly methods are highly relevant to the present plan. Included in the authorization were provisions to package and store the AGN-201M fuel and neutron start-up source during reconstruction of the reactor. The successful move and subsequent operation of the reactor supports TAMU's desire to move forward with the project plan to not only store SNM in the NSC Fuel Storage Vault, but also with planning for the construction of a new dedicated building to house the reconstructed AGN-201M reactor adjacent to the NSC site.

As noted in Section 1.0, Summary Description, a similar request was approved by the Commission for storage of the Oregon State Universitys identical AGN-201 reactor fuel at its TRIGA facility. This fuel has been successfully stored for over 30 years.

4.0 STORAGE The AGN-201M reactor fuel will be stored in two containers [5-gallon bolted-ring drums], each containing nominally half of the AGN-201M fuel inventory, and placed within the NSC fuel storage vault. Each of the two drums will be placed in a corner of the fuel storage vault, directly under the existing aluminum fuel storage tubes. Using the existing fuel storage tube locks and cable or chain, each drum will be secured to two lowest fuel storage tubes immediately above the AGN-201M storage drums. Accordingly, the two fuel storage tubes [4 total] will be unavailable for NSC fuel storage while the AGN-201M fuel is in the fuel storage vault. Based upon information in the NSC Safety Analysis Report (Texas A&M University System, 2011),

section 9.2.2.1, these 4 storage tubes were modeled as containing up to 2.39 kilograms of 235U in low-enriched NSC reactor fuel [i.e., a 4-element bundle], or approximately 3.5 times the quantity of AGN-201M fissile material to be stored. To minimize the need for direct physical inspection of the fuel plates, a tamper seal will be applied to each storage package when closed. Fueled control element ends will be stored in the NSC aluminum fuel storage tubes. In addition to the requisite radioactive materials labels, each storage package will be marked to identify which fuel plates it contains and the corresponding fissile mass. The 239PuBe neutron start-up source will be placed in an existing source well within the NSC fuel storage vault or in another source shield, as approved by the site Radiation Protection staff.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 9 Tel. [979] 845-7551

Fissile loading of storage packages has been considered relative to the approved fuel storage vault inventory limit and storage restrictions from NSC Technical Specification 5.6, Fuel Storage (Nuclear Regulatory Commission, 2015):

1) All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.

2) Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.

Approximately 665 fissile grams of AGN-201M fuel displaces the storage space allotment for up to approximately 2.39 fissile kilograms [4 fuel bundles] of fresh NSC reactor fuel, while retaining the current 15 kg fuel possession limit.

This proposed fuel packaging for storage is consistent with the Oregon State University storage of its fuel [fuel plates in the core tank, overpacked in a drum] for over 30 years Potentially contaminated or activated reactor components and support equipment will be stored within the NSC Restricted Area in appropriate packaging. Packages will also be provided with tamper seals to simplify inventory.

5.0 TECHNICAL EVALUATION

The disassembled AGN-201M reactor shield tank and supporting components will be standalone entities that remain subject to the AGN-201M license while in storage [i.e., the AGN-201M license will not be terminated]. The associated amendment[s] to the AGN-201M license will be handled separately. The new configuration will be provided in a separate correspondence to the NRC. Once the new building is under construction and the AGN-201M reactor is being reconstructed, TAMU will engage the NRC to request approval to move the SNM from the NSC storage location to the new AGN-201M facility [i.e., an authorized license-to-license transfer]. Other licensing actions may be required at that point in time.

Once the AGN-201M reactor is completely defueled and drained, the reactor as defined in the SAR, no longer exists. The fuel plates will be packaged in at least two separate containers and the reactor components will be disassembled and packaged for relocation and storage. Thus, reactivity events are not credible.

6.0 INDEMNIFICATION AND INSURANCE TEES/TAMU has reviewed the criteria contained in 10 CFR 140.92 Appendix B to identify potential extraordinary nuclear occurrences at the NSC site and has determined there are no credible events to be considered. Transportation is outside the scope of this present License Amendment Request. The existing coverage is sufficient for the requested possession authorization.

7.0 DECOMMISSIONING FUND Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 10 Tel. [979] 845-7551

The decommissioning fund for each reactor will be maintained according to established requirements pursuant to 10 CFR 75.

8.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.22[b], an evaluation of this LAR has been performed to determine whether or not it meets the criteria for categorical exclusion set forth in 10 CFR 51.22[c] [9]

regarding environmental reviews. Implementation of this amendment will have no adverse impact upon the NSC site or facilities. In addition, it will not contribute to any additional quantity or type of effluent being available for adverse environmental impact or personnel exposure. It has been determined that:

There are no new or increased hazards associated with the receipt and storage of the AGN-201M reactor components or fuel. The packaged materials will be secured in robust containers and will be non-dispersible. The SNM, including the AGN-201M 239PuBe neutron start-up source, is to be stored segregated from the NSC fuel, and will remain in the NSC Fuel Storage Vault until the new building has been constructed.

Given that possession of the AGN-201M components will be restricted to storage, there are no credible scenarios that could result in new or increased effluents from the facility.

There are no projected impacts to individual or collective occupational radiation exposures. All non-radiological hazards [if any] will be addressed in accordance with state and local regulations. Therefore, this LAR and License Change Request meets the criteria of 10 CFR 51.22[c] [9] for categorical exclusion from an environmental impact statement.

9.0 SIGNIFICANT HAZARDS CONSIDERATION The proposed amendment will allow TEES to undertake storage of the AGN-201M reactor fuel, 239 PuBe neutron start-up source, and numerous components from the current location in Zachry Engineering Center, Room 61a to the TEES NSC Fuel Storage Vault for storage of fuel, the 239 PuBe neutron start-up source, and supporting equipment. The total quantity of fuel authorized for NSC site will remain unchanged. TEES has evaluated the potential for significant hazards associated with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment", as presented below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated? Response: No.

The addition of the AGN-201M fuel SNM does not require an increase to the existing fuel possession limit of 15 kilograms. No additional risks are presented by the proposed storage.

The 239PuBe neutron start-up source does not require an increase to the existing quantity of Pu authorized for possession. The packaged materials will be received, surveyed, and stored in accordance with TEES NSC procedures. Thus, the proposed activity does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated? Response: No.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 11 Tel. [979] 845-7551

The NSC facility has established procedures for shipment, receipt, and storage of radioactive materials. There are no new accidents or unevaluated scenarios presented by the receipt of AGN-201M radioactive materials [radioactive materials receipt activities are addressed in the NSC SAR and site implementing procedures].

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

There are no requested increases in the total SNM inventory, thus rendering the existing margin of safety unchanged.

The evaluation above, along with the current approved NSC procedures to receive and handle the AGN-201M materials at the NSC site demonstrates that there will be no reduction in the margin of safety and no adverse consequences to the staff and surrounding areas. Based on the preceding discussion, TEES concludes that the proposed changes do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92[c], and, accordingly, a finding of "no significant hazards consideration" is justified.

10.0 CONCLUSION

S The TAMU College of Engineering plans to construct a new building adjacent to the NSC site to support the relocation, reconstruction and operation of its AGN-201M reactor currently licensed for use at the Zachry Engineering Center. This will consolidate the university's reactor operations on two adjacent sites. In addition, the university has pressing needs for the space currently used for this reactor, and proposes an interim storage plan to allow for a thorough design phase, regulatory approval, permitting, and construction of the new building without delaying the unrelated expansion of the Zachry Engineering Center. The proposed storage does not involve any foreseeable adverse radiological impacts on the public or TAMU and TEES staff and is very similar to the approval granted to Oregon State University for storage of its AGN-201 fuel. The storage plan includes the transfer of the AGN-201M SNM to the NSC Fuel Storage Vault, pending completion of the new facility and receipt of Commission authorization to transfer it back to the AGN-201M reactor. TAMU anticipates the project will take 3 to 5 years to complete.

TEES believes that the authorizations requested in this license change and storage request are very similar to those approved by the Commission for the Oregon State University to store their AGN-201 fuel in their TRIGA facility. All activities will be performed in accordance with current NRC Rules and Regulations and the facility license, as amended. TEES believes that the information presented in this document fully justifies and supports approval of the requested changes to the license and technical specifications.

11.0 REFERENCES

Atomic Energy Commission. (1972, February 4). Letter from Donald J. Skovolt, Assistant Director for Reactor Operations, Division of Reactor Licensing, approving the relocation and reconstruction in accordance with the Construction Permit CPRR-112, and operation in the new location...

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 12 Tel. [979] 845-7551

McDeavitt, D. S. (2015, April 15). Letter from Sean M. McDeavitt, Ph.D., TAMU, to USNRC, Overview of Project Plan.

Nuclear Regulatory Commission. (1971, February 6). Letter from Eber R. Price, Director, Division of State and Licensee Relations, approving an amendment to Indemnity Agreement E-12, and the movement of the reactor from the Mechanical Engineering Shops Building to the new Engineering Center...

Nuclear Regulatory Commission. (2015, September 30). Operating License, Texas Engineering Experiment Station, Texas A&M University System, Facility License R-83, renewed in its entirety.

Nuclear Regulatory Commission. (2015, September 30). Technical Specifications and Bases, Texas Engineering Experiment Station Nuclear Science Center (NSC).

Oregon State University. (2008a, September 10). Safety Evaluation Report Related to the Renewal of the Operating License for the TRIGA Reactor at the Oregon State University, Corvallis, Oregon, ADAMS Accession No. ML082340035.

Oregon State University. (2008b, September 10). Renewed TRIGA Facility Operating License, Number R-106, Oregon State University, Corvallis, Oregon, ADAMS Accession No. ML082520047.

Texas A&M University. (2010, June). Safety Analysis Report, Facility License R-23, Docket 50-59, AGN-201M.

Texas A&M University System. (2011, May). Safety Analysis Report, Texas Engineering Experiment Station, Nuclear Science Center Reactor, Docket Number 50-128, Facility License Number R-83.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 13 Tel. [979] 845-7551

THE FOLLOWING TWO ENCLOSURES HAVE ONE PAGE FROM THE CURRENT LICENSE AND CURRENT TECHNICAL SPECIFICATION THE RECOMMENDED REPLACEMENT PAGES FOLLOW THE CURRENT PAGES Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 14 Tel. [979] 845-7551 TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:

1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.

2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:

a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;

b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,

c. to receive, possess, and use, but not separate, in connection with the operation of the facility, such special nuclear material as may be produced by the operation of the facility.

3. Pursuant to the Act and 10 CFR Part 30, the following activities are included:

a. to receive, possess, and use, in connection with the operation of the facility, a sealed antimony-beryllium neutron startup source,

b. to receive, possess, and use, in connection with the operation of the facility, a sealed 2.5-curie americium-beryllium neutron source; and,

c. to receive, possess, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which can not be separated except for byproduct material produced in reactor experiments.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 15 Tel. [979] 845-7551

4. Pursuant to the Act and 10 CFR Part 40, Domestic Licensing of Source Material, to receive, possess, and use in connection with operation of the facility, not more than 6.8 kilograms of source material.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 16 Tel. [979] 845-7551 a

PROPOSED LICENSE CHANGE FOR THE NSC FACILITY TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 __________

As Amended Through Amendment No. XX

. 2-15-2016 A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.