ML16103A249

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Review of Proposed License Conditions for Texas A&M University Agn License Amendment Supporting Relocation
ML16103A249
Person / Time
Site: Texas A&M University
Issue date: 04/12/2016
From: Patrick Boyle
NRC/NRR/DPR/PRLB
To: Mcdeavitt S
Texas A&M Univ
Boyle P, NRR/DPR, 301-415-3936
References
Download: ML16103A249 (2)


Text

From: Boyle, Patrick Sent: Tuesday, April 12, 2016 9:49 AM To: Dr. Sean McDeavitt Cc: Jerry Newhouse (newhouse@tamu.edu); 'Jeremy Osborn'; Adams, Alexander; Helvenston, Edward; Boyle, Patrick

Subject:

Review of Proposed License Conditions for Texas A&M University AGN license amendment supporting relocation Dr. McDeavitt, As we discussed on the phone, the facility operating license conditions proposed in your letter dated March 3, 2016 (ML16063A384) for the AGN reactor do not support the intended condition of the AGN reactor and associated components once the core (AGN fuel) has been transferred to the R-83 license and the non-core components relocated to the NSC. I have highlighted the area of each condition than needs to be revised and I have suggested some possible wording that can be used for these license conditions. As we discussed, the key to developing the license conditions is considering what will be in place at the time the amended license takes effect. The effective date of the license amendment will be predicated on the transfer of the material from the Zachry building to the NSC storage location and onto the TRIGA (R-83) license. You proposed the following license condition for section 2.B:

In this case, at the effective date of the license amendment, the license should become a possession only license, so the conditions allowing use and operate should be deleted or negated (but not use, etc.).

You proposed the following license condition for section 2.B:

Condition (2) should be deleted in its entirety as the AGN fuel (700 grams of contained uranium 235) and Pu-Be neutron source have their physical and regulatory control transferred to the R-83 license and would not need to appear on the R-23 license at all when the amended license takes effect.

You proposed the following license condition for section 2.B:

Condition (3) needs to remain in place, but with some modifications. The intention of condition (3) is to allow storage of the reactor core tank, shield tank, supports, and additional equipment at the NSC. It can be assumed that some activation of the non-fuel components has occurred which would produce small amounts of material that would be governed by 10 CFR Part 30. It is also possible, that some of the transuranic material (Part 70) produced in the fuel could have been deposited on the surfaces of the core tank from direct contact with the fuel. So, the Part 70 possession also needs to remain. What needs to be deleted from this license condition is any reference to the R-83 license. Also, it would make sense to indicate that the byproduct and special nuclear material production had occurred in the past. This can be achieved by changing the statement about as may be produced to as may have been produced by previous operation or some similar statement.

Please contact me with any questions or to discuss these concerns.

Patrick G. Boyle Nuclear Engineer - U.S.NRC Project Manager for Texas A&M University AGN reactor (301)415-3936 Office O-12C02; Mailstop O-12D20 Office of Nuclear Reactor Regulation, Division of Policy and Rulemaking Research and Test Reactors Licensing branch Docket Number 50-59 License Number R-23

From: Boyle, Patrick Sent: Tuesday, April 12, 2016 9:49 AM To: Dr. Sean McDeavitt Cc: Jerry Newhouse (newhouse@tamu.edu); 'Jeremy Osborn'; Adams, Alexander; Helvenston, Edward; Boyle, Patrick

Subject:

Review of Proposed License Conditions for Texas A&M University AGN license amendment supporting relocation Dr. McDeavitt, As we discussed on the phone, the facility operating license conditions proposed in your letter dated March 3, 2016 (ML16063A384) for the AGN reactor do not support the intended condition of the AGN reactor and associated components once the core (AGN fuel) has been transferred to the R-83 license and the non-core components relocated to the NSC. I have highlighted the area of each condition than needs to be revised and I have suggested some possible wording that can be used for these license conditions. As we discussed, the key to developing the license conditions is considering what will be in place at the time the amended license takes effect. The effective date of the license amendment will be predicated on the transfer of the material from the Zachry building to the NSC storage location and onto the TRIGA (R-83) license. You proposed the following license condition for section 2.B:

In this case, at the effective date of the license amendment, the license should become a possession only license, so the conditions allowing use and operate should be deleted or negated (but not use, etc.).

You proposed the following license condition for section 2.B:

Condition (2) should be deleted in its entirety as the AGN fuel (700 grams of contained uranium 235) and Pu-Be neutron source have their physical and regulatory control transferred to the R-83 license and would not need to appear on the R-23 license at all when the amended license takes effect.

You proposed the following license condition for section 2.B:

Condition (3) needs to remain in place, but with some modifications. The intention of condition (3) is to allow storage of the reactor core tank, shield tank, supports, and additional equipment at the NSC. It can be assumed that some activation of the non-fuel components has occurred which would produce small amounts of material that would be governed by 10 CFR Part 30. It is also possible, that some of the transuranic material (Part 70) produced in the fuel could have been deposited on the surfaces of the core tank from direct contact with the fuel. So, the Part 70 possession also needs to remain. What needs to be deleted from this license condition is any reference to the R-83 license. Also, it would make sense to indicate that the byproduct and special nuclear material production had occurred in the past. This can be achieved by changing the statement about as may be produced to as may have been produced by previous operation or some similar statement.

Please contact me with any questions or to discuss these concerns.

Patrick G. Boyle Nuclear Engineer - U.S.NRC Project Manager for Texas A&M University AGN reactor (301)415-3936 Office O-12C02; Mailstop O-12D20 Office of Nuclear Reactor Regulation, Division of Policy and Rulemaking Research and Test Reactors Licensing branch Docket Number 50-59 License Number R-23