ML19053A521

University of Texas, Request for Possession Limit Change of License R-129

ML19053A521
Person / Time
Site:	University of Texas at Austin
Issue date:	02/18/2019
From:	Whaley P University of Texas at Austin
To:	Geoffrey Wertz Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19053A521 (5)

Text

coll.EGE OF ENGINEERING THE UNIVERSIIT OF TEXAS AT AUSTIN Department ofMfChanical Engineering* 1 University Station C2200 *Austin, Texas 78712-0292 Telephone(512)471-113 l FAX (512)471-8727 02/18/2018 ATTN: Document Control Desk Nuclear Regulatory Commission Washington, DC 20555-0001 Geoffrey Wertz, P.E.

Research and Test Reactors Branch

SUBJECT:

Docket No. 50-602, Request for Possession Limit Change of License R-129 Sir:

In 2018 an 'internal audit of the University of Texas reactor license and Technical Specifications identified inconsistencies between the possession limits for accountable uranium foils as stated in the facility license and the quantity of the materials in possession as identified by physical inventory. Radiological assay is now complete, and we are requesting an amendment to the facility operating license (R-129) paragraph 2.8.(2) to resolve the discrepancy.

The propose revisions and rationale for each are:

• In (2): The words "Domestic Licensing of Special Nuclear Material," are removed

• In (2): The words {with "contained uranium-235" referring to uranium enriched in uranium-235} are added to differentiate "contained uranium-235" from physical containment

• In (2) (a) (i), the words "but not separate," are added

• In (2) (a) (iii) a colon is added to denote a list of independent items

• In (2) (a) (iii) the possession limit previously "1.0 gram of contained uranium-235 of any enrichment," is revised to "30.0 grams of contained uranium-235 of any enrichment,"

• In (2) (a) (iv) "up to:" is added to denote a list of independent items

• In (2) (a) (v), the words "but not separate," are added

• In (2) (c) the words "contained in TRIGA fuel" are added to differentiate experimental activities and to be consistent with (2) (b ).

• The proposed change reads as follows:

(2) Pursuant to the Act and 10 CFR Part 70, in connection with the operation of the facility (with "contained uranium-235" referring to uranium enriched in uranium-235):

(a) to receive, possess and use:

(i) but not separate, up to 9.5 kilograms of contained uranium-235 enriched to less than 20 percent 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, 30.0 grams 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) up to: 1.0 gram of plutonium-239, and 10 grams of contained uranium-235 of any enrichment in the form of reference materials; (v) but not separate, up to 150 grams of plutonium in the form of 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 materials 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 contained in TRIGA fu~I as may be produced by the operation of the facility.

The security classificationlcategorization of 10 CFR Part 73 (Category I, Special nuclear material of low strategic significance) is unchanged. The possession limits for combiqed quantity of contained U-235, U-233 and plutonium remains well below the threshold for a special nuclear material of moderate significance. Therefore, the Physical Security Plan is not affected by this change.

The Radiological Protection Program, and the Emergency Plan are not affected by this change. This change does not require a reyision to the Safety Analysis Report or the

. Technical Specifications. No facility changes are required for this proposed amendment.

• Small quantities of special nuclear material are routinely produced in experimental activities at the facility. Sample processing is sometimes required to accomplish research goals. Revising the specification in (c) with "contained in TRIGA fuel" clarifies

that the possession limit does not interfere with standard research programs permitted for materials in (2) except as specified.

Therefore, this proposed increase in possession limit for uranium-235 contained in uranium in the form of foils from 1.0 gram to 30.0 grams does not significantly change the possession limits for uranium-235, and there is reasonable assurance that the health and safety of the public will not be endangered by this proposed amendment.

If there are any questions, please feel free to contact P. M. Whaley at whaley@maiL_~texas:edu or512 232 5374.

SLrely...---)_IJ

~ -

. M. w~~;e;/

I declare under penalty of perjury that the foregoing is true and correct.

W. S. Charlton

. 1 Att: Attachment 1, Technical Specifications, paragraph 2.8.(2)

Attachment 2, Markup for Proposed Technical Specifications, Paragraph 2.8.(2)

Attachment 1, Technical Specifications, Paragraph 2.B.(2)

(2) Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nl.Jclear Material.II In connection with operation of the facility:

(a) to receive, possess and use:

(i) up to 9.S_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 1O*grams of contained uranium-235 of any enrichment in the form of reference materials:

(v) 150 grams of pluton_ium 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.

Attachment 2, Markup for Proposed Technical Specifications, Paragraph 2.8.(2)

(2) Pursuant to the Act and 10CFR Part 70, f'Domestic Licer 1sh ig of S13ecial NJ *clear I l"Ma@:@J in connection with operation of the facility: ,

I\

(with "contained uranium-235" referring a to receive, possess and use:

but not to separate o uranium enriched in uranium-235)

(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 ~f fission chambers; [~~ @

(iii) up ~-0 gram of uranlum-233, . gram of contained uranium-235 of any enrichment, 1.Qgram of plutonium-240, 1.0 gram of dutoniu~-239, and 1.0 gram of plutonium-241 in the form of foils; (iv) iw.o gram of plutonium-239, and 10 grams of contained uranium-

~ - - - - - - - " ~ of any enrichment in the form of reference materials; but not to separate (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.

contained in TRIGA fuel