ML20279A591

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U.S. Geological Survey - Regulatory Audit Proposed License Amendment No. 14 Tt Increase the Special Nuclear Material Possession Limit
ML20279A591
Person / Time
Site: U.S. Geological Survey
Issue date: 10/06/2020
From: Geoffrey Wertz
NRC/NRR/DANU/UNPL
To: Horton R
Denver Federal Center, US Dept of Interior, Geological Survey (USGS)
Wertz G, NRR/DANU/UNPL, 301-415-0893
References
EPID L-2020-LLA-0201
Download: ML20279A591 (7)


Text

October 6, 2020 Mr. Robert Horton, Reactor Administrator U.S. Geological Survey Denver Federal Center P.O. Box 25046, MS 911 Denver, CO 80225-0046

SUBJECT:

U.S. GEOLOGICAL SURVEY - REGULATORY AUDIT RE: PROPOSED LICENSE AMENDMENT NO. 14 TO INCREASE THE SPECIAL NUCLEAR MATERIAL POSSESSION LIMIT (EPID L-2020-LLA-0201)

Dear Mr. Horton:

By letter dated October 1, 2020 (Agencywide Documents Access and Management System Accession No. ML20275A267), U.S. Geological Survey (USGS) staff applied for an amendment to Renewed Facility Operating License No. R-113 for the USGS TRIGA Research Reactor. The license amendment request (LAR) proposes to increase the special nuclear material possession limit of the license to receive, possess, but not use or separate, in connection with the operation of the facility, up to 4 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel.

The U.S. Nuclear Regulatory Commission (NRC) staff will conduct an onsite regulatory audit on October 15, 2020, and continue the audit remotely (via teleconference) as necessary throughout the review period, in order to expedite the NRC staff review. The intent of the audit is to gain a better understanding of the LAR. In addition, the regulatory audit will identify information that will support the basis of the licensing decision, or needs to be docketed, and will allow the NRC staff to efficiently gain insights necessary to complete the review of the USGS LAR. The NRC staff has provided a copy of the audit plan as an enclosure to this letter.

At the completion of the regulatory audit, a regulatory audit summary will be prepared and provided to you. If necessary, you will have the opportunity to supplement the application to provide additional information, or the option to withdraw the application.

We appreciate your support in providing space, the requested documentation and access to the necessary personnel and other materials that will assist in an efficiently conducted audit.

R. Horton If you have any questions regarding the NRC staffs audit, please contact me at 301-415-0893, or by electronic mail at Geoffrey.Wertz@nrc.gov.

Sincerely,

/RA/

Geoffrey A. Wertz, Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-274 License No. R-113

Enclosure:

As stated cc: See next page

U.S. Geological Survey Docket No. 50-274 cc:

Brian Nielsen Environmental Services Manager 480 South Allison Parkway Lakewood, CO 80226 Steve Tarlton State of Colorado Radiation Management Program HMWM-RM-B2 4300 Cherry Creek Drive South Denver, CO 80246 Jonathan Wallick, Reactor Supervisor U.S. Geological Survey P.O. Box 25046, MS 974 Denver Federal Center Denver, CO 80225 Test, Research and Training Reactor Newsletter Attention: Amber Johnson Dept. of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

ML20279A591 *concurred via email NRR-106 OFFICE NRR/DANU/UNPL/PM* NRR/DANU/UNPL/LA* NRR/DANU/UNPL/BC* NRR/DANU/UNPL/PM*

NAME GWertz NParker GCasto GWertz DATE 10/6/2020 10/6/2020 10/6/2020 10/6/2020 OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT PLAN REGARDING PROPOSED AMENDMENT NO. 14 TO RENEWED FACILITY OPERATING LICENSE NO. R-113 U.S. GEOLOGICAL SURVEY U.S. GEOLOGICAL SURVEY TRIGA RESEARCH REACTOR DOCKET NO. 50-274

Background

The U.S. Nuclear Regulatory Commission (NRC) staff is continuing its review of the U.S.

Geological Survey (USGS) TRIGA Research Reactor license amendment request (LAR),

provided by letter dated October 1, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20275A267). The LAR proposes to increase the special nuclear material (SNM) possession limit of the license to receive and possess, but not to use or separate, in connection with the operation of the facility, up to 4 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel from a foreign research reactor. This regulatory audit is intended to assist the NRC staff in its review of the LAR.

Regulatory Audit Bases The purpose of this audit is to determine if the licensees proposed LAR requesting an increase in the SNM possession limit meets all the applicable regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) and addresses applicable guidance provided in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Part 1, Format and Content, and Part 2, Standard Review Plan and Acceptance Criteria (ADAMS Accession Nos. ML042430055 and ML042430048, respectively).

Regulatory Audit Scope The NRC staff will tour the facility to gain an understanding of the licensees fuel storage plan, review the applicable USGS safety analysis report (SAR) design bases, determine if any technical specification (TS) requirements are necessary, and review applicable processes and procedures needed for maintaining the safe and secure possession of the additional TRIGA reactor fuel. This audit will provide information necessary to complete the NRC staffs evaluation of the LAR. In addition, the regulatory audit may identify additional information that will be required to be docketed to support the basis of the licensing decision and will allow NRC staff to efficiently gain insights for the LAR.

Information and Other Material Necessary for the Regulatory Audit USGS staff should be prepared to support the NRC staff with a comprehensive tour of the facility, including observation of the proposed fuel storage locations. A copy of the licensees Enclosure

current SAR, TSs, physical security plan, emergency plan, Operator Requalification Program, and Operating Procedures should also be made available to the NRC staff.

The following information, most of which was referenced in the LAR, should be available for the audit includes:

  • K-effective information on the proposed fuel storage configurations
  • Certificate of Compliance No. 9225, revision 69, docket 71-9225, package ID USA/9225/B(U)F-96
  • Nuclear Assurance Corporation drawings 315-40-086, 087, and 088
  • Benchmarking criticality analysis of TRIGA fuel storage racks, Applied Radiation and Isotopes, issue 119 (2017)
  • TRIGA Fuel Element Examination sheet, FRM-898 Team Assignments The NRC staff performing this audit will be:
  • Molly-Kate Gavello (Technical Reviewer)

Logistics The audit will initiate on Thursday, October 15, 2020, with an entrance meeting, and will involve up to one day on-site, consisting of a focused review between the NRC staff and USGS staff, as agreed by teleconference on September 24, 2020. Following the on-site audit review on October 15, 2020, the audit period will continue remotely (via teleconference) as necessary until the NRC staff have adequate understanding of issues to be addressed to complete the review of the LAR.

Audit Questions Audit questions will be provided during and following the on-site tour and detailed review of the proposed storage locations. The NRC staff will generate a list of open items, if any, during the audit to discuss and close as applicable. At the conclusion of the audit, necessary requests for additional information (RAIs) will be drafted to ensure the licensee has a clear understanding of the RAI scope.

Deliverables At the completion of the regulatory audit the NRC staff will prepare a regulatory audit summary, which will be issued by letter, within 90 days after the audit. The regulatory audit summary will include the documents reviewed, the audit activities, and any RAIs that were discussed, or that will be issued based on the audit, as applicable.

Audit Schedule The NRC staff will conduct the on-site portion of the audit during a site visit on October 15, 2020. Additional audit interaction will continue remotely (via teleconference) as necessary.