ML20336A020

U.S. Geological Survey Triga Reactor - License Amendment Request LAR 14, Supplemental Information Letter 04 Provided in Response to Phone Call with NRC Project Manager at 0854 Mst on 2020-11-30

ML20336A020
Person / Time
Site:	U.S. Geological Survey
Issue date:	12/01/2020
From:	Wallick J US Dept of Interior, Geological Survey (USGS)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML20336A020 (3)

Text

U.S. Geological Survey Rocky Mountain Region Box 25046 M.S. 974 Denver Federal Center Denver, Colorado 80225 Tuesday, December 01, 2020 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

SUBJECT:

U.S. Geological Survey TRIGA Reactor, Docket Number 50-274, License Number R-113, License Amendment Request LAR 14, Supplemental Information Letter 04 Provided in Response to Phone Call with NRC Project Manager at 0854 MST on 2020-11-30 Purpose By way of this letter, the U.S. Geological Survey (USGS) is providing supplemental information in order to resolve an inquiry from our NRC Project Manager during a phone call on 30 November 2020.

Discussion A request to clarify the purpose of obtaining damaged fuel as part of the larger shipment from the foreign decommissioning research reactor has been received by the GSTR from the NRC. In order to receive any of the lightly irradiated fuel from the foreign reactor facility, all of the fuel, including those elements categorized as damaged, must be taken by the GSTR. In analyzing the situation in terms of benefits and drawbacks, the following rationale is presented:

• Benefit: The GSTR is equipped with fuel for the rest of the planned lifetime of the facility, extending from 12-16 years out to 40-55 years, enabling scientific research and collaboration by the U.S. Geological Survey and many partners.

o Counterpoint: Additional fuel may be gathered from another source, but condition would be similar or worse, or cost would be orders of magnitude higher.

• Benefit: The fuel is provided at no cost to the U.S. government from the foreign reactor.

The only costs are from unpacking the fuel from the shipping container. Compared to the cost of the baskets or equivalent required to ship fuel from the facility, it is actually a net positive transaction.

o Counterpoint: Some costs do come from having the container unpacking professionally supported but is in the interest of safety and would occur no matter the fuel source, unless fresh fuel were obtained where cost of the actual fuel would be exorbitant.

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• Benefit: Manufacturing burden on TRIGA Internationals already backed up fabrication line is lessened, and they can supply university reactors more readily.

o Counterpoint: An individual organization such as USGS would be put to the back of the line in priority of Department of Energy and supported university research reactors, as DOE has put substantial funding into bringing the TRIGA International fabrication plant online.

• Benefit: By utilizing this source of fuel, approximately $10,000,000 of taxpayer money is saved as opposed to purchasing at open market prices.

o Counterpoint: Some money does need to be expended to safely unpack the shipment but does pale in comparison to $10,000,000 by a substantial degree.

• Benefit: With additional fuel inventory, a more acceptable core configuration to NRC may be adopted for thermal-hydraulic analysis, removing a previous power limit restriction.

o Counterpoint: Provides a benefit to researchers and users of the GSTR in the form of decreased irradiation times and overall higher scientific throughput of the facility.

• Drawback: Some fuel is damaged and must be kept in storage until it can be removed to the Department of Energys indefinite repository.

o Counterpoint: Fuel storage locations were not being utilized before and the methods / equipment used ensure its secure and safe storage.

• Drawback: Burden on the regulators due to the short timeline for the licensing action.

o Counterpoint: Licensing action, if properly presented, should not impose great burden on regulators, but impacts timeline of other facilities licensing actions.

• Drawback: Fuel has been previously irradiated and undergone some amount of burn up.

o Counterpoint: Amount of uranium burn up of most elements is negligible and far below the average of the fuel currently possessed by the GSTR.

With the analysis complete, it was apparent to the GSTR that the acquisition of this fuel inventory, even with the requirement of receiving the damaged elements, was of greater benefit than not accepting the fuel.

Contact If you have any questions regarding this matter, please contact me at (303) 236-4726.

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

Digitally signed by JONATHAN WALLICK Date: 2020.12.01 06:08:08 -07'00' Sincerely, Jonathan Wallick, Reactor Director Copied to:

Dr. Robert Horton, Reactor Administrator, USGS Geoffrey Wertz, Project Manager, US NRC Craig Bassett, Inspector, US NRC Attachments: None.

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