ML22038A140

Regents of the University of California - Request for Additional Information Regarding License Renewal Application for the University of California - Davis/Mcclellan Nuclear Research Center

ML22038A140
Person / Time
Site:	University of California-Davis
Issue date:	02/08/2022
From:	Geoffrey Wertz NRC/NRR/DANU/UNPL
To:	Mohapatra P McClellan Nuclear Research Center
Wertz G
References
EPID L-2020-NFR-0002
Download: ML22038A140 (7)

Text

P. Mohapatra Dr. Prasant Mohapatra Vice Chancellor for Research Department of Computer Science University of California Davis, CA 95616

SUBJECT:

REGENTS OF THE UNIVERSITY OF CALIFORNIA - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE RENEWAL APPLICATION FOR THE UNIVERSITY OF CALIFORNIA - DAVIS/MCCLELLAN NUCLEAR RESEARCH CENTER (EPID NO. L-2020-NFR-0002)

Dear Dr. Mohapatra:

By letter dated June 11, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18179A501), the Regents of the University of California submitted a license renewal application (LRA) for a 20-year renewal of the Class 104c Facility Operating License No. R 130, Docket No. 50 607, for the University of California - Davis McClellan Nuclear Research Center Training, Research, Isotope, General Atomics nuclear reactor. By letter dated July 6, 2020 (ADAMS Accession No. ML20188A368), the licensee updated its LRA to reflect its decision to reduce the licensed thermal operating power level from 2.3 megawatt thermal (MWt) to 1.0 MWt, and to eliminate pulsing capability and irradiation of explosive materials in the reactor tank.

The U.S. Nuclear Regulatory Commission (NRC) staff identified additional information needed to continue its review of the LRA, as described in the enclosed request for additional information (RAI). As discussed by telephone on February 1, 2022, provide a response to the RAI or a written request for additional time to respond, including the proposed response date and a brief explanation of the reason, by 30 days from the date of this letter. Following receipt of the complete response to the RAI, the NRC staff will continue its review of the LRA.

The response to the RAI must be submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.4, Written communications, and pursuant to 10 CFR 50.30(b), Oath or affirmation, be executed in a signed original document under oath or affirmation. Information included in the response that you consider sensitive or proprietary, and seek to have withheld from public disclosure, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Any information related to safeguards should be submitted in accordance with 10 CFR 73.21, Protection of Safeguards Information:

Performance Requirements.February 8, 2022 If you have any questions regarding the NRC staffs review or if you intend to request additional time to respond, please contact me at (301) 415-0893, or by electronic mail at Geoffrey.Wertz@nrc.gov.

Sincerely, Geoffrey 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. 50-607 License No. R-130

Enclosure:

As stated cc: See next page Signed by Wertz, Geoffrey on 02/08/22

University of California-Davis/McClellan Docket No. 50-607

cc:

David Reap, Radiation Safety Officer 5335 Price Avenue, Bldg. 258 McClellan, CA 95652-2504

California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814

Radiologic Health Branch California Department of Public Health P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414

Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

Dr. Wesley D. Frey, Reactor Director McClellan Nuclear Research Center University of California, Davis 5335 Price Avenue, Building 258 McClellan, CA 95652-2504

ML22038A140 NRR-088 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME GWertz NParker JBorromeo GWertz DATE 02/07/2022 02/07/2022 02/08/2022 02/08/2022 OFFICE OF NUCLEAR REACTOR REGULATION

REQUEST FOR ADDITIONAL INFORMATION

REGARDING RENEWAL OF FACILITY OPERATING LICENSE NO. R-130

UNIVERSITY OF CALIFORNIA-DAVIS/MCCLELLAN NUCLEAR RESEARCH CENTER

DOCKET NO. 50-607

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the license renewal application (LRA) for compliance with Title 10 of the Code of Federal Regulations (10 CFR) using the following guidance and standard(s):

The regulation, 10 CFR 20.1101, Radiation protection programs, item (d) requires, in part, a constraint on air emissions of radioactive material to the environment such that the individual member of the public likely to receive the highest dose will not be expected to receive a total effective dose equivalent in excess of 10 millirem (mrem) per year from these emissions.

NUREG-1537 Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, issued February 1996 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML042430055)

NUREG-1537 Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Standard Review Plan and Acceptance Criteria, issued February 1996 (ADAMS Accession No. ML042430048)

Interim Staff Guidance for the Streamlined Research Reactor License Renewal Process, A. Adams to K. Brock, October 15, 2009 (ADAMS Accession Nos. ML092240256 and ML092240244)

The NRC staff reviewed the University of California-Davis (UCD), McClellan Nuclear Research Center updated safety analysis report (SAR) (redacted version ADAMS Accession No. ML20238B984), and the Environmental Report (redacted version ADAMS Accession No. ML20238B993), submitted by letter dated July 6, 2020.

As part of the LRA review, the NRC staff also reviewed the annual reports for calendar years (CYs): CY 2020, ADAMS Accession No. ML21175A335; CY 2019, ADAMS Accession No. ML20188A338; CY 2018, ADAMS Accession No. ML20062C059; CY 2017, ADAMS Accession No. ML18178A602; CY 2016, ADAMS Accession No. ML17181A173; CY 2015 (corrected copy), ADAMS Accession No. ML17181A174; CY 2014, ADAMS Accession No. ML15191A047; CY 2013, ADAMS Accession No. ML14183A016; CY 2012, ADAMS Accession No. ML13169A248; CY 2011, ADAMS Accession No. ML12178A445; CY 2010, ADAMS Accession No. ML11180A268; CY 2009, ADAMS Accession No. ML101820075; CY 2005, ADAMS Accession No. ML061780163.

Enclosure

Based on its review, the NRC staff requires the following additional information to continue its review of the LAR.

The regulation, 10 CFR 20.1101, Radiation protection programs, item (d) requires, in part, a constraint on air emissions of radioactive material to the environment such that the individual member of the public likely to receive the highest dose will not be expected to receive a total effective dose equivalent in excess of 10 mrem per year from these emissions. The guidance in NUREG-1537, Part 1, Section 11.1.1.1, Airborne Radiation Sources, states, in part, that the application should discuss and provide calculations that show how the facility design ensures that doses to the public will not exceed 10 CFR Part 20 limits and that its ALARA requirements for effluents are satisfied.

The NRC staff review of the licensees annual reports for CYs 2009 through 2020 finds that the total estimate dose from Argon-41 (Ar-41) for unrestricted area in Table 2, 2009 Summary of Airborne Effluents, of the CY 2009 and Table 1, 2020 Summary of Airborne Effluents, of the CY 2020 appear to exceed the 10 mrem dose limit, with the highest doses to a member of the public from the release of Ar-41 of 10.36 mrem, and 12.80 mrem, respectively. Further, the NRC staff noted that the column titles in the respective tables indicate estimated quantities, concentrations, and doses, whereas the description in the annual reports indicate actual releases.

Further, the NRC staff reviewed the updated SAR, Appendix A, Radiological Impact of Ar-41, N-16, Fission Products, and Activated Materials During Normal Operations (referenced in Table 1, Note (2)), and could not understand: 1) the continuous effluence rate Ar-41 of 2.0E-06

µCi/ml (SAR page A-4, Section A.4); and, 2) the delusion [dilution] factor of 4640 (SAR page A-6), Further, the NRC staff could not determine the basis for the 2020 Annual Report, Table 1, Note (2), describing the Ar-41 concentration to dose relationship of 2.3E-10 micro-Curies per milliliter (µCi/ml) for one year equals 1.4 mrem, based on calculations techniques described in SAR Appendix A.

The NRC staff noted that the annual dose to the unrestricted area reported in the UCD LRA Environmental Report, Figure 20, Off-Site Maximum Exposed Individual from Ar-41 Effluence

[Effluent], for CY 2005 was approximately 0.2 mrem, whereas the CY 2005 Annual Report indicated a dose of 2.19 mrem.

In order for the NRC staff to complete its review and confirm that the operation of the UCD reactor has been compliant with the dose constraint of 10 CFR 20.1101(d) that the highest exposed member of the public did not receive more than 10 mrem per year, provide the following information:

1. Provide an explanation of the first column of the CY 2020 Annual Report, Table 1, Summary of Airborne Effluents, including if the Ar-41 quantity is estimated, as indicated in the title, or measured as a release, as described in Section 8.0, Radioactive Effluents, preceding the Table 1.

2. In the remaining six columns in the CY 2020 Annual Report, Table 1, for each column:

a. indicate if the column titles accurately describe the information listed in each column, and

b. provide an example of any calculations used for the numerical values provided.

3. For annual reports for CYs 2009 through 2020, provide updated Summary of Airborne Effluents, tables.

4. Provide the calculational methodology used in the 2020 UCD LRA SAR Appendix A, for determination of the:

a. Ar-41 effluent concentration of 2.0E-06 µCi/ml;

b. Delusion [Dilution] factor of 4640; and

c. Ar-41 concentration to dose relationship described in the 2020 Annual Report, Table 1, Note (2), of 2.3E-10 µCi/ml continuous for one year equals 1.4 mrem.

5. Explain the apparent discrepancy for the dose from Ar-41 between the UCD LRA Environmental Report, Figure 20 and the CY 2005 Annual Report of 0.2 mrem and 2.19 mrem, respectively. Provide updated Figure 20.