ML22181B082

University of California-Davis/McClellan Nuclear Research Center, Response to NRC Request for Additional Information Letter Dated June 24th, 2022 Regarding License Renewal Application

ML22181B082
Person / Time
Site:	University of California-Davis
Issue date:	06/30/2022
From:	Frey W McClellan Nuclear Research Center
To:	Office of Nuclear Reactor Regulation
References
Download: ML22181B082 (2)

Text

UNIVERSITY OF CALIFORNIA, DA VIS BERKELEY - DA VIS

• IRVINE

• LOS ANGELES

• MERCED - RIVERSIDE - SAN DIEGO

• SAN FRANCISCO McClellan Nuclear Research Center UNIVERSITY OF CALIFORNIA Davis (916)-614-6200 SANT A BARBARA

• SANTA CRUZ June 30th, 2022 US Nuclear Regulatory Commission 11555 Rockville Pike MS 12-03 Rockville, MD 20852-2738

SUBJECT:

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION LETTER DATED JUNE 24th 2022 REGARDING LICENSE RENEWAL APPLICATION FOR THE UNIVERSITY OF CALIFORNIA-DAVIS/MCCLELLAN NUCLEAR RESEARCH CENTER.

The purpose of this letter is to provide a response to the RAI letter received by UCD/MNRC from the NRC on June 24th 2022.

NRC RA/ Question 1. The current LC 2.8.(ii) states, in part, "21.0 kilograms of contained uranium-235 enriched to less than 20 percent in the isotope uranium-235 in the form of reactor fuel." The NRG staff proposes to restate this as LC 2.8.2.a below. However, the NRG staff notes that it exceeds the 10 kilogram limit for "Special nuclear material of low strategic significance,"

item (2), as defined in 1 O CFR 73. 2, "Definitions," and requests a justification for this amount of uranium-235.

UCD/MNRC Response: UCD/MNRC does not require a limit of 21.0 kilograms of uranium-235 enriched to less than 20 percent in the isotope uranium-235 in the form of reactor fuel. Based on the current fuel inventory (spent fuel, unirradiated fuel, and in-core fuel) and fuel guaranteed to be delivered to MNRC by DOE over the next few years, the MNRC requires a U-235 possession limit of 16.0 kilograms.

NRC RA/ Question 2. The NRG staff review finds no information as to whether any of the current TR/GA fuel has been previously used (irradiated) at other facilities. Confirm if any of the current TR/GA fuel has been previously irradiated at other facilities.

UCD/MNRC Response: No fuel at UCD/MNRC has ever been previously irradiated at other facilities.

NRC RA/ Question 3. The current LC 2.8.(iii) states, in part, "small instrument calibration and check sources of less than 0. 1 millicurie each." The NRG staff proposes to restate this as LC 2.8.3.c. below. However, the NRG staff finds that there is no limit on the total curie amount for the instrument calibration and check sources. Provide a curie limit for the total instrument calibration and check sources needed to support operation of the UCDIMNRC facility.

UCD/MNRC Response: UCD/MNRC proposes a total curie limit of 10.0 mCi for the instrument calibration and check sources needed to support operation of the UCD/MNRC facility. To clarify, these sources are not produced by the UCD/MNRC reactor and may not be used in reactor-based experiments.

NRC RA/ Question 4. The current LC 2.B.(4).A, states, in part, "[a]ny radioactive material between atomic number 1 through 83, inclusive," with respect to "[r]adioactive [m]aterial (element and mass number)," "[a]ny" with respect to "[c]hemical and/or [p]hysical [f]orm," and "20 [c]uries (1 [c]urie each, except as provided below)" with respect to "[m]aximum [q]uantity.... " The NRG staff proposes to restate this as LC 2.8.3.d.below. However, the NRG staff needs to better understand the source of the material and the need for 20 curies. Provide the source of the material and a justification for the proposed quantity of 20 curies.

UCD/MNRC Response: UCD/MNRC proposes the following revised language for LC 2.8.3.d:

"up to 5.0 curies of byproduct material used in reactor-based experiments, in sources for calibration of radiation detectors, and reference sources for use in reactor-based analytic techniques" I declare under penalty of perjury that the foregoing is true and correct executed on June 30th, 2022.

~

rely,

~.~o Facility Director