ML23279A081

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Abilene Christian University, Report on the Pre-Submittal Regulatory Audit Related to Physical Security for the Molten Salt Research Reactor
ML23279A081
Person / Time
Site: Abilene Christian University
Issue date: 11/13/2023
From: Edward Helvenston
NRC/NRR/DANU/UNPL
To: Michael Wentzel
NRC/NRR/DANU/UAL2
References
EPID L-2023-NFN-0008
Download: ML23279A081 (7)
v • d • e


Text

November 13, 2023 MEMORANDUM TO: Michael Wentzel, Branch Chief Advanced Reactor Licensing Branch 2 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Signed by Helvenston, Edward FROM: Edward Helvenston, Project Manager on 11/13/23 Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation

SUBJECT:

REPORT ON THE PRE-SUBMITTAL REGULATORY AUDIT RELATED TO PHYSICAL SECURITY FOR THE MOLTEN SALT RESEARCH REACTOR (EPID L-2023-NFN-0008)

The U.S. Nuclear Regulatory Commission (NRC) staff audited Abilene Christian University (ACU) preliminary plans and Science and Engineering Research Center building features for security for ACUs proposed Molten Salt Research Reactor (MSRR), and ACUs preparations and readiness to submit a physical security plan with an MSRR operating license application.

The audit plan, dated July 13, 2023, is provided in the NRCs Agencywide Documents Access and Management System (ADAMS) under Accession No. ML23194A064. The audit was conducted during July and August 2023, at the ACU campus in Abilene, Texas, and via teleconference.

Docket No.: 05000610

Enclosure:

Audit Report CONTACT: Edward Helvenston, NRR/DANU/UNPL (301) 415-4067

M. Wentzel

SUBJECT:

REPORT ON THE PRE-SUBMITTAL REGULATORY AUDIT RELATED TO PHYSICAL SECURITY FOR THE MOLTEN SALT RESEARCH REACTOR (EPID L-2023-NFN-0008) DATE: NOVEMBER 13, 2023 DISTRIBUTION:

PUBLIC RidsNrrDanuUal1 Resource RidsNrrDanuUal2 Resource RidsNrrDanu Resource RRivera, NRR MGhazali, NRR BTravis, NRR EHelvenston, NRR MWentzel, NRR EReed, NRR TTate, NRR CSmith, NRR ADAMS Accession Number: ML23279A081 NRR-106 OFFICE NRR/DANU/UNPL:PM NRR/DANU/UAL2:LA NRR/DANU/UARP:SS NAME EHelvenston CSmith EReed DATE 10/26/2023 11/6/2023 11/9/2023 OFFICE NRR/DANU/UNPO:BC NRR/DANU/UAL2:BC NRR/DANU/UNPL:PM NAME TTate MWentzel EHelvenston DATE 11/9/2023 11/13/2023 11/13/2023 OFFICIAL RECORD COPY

ABILENE CHRISTIAN UNIVERSITY

SUMMARY

REPORT ON THE PRE-SUBMITTAL REGULATORY AUDIT RELATED TO PHYSICAL SECURITY FOR THE MOLTEN SALT RESEARCH REACTOR July - August 2023

1.0 BACKGROUND

By letter dated August 12, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22227A202), as supplemented by letter dated October 14, 2022 (ML22293B816), Abilene Christian University (ACU) submitted to the U.S. Nuclear Regulatory Commission (NRC), an application for a construction permit (CP) for its planned Molten Salt Research Reactor (MSRR), including a preliminary safety analysis report (PSAR). The MSRR would be located in the Science and Engineering Research Center (SERC) building on the ACU campus. By letter dated November 18, 2022 (ML22313A097), the NRC accepted ACUs CP application for docketing and initiated the detailed technical review of the CP application. The PSAR states that ACU will submit an operating license (OL) application for the MSRR at a future date, and that an OL application would include a description of the security plan for the facility.

ACU requested an audit to provide the NRC staff an opportunity to assess ACUs preliminary plans and SERC building features for MSRR physical security, and ACUs preparations and readiness to submit a physical security plan (PSP) with an MSRR operating license application.

Prior to the audit, the NRC staff held two pre-application meetings with ACU related to security on November 3, 2020 (ML20317A093), and April 13, 2023 (ML23193A347).

2.0 AUDIT REGULATORY BASES The bases for the audit were the regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Physical Protection of Plants and Materials, particularly 10 CFR 73.37, Requirements for physical protection of irradiated reactor fuel in transit, 10 CFR 73.57, Requirements for criminal history records checks of individuals granted unescorted access to a nuclear power facility, a non-power reactor, or access to Safeguards Information, and 10 CFR 73.67, Licensee fixed site and in-transit requirements for the physical protection of special nuclear material of moderate and low strategic significance, as well as the regulations in 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material.

The NRC staff also conducted the audit considering information in:

  • Staff Requirements Memorandum (SRM)-COMSECY-17-0008, Staff Requirements -

COMSECY-17-0008 - Physical Protection for Non-Power Production and Utilization Facilities Intending to Produce Molybdinum-99, dated August 1, 2017

  • SRM-18-0063, Staff Requirements - SECY-18-0063 - Response to Staff Requirements Memorandum (SRM)-COMSECY-17-0008 on Physical Protection for Non-power Production and Utilization Facilities Intending to Produce Molybdenum-99, dated September 26, 2019

COMSECY-17-0008, SRM-COMSECY-17-0008, SECY-18-0063, and SRM-18-0063 listed above contain security-related information and are withheld from public disclosure.

3.0 AUDIT PURPOSE AND OBJECTIVES The purpose and objectives of the audit were to allow the NRC staff to assess ACUs preliminary plans and SERC building features for MSRR security, and ACUs preparations and readiness to submit a PSP with an MSRR operating license application, such that the NRC staff could: (1) identify any potential security measures or information that may be missing from ACUs preliminary assessment of security needs, (2) identify technical or regulatory issues that may complicate the acceptance or technical reviews of an OL application including a PSP, and (3) become familiar with the planned MSRR design and operations, SERC facility, and potential content of an OL application and PSP, particularly in areas relevant to security.

4.0 SCOPE OF THE AUDIT AND AUDIT ACTIVITIES The audit was conducted during July and August 2023, primarily during a site visit at the ACU campus in Abilene, Texas on July 26, 2023, which included discussions with ACU personnel and a tour of the SERC building. The NRC staff conducted the audit in accordance with the pre-application audit plan dated July 13, 2023 (ML23194A064). There were no significant deviations from the audit plan.

NRC staff audit team members included:

Edward Helvenston Project Manager (responsible for audit logistics)

Elizabeth Reed Project Manager, Security Specialist Boyce Travis Sr. Nuclear Engineer Prior to the onsite audit, on July 18, 2023, the NRC staff provided ACU with a list of questions and topics to inform discussion during the audit site visit. This ACU-specific document was developed considering information discussed in the pre-application meetings related to security and the characteristics of the proposed MSRR facility as described in the PSAR. The document contains security-related information and is withheld from public disclosure.

The NRC staff did not acquire any documents during the audit.

5.0

SUMMARY

OF OBSERVATIONS The NRC staffs summary of observations listed below is based on the notes taken by the NRC staff during the onsite audit. The audit was intended to identify any potential security measures or information that may be missing from ACUs preliminary assessment of security needs and identify any challenging technical or regulatory issues that may complicate the acceptance or technical reviews of an OL application including a PSP. The NRC staff also used the audit to

gain familiarity with the planned MSRR design and operations, to aid in determining the security requirements that may be applicable during the NRC staffs review of a PSP. The NRC staff made or provided the following general observations:

  • The NRC staff expects that, in addition to the specific requirements in 10 CFR Part 73, the MSRR will also be subject to supplemental security measures (SSMs) similar to those described in, for example, COMSECY-17-0008.
  • Based on the quantity and form of special nuclear material (SNM) that will be present at the MSRR, the NRC staff expects that the SNM at the MSRR will be SNM of moderate strategic significance (i.e., Category II) and moderately-dilute, pursuant to 10 CFR Part 73 definitions and the Rulemaking for Enhanced Security of Special Nuclear Material, Regulatory Basis Document, framework for determining necessary security measures.
  • Based on the expected classification of the MSRR facility for the security of SNM, the NRC staff discussed SSMs that may be applicable for the MSRR and provided feedback on ACUs preliminary plans for incorporating these measures.
  • ACU expects that MSRR fuel will be delivered by the U.S. Department of Energy as high-assay low-enriched uranium (HALEU) in the form of uranium tetrafluoride (UF4).

ACU anticipates that some of this UF4 will be in pure granular form, while some will be premixed with salt (Flibe). ACU expects that all fuel for the lifetime of the MSRR will be delivered in one batch prior to initial commencement of reactor operation.

  • ACU expects that premixed UF4 and Flibe will be used for initial fuel loading of the MSRR, while additional pure UF4 will be titrated in over time to offset burnup and allow the MSRR to continue to maintain criticality.
  • The NRC staff noted, based on the MSRR design and operations, that in evaluating necessary security measures for the MSRR, it may not be necessary to consider the entire facility as Category II at all times. Only certain parts of the facility where SNM is located may need to be treated as Category II while other areas could potentially be treated as Category III based on their containing SNM of low strategic significance pursuant to 10 CFR Part 73 definitions. The NRC staff noted that in general, specific amounts and locations of SNM, and the timing of SNM movements and other activities involving SNM will be important in determining the necessary security measures in various parts of the facility at various times (e.g., when fuel salt sampling ports are being accessed, and when additional fuel is being added to offset burnup).
  • ACU noted that it does not expect to have issues with plutonium (Pu) coming out of the salt solution in the MSRR to the extent that it could affect security requirements, because it expects Pu concentrations to be well below the solubility of Pu in the salt.
  • The NRC staff provided observations regarding ACUs plans for a vault-time room as discussed in the Rulemaking for Enhanced Security of Special Nuclear Material, Regulatory Basis Document.
  • The NRC staff noted that, with respect to byproduct material, the MSRR would be subject to 10 CFR Part 37 and based on the types of activities at the MSRR, byproduct materials at the facility in aggregate could potentially reach Category 2 quantities of

byproduct material under 10 CFR Part 37 definitions, requiring 10 CFR Part 37 regulations for byproduct material security to be met as appropriate. The NRC staff noted that there are separate considerations, pursuant to 10 CFR Part 37, for byproduct material security compared to SNM security (10 CFR Part 73) and guidance for compliance with the prescriptive regulations in 10 CFR Part 37 may be found in NUREG-2155, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material, Revision 2, dated March 2022 (ML22083A141), and NUREG-1959, Intrusion Detection Systems and Subsystems: Technical Information for NRC Licensees, Revision 1, dated September 2017 (ML17250A867).

  • The NRC staff noted that ACU has obtained NRC approval of reviewing officials for access to safeguards information but will also need, prior to obtaining a license to possess SNM, to obtain approval for reviewing officials for access to the MSRR facility.
  • The NRC staff noted that ACU could consider making provisions in the MSRR PSP for the establishment of temporary controlled access areas to facilitate meeting security requirements when MSRR fuel is being transported. Regulations related to transportation of reactor fuel are in 10 CFR 73.67 (for fresh fuel) and 10 CFR 73.37 (for irradiated fuel).
  • The NRC staff noted that portions of the new regulations in 10 CFR Part 73, Subpart T, Security Notifications, Reports, and Recordkeeping, would apply to the MSRR. The NRC staff noted that guidance for implementing these regulations may be found in NRC Regulatory Guide (RG) 5.62, Revision 2, Physical Security Event Notifications, Reports, and Records (ML17131A285), with respect to event notifications; and RG 5.87, Revision 0, Suspicious Activity Reports Under 10 CFR Part 73 (ML17138A384), with respect to suspicious activity reporting.
  • The NRC staff noted that construction of the SERC building was nearly complete as of the date of the onsite audit, and that ACU included several security features in the building that could be used during MSRR operation.
  • The NRC staff noted that the ACU Campus Police have jurisdiction over the campus and provide the primary support for security of the entire campus including the SERC.
  • The NRC staff noted that, in continuing to develop appropriate security infrastructure to support the MSRR, ACU should evaluate its ability to ensure adequate monitoring, detection, and response capabilities consistent with SSMs that are likely to be necessary (in accordance with 10 CFR 73.67 as well as with site-specific SSMs).

6.0 EXIT BRIEFING The NRC staff conducted an audit closeout meeting by teleconference on August 17, 2023. At the exit briefing, the NRC staff reiterated the purpose of the audit and discussed the activities conducted. In addition, the NRC staff discussed processes by which ACU could submit a request to obtain copies of non-public NRC documents containing security-related information, which could inform ACUs continued security planning for the MSRR.

7.0 REQUESTS FOR ADDITIONAL INFORMATION RESULTING FROM AUDIT The NRC staff did not use the formal request for additional information process as part of this audit. The NRC staff provided ACU questions and feedback during the audit, which ACU could consider and use to complete development of its PSP prior to submittal of an OL application.

8.0 OPEN ITEMS AND PROPOSED CLOSURE PATHS Not applicable. There are no open items as a result of this audit.

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