Text

Texas A&M Engineering Experiment Station - License Amendment Request for Facility Operating License No. R-23 (Docket No. 50-59) - Revision to TS 3.5 to Remove the Reactor Console, Control Rod Drives, and Associated Electronics from Storage
	ML25240B609
Person / Time
Site:	Texas A&M University
Issue date:	08/28/2025
From:	Joel Jenkins; Texas A&M Univ
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	AGN-R23-LAR-2025-02, 2025-014
	Download: ML25240B609 (1)
	v • d • e

Nuclear Engineering & Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551 August 28, 2025 2025-014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Facility License No. R-23 Docket No. 050-00059 Internal Document Number: AGN-R23-LAR-2025-02

Subject:

License Amendment Request for Facility Operating License No. R-23 (Docket No.

50-59) - Revision to Technical Specification 3.5 to Remove the Reactor Console, Control Rod Drives, and Associated Electronics from Storage

References:

1. NRC Amendment No. 15 to Facility Operating License No. R-23, dated October 14, 2016 (ML16278A497).

2. NRC Amendment No. 16 to Facility Operating License No. R-23, dated January 19, 2017 (ML17019A385).

3. Confirmatory Action Letter (CAL) No. EA-2013-154, dated July 30, 2013 (ML13189A058).

4. Texas A&M University Response to CAL, dated December 17, 2013 (ML14015A315).

5. Texas A&M University Response to CAL, dated March 10, 2014 (ML14087A006).

6. NRC Acknowledgment of Commitments in CAL No. EA-2013-154, dated May 23, 2014 (ML14105A442).

7. Texas A&M University Request for Additional Information Response Regarding CAL, dated September 16, 2014 (ML14276A033).

8. Texas A&M University License Amendment Request for Interim Storage, dated November 11, 2015 (ML15315A027).

9. NRC Request for Additional Information on Interim Storage Amendment Request, dated February 16, 2016 (ML16032A022).

10. Texas A&M University Response to NRC RAI on Interim Storage, dated March 3, 2016 (ML16063A384).

11. Texas A&M University Supplemental Information on Interim Storage Amendment Request, dated June 3, 2016 (ML16155A388).

12. Texas A&M University Supplemental Information on Interim Storage Amendment Request, dated June 17, 2016 (ML16169A346).

13. Texas A&M University Proposed Changes to TS Table of Contents, dated August 24, 2016 (ML16237A440).

14. Texas A&M University Proposed Changes to TS Page 15, dated September 27, 2016 (ML16272A434).

AGN-R23-LAR-2025-02 2/3 August 28, 2025

15. Texas A&M University Changes to TS Pages 11 and 14, dated October 5, 2016 (ML16279A000).

16. Texas A&M University Changes to TS Associated with November 11, 2015 LAR, dated October 7, 2016 (ML16281A380).

Pursuant to 10 CFR 50.90, The Texas A&M Engineering Experiment Station (TEES)as delegated by a Memorandum of Understanding with Texas A&M University (TAMU)hereby requests an amendment to Facility Operating License No. R-23 for the AGN-201M Reactor (Docket No.50-059). The proposed amendment would revise the Technical Specifications (TS) to remove restrictions imposed by Amendment No. 15 (ML16278A497) on access to the reactor console (including associated electronic equipment and nuclear instrumentation such as the neutron detector channels for Nuclear Safety Channels #1, #2, and #3), and the Control Rod Drive Mechanisms (CRDMs). These restrictions, detailed in TS Sections 3.5 and 4.5, currently require secured storage with tamper-proof seals and quarterly surveillances to prevent tampering, as the reactor components are stored at the Nuclear Science Center (NSC) facility in a possession-only configuration. The proposed change retains restrictions on other reactor components (e.g., shield tank, reactor tank, core tank, and associated internal components excluding CRDMs) to maintain security and prevent tampering for those items.

The AGN-201M reactor was designed to operate as a low-power research reactor but has been in a shutdown (since 2013) and possession-only storage state (since 2015), following issuance of CAL No. EA-2013-154 (ML13189A058) due to issues with an unauthorized digital upgrade to the reactor protection system (RPS) in the console. The restrictions in TS Sections 3.5 and 4.5 were incorporated via Amendment No. 15 (ML16278A497) to support disassembly and interim storage of non-fuel components at the NSC facility, ensuring configuration control and preventing unauthorized modifications during storage. Removing these restrictions for the specified items (console, nuclear instrumentation, and CRDMs) would allow inspection, maintenance, testing, and potential upgrades or replacement to support future efforts toward reactor relicensing, relocation, and restart, including resolution of the CAL and updates to the Final Safety Analysis Report (FSAR) Chapter 7 in preparation for application for a Construction Permit (CP) and eventual Operating License (OL). The plan for the CRDMs is that they will be serviced and tested with the console, not replaced.

All work on the console, nuclear instrumentation, and CRDMs will be performed in accordance with ANSI/ANS-15.8-1995 (R2018), "Quality Assurance Program Requirements for Research Reactors," as implemented in the NSC Quality Assurance Program (QAP) and evaluated per 10 CFR 50.59 to ensure no unreviewed safety questions are introduced and that any changes maintain or enhance safety. The NSC QAP is established for the Nuclear Science Center Reactor (NSCR, R-83, Docket No. 50-128) and will be applied here, as the AGN-201M components are stored at the NSC facility.

Enclosed are:

1. Evaluation of the Proposed Change.

2. Marked-up TS pages.

3. Retyped TS pages.

AGN-R23-LAR-2025-02 3/3 August 28, 2025 The AGN-201M Reactor is currently disassembled and stored at the Nuclear Science Center Facility, with no operations conducted. The proposed amendment involves no significant hazards consideration, as evaluated in accordance with 10 CFR 50.92(c). Additionally, the amendment qualifies for categorical exclusion from environmental review under 10 CFR 51.22(c)(9). This administrative change has no impact on reactor safety or public health.

TEES requests approval of this amendment within one-hundred twenty (120) days of submittal to support ongoing planning for reactor restart. If you have any questions, please contact Jere Jenkins at 979.845.7551 or jere@tamu.edu.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 5, 2025.

Jere Jenkins Director, Nuclear Engineering & Science Center Texas A&M Engineering Experiment Station

Enclosures:

As stated above.

cc: Reactor Files Jere H.

Jenkins Digitally signed by Jere H.

Jenkins Date: 2025.08.28 12:18:06

-05'00'

ENCLOSURE 1 EVALUATION Facility License No. R-23 Docket No. 050-00059 Internal Document Number: AGN-R23-LAR-2025-02

Subject:

License Amendment Request for Facility Operating License No. R-23 (Docket No.

50-59) - Revision to Technical Specification 3.5 to Remove the Reactor Console, Control Rod Drives, and Associated Electronics from Storage

AGN-R23-LAR-2025-02 1/5 2025-08-28 : Evaluation of the Proposed Change 1.0 Summary Description The proposed amendment revises TS Section 3.5 to remove restrictions on the reactor console (including associated electronic equipment and nuclear instrumentation such as the neutron detector channels for Nuclear Safety Channels #1, #2, and #3), and the CRDMs, while retaining restrictions on other reactor components (e.g., shield tank, reactor tank, core tank, and associated internal components excluding CRDMs). This removes those specific items from secured storage requirements with tamper-proof seals and quarterly surveillances, allowing access for maintenance and testing. TS Section 4.5 describes the surveillance requirements of the storage areas but does not specifically mention the items in storage. There are no changes to operating license conditions.

2.0 Detailed Description The AGN-201M reactor (Serial #106) was designed as a homogeneous, polyethylene-moderated research reactor with a maximum licensed power of 5 watts (thermal). It was originally licensed in 1959 and operated until 2013, when operations were suspended due to CAL No. EA-2013-154 (ML13189A058), which addressed issues with an unauthorized digital upgrade to the reactor protection system (RPS) in the console. The reactor was subsequently disassembled when a relocation was required due to construction on the building which was its previous home, and its non-fuel components placed in secure storage at the Nuclear Engineering & Science Center (NESC) facility per Amendment No. 15 (ML16278A497). The reactor is currently in a possession-only state and is not operable. A Memorandum of Understanding was generated in 2021 transferring the license responsibilities from Texas A&M University (TAMU) to NESC and the Texas A&M Engineering Experiment Station (TEES) until the license is officially transferred with the future relicensing, relocation, and restart of the reactor.

The console includes electronic equipment for monitoring and control, including nuclear instrumentation (e.g., neutron detector channels for Nuclear Safety Channels #1, #2, and #3, which provided scram signals based on count rate, power level, and period). The CRDMs were designed to manipulate the control and safety rods via electromagnets and lead screws. These components have not been accessed or maintained since storage began in 2016, and operating experience from similar AGN reactors (e.g., University of New Mexico and Idaho State University) indicates that CRDMs of this vintage require extensive maintenance after prolonged inactivity.

The proposed change would revise TS Section 3.5.1 (Accelerator Building) to remove "a. AGN-201M reactor control panel and associated electronic equipment" and exclude CRDMs from "b.

AGN-201M Shield Tank, Reactor Tank, Core Tank, and associated internal components." TS 4.5 surveillances would continue on the items remaining in storage in the designated areas.

Restrictions remain on other components to prevent tampering.

AGN-R23-LAR-2025-02 2/5 2025-08-28 This aligns with ANSI/ANS-15.1-2007 (endorsed by NRC for research reactor TS format and content), which does not prescribe such storage restrictions for non-operational components under a possession-only license, while maintaining controls on remaining stored items.

3.0 Technical Evaluation The restrictions originated from TAMU's 2015 LAR (ML15315A027) for interim storage, which proposed secured locations to prevent tampering and maintain configuration control during disassembly. NRC approved this in Amendment No. 15 (ML16278A497), incorporating TS 3.5 and 4.5 to ensure integrity, as noted in the Safety Evaluation Report (SER) enclosed with the amendment: "These Technical Specifications ensure that the AGN-201M reactor components are secured and prevent tampering while stored at the NSC facility." This was in response to prior issues with unauthorized console modifications (leading to the CAL, ML13189A058) and to support safe storage by preventing unintended changes or contamination migration.

Removing the restrictions for the specified items (console, nuclear instrumentation, and CRDMs) does not violate applicable requirements, as:

The reactor is non-operational and possession-only; components are not in use.

All future work will be under ANSI/ANS-15.8-1995 (R2018) as implemented in the NESC QAP and evaluated per 10 CFR 50.59. If changes involve unreviewed safety questions, a future LAR will be submitted.

Radiation/contamination surveys (per current TS 4.5) show no migration; ongoing surveys will continue under facility procedures for the retained components.

Potential outcomes: Restore the analog RPS, redesign the RPS utilizing commercially sourced parts and equipment, or replace the console; service and test CRDMsboth enhancing safety per original design basis. Retaining restrictions on tanks and internal components (excluding CRDMs) maintains configuration control for core-related items.

There is no impact on safety limits (TS 2.0), reactivity limits (TS 3.1), or design features (TS 5.0). The change supports eventual CAL resolution (ML13189A058, ML14015A315, ML14087A006, ML14105A442, ML14276A033).

4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria The change complies with 10 CFR 50.90 and does not involve:

New safety analyses (reactor non-operational).

Changes to accident analyses in FSAR (no operation).

Violation of applicable criteria (e.g., 10 CFR 50.34(b) for design/safety basis description).

AGN-R23-LAR-2025-02 3/5 2025-08-28 The NESC QAP follows ANSI/ANS-15.8-1995 (R2018), endorsed by NRC Regulatory Guide 2.5, which provides QA requirements specifically for research reactors, ensuring appropriate controls for design, inspection, and testing.

4.2 Precedent NRC Amendment for similar research reactor storage changes: University of Missouri Research Reactor Amendment (ML19269C015, 2019) - Removed storage restrictions for non-operational components to allow maintenance.

Purdue University Reactor Decommissioning (ML19211C044, 2019) - Allowed access to stored components under QAP without TS restrictions.

General: NRC guidance in NUREG-1537, Part 2, allows TS revisions for non-operational reactors to facilitate maintenance without security seals if configuration control is assured.

4.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.92, TEES has evaluated the proposed change and determined it does not involve a significant hazards consideration:

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

No. The reactor is non-operational and stored; no accidents are possible. Removal allows maintenance under the NSC QAP (per ANSI/ANS-15.8) and 50.59, which could reduce future accident probabilities (e.g., by restoring RPS). Consequences remain unchanged as no fission products or operations are involved. Retaining restrictions on other components maintains safety for core elements.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

No. Storage access does not introduce new failure modes; work is controlled per regulations. FSAR accidents (e.g., maximum hypothetical accident) assume operational states not present here.

Does the proposed change involve a significant reduction in a margin of safety?

No. Safety margins (e.g., reactivity, temperature) are not affected in storage. Assured QAP/50.59 compliance maintains margins. Retaining restrictions on tanks/internal components preserves margins for those items.

TEES concludes that the proposed change presents no significant hazards consideration.

AGN-R23-LAR-2025-02 4/5 2025-08-28 4.4 Conclusions Based on the above evaluation, TEES concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

5.0 Environmental Consideration Pursuant to 10 CFR 51.22(c)(9), the proposed change is eligible for categorical exclusion from environmental assessment:

No significant hazards consideration.

No significant change in types or amounts of effluents.

No significant increase in individual or cumulative occupational radiation exposure.

No environmental impact statement or assessment is required.

6.0 References