Text

Texas A&M Nuclear Engineering & Science Center - License Amendment Request - Revision to Technical Specifications Section 6.2 and 6.2 to Align with Ans/Ansi 15.1 Standard for Reactor Safety Board
	ML25241A097
Person / Time
Site:	05000128
Issue date:	08/28/2025
From:	Joel Jenkins; Texas A&M Univ
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	2025-012
	Download: ML25241A097 (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 2025-012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Facility License No. R-83 Docket No. 050-00128 Internal Document Number: NSCR-R83-LAR-2025-02

Subject:

License Amendment Request - Revision to Technical Specifications Section 6.2 and 6.2.1 to Align with ANS/ANSI 15.1 Standard for Reactor Safety Board

References:

1. Facility License No. R-83, Amendment No. 19, issued July 22, 2021 (ML21189A263).

2. ANS/ANSI 15.1-2007, The Development of Technical Specifications for Research Reactors.

3. NUREG-1537, Part 1, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content," February 1996.

Pursuant to 10 CFR 50.90, Texas A&M Engineering Experiment Station (TEES), as licensee for the Nuclear Science Center Reactor (NSCR), hereby requests an amendment to Facility License No. R-83. This License Amendment Request (LAR) proposes revisions to Technical Specifications (TS) Sections 6.2 and 6.2.1 to align the Reactor Safety Board (RSB) with the exact language endorsed in ANS/ANSI 15.1-2007 and NUREG-1537, Part 1. The proposed changes reduce unnecessary prescriptiveness, eliminate a potential conflict of interest in the RSB Chair appointment, and remove specific ex officio member designations that are not required by regulation.

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).

Enclosed are:

1. Evaluation of the Proposed Change.

2. Marked-up TS pages.

3. Retyped TS pages.

Due to the very low safety significance of the requested license amendment, and the fact that the request is purely administrative, TEES requests NRC approval of this LAR within

NSCR-R83-LAR-2025-002 2/2 August 28, 2025 ninety (90) days of submittal, with implementation within 60 days of issuance. 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 05, 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 16:48:31

-05'00'

ENCLOSURE 1 TECHNICAL EVALUATION Facility License No. R-83 Docket No. 050-00128 Internal Document Number: NSCR-R83-LAR-2025-02

Subject:

License Amendment Request - Revision to Technical Specifications Section 6.2 and 6.2.1 to Align with ANS/ANSI 15.1 Standard for Reactor Safety Board

NSCR-R83-LAR-2025-02 Enclosure 1 1/4 2025-08-28 : Evaluation of the Proposed Change 1.0 Summary Description This License Amendment Request (LAR) proposes revisions to Technical Specifications (TS)

Sections 6.2 and 6.2.1 of Facility License No. R-83 for the Nuclear Science Center Reactor (NSCR). The changes adopt the exact language for the Reactor Safety Board (RSB) from ANS/ANSI 15.1-2007, "The Development of Technical Specifications for Research Reactors,"

and NUREG-1537, Part 1, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content."

The proposed changes:

Adopt verbatim the introductory language for review and audit functions in TS 6.2.

Adopt verbatim the composition and qualifications for the review and audit group in TS 6.2.1, ensuring independence while removing prescriptive details like the Level 1 serving as Chair and ex officio members.

These changes maintain the RSB's independence and effectiveness while reducing administrative burden and aligning precisely with NRC-endorsed standards for Research and Test Reactors (RTRs), minimizing the need for justification of deviations.

2.0 Detailed Description The current TS 6.2 states:

"6.2 Review and Audit" The current TS 6.2.1 states:

"The Reactor Safety Board shall be comprised of at least 3 voting members knowledgeable in fields which relate to Nuclear Safety. One of these members, the Director of TEES (Level 1 Management), will serve as the Chair. If the Chair is unable to attend one or a number of committee meetings, then the Chair may designate a committee member as Chair pro tem. The members are appointed by the Director of TEES (Level 1 Management) to serve one year terms. It is expected that the members will be reappointed each year as long as they are willing to serve so that their experience and familiarity with the past history of the NSC will not be lost to the committee. The Director of the NSC, TAMU Radiological Safety Officer, Head of the Department of Nuclear Engineering, and a senior member of the NSC Radiation Safety Staff shall be ex-officio members of the RSB."

The proposed TS 6.2 would read:

6.2 Review and Audit "A method for the independent review and audit of the safety aspects of reactor facility operations shall be established to advise management. The two functions may be

NSCR-R83-LAR-2025-02 Enclosure 1 2/4 2025-08-28 performed by a single group or separate groups. The information in Secs. 6.2.1 through 6.2.4 shall be shown. The review and audit group is called the Reactor Safety Board (RSB)."

The proposed TS 6.2.1 would read:

"The review and audit group shall be composed of a minimum of three members if a single group is used. If separate groups are used, then there shall be a minimum of three persons for review and one for auditing. The members shall collectively represent a broad spectrum of expertise in the appropriate reactor technology. Members and alternates shall be appointed by and report to Level I management. Individuals may be either from within or outside the operating organization. Qualified and approved alternates may serve in the absence of regular members."

Marked-up and retyped TS pages are provided as Enclosures 2 and 3.

3.0 Technical Evaluation The NSCR is a non-power research reactor (RTR) licensed under 10 CFR Part 50, but portions of Part 50 (e.g., Appendix B for quality assurance) do not apply to RTRs as they are tailored to power reactors. NRC guidance for RTR licensing, including TS, is provided in NUREG-1537, Part 1, which endorses ANS/ANSI 15.1 as the standard for TS format and content.

ANS/ANSI 15.1 Section 6.2 and 6.2.1 provide the exact language for establishing an independent review and audit method, emphasizing a minimum composition for the group(s) and broad expertise without prescribing specific positions or roles. This ensures independence from operational management while allowing flexibility.

The current TS 6.2 and 6.2.1 are legacies from earlier prescriptive approaches to RTR TS.

Naming the Level 1 (Director of TEES) as Chair creates a conflict where the appointee oversees their own appointees. Specifying ex officio members limits adaptability to organizational changes and is not regulatory-required.

The proposed changes:

Adopt verbatim language to preserve RSB independence, with members appointed by and reporting to Level 1.

Ensure expertise by requiring a broad spectrum in reactor technology.

Align exactly with NUREG-1537, Part 1, Chapter 12, which supports non-prescriptive administrative controls for RTRs.

No physical changes to the reactor, systems, or operations are involved. The RSB's review/audit functions (TS 6.2.3-6.2.5) remain unchanged.

NSCR-R83-LAR-2025-02 Enclosure 1 3/4 2025-08-28 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36(c)(5): Administrative controls in TS must ensure safe operation. The proposed changes maintain RSB oversight without altering functions.

ANS/ANSI 15.1-2007 (endorsed by NUREG-1537): The exact language supports the revised structure.

NUREG-1537, Part 1, Section 12.1.2: Recommends review and audit group with at least three members appointed by Level 1, no specific positions required.

The changes comply with these requirements.

4.2 Precedent Similar amendments aligning RTR TS with ANS/ANSI 15.1 have been approved:

Purdue University Reactor Facility License No. R-87, Amendment No. 10 (License Renewal), issued July 10, 2012 (ML12171A355): Revised TS to align with ANS/ANSI 15.1, including administrative controls in Section 6 for Reactor Safety Committee composition and appointment.

Aerotest Radiography and Research Reactor, Facility License No. R-98, Amendment Request Responses (ML22215A152, July 2022): Proposed revisions to TS organization (including review committee) to conform with ANS/ANSI 15.1, addressing NRC RAIs on administrative structure.

Differences: Both are U.S. NRC licensed research reactors; no plant-specific variances affect applicability. The precedents focused on reducing prescriptiveness in administrative TS while maintaining safety oversight.

4.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.92(c), the proposed amendment does not:

Involve a significant increase in the probability or consequences of an accident previously evaluated, as it is administrative and affects no safety systems.

Create the possibility of a new or different kind of accident, as no physical changes occur.

Involve a significant reduction in a margin of safety, as RSB oversight remains robust.

NSCR-R83-LAR-2025-02 Enclosure 1 4/4 2025-08-28 4.4 Conclusions The proposed changes are acceptable, aligning exactly with NRC-endorsed standards without impacting safety.

5.0 Environmental Consideration The amendment qualifies for categorical exclusion under 10 CFR 51.22(c)(9): No significant hazards, no effluent increase, no environmental impact.

6.0 References ANS/ANSI 15.1-2007.

NUREG-1537, Part 1 (February 1996).

10 CFR 50.36, 50.90-50.92.

Purdue University Amendment No. 10 (ML12171A355).

Aerotest RAI Responses (ML22215A152).

ENCLOSURE 2 TECHNICAL SPECIFICATION MARKUP Facility License No. R-83 Docket No. 050-00128 Internal Document Number: NSCR-R83-LAR-2025-02

Subject:

License Amendment Request - Revision to Technical Specifications Section 6.2 and 6.2.1 to Align with ANS/ANSI 15.1 Standard for Reactor Safety Board

Page l 56 Texas Engineering Experiment Station NSC 6.2 Review and Audit A method for the independent review and audit of the safety aspects of reactor facility operations shall be established to advise management. The two functions may be performed by a single group or separate groups. The information in Secs. 6.2.1 through 6.2.4 shall be shown. The review and audit group is called the Reactor Safety Board (RSB).

6.2.1 Reactor Safety Board (RSB) Composition and qualifications The review and audit group shall be composed of a minimum of three members if a single group is used.

If separate groups are used, then there shall be a minimum of three persons for review and one for auditing. The members shall collectively represent a broad spectrum of expertise in the appropriate reactor technology. Members and alternates shall be appointed by and report to Level 1 management.

Individuals may be either from within or outside the operating organization. Qualified and approved alternates may serve in the absence of regular members.

The Reactor Safety Board shall be comprised of at least 3 voting members knowledgeable in fields which relate to Nuclear Safety. One of these members, the Director of TEES (Level 1 Management), will serve as the Chair. If the Chair is unable to attend one or a number of committee meetings, then the Chair may designate a committee member as Chair pro tem. The members are appointed by the Director of TEES (Level 1 Management) to serve one year terms. It is expected that the members will be reappointed each year as long as they are willing to serve so that their experience and familiarity with the past history of the NSC will not be lost to the committee. The Director of the NSC, TAMU Radiological Safety Officer, Head of the Department of Nuclear Engineering, and a senior member of the NSC Radiation Safety Staff shall be ex-officio members of the RSB.

6.2.2 RSB Charter and Rules The operations of the RSB shall be in accordance with a written charter, including provisions for:

1. Meeting Frequency: The RSB shall meet annually at intervals not to exceed 15 months. (Note:

The facility license requires a meeting at least once per year and as frequently as circumstances warrant consistent with effective monitoring of facility activities);

2. Quorum: A quorum is comprised of not less than one-half of the voting membership where the operating staff does not constitute a majority;

3. Voting Rules: On matters requiring a vote, if only a quorum is present a unanimous vote of the quorum is required; otherwise a majority vote is required;

4. Subcommittees: The Chair may appoint subcommittees comprised of members of the RSB including ex-officio members to perform certain tasks. Subcommittees or members of the RSB may be authorized to act for the board; and

5. Meeting Minutes: The Chair will designate one individual to act as recording secretary. It will be the responsibility of the secretary to prepare the minutes which will be distributed to the RSB, including the Director of TEES (Level 1 Management), within three months. The RSB will review and approve the minutes of the previous meetings. A complete file of the meeting minutes will be maintained by the Chair of the RSB and by the Director of the NSC.

6.2.3 RSB Review Function

Page l 56 Texas Engineering Experiment Station NSC The review responsibilities of the Reactor Safety Board or a designated subcommittee shall include, but are not limited to the following:

1. Review and evaluation of determinations of whether proposed changes to equipment, systems, tests, experiments, or procedures can be made under 10 CFR 50.59 or would require a change in Technical Specifications or license conditions;

2. Review of new procedures, major revisions of procedures, and proposed changes in reactor facility equipment or systems which have significant safety impact to reactor operations;

ENCLOSURE 3 TECHNICAL SPECIFICATION CLEAN Facility License No. R-83 Docket No. 050-00128 Internal Document Number: NSCR-R83-LAR-2025-02