ML25244A001

From kanterella
Jump to navigation Jump to search
Texas Engineering Experiment Station/Nuclear Science Center Reactor - Submission of Revised License Amendment Request for Facility Operating License R-83: Revision of the License Conditions for Transfer Ob Byproduct Material Used in Associa
ML25244A001
Person / Time
Site: 05000128
Issue date: 09/01/2025
From: Joel Jenkins
Texas A&M Univ
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
L2025-016
Download: ML25244A001 (1)


Text

Nuclear Engineering & Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551 September 1, 2025 L2025-016 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 FACILITY:

Texas Engineering Experiment Station/Nuclear Science Center Reactor DOCKET #:

05000128

SUBJECT:

Submission of Revised License Amendment Request for Facility Operating License R-83: Revision of the License Conditions for Transfer of Byproduct Material Used in Association with Facility Operation Back to the R-83 License

REFERENCES:

1. License Amendment Request for Facility Operating License R-83: Revision of the License Conditions for Transfer of Byproduct Material Used in Association with Facility Operation Back to the R-83 License (ADAMS Accession No. ML24340A112)
2. Revised License Amendment Request for Facility Operating License R-83:

Revision of the License Conditions for Transfer of Byproduct Material Used in Association with Facility Operation Back to the R-83 License (ADAMS Accession No. ML25008A256)

3. NON-ACCEPTANCE WITH CHANCE TO SUPPLEMENT - LICENSE AMENDMENT REQUEST TO THE R-83 LICENSE REGARDING TRANSFER OF BYPRODUCT MATERIAL FROM STATE LICENSE (ADAMS Accession No. ML25013A119)
4. TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM - NONACCEPTANCE OF THE APPLICATION FOR A LICENSE AMENDMENT RE: TRANSFER OF BYPRODUCT MATERIAL FROM STATE LICENSE (EPID: L-2024-NFA-0004) (ADAMS Accession No. ML25083A278)

Pursuant to 10 CFR 50.90, The Texas A&M Engineering Experiment Station (TEES), a part of the Texas A&M University System (TAMUS), is herein submitting a request to amend the Facility Operating License R-83. This is a revision of two previous submissions dated 5 December 2024 (see Accession No. ML23340A112) and 8 January 2026 (see Accession No. ML25008A256). This revision answers questions received by email (see Accession No. ML25013A119) regarding the previous submissions, specifically limits on activities of the externally sourced radioactive materials.

The revised justification (enclosed as Attachment) presents the justification for the transfer of the byproduct material presently held on the State of Texas Broadscope license [Texas A&M University, (TAMU), as Licensee] to the R-83 reactor license. The material in question was previously held on the R-83 license, but was transferred to the State of Texas License because of changes to the R-83 license conditions in the 2016 License Renewal.

2 Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551 The Facility (R-83) is requesting a resumption of the license conditions prescribed in Amendment 14, with suggested activities and limits, to the reactor operating license.

Approval of the proposed amendment is requested within 90 days of submission. This is an administrative change and has no new safety implications. Once approved, the amendment shall be implemented within 60 days.

We appreciate your timely review of this license amendment request. Should you have any questions, or require further information, please contact me 979.845.7551, or via email at jere@tamu.edu.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 1 September 2025.

Sincerely, Jere H. Jenkins Director; Nuclear Engineering & Science Center Enclosure Jere H Jenkins Digitally signed by Jere H Jenkins Date: 2025.09.01 16:54:48

-05'00'

Docket 50-128; LAR 2024-01; Rev. 02 Pg 1 of 15 2025-08-28 ENCLOSURE Evaluation of the Proposed Change

Subject:

Application for License Amendment to Facility Operating License R-83; Transfer of Byproduct Material, Including Category 2 Material, to the R-83 License.

Revision 2; 28 August 2025 Contents of this Evaluation 1

Summary Description 2

Detailed Description 3

Technical Evaluation 3.1 Facility Description 3.2 Material Storage Location Details 3.3 Technical Basis for the License Condition Modification 3.4 Proposed Changes to License Conditions 4

Regulatory Evaluation 4.1 Regulatory Requirements 4.2 No Significant Hazards Consideration Determination 5

Environmental Consideration 6

References : List of Regulatory Commitments : Operating License Page Markups : Retyped Operating License Pages

Docket 50-128; LAR 2024-01; Rev. 02 Pg 2 of 15 2025-08-28 1

Summary Description This evaluation supports a request to amend Renewed Operating license No. R-83 for the Texas A&M Engineering Experiment Station/Nuclear Science Center Reactor. The request is for a change to the R-83 license conditions and does not involve a change to the reactor technical specifications.

The proposed change would revise the Operating License Condition 2.B.3 as currently detailed in Refs. 1 and 2 to include possession of byproduct material not created with the reactor but used in association with reactor operations, research and development, the Radiation Safety Program, and surveillances related to these activities. This amendment request is attempting to recover the ability to acquire, possess, and utilize any byproduct material that has definite research and development purpose as was granted in Amendments 13 [Refs. 3-5] and 14 [Refs.

6-8] to R-83. This license condition was lost in the R-83 license renewal of 2016 [Ref. 2].

A similar previous License Amendment Request (LAR) was submitted in December 2024 (Ref.

8), with a revision submitted 8 January 2025 (Ref. 9). The revision requested recovery of the license conditions granted in Amendments 13 and 14, as stated above. Proposed license conditions in Ref. 9 were identical to the language incorporated in Amendment 14 as granted by the U.S. Nuclear Regulatory Commission (NRC). That license condition language did not include activities of sources or limits on total activities. An email was received from NRC dated 10 January (Ref. 10) requesting activities and limits; however, it was assumed that the email was referring to the submission of December and not the January submission due to the proximity of the NRC response to the January submission. Since the language in the license conditions that were granted in Amendment 14 was proposed in the 8 January revision submissionwhich did not include activities or limitsit was not understood why the activities and limits were sought by NRC after that submission. There was no other communication forthcoming from NRC until the rejection of the LAR (Ref. 11).

The Facility has added activities and limits to the proposed license conditions in this revised request and is requesting the amendment be issued by within 90 days of submission. It will be implemented by the Facility within 60 days of issue.

2 Detailed Description The Texas A&M Engineering Experiment Station (TEES) is requesting a license amendment for the TRIGA reactor at the Nuclear Engineering & Science Center (NESC). The amendment includes revising the license conditions in paragraph 2.B.3 from Amendment 20 [Ref. 1] to the Renewed Facility Operating License No. R-83 (ML13030A410) [Ref. 2]. The current referenced paragraphs limit byproduct material receipt, possession, and use, to byproduct material produced by operation of the reactor (see 2.B.3.c of Ref. 1).

In October 1993, R-83 License Amendment 13 was issued [Refs. 3-5] granting the NSCR the ability to receive, possess, and use in amounts as required, any byproduct material without restriction to chemical or physical form, for analysis or instrument calibration but not to separate such byproduct material as may be produced by operation of the reactor. This license condition was revised and clarified in Amendment 14 [Refs. 6-8] to read to receive, possess, and use in amounts as required any byproduct material without restriction to chemical or physical form in connection with operation of the reactor that has a definite research, and development purpose

Docket 50-128; LAR 2024-01; Rev. 02 Pg 3 of 15 2025-08-28 and any byproduct material generated by the licensed activities, but not to separate such byproduct material except for byproduct material produced in reactor experiments. An additional condition was added in Amendment 14, No. II.B.7, to include possession of the legacy byproduct material for storage and decay that was within the site boundary.

In the justification included in the License Amendment Request for Amendment 13 [Ref. 12], the inclusion of byproduct materials produced by outside parties to the NESC on the R-83 license was intended to deconflict the necessary delineation between the Federal and State licensed materials onsite. This issue was identified in discussions between NRC Region IV representatives and the State of Texas held on September 21, 1992. An agreement was reached between all parties that broadening of License R-83 to include material then on the State of Texas broadscope license would be an appropriate action to resolve the concerns.

Amendment 14 [Refs. 6-8] provided some additional clarification of the license conditions modified in Amendment 13. A review of the Safety Evaluation Reports (SERs) for each license amendment [Refs. 5 and 8] presented the conclusions reached by the NRC that the transfer of the licensed byproduct material to the reactor license would not present any increase in the probability of previously evaluated accidents, there is reasonable assurance that there is no danger to the safety and health of the public and the environment, and that the activities would be conducted in compliance with NRC regulations.

Please see Attachment 2 of this Enclosure for the suggested markups of the Operating License.

There are no changes to the Safety Bases of the NSCR included in this amendment request.

There are also no necessary changes to the Technical Specifications. The existing R-83 Part 73 Physical Security Plan will be revised to include the Category 2 material activities in accordance with 10 CFR 37.11(b). The revision will be sent under separate cover.

While the transfer of the referenced material to the R-83 license necessitates a transfer of ownership to the Texas A&M Engineering Experiment Stationthe owner and licensee of the NSCRthe custody and responsibility for the material remain unchanged since it has been used and stored at the NSCR Facility to date.

3 Technical Evaluation 3.1 Facility Description The are no changes to the storage facility as part of this license amendment request. The facility description was evaluated in the SER of Ref. 1.

3.2 Material Storage Location Details The Category 2 radioactive material will continue to be stored and used in the Controlled Area of the NSCR Facility. Lower activity and exempt sources will be used in accordance with the existing NSCR Radiation Safety Program. Security will meet the requirements of 10 CFR Parts 37 and 73.

Docket 50-128; LAR 2024-01; Rev. 02 Pg 4 of 15 2025-08-28 3.3 Technical Basis for the License Condition Modification The referenced material has already been in use at the Facility for over 20 years in the case of the Category 2 quantities under the existing NSCR Radiation Safety Program. There are no changes other than the licensed owner necessitated by this license amendment request.

3.4 Proposed Changes to License Conditions TEES is not requesting any changes to the Technical Specifications. TEES is requesting changes to the license conditions. The requested changes are presented as a marked-up version in Attachment 2, and a final suggested version (without mark-up) in Attachment 3.

4 Regulatory Evaluation 4.1 Regulatory Requirements The regulations in 10 CFR Part 20, Standards for Protection Against Radiation, establish standards for protection against ionizing radiation resulting from activities conducted under licenses issued by the NRC. Section 20.1801, Security of stored material, states, [t]he licensee shall secure from unauthorized removal or access license materials that are stored in controlled or unrestricted areas. The proposed change does not include any changes to the storage requirements or configurations, or the security thereof. The existing R-83 Part 73 Physical Security Plan will be revised to include the Category 2 material activities in accordance with 10 CFR 37.11(b). The revision will be sent under separate cover.

The regulations in 10 CFR Part 30, Rules of General Applicability to Domestic Licensing of Byproduct Material, provide, in part, the regulatory requirements for transfer and storage of byproduct material. The proposed change involves the transfer of Category 2 quantities of Radioactive material, and additional low-activity and exempt-quantity material, from the Agreement State License held by Texas A&M University System to the R-83 Part 50 License.

The change does not, however, involve the relocation of the material. The Category 2 material is already stored and used in the Controlled Area of The Facility and that usage will not change in the future unless an additional License Amendment Request is submitted to the NRC. The low-activity and exempt-quantity material are used in designated radiation laboratories in accordance with the NSCR Radiation Safety Program. The proposed change does not include any changes to the present storage requirements or configurations.

The regulations in 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material, provide the regulatory requirements for the protection and storage of high-activity radioactive material, including the referenced Category 2 quantity materials.

The regulations in 10 CFR Part 37.11(b) states that Any licensee's NRC-licensed activities are exempt from the requirements of subparts B and C of this part to the extent that its activities are included in a security plan required by part 73 of this chapter. The existing R-83 Part 73 Physical Security Plan will be revised to include the Category 2 material activities in accordance with 10 CFR 37.11(b). The revision will be sent under separate cover.

Docket 50-128; LAR 2024-01; Rev. 02 Pg 5 of 15 2025-08-28 The regulations in 10 CFR Part 37.25(b)(2) allows for granting unescorted access to Category 2 materials to individuals determined to be trustworthy and reliable (T&R) under a Part 73 T&R program such as the one that already exists under the R-83 license.

The regulations in 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, provide the regulatory requirements for licensing of non-power reactors. The regulations in 10 CFR 50.92, Issuance of amendment, paragraph(a), state, in part, that [i]n determining whether an amendment to a license [] will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses [] to the extent applicable and appropriate. As shown in the next section, TEES has evaluated that there are no significant hazards associated with the proposed change.

The regulations in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, provide regulatory requirements for the protection of the environment. Based on the evaluation that there are no significant hazards associated with the proposed change, there is no risk to the environment because of this amendment.

The regulations in 10 CFR Part 70, Domestic Licensing of Special Nuclear Material, provide regulatory requirements for the handling and security of SNM. The proposed change does not include any changes to the storage requirements or configurations, or the security thereof. The existing R-83 Part 73 Physical Security Plan will be revised to include the Category 2 material activities in accordance with 10 CFR 37.11(b). The revision will be sent under separate cover.

The regulations in 10 CFR 73.40, Physical protection: General requirements at fixed sites, provide regulatory requirements for physical protection of special nuclear material. The existing R-83 Part 73 Physical Security Plan will be revised to include the Category 2 material activities in accordance with 10 CFR 37.11(b). The revision will be sent under separate cover.

The regulations in 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 provide regulatory requirements to minimize the possibility and detection of unauthorized removal of SNM. The existing R-83 Part 73 Physical Security Plan will be revised to include the Category 2 material activities in accordance with 10 CFR 37.11(b). The revision will be sent under separate cover.

The Atomic Energy Act of 1954, as amended, Section 182a, requires applicants for utilization facilities to include Technical Specifications (TS) as a part of the license. The regulatory requirements related to the content of the TSs are in 10 CFR 50.36, Technical specifications.

Section 50.36 requires that TSs include the following categories: (1) safety limits, limiting safety systems settings and limiting control settings, (2) limiting conditions for operation, (3) surveillance requirements, (4) design features, and (5) administrative controls. All Technical Specification requirements established with Amendment 19 will continue.

NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, (Ref. 11) provides guidance for development of TSs in Appendix 14.1, Format and Content of Technical Specification for Non-Power Reactors.

Appendix 14.1 states that the NRC accepts the guidance of the American Nuclear Standards Institute, Incorporated/American Nuclear Society (ANSI/ANS) Standard 15.1 1990. The Development of Technical Specifications for Research Reactors, as modified by Appendix 14.1. NUREG-1537, Part 1, Chapter 14, Appendix 14.1, Section 5, Design Features, states

Docket 50-128; LAR 2024-01; Rev. 02 Pg 6 of 15 2025-08-28 NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, (Ref. 12), provides guidance to NRC staff on the conduct reviews of non-power reactor license applications.

Chapters referenced in the conduct of this review include: Auxiliary Systems (Chapter (Ch.) 9),

specifically Section 9.2, Handling and Storage of Reactor Fuel, and Ch. 14, Technical Specifications. No Technical Specification changes are required.

NUREG-2155, Revision 2, Implementation Guidance for 10 CFR Part 37 Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material, provides guidance for maintaining the security of Category 2 materials.

NUREG-2166, Physical Security Best Practices for the Protection of Risk-Significant Radioactive Material, delineates additional guidance.

RIS 2015-15, Information Regarding a Specific Exemption in the Requirements for the Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material, describes the pathway utilizing Part 73 Security Plans, or creating additional Part 37 specific Security Plans for existing license holders.

4.2 No Significant Hazards Consideration Determination The Texas Engineering Experiment Station has evaluated whether a significant hazards consideration is involved with the proposed change by focusing on the three standards set forth in 10 CFR 50.92, as discussed below:

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

Response: No This amendment is an administrative change only and does not involve the reactor safety bases. The proposed change does not involve any modifications of storage configuration or material being stored, therefore there are no changes to the consequences of previously evaluated accidents.

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

Response: No This amendment is an administrative change only and does not involve the reactor safety bases. The proposed change does not involve any modifications of storage configuration or material being stored; therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No This amendment is an administrative change only and does not involve the reactor safety bases. The proposed change does not involve any modifications of storage

Docket 50-128; LAR 2024-01; Rev. 02 Pg 7 of 15 2025-08-28 configuration or material being stored; therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, TEES concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c) 5 Environmental Consideration A review has determined that the proposed amendment would change the license ownership of the sealed and normal form byproduct material already in use and storage at the Facility to the R-83 license, requiring a change in the R-83 license conditions only. The proposed amendment does not involve (i) a significant hazards consideration [see Section 4.2], (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6 References

[1]

U.S. Nuclear Regulatory Commission, TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM - ISSUANCE OF AMENDMENT NO. 20 TO FACILITY OPERATING LICENSE NO. R-83, FOR THE TEXAS ENGINEERING EXPERIMENT STATION/ TEXAS A&M UNIVERSITY SYSTEM NUCLEAR SCIENCE CENTER TO CONFORM IT WITH ORDER EA-NRR-2025-0013 (EPID NO. L-2024-NLO-0000), Date February 10, 2025, (ADAMS Accession No. ML25038A093)

[2]

U.S. Nuclear Regulatory Commission, Texas Engineering Experiment Station/Texas A&M University System - Issuance of Renewed Facility Operating License No. R-83 (TAC No. ME1584), October 1, 2015 (ADAMS Accession No. ML13030A410)

[3]

U.S. Nuclear Regulatory Commission, Issuance of Amendment No. 13 to Facility Operating License R-83, October 26, 1993. (ADAMS Accession No. ML20059F997)

[4]

U.S. Nuclear Regulatory Commission, Texas Engineering Experiment Station/Texas A&M University System; Docket No. 50-128; Amendment to Facility Operating License,.

50-128, October 26, 1993. (ADAMS Accession No. ML20059G012)

[5]

U.S. Nuclear Regulatory Commission, Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting Amendment No. 13 to Facility Operating License No. R-83; Texas Engineering Experiment Station; Texas A&M University System, Docket No.

50-128, October 26, 1993. (ADAMS Accession No. ML20059G030)

[6]

U.S. Nuclear Regulatory Commission, Issuance of Amendment No. 14 to Facility Operating License R-83 (TAC No. M98495), July 15, 1997. (ADAMS Accession No. ML20149F346)

Docket 50-128; LAR 2024-01; Rev. 02 Pg 8 of 15 2025-08-28

[7]

U.S. Nuclear Regulatory Commission, Texas Engineering Experiment Station/Texas A&M University System; Docket No. 50-128; Amendment to Facility Operating License; Amendment No. 14, July 15, 1997. (ADAMS Accession No. ML20149F381)

[8]

Texas A&M Engineering Experiment Station, License Amendment Request for Facility Operating License R-83: Revision of the License Conditions for Transfer of Byproduct Material Used in Association with Facility Operation Back to the R-83 License (ADAMS Accession No. ML24340A112)

[9]

Texas A&M Engineering Experiment Station, Revised License Amendment Request for Facility Operating License R-83: Revision of the License Conditions for Transfer of Byproduct Material Used in Association with Facility Operation Back to the R-83 License (ADAMS Accession No. ML25008A256)

[10]

U.S. Nuclear Regulatory Commission, NON-ACCEPTANCE WITH CHANCE TO SUPPLEMENT - LICENSE AMENDMENT REQUEST TO THE R-83 LICENSE REGARDING TRANSFER OF BYPRODUCT MATERIAL FROM STATE LICENSE (ADAMS Accession No. ML25013A119)

[11]

U.S. Nuclear Regulatory Commission, TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM - NONACCEPTANCE OF THE APPLICATION FOR A LICENSE AMENDMENT RE: TRANSFER OF BYPRODUCT MATERIAL FROM STATE LICENSE (EPID: L-2024-NFA-0004) (ADAMS Accession No. ML25083A278)

[12]

U.S. Nuclear Regulatory Commission, Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting Amendment No. 14 to Facility Operating License No. R-83; Texas Engineering Experiment Station; Texas A&M University System, Docket No.

50-128, July 15, 1997. (ADAMS Accession No. ML20149F390)

[13]

Reece, W. D. (August 24, 1993). [Application for License Amendment, Amendment of Facility Operating License No. R-83 (Docket No. 50-128) and Indemnity Agreement E-12]. (ADAMS Accession No. ML20056H445)

[14]

Reece, W. D. (May 26, 1997). [Application for License Amendment, Request for Amendment to License No. R-83]. (ADAMS Accession No. ML20148G556)

Docket 50-128; LAR 2024-01; Rev. 02 Pg 9 of 15 2025-08-28 ENCLOSURE 1 : List of Regulatory Commitments 2

The following table identifies the regulatory commitments in this document. Any other 3

statements in this submittal represent intended or planned actions. They are provided for 4

information purposes only and are not considered to be regulatory commitments.

5 6

TYPE COMMITMENT One-Time Continuing Compliance SCHEDULED COMPLETION DATE Secure storage of the material in compliance with 10 CFR 20.1801.

X NA Storage of byproduct material in compliance with 10 CFR 30.

X NA Storage of special nuclear material in a criticality-safe geometry and location per 10 CFR 70.24.

X NA Storage and use of Category 2 quantities of radioactive material in compliance with 10 CFR 37.

X NA Appropriate storage in accordance with SNM handling in accordance with 10 CFR 70, 10 CFR 73.40, and 10 CFR 73.67.

X NA All surveillances and record-keeping necessitated by the above requirements.

X NA 7

8 9

Docket 50-128; LAR 2024-01; Rev. 02 Pg 10 of 15 2025-08-28 ENCLOSURE 10 : Operating License Page Markups 11 12 13 14 15 16 17 18 19 20 The following page contains the marked-up text of the present operating license showing 21 requested changes.

22 23 Docket 50-128; LAR 2024-01; Rev. 02 Pg 11 of 15 2025-08-28

c. to receive, possess, and use, but not separate, in connection with the operation of the facility, such special nuclear material as may be produced by the operation of the facility.
d. To receive, possess, but not use up to 0.7 kilograms of contained Uranium-235

<20% enriched 235U Fuel - AGN-201M, and any special nuclear materials produced by the operation of the AGN-201M reactor.

e. To receive, possess, but not use up to 0.020 kilograms of 239Pu as a 239PuBe AGN-201M Neutron Start Up Source in connection with storage of the AGN-201M reactor.
2. Pursuant to the Act and 10 CFR Part 30, the following activities are included:
c. to receive, possess, and use, in connection with the operation of the facility, a sealed antimony-beryllium neutron startup source,
d. to receive, possess, and use, in connection with the operation of the facility, a sealed 2.5-curie americium-beryllium neutron source; and,
e. to receive, possess, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which cannot be separated except for byproduct material produced in reactor experiments.
f. to receive, possess, but not use, byproduct materials including contaminated or activated Fuel - AGN-201M and AGN-201M Neutron Start Up Source.
g. to receive, possess, and use, in connection with operation of the facility, a 60-curie Technical Operations, Inc., Model CDV-794 Model No. 2 calibrator,
h. to receive, possess, and use, in connection with the operation of the facility, any externally sourced radioactive material with atomic number 1 through 83, without restriction to chemical or physical form, no single source to exceed 1-curie, not to exceed 5-curies total,
i.

to receive, possess, and use, in connection with the operation of the facility, any externally sourced radioactive material with atomic number 84 or greater, excluding special nuclear material, except as otherwise listed, in normal or special form, with no single source to exceed 3-curies, not to exceed 5 curies

total,
j.

to possess and store for decay such byproduct material as are within the site boundary at the time of Amendment No. XX

3. Pursuant to the Act and 10 CFR Part 40, Domestic Licensing of Source Material, to receive, possess, and use in connection with operation of the facility, not more than 6.8 kilograms of source material.

B. This license shall be deemed to contain, and is subject to the conditions specified 10 CFR Parts 20, 30, 40, 50, 51, 55, 70, and 73 of the Commissions regulations; is subject to all provisions of the Act, and to the rules, regulations and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified or incorporated below:

1. Maximum Power Level Docket 50-128; LAR 2024-01; Rev. 02 Pg 12 of 15 2025-08-28
1. The licensee is authorized to operate the reactor at a steady-state power level up to a maximum of 1000 kilowatts (thermal) and to pulse the reactor in accordance with the limitations in the Technical Specifications.

Docket 50-128; LAR 2024-01; Rev. 02 Pg 13 of 15 2025-08-28 ENCLOSURE 1 : Retyped Operating License Pages 2

3 4

5 6

7 8

9 10 11 12 The following page contains the suggested text for the amended operating license.

13 14 Docket 50-128; LAR 2024-01; Rev. 02 Pg 14 of 15 2025-08-28

c.

to receive, possess, and use, but not separate, in connection with the operation of the facility, such special nuclear material as may be produced by the operation of the facility.

d.

To receive, possess, but not use up to 0.7 kilograms of contained Uranium-235 <20% enriched 235U Fuel - AGN-201M, and any special nuclear materials produced by the operation of the AGN-201M reactor.

e.

To receive, possess, but not use up to 0.020 kilograms of 239Pu as a 239PuBe AGN-201M Neutron Start Up Source in connection with storage of the AGN-201M reactor.

3.

Pursuant to the Act and 10 CFR Part 30, the following activities are included:

a.

to receive, possess, and use, in connection with the operation of the facility, a sealed antimony-beryllium neutron startup source,

b.

to receive, possess, and use, in connection with the operation of the facility, a sealed 2.5-curie americium-beryllium neutron source;

and,
c.

to receive, possess, amd use in amounts as required any byproduct material without restriction to chemical or physical form in connection with operation of the reactor that has a definite research and development purpose, and any byproduct material generated by the licensed activities, but not to separate such byproduct material except for byproduct material produced in reactor experiments.

d.

to receive, possess, but not use, byproduct materials including contaminated or activated Fuel - AGN-201M and AGN-201M Neutron Start Up Source.

e.

to receive, possess, and use, in connection with operation of the facility, a 60-curie Technical Operations, Inc., Model CDV-794 Model No. 2 calibrator,

f.

to receive, possess, and use, in connection with the operation of the facility, any externally sourced radioactive material with atomic number 1 through 83, without restriction to chemical or physical form, no single source to exceed 1-curie, not to exceed 5-curies

total,
g.

to receive, possess, and use, in connection with the operation of the facility, any externally sourced radioactive material with atomic number 84 or greater, excluding special nuclear material, except as otherwise listed, in normal or special form, with no single source to exceed 3-curies, not to exceed 5 curies total,

h.

to possess and store for decay such byproduct material as are within the facility at the time of Amendment No. XX.

4.

Pursuant to the Act and 10 CFR Part 40, Domestic Licensing of Source Material, to receive, possess, and use in connection with operation of the facility, not more than 6.8 kilograms of source material.

Docket 50-128; LAR 2024-01; Rev. 02 Pg 15 of 15 2025-08-28 C.

This license shall be deemed to contain, and is subject to the conditions specified 10 CFR Parts 20, 30, 40, 50, 51, 55, 70, and 73 of the Commissions regulations; is subject to all provisions of the Act, and to the rules, regulations and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified or incorporated below:

1.

Maximum Power Level The licensee is authorized to operate the reactor at a steady-state power level up to a maximum of 1000 kilowatts (thermal) and to pulse the reactor in accordance with the limitations in the Technical Specifications.