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| issue date = 03/03/2016
| issue date = 03/03/2016
| title = Texas A&M Univ. - Supplement to License Amendment Request Dated October 14, 2015
| title = Texas A&M Univ. - Supplement to License Amendment Request Dated October 14, 2015
| author name = McDeavitt S M
| author name = Mcdeavitt S
| author affiliation = Texas A&M Univ
| author affiliation = Texas A&M Univ
| addressee name = Adams A, Boyle P
| addressee name = Adams A, Boyle P
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| document type = Letter, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| document type = Letter, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 14
| page count = 14
| project =
| stage = Supplement
}}
}}


=Text=
=Text=
{{#Wiki_filter:NUCLEAR SCIENCE CENTER 1Nuclear Science Center1095NuclearScienceRoad,3575TAMUCollegeStation,TX778433575Tel. (979) 845-7551 Dr. Sean M. McDeavitt Director, TEES Nuclear Science Center Texas A&M University Texas A&M Engineering Experiment Station 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 March 3, 2016 2016-0011 Ref: 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555  
{{#Wiki_filter:NUCLEAR SCIENCE CENTER Dr. Sean M. McDeavitt Director, TEES Nuclear Science Center Texas A&M University Texas A&M Engineering Experiment Station 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 March 3, 2016                                                                                 2016-0011 Ref: 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555


==SUBJECT:==
==SUBJECT:==
SUPPLEMENT TO LICENSE AMENDMENT REQUEST DATED OCTOBER 14, 2015, FACILITY LICENSE R-83, DOCKET NUMBER 50-128. (ADAMS ACCESSION NO. ML15287A148) Attn: Mr. Alexander Adams, Jr., Chief, Research and Test Reactors Branch Office of Nuclear Reactor Regulation Mr. Patrick M. Boyle, Project Manager, Research and Test Reactors Branch Office of Nuclear Reactor Regulation The purpose of this letter is to provide supplemental information to clarify and enhance the October 14, 2015 license amendment request (LAR) and revised License and Technical Specification pages (ADAMS Accession No. ML15287A148), the subsequent Request for Additional Information (RAI) dated November 2, 2015 (ADAMS Accession No. ML15302A018), and the Texas A&M Engineering Experiment Station (TEES) response dated November 18, 2015 (ADAMS Accession No. ML15322A354). The October 14, 2015 license amendment request was submitted to change the licensing basis for the NSC Facility and amend the License and Technical Specifications to allow the receipt, possession, but not use of the AGN-201M SNM in the NSC Fuel Storage Vault. Information provided in the RAI response and this supplement does not change the conclusions reached relative to the significant hazards consideration and the environmental impact.
SUPPLEMENT TO LICENSE AMENDMENT REQUEST DATED OCTOBER 14, 2015, FACILITY LICENSE R-83, DOCKET NUMBER 50-128.
Movement of the AGN-201M will occur in two distinct phases: the first is to relocate the fuel and other special nuclear material (SNM) from the current AGN location to the NSC Fuel Storage Vault and the second is to remove all remaining AGN-201M components to the NSC site for long term storage while the project plan to construct a new reactor facility to house the reconstructed AGN-201 M reactor is implemented. The fuel and other SNM, together with associated byproduct material (e.g., fission and activation products in the fuel), will be received, possessed, but not used under the NSC Facility Operating License No. R-83. Byproduct material not contained in or on fuel-bearing components will continue to be possessed under the AGN-201M Facility Operating License R-23 during storage on the NSC site. This point is addressed further in the LAR for the AGN-201 M Facility Operating License No. R-23 submitted on November 11, 2015 (ADAMS Accession No. ML 1531 A027). TEES is seeking approval of the October 14, 2015 license amendment request by the end of March 2016. TEES believes this short time to review the License and Technical Specification Change Request is achievable as this request contains no increased risk or impact above the currently designed, analyzed, and approved NSC reactor license. TEES notes that the proposed receipt, possession, but not use, of the AGN-201 M fuel and other SNM at the TEES NSC facility does not constitute a concern to public health and safety. Prior to undertaking efforts to support the engineering, design and construction of a new building to house the reconstructed AGN-201 M, several important actions must be completed. One action to be resolved in the near term is bringing closure to the July 30, 2013 Confirmatory Action Letter No. EA-2013-154 (ADAMS Accession No. ML 13189A058). Secondly, the ongoing License Renewal efforts should be put on hold until the efforts associated with the new building can be merged with the License Renewal completion efforts. Third, the AGN-201 M License and the NSC Facility License each have a Safety Analysis Report (SAR) which is required to be updated to reflect the current configuration of each reactor. Once the AGN-201 M has been relocated to the NSC Facility site, both SARs shall be revised to reflect the changes, as required by 10 CFR 50.71(e). Should you have any questions regarding the information provided in this submittal, please contact me or Mr. Jerry Newhouse at (979) 845-7551 or via email at mcdeavitt@tamu.edu or newhouse@tamu.edu. Oath of Affirmation I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Sinc71y, /0--/71. / /. Sean M. McDeavitt, PhD. Director, TEES Nuclear Science Center  
(ADAMS ACCESSION NO. ML15287A148)
Attn:   Mr. Alexander Adams, Jr., Chief, Research and Test Reactors Branch Office of Nuclear Reactor Regulation Mr. Patrick M. Boyle, Project Manager, Research and Test Reactors Branch Office of Nuclear Reactor Regulation The purpose of this letter is to provide supplemental information to clarify and enhance the October 14, 2015 license amendment request (LAR) and revised License and Technical Specification pages (ADAMS Accession No. ML15287A148), the subsequent Request for Additional Information (RAI) dated November 2, 2015 (ADAMS Accession No. ML15302A018),
and the Texas A&M Engineering Experiment Station (TEES) response dated November 18, 2015 (ADAMS Accession No. ML15322A354). The October 14, 2015 license amendment request was submitted to change the licensing basis for the NSC Facility and amend the License and Technical Specifications to allow the receipt, possession, but not use of the AGN-201M SNM in the NSC Fuel Storage Vault. Information provided in the RAI response and this supplement does not change the conclusions reached relative to the significant hazards consideration and the environmental impact.
Movement of the AGN-201M will occur in two distinct phases: the first is to relocate the fuel and other special nuclear material (SNM) from the current AGN location to the NSC Fuel Storage Vault and the second is to remove all remaining AGN-201M components to the NSC site for long term storage while the project plan to construct a new reactor facility to house the reconstructed AGN-201 M reactor is implemented. The fuel and other SNM, together with associated byproduct material (e.g., fission and activation products in the fuel), will be received, possessed, but not used under the NSC Facility Operating License No. R-83. Byproduct material not contained in or on fuel-bearing components will continue to be possessed under the AGN-201M Facility Operating License R-23 during storage on the NSC site. This point is Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 1                                                                                          Tel. (979) 845-7551
 
addressed further in the LAR for the AGN-201 M Facility Operating License No. R-23 submitted on November 11 , 2015 (ADAMS Accession No. ML 1531 A027) .
TEES is seeking approval of the October 14, 2015 license amendment request by the end of March 2016. TEES believes this short time to review the License and Technical Specification Change Request is achievable as this request contains no increased risk or impact above the currently designed, analyzed, and approved NSC reactor license. TEES notes that the proposed receipt, possession, but not use, of the AGN-201 M fuel and other SNM at the TEES NSC facility does not constitute a concern to public health and safety.
Prior to undertaking efforts to support the engineering, design and construction of a new building to house the reconstructed AGN-201 M, several important actions must be completed .
One action to be resolved in the near term is bringing closure to the July 30, 2013 Confirmatory Action Letter No. EA-2013-154 (ADAMS Accession No. ML13189A058). Secondly, the ongoing License Renewal efforts should be put on hold until the efforts associated with the new building can be merged with the License Renewal completion efforts. Third, the AGN-201 M License and the NSC Facility License each have a Safety Analysis Report (SAR) which is required to be updated to reflect the current configuration of each reactor. Once the AGN-201 M has been relocated to the NSC Facility site, both SARs shall be revised to reflect the changes, as required by 10 CFR 50.71(e).
Should you have any questions regarding the information provided in this submittal, please contact me or Mr. Jerry Newhouse at (979) 845-7551 or via email at mcdeavitt@tamu.edu or newhouse@tamu.edu.
Oath of Affirmation I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
Sinc7 1y,
  /
      /0--/71.
/.
Sean M. McDeavitt, PhD.
Director, TEES Nuclear Science Center


==Attachment:==
==Attachment:==
Supplemental Information  
Supplemental Information


==Enclosures:==
==Enclosures:==
1A Current License 1 B Proposed License Changes 2A Current Technical Specification 28: Proposed Technical Specification Changes 2 Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551 3Nuclear Science Center1095NuclearScienceRoad,3575TAMUCollegeStation,TX778433575Tel. (979) 845-7551cc:
1A   Current License 1B  Proposed License Changes 2A   Current Techn ical Specification 28: Proposed Technical Specification Changes Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 2                                                                                          Tel. (979) 845-7551
Mr. William Dean, Office Director United States Nuclear Reactor Commission Office of Nuclear Reactor Regulation
 
Mr. Michael Young, President Texas A&M University 1246 TAMU College Station, TX 77843-1246  Dr. M. Katherine Banks, Vice Chancellor and Dean Dwight Look College of Engineering  3126 TAMU College Station, TX 77843-3126 Dr. Dimitris Lagoudas, Deputy Director Texas A&M Engineering Experiment Station 3470 TAMU College Station, TX 77843-3577 Dr. Costas Georghiades, Associate Agency Director Texas A&M Engineering Experiment Station 3470 TAMU College Station, TX 77843-3577 Dr. Yassin Hassan, Department Head Nuclear Engineering Texas A&M University Nuclear Engineering Department 3133 TAMU College Station, TX 77843-3133
 
Dr. John Hardy Reactor Safety Board Chairman Texas A&M University 3255 TAMU College Station, TX 77843-3255
 
Dr. Latha Vasudevan Radiological Safety Officer Texas A&M University Environmental Health and Safety 1111 Research Parkway College Station, TX 77843-4472 Mayor, City of College Station P.O. Box Drawer 9960 College Station, TX 77840-3575
 
Governor's Budget and Policy Office P.O. Box 12428 Austin, TX, 78711-2428  Radiation Program Officer Bureau of Radiation Control Dept. of State Health Services Division for Regulatory Services 1100 West 49th St., MC 2828 Austin, TX  78756-3189
 
Technical Advisor Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087, MS 122 Austin, TX 78711-3087 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611-8300  Mr. Jerry Newhouse, NSC Assistant Director Texas A&M Engineering Experiment Station 3575 TAMU College Station, TX 77843-3575  Mr. Scott Miller, NSC Manager of Reactor Operations Texas A&M Engineering Experiment Station 3575 TAMU College Station, TX 77843-3575 Mr. Jeremy Osborn AGN-201M Reactor Supervisor Texas A&M University Nuclear Engineering Department 3133 TAMU College Station, TX 77843-3133 4Nuclear Science Center1095NuclearScienceRoad,3575TAMUCollegeStation,TX778433575Tel. (979) 845-7551Supplemental Information to License Amendment Request dated October 14, 2015, Facility License R-83, Docket Number 50-128. (ADAMS Accession No. ML15287A148)
Relocation and storage of a nuclear reactor is a rare occurrence. To assist with preparations to relocate and store the AGN-201M reactor, Texas A&M University/Texas A&M Engineering Experiment Station (TAMU/TEES) has reviewed a similar possession approval requested and granted to the Oregon State University (OSU) facility for storage of its AGN-201 fuel in their TRIGA Reactor Fuel Storage Vault. The planned activity includes requesting the AGN-201M special nuclear material (SNM) be received, possessed, but not used in the NSC Fuel Storage Vault. This requires approval of the October 14, 2015 License Amendment. The duration of the storage of the fuel and special nuclear materials in the NSC Fuel Storage Vault will be no longer than 5 years, to allow for approval of the Construction Permit and completion of construction of a new building adjacent to the NSC site. Once the new facility is completed, and pending receipt of Commission approval, the AGN-201M reactor will be assembled in its new licensed location. TAMU AGN-201M fuel and other SNM contained in the TEES NSC Fuel Storage Vault will be relocated to the new AGN-201M reactor facility for installation. This will reconstitute the original reactor licensing basis.


The following information has been generated to supplement the Amendment Request of October 14, 2015. Information obtained from experts in this field and discussions with NRC Staff have led to the conclusion that enhancement is required to ensure the docket is complete and easily reviewable by the NRC staff. The SAR will be updated to reflect this information upon approval of the October 14, 2015, amendment request to address the receipt, possession, but not for use, of the AGN-201M fuel, special nuclear materials and components. The current AGN-201M Safety Analysis Report uses multiple terms when referring to the reactor fuel and the control rods. This will be addressed further in the next revision to the SAR and in coordination with the License and Technical Specifications.  
cc:
Mr. William Dean, Office Director        Mayor, City of College Station United States Nuclear Reactor Commission P.O. Box Drawer 9960 Office of Nuclear Reactor Regulation    College Station, TX 77840-3575 Mr. Michael Young, President            Governors Budget and Policy Office Texas A&M University 1246 TAMU          P.O. Box 12428 College Station, TX 77843-1246          Austin, TX, 78711-2428 Dr. M. Katherine Banks, Vice Chancellor  Radiation Program Officer and Dean                              Bureau of Radiation Control Dwight Look College of Engineering      Dept. of State Health Services 3126 TAMU                                Division for Regulatory Services College Station, TX 77843-3126          1100 West 49th St., MC 2828 Austin, TX 78756-3189 Dr. Dimitris Lagoudas, Deputy Director Texas A&M Engineering Experiment Station Technical Advisor 3470 TAMU                                Office of Permitting, Remediation &
College Station, TX 77843-3577            Registration Texas Commission on Environmental Dr. Costas Georghiades, Associate Agency  Quality Director                              P.O. Box 13087, MS 122 Texas A&M Engineering Experiment Station Austin, TX 78711-3087 3470 TAMU College Station, TX 77843-3577          Test, Research and Training Reactor Newsletter Dr. Yassin Hassan, Department Head      P.O. Box 118300 Nuclear Engineering                    University of Florida Texas A&M University                    Gainesville, FL 32611-8300 Nuclear Engineering Department 3133 TAMU                                Mr. Jerry Newhouse, College Station, TX 77843-3133          NSC Assistant Director Texas A&M Engineering Experiment Station Dr. John Hardy                          3575 TAMU Reactor Safety Board Chairman Texas A&M  College Station, TX 77843-3575 University 3255 TAMU                                Mr. Scott Miller, College Station, TX 77843-3255          NSC Manager of Reactor Operations Texas A&M Engineering Experiment Station Dr. Latha Vasudevan                      3575 TAMU Radiological Safety Officer              College Station, TX 77843-3575 Texas A&M University Environmental Health and Safety          Mr. Jeremy Osborn 1111 Research Parkway                    AGN-201M Reactor Supervisor College Station, TX 77843-4472          Texas A&M University Nuclear Engineering Department 3133 TAMU College Station, TX 77843-3133 Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 3                                                                                Tel. (979) 845-7551


Supplemental Information to License Amendment Request dated October 14, 2015, Facility License R-83, Docket Number 50-128.
(ADAMS Accession No. ML15287A148)
Relocation and storage of a nuclear reactor is a rare occurrence. To assist with preparations to relocate and store the AGN-201M reactor, Texas A&M University/Texas A&M Engineering Experiment Station (TAMU/TEES) has reviewed a similar possession approval requested and granted to the Oregon State University (OSU) facility for storage of its AGN-201 fuel in their TRIGA Reactor Fuel Storage Vault. The planned activity includes requesting the AGN-201M special nuclear material (SNM) be received, possessed, but not used in the NSC Fuel Storage Vault. This requires approval of the October 14, 2015 License Amendment. The duration of the storage of the fuel and special nuclear materials in the NSC Fuel Storage Vault will be no longer than 5 years, to allow for approval of the Construction Permit and completion of construction of a new building adjacent to the NSC site. Once the new facility is completed, and pending receipt of Commission approval, the AGN-201M reactor will be assembled in its new licensed location. TAMU AGN-201M fuel and other SNM contained in the TEES NSC Fuel Storage Vault will be relocated to the new AGN-201M reactor facility for installation. This will reconstitute the original reactor licensing basis.
The following information has been generated to supplement the Amendment Request of October 14, 2015. Information obtained from experts in this field and discussions with NRC Staff have led to the conclusion that enhancement is required to ensure the docket is complete and easily reviewable by the NRC staff. The SAR will be updated to reflect this information upon approval of the October 14, 2015, amendment request to address the receipt, possession, but not for use, of the AGN-201M fuel, special nuclear materials and components. The current AGN-201M Safety Analysis Report uses multiple terms when referring to the reactor fuel and the control rods. This will be addressed further in the next revision to the SAR and in coordination with the License and Technical Specifications.
The purpose of the October 14, 2015 License Amendment is to allow the TEES NSC facility to receive, possess, but not use the AGN-201M fuel, SNM, and components currently authorized under license R-23, Docket 50-59. The storage of all components will be in accordance with the current NSC license basis. Enclosures 1A and 1B are the current and proposed NSC License pages. Enclosures 2A and 2B are the current and proposed NSC Technical Specification pages that address receipt, possession, but not use, of the AGN-201M fuel, SNM, and components. The following sections contain additional clarification for issues associated with receipt, possession, but not use, of the AGN-201M fuel, SNM and components at the NSC facility.
The purpose of the October 14, 2015 License Amendment is to allow the TEES NSC facility to receive, possess, but not use the AGN-201M fuel, SNM, and components currently authorized under license R-23, Docket 50-59. The storage of all components will be in accordance with the current NSC license basis. Enclosures 1A and 1B are the current and proposed NSC License pages. Enclosures 2A and 2B are the current and proposed NSC Technical Specification pages that address receipt, possession, but not use, of the AGN-201M fuel, SNM, and components. The following sections contain additional clarification for issues associated with receipt, possession, but not use, of the AGN-201M fuel, SNM and components at the NSC facility.
Security Plan:
Security Plan:
TEES has reviewed the NSC (TEES) Security Plan and finds that the proposed changes to allow TEES to receive, possess, but not use the AGN-201M fuel, SNM and components at the NSC facility does not constitute a change or decrease of the safeguards effectiveness of the NSC (TEES) Security Plan in accordance with 10 CFR 50.54 (p)(1,2), and does not require prior NRC review and approval. TEES will maintain all records of any proposed changes to the NSC Security Plan in accordance with 10 CFR 50.54 (p)(1,2). Accordingly, no changes to the NSC (TEES) Security Plan are required.
TEES has reviewed the NSC (TEES) Security Plan and finds that the proposed changes to allow TEES to receive, possess, but not use the AGN-201M fuel, SNM and components at the NSC facility does not constitute a change or decrease of the safeguards effectiveness of the NSC (TEES) Security Plan in accordance with 10 CFR 50.54 (p)(1,2), and does not require prior NRC review and approval. TEES will maintain all records of any proposed changes to the NSC Security Plan in accordance with 10 CFR 50.54 (p)(1,2). Accordingly, no changes to the NSC (TEES)
5Emergenc TEES hasallow TEEcomponenthe event no change Use of the TEES is p(ADAMS Adated Novinformationstorage vaconservati unnecessain the origdefense-inreactivity im
Security Plan are required.
Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 4                                                                                                Tel. (979) 845-7551


Figure 1. y Plan: s reviewed tES to receivnts does not of a radiologes to the currterm borateproviding theAccession November 2, 2n pertains toault and the vely calculaary for the saginal NSC fun-depth provmpact from tNominathe NSC (Te, possess,result in redgical emergrent NSC (Ted aluminume following o. ML15322A2015 (ADAMo Item 1 conuse of a borted for the tafe storage uel storage ision in the sthis materialal configuratiEES) Emerg but not usducing the caency, in accEES) Emergm is not discuinformation A354) to theMS Accessionncerning rearated aluminwo 5-gallonof the AGNvault designstorage druml is not crediion of the stogency Plan se the AGN-apability to pcordance witgency Plan aussed in the supplemene NRC Staffn No. ML15activity of thenum neutronSNM storag-201M fuel. n, borated ams in a manted in the reorage drumsand finds t-201M fuel, perform an eth 10 CFR 5are requiredSAR: ntal to the Nf Request fo5302A018). Me stored AGn absorber. Gge drums, thSimilar to thaluminum wners shown eactivity calcs to be used1095NucCthat the prospecial nucemergency p50.54 (q) (iv. November 1or AdditionaMore specifiGN-201M fueGiven the lohe use of bohe use of thill be utilizeschematicaculations shod for SNM stoNuclear SciencclearScienceRoad,3CollegeStation,TX7Tel. (979)posed chanclear materplanning funcv) (3). Accor8, 2015 resl Informationically, the foel in the NSow reactivity orated alumie cadmium d as an addally in Fig.1, own below.orage. ce Center3575TAMU778433575845-7551nges to ial and ction in rdingly, sponse n (RAI) ollowing SC fuel values inum is sheets ditional but the 6Nominal sthicknessecylinder fitinformationpossession TEES is presponse clocation. Aborated al storage co14.3" outsgasket. Thone at 310drum. 
Emergency Plan:
TEES has  s reviewed the t    NSC (TEES) Emerg      gency Plan and finds tthat the proposed chan                nges to allow TEE ES to receive, possess, but not us      se the AGN--201M fuel, special nucclear material and componen  nts does not result in red ducing the ca  apability to pperform an e emergency p  planning funcction in the event of a radiolog  gical emergency, in acc  cordance witth 10 CFR 5    50.54 (q) (ivv) (3). Accorrdingly, no change  es to the currrent NSC (TEES) Emerg    gency Plan a  are required.
Use of the term borate ed aluminum  m is not discu ussed in the SAR:
TEES is providing p          thee following information supplemen      ntal to the N November 18, 2015 ressponse (ADAMS Accession A          No o. ML15322A  A354) to the e NRC Stafff Request fo    or Additional Information            n (RAI) dated Nov  vember 2, 2015 2      (ADAMMS Accession    n No. ML15  5302A018). M  More specifiically, the fo        ollowing informationn pertains to o Item 1 con  ncerning rea  activity of thee stored AG GN-201M fue    el in the NS      SC fuel storage va ault and the use of a borrated alumin  num neutron  n absorber. G  Given the lo ow reactivity values conservatively calculated for the two 5-gallon SNM storag        ge drums, th he use of bo  orated alumiinum is unnecessa  ary for the saafe storage of the AGN-201M fuel. Similar to th      he use of the cadmium sheets in the origginal NSC fu uel storage vault design  n, borated a  aluminum will be utilized as an add              ditional defense-in n-depth provision in the storage s            ms in a man ners shown schematica drum                                        ally in Fig.1, but the reactivity im mpact from this t    materiall is not credited in the re eactivity calcculations sho own below.
Figure 1.        Nomina al configuratiion of the stoorage drumss to be used  d for SNM sto    orage.
Nuclear Scienc    ce Center 1095 Nucclear Science Road, 33575 TAMU C
College Station, TX 7778433575 5                                                                                                      Tel. (979) 845-7551


Figure 2.
Nominal specification s              s for the inserts inclu ude aluminu  um containin ng 16% (or greater) B4C at thicknessees ranging fromf      approxximately 1/88 to 3/8, TTop and bo  ottom absorrber plates, and a cylinder fittted to the in nside wall off the drum (Fig.
(    1). Thee NSC SAR will be upd    dated to refle        ect this information n upon app  proval of thhe October 14, 2015 a    amendmentt request to    o address rreceipt, possession  n, but not usse, of the AG GN-201M fue  el special nu uclear materials and com  mponents.
TEES is providing p          thee following information supplementa s          al to the Noovember 18, 2015 RAI Item 1 response concerning c          calculation c            of o reactivity of the stored d AGN-201M  M fuel in the e NSC fuel sstorage location. As A noted ab  bove, TEES will not tak    ke credit fo r the prese ence of the neutron-abssorbing borated aluminum lining that will be placed inside the 5      5-gallon storage contain    ners. The 5      5-gallon storage coontainers (bo  olted-ring dru ums) have th he following nominal sppecifications (refer to Fig        gure 2):
14.3 outside diamete  er, 10.4 outtside height,, with 20 ga auge wall thhickness, an  nd a 3/8 dia          ameter gasket. Thhe fuel plates will be separated into  o 2 roughly eequal stackss for packag  ging (one at 312 g, one at 310  0 g). Note that the core  e thermal fuuse containinng 0.4 g 2355U will be pllaced in the 310 g drum.
Figure 2.         Design drawing of the t 5-gallon drums to be  e used for SNNM storage..
Nuclear Scienc    ce Center 1095 Nucclear Science Road, 33575 TAMU C
College Station, TX 7778433575 6                                                                                                    Tel. (979) 845-7551


specificationes ranging ftted to the inn upon appn, but not usproviding theconcerning cAs noted abuminum liniontainers (boide diametehe fuel plate0 g). Note tDesign s for the ifrom approxnside wall ofproval of thse, of the AGe following icalculation obove, TEES ng that will olted-ring druer, 10.4" outs will be sehat the coredrawing of tnserts incluximately 1/8f the drum (he October GN-201M fuenformation sof reactivity will not takbe placed ums) have thtside height,parated intoe thermal futhe 5-gallon ude aluminu8" to 3/8", T(Fig. 1). The14, 2015 ael special nusupplementaof the storedke credit foinside the 5he following, with 20 gao 2 roughly euse containindrums to beum containinTop and boe NSC SAR amendmentuclear materal to the Nod AGN-201Mr the prese5-gallon sto nominal spauge wall thequal stacksng 0.4 g 235e used for SN1095NucCng 16% (oottom absor will be updt request toials and comovember 18M fuel in theence of the rage containpecifications hickness, ans for packag5U will be plNM storage.Nuclear SciencclearScienceRoad,3CollegeStation,TX7Tel. (979)r greater) Brber plates, dated to refleo address rmponents. , 2015 RAIe NSC fuel sneutron-absners. The 5(refer to Fignd a 3/8" diaging (one at laced in the. ce Center3575TAMU778433575845-7551B4C at and a ect this receipt, Item 1 storage sorbing 5-gallon gure 2): ameter 312 g,  310 g 7Nuclear Science Center1095NuclearScienceRoad,3575TAMUCollegeStation,TX778433575Tel. (979) 845-7551Description of storage drums and proposed storage layout   A nominal quantity of 312 grams of fissile AGN-201M fuel has been modeled in one of these drums under the following conditions: in air and reflected by 12" of concrete, and   reflected by 12" of water and by 12" of concrete. The results are presented in the following table. An additional calculation for 9 fuel plates (as described in the SAR and discussed in the November 18, 2015 response to RAI item 1) in a single right cylindrical stack, reflected by 12" of water and 12" of concrete was also performed with a resulting keff = 0.8945. This result approximates the outcome of stacking two drums containing all of the AGN-201M fuel plates without an air gap. The reactivity calculations performed represent very conservative bounding estimates, as demonstrated by an estimate of the reactivity of the nine fuel plates in the AGN-201M reactor with all control rods inserted. The resulting reactivity value (keff = 1.0760) is very conservative relative to the excess reactivity margin described in the Safety Evaluation Report (keff = 1.005), and is the result of simplifying assumptions used for the SCALE/KENO-VI calculations. This includes using a fuel concentration averaged over the external volume of the stacked fuel plates without modeling the voids for control rod drive mechanisms and the glory hole penetration.
Description of storage drums and proposed storage layout A nominal quantity of 312 grams of fissile AGN-201M fuel has been modeled in one of these drums under the following conditions:
Scenario       # configuration keff +/- 1 312 g fuel in can, 12" air 0.5339 0.0018 2 312 g fuel in can, with 12" water +12" concrete 0.6665 0.0024 3 9 fuel plates, single stack, 12" water + 12" concrete (represents stacked drums) 0.8945* 0.0023 TEST 665 g fuel (all control rods inserted) in Al core tank, with graphite reflector, lead shield, Fe reactor tank, and water-filled Fe outer shield tank 1.0760 0.0019
in air and reflected by 12 of concrete, and reflected by 12 of water and by 12 of concrete.
* The Hazard Summary Report for the AGN-201 reactor predicts a 5% to 10% reduction in reactivity from a     nominal 2" air gap between the upper and lower core halves. (ANL-6510, page 9). Given the stacked drums have the potential to exceed the reactivity limit of keff = 0.8 specified in Technical Specification 5.6, item 1, the two drums will be placed in opposite corners of the NSC fuel storage vault with and secured to the lower TRIGA fuel storage tubes (empty) using cable, chain, or similar methods, and locked.
The results are presented in the following table. An additional calculation for 9 fuel plates (as described in the SAR and discussed in the November 18, 2015 response to RAI item 1) in a single right cylindrical stack, reflected by 12 of water and 12 of concrete was also performed with a resulting keff = 0.8945. This result approximates the outcome of stacking two drums containing all of the AGN-201M fuel plates without an air gap.
The reactivity calculations performed represent very conservative bounding estimates, as demonstrated by an estimate of the reactivity of the nine fuel plates in the AGN-201M reactor with all control rods inserted. The resulting reactivity value (keff = 1.0760) is very conservative relative to the excess reactivity margin described in the Safety Evaluation Report (keff = 1.005), and is the result of simplifying assumptions used for the SCALE/KENO-VI calculations. This includes using a fuel concentration averaged over the external volume of the stacked fuel plates without modeling the voids for control rod drive mechanisms and the glory hole penetration.
Scenario   configuration                                                                               keff             +/-
1         312 g fuel in can, 12 air                                                                 0.5339           0.0018 2         312 g fuel in can, with 12 water +12 concrete                                             0.6665           0.0024 3         9 fuel plates, single stack, 12 water + 12 concrete (represents stacked drums)           0.8945*         0.0023 TEST       665 g fuel (all control rods inserted) in Al core tank, with graphite reflector, lead     1.0760          0.0019 shield, Fe reactor tank, and water-filled Fe outer shield tank
* The Hazard Summary Report for the AGN-201 reactor predicts a 5% to 10% reduction in reactivity from a nominal 2 air gap between the upper and lower core halves. (ANL-6510, page 9).
Given the stacked drums have the potential to exceed the reactivity limit of keff = 0.8 specified in Technical Specification 5.6, item 1, the two drums will be placed in opposite corners of the NSC fuel storage vault with and secured to the lower TRIGA fuel storage tubes (empty) using cable, chain, or similar methods, and locked.
Horizontal spacing of the two drums has been further evaluated using the solid angle assessment method presented in TID-7016, Rev 2, Nuclear Safety Guide. Using a conservative keff of 0.7 and the nominal drum dimensions, the allowed solid angle must be <2 steradians and is met with the drums even at very close distances (e.g., with an air gap < 1 foot). A revised proposed minimum center-to-center separation distance of 10 feet is sufficient to consider the storage drums uncoupled for nuclear safety considerations and allows flexibility for drum inspections.
Horizontal spacing of the two drums has been further evaluated using the solid angle assessment method presented in TID-7016, Rev 2, Nuclear Safety Guide. Using a conservative keff of 0.7 and the nominal drum dimensions, the allowed solid angle must be <2 steradians and is met with the drums even at very close distances (e.g., with an air gap < 1 foot). A revised proposed minimum center-to-center separation distance of 10 feet is sufficient to consider the storage drums uncoupled for nuclear safety considerations and allows flexibility for drum inspections.
Figure 3 illustrates the proposed positions of SNM-bearing components in the NSC fuel storage vault, with the exception of the 239PuBe source. To maintain personnel exposures ALARA, this source will be stored in a neutron-attenuating shield and placed in a location within the fuel storage vault, as approved by site Radiation Safety Officer.
Figure 3 illustrates the proposed positions of SNM-bearing components in the NSC fuel storage vault, with the exception of the 239PuBe source. To maintain personnel exposures ALARA, this source will be stored in a neutron-attenuating shield and placed in a location within the fuel storage vault, as approved by site Radiation Safety Officer.
8Figure 3.
Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 7                                                                                                            Tel. (979) 845-7551
Authorizat The requeexplicitly aAGN-201Mcontained This requeAGN-201Mactivated cstorage at Photogion to posseest to possesauthorize fisM fuel, 239Puin the startuest does notM Facility Ocomponents the NSC sitgraph of the ess AGN-201ss AGN-201sion producuBe startup up source cat have a parperating Lic(e.g., the we. NSC fuel sto1M byproducM componects and activsource, fueapsule and trallel requescense R-23, water shield torage vault wct material ents under Nvation produel-bearing che mechanicst to remove as it is TAMtank and its where the ANSC Facilityucts as maycontrol rod ecal portions  the byprodMU's intent contained c1095NucCAGN-201M Sy Operating y be presenends, and aof the contruct materialto retain pocomponent) Nuclear SciencclearScienceRoad,3CollegeStation,TX7Tel. (979)SNM will be sLicense R-8nt in the irraactivation prrol rod assem possessionossession ounder R-23 ce Center3575TAMU778433575845-7551stored. 83 is to adiated roducts mblies. n in the of other during 9  THE FOLLOWING PAGES INCLUDE THE ORIGINAL AND PROPOSED REPLACEMENT PAGES FOR THE LICENSE AND  TECHNICAL SPECIFICATIONS   
 
Figure 3.        Photog graph of the NSC fuel sto orage vault wwhere the A AGN-201M S    SNM will be sstored.
Authorization to posse  ess AGN-201  1M byproduc ct material The reque  est to posses ss AGN-201M compone    ents under N  NSC Facilityy Operating License R-8          83 is to explicitly authorize a          fission produc cts and activvation produ ucts as mayy be presen  nt in the irra        adiated AGN-201M  M fuel, 239Pu uBe startup source, fue  el-bearing ccontrol rod eends, and a  activation prroducts contained in the startu up source ca apsule and the mechaniccal portions of the contrrol rod assem            mblies.
This reque est does nott have a parrallel reques st to remove the byproduct material possession            n in the AGN-201M  M Facility Operating Lic  cense R-23, as it is TAM  MUs intent to retain po  ossession o      of other activated components c              (e.g., the water w    shield tank t    and its contained ccomponent) under R-23 during storage at the NSC site.
Nuclear Scienc    ce Center 1095 Nucclear Science Road, 33575 TAMU C
College Station, TX 7778433575 8                                                                                                  Tel. (979) 845-7551


10Enclosure 1A  TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein "the facility"] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein "the licensee"], located on the campus of Texas A&M University at College Station, Texas, and described in the licensee's application for license renewal, dated February 27, 2003, as supplemented. B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows: 1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license. 2. Pursuant to the Act and 10 CFR Part 70, the following activities are included: a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel; b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and, 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. 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, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which can not be separated except for byproduct material produced in reactor experiments.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.
THE FOLLOWING PAGES INCLUDE THE ORIGINAL AND PROPOSED REPLACEMENT PAGES FOR THE LICENSE AND TECHNICAL SPECIFICATIONS 9
11Enclosure 1B  PROPOSED LICENSE CHANGE FOR THE NSC FACILITY TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 As Amended Through Amendment No. XX A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein "the facility"] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein "the licensee"], located on the campus of Texas A&M University at College Station, Texas, and described in the licensee's application for license renewal, dated February 27, 2003, as supplemented. B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows: 1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license. 2. Pursuant to the Act and 10 CFR Part 70, the following activities are included: a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel; b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and, 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 as AGN-201M <20% enriched 235U reactor fuel, and actinides and activation products for up to 5 years from the date of issuance of license amendment xx. e. To receive, possess, but not use up to 0.020 kilograms of 239Pu as a 239PuBe sealed neutron start-up source in connection with storage of the AGN-201M reactor for up to 5 years from the date of issuance of license amendment xx. _______________        Date-2016 123. 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,  
A TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.
: c. 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.  
B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:
: d. to receive, possess, but not use, byproduct materials including contaminated or activated AGN-201M reactor components for up to 5 years from the date of issuance of amendment xx. __________ Date-2016 13Enclosure 2A  CURRENT TECHNICAL SPECIFICATION FOR THE TEES NSC FACILITY The current NSC reactor Technical Specification affected is Section 5.6 titled, "Fuel Storage" which follows. The proposed new Technical Specification has a vertical line indicating the changes made to the existing Technical Specification: 5.6 Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core. Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature. Specification 1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.  
: 1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.
: 2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values. Basis The limits imposed by Specifications 5.6.1 and 5.6.2 are conservative and ensure safe storage.
: 2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:
14Enclosure 2B  Proposed Technical Specification Change TEES recommends the following replacement Technical Specification change containing wording to support this LAR is as follows:
: a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;
5.6 Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core. This includes the combined 235U fissile mass of no more than 0.7 kilograms, actinides and activation products, and the 239PuBe neutron start-up source with a 239Pu fissile mass of no more than 20 grams, from the TAMU AGN-201M reactor.
: b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,
Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.
: 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.
Specification 1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection. 2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.  
: 3. Pursuant to the Act and 10 CFR Part 30, the following activities are included:
: 3. Possession of the AGN-201M fuel, and actinides and activation products and neutron start-up source is restricted to receipt, possession, but not use in the operation of the NSC reactor. Specification 2, above, is not applicable to these materials. Basis The limits imposed by Specifications 5.6.1, 5.6.2, and 5.6.3 are conservative and ensure safe storage. __________ Date-2016 __________ Date-2016 __________ Date-2016 NUCLEAR SCIENCE CENTER 1Nuclear Science Center1095NuclearScienceRoad,3575TAMUCollegeStation,TX778433575Tel. (979) 845-7551 Dr. Sean M. McDeavitt Director, TEES Nuclear Science Center Texas A&M University Texas A&M Engineering Experiment Station 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 March 3, 2016 2016-0011 Ref: 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555  
: 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, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which can not be separated except for byproduct material produced in reactor experiments.
: 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.
10 B
PROPOSED LICENSE CHANGE FOR THE NSC FACILITY TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 As Amended Through Amendment No. XX A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility]
TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.
B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:
: 1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.
: 2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:
: a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;
: b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,
: 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 as AGN-201M <20% enriched 235U reactor fuel, and actinides and activation products for up to 5 years from the date of issuance of license amendment xx.
: e. To receive, possess, but not use up to 0.020 kilograms of 239Pu Date-2016 as a 239PuBe sealed neutron start-up source in connection with storage of the AGN-201M reactor for up to 5 years from the date of issuance of license amendment xx.
11
: 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, 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.
: d. to receive, possess, but not use, byproduct materials including contaminated or activated AGN-201M reactor components for                     __________
up to 5 years from the date of issuance of amendment xx.
Date-2016 12 A
CURRENT TECHNICAL SPECIFICATION FOR THE TEES NSC FACILITY The current NSC reactor Technical Specification affected is Section 5.6 titled, Fuel Storage which follows. The proposed new Technical Specification has a vertical line indicating the changes made to the existing Technical Specification:
5.6     Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core.
Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.
Specification
: 1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.
: 2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.
Basis The limits imposed by Specifications 5.6.1 and 5.6.2 are conservative and ensure safe storage.
13 B
Proposed Technical Specification Change TEES recommends the following replacement Technical Specification change containing wording to support this LAR is as follows:
5.6   Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core.
This includes the combined 235U fissile mass of no more than 0.7 kilograms, actinides                         __________
and activation products, and the 239PuBe neutron start-up source with a 239Pu fissile mass Date-2016 of no more than 20 grams, from the TAMU AGN-201M reactor.
Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.
Specification
: 1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.
: 2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.
: 3. Possession of the AGN-201M fuel, and actinides and activation products and neutron                         __________
start-up source is restricted to receipt, possession, but not use in the operation of the Date-2016 NSC reactor. Specification 2, above, is not applicable to these materials.
Basis The limits imposed by Specifications 5.6.1, 5.6.2, and 5.6.3 are conservative and ensure safe Date-2016 storage.
14
 
NUCLEAR SCIENCE CENTER Dr. Sean M. McDeavitt Director, TEES Nuclear Science Center Texas A&M University Texas A&M Engineering Experiment Station 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 March 3, 2016                                                                                 2016-0011 Ref: 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555


==SUBJECT:==
==SUBJECT:==
SUPPLEMENT TO LICENSE AMENDMENT REQUEST DATED OCTOBER 14, 2015, FACILITY LICENSE R-83, DOCKET NUMBER 50-128. (ADAMS ACCESSION NO. ML15287A148) Attn: Mr. Alexander Adams, Jr., Chief, Research and Test Reactors Branch Office of Nuclear Reactor Regulation Mr. Patrick M. Boyle, Project Manager, Research and Test Reactors Branch Office of Nuclear Reactor Regulation The purpose of this letter is to provide supplemental information to clarify and enhance the October 14, 2015 license amendment request (LAR) and revised License and Technical Specification pages (ADAMS Accession No. ML15287A148), the subsequent Request for Additional Information (RAI) dated November 2, 2015 (ADAMS Accession No. ML15302A018), and the Texas A&M Engineering Experiment Station (TEES) response dated November 18, 2015 (ADAMS Accession No. ML15322A354). The October 14, 2015 license amendment request was submitted to change the licensing basis for the NSC Facility and amend the License and Technical Specifications to allow the receipt, possession, but not use of the AGN-201M SNM in the NSC Fuel Storage Vault. Information provided in the RAI response and this supplement does not change the conclusions reached relative to the significant hazards consideration and the environmental impact.
SUPPLEMENT TO LICENSE AMENDMENT REQUEST DATED OCTOBER 14, 2015, FACILITY LICENSE R-83, DOCKET NUMBER 50-128.
Movement of the AGN-201M will occur in two distinct phases: the first is to relocate the fuel and other special nuclear material (SNM) from the current AGN location to the NSC Fuel Storage Vault and the second is to remove all remaining AGN-201M components to the NSC site for long term storage while the project plan to construct a new reactor facility to house the reconstructed AGN-201 M reactor is implemented. The fuel and other SNM, together with associated byproduct material (e.g., fission and activation products in the fuel), will be received, possessed, but not used under the NSC Facility Operating License No. R-83. Byproduct material not contained in or on fuel-bearing components will continue to be possessed under the AGN-201M Facility Operating License R-23 during storage on the NSC site. This point is addressed further in the LAR for the AGN-201 M Facility Operating License No. R-23 submitted on November 11, 2015 (ADAMS Accession No. ML 1531 A027). TEES is seeking approval of the October 14, 2015 license amendment request by the end of March 2016. TEES believes this short time to review the License and Technical Specification Change Request is achievable as this request contains no increased risk or impact above the currently designed, analyzed, and approved NSC reactor license. TEES notes that the proposed receipt, possession, but not use, of the AGN-201 M fuel and other SNM at the TEES NSC facility does not constitute a concern to public health and safety. Prior to undertaking efforts to support the engineering, design and construction of a new building to house the reconstructed AGN-201 M, several important actions must be completed. One action to be resolved in the near term is bringing closure to the July 30, 2013 Confirmatory Action Letter No. EA-2013-154 (ADAMS Accession No. ML 13189A058). Secondly, the ongoing License Renewal efforts should be put on hold until the efforts associated with the new building can be merged with the License Renewal completion efforts. Third, the AGN-201 M License and the NSC Facility License each have a Safety Analysis Report (SAR) which is required to be updated to reflect the current configuration of each reactor. Once the AGN-201 M has been relocated to the NSC Facility site, both SARs shall be revised to reflect the changes, as required by 10 CFR 50.71(e). Should you have any questions regarding the information provided in this submittal, please contact me or Mr. Jerry Newhouse at (979) 845-7551 or via email at mcdeavitt@tamu.edu or newhouse@tamu.edu. Oath of Affirmation I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Sinc71y, /0--/71. / /. Sean M. McDeavitt, PhD. Director, TEES Nuclear Science Center  
(ADAMS ACCESSION NO. ML15287A148)
Attn:   Mr. Alexander Adams, Jr., Chief, Research and Test Reactors Branch Office of Nuclear Reactor Regulation Mr. Patrick M. Boyle, Project Manager, Research and Test Reactors Branch Office of Nuclear Reactor Regulation The purpose of this letter is to provide supplemental information to clarify and enhance the October 14, 2015 license amendment request (LAR) and revised License and Technical Specification pages (ADAMS Accession No. ML15287A148), the subsequent Request for Additional Information (RAI) dated November 2, 2015 (ADAMS Accession No. ML15302A018),
and the Texas A&M Engineering Experiment Station (TEES) response dated November 18, 2015 (ADAMS Accession No. ML15322A354). The October 14, 2015 license amendment request was submitted to change the licensing basis for the NSC Facility and amend the License and Technical Specifications to allow the receipt, possession, but not use of the AGN-201M SNM in the NSC Fuel Storage Vault. Information provided in the RAI response and this supplement does not change the conclusions reached relative to the significant hazards consideration and the environmental impact.
Movement of the AGN-201M will occur in two distinct phases: the first is to relocate the fuel and other special nuclear material (SNM) from the current AGN location to the NSC Fuel Storage Vault and the second is to remove all remaining AGN-201M components to the NSC site for long term storage while the project plan to construct a new reactor facility to house the reconstructed AGN-201 M reactor is implemented. The fuel and other SNM, together with associated byproduct material (e.g., fission and activation products in the fuel), will be received, possessed, but not used under the NSC Facility Operating License No. R-83. Byproduct material not contained in or on fuel-bearing components will continue to be possessed under the AGN-201M Facility Operating License R-23 during storage on the NSC site. This point is Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 1                                                                                          Tel. (979) 845-7551
 
addressed further in the LAR for the AGN-201 M Facility Operating License No. R-23 submitted on November 11 , 2015 (ADAMS Accession No. ML 1531 A027) .
TEES is seeking approval of the October 14, 2015 license amendment request by the end of March 2016. TEES believes this short time to review the License and Technical Specification Change Request is achievable as this request contains no increased risk or impact above the currently designed, analyzed, and approved NSC reactor license. TEES notes that the proposed receipt, possession, but not use, of the AGN-201 M fuel and other SNM at the TEES NSC facility does not constitute a concern to public health and safety.
Prior to undertaking efforts to support the engineering, design and construction of a new building to house the reconstructed AGN-201 M, several important actions must be completed .
One action to be resolved in the near term is bringing closure to the July 30, 2013 Confirmatory Action Letter No. EA-2013-154 (ADAMS Accession No. ML13189A058). Secondly, the ongoing License Renewal efforts should be put on hold until the efforts associated with the new building can be merged with the License Renewal completion efforts. Third, the AGN-201 M License and the NSC Facility License each have a Safety Analysis Report (SAR) which is required to be updated to reflect the current configuration of each reactor. Once the AGN-201 M has been relocated to the NSC Facility site, both SARs shall be revised to reflect the changes, as required by 10 CFR 50.71(e).
Should you have any questions regarding the information provided in this submittal, please contact me or Mr. Jerry Newhouse at (979) 845-7551 or via email at mcdeavitt@tamu.edu or newhouse@tamu.edu.
Oath of Affirmation I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
Sinc7 1y,
  /
      /0--/71.
/.
Sean M. McDeavitt, PhD.
Director, TEES Nuclear Science Center


==Attachment:==
==Attachment:==
Supplemental Information  
Supplemental Information


==Enclosures:==
==Enclosures:==
1A Current License 1 B Proposed License Changes 2A Current Technical Specification 28: Proposed Technical Specification Changes 2 Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551 3Nuclear Science Center1095NuclearScienceRoad,3575TAMUCollegeStation,TX778433575Tel. (979) 845-7551cc:
1A   Current License 1B  Proposed License Changes 2A   Current Techn ical Specification 28: Proposed Technical Specification Changes Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 2                                                                                          Tel. (979) 845-7551
Mr. William Dean, Office Director United States Nuclear Reactor Commission Office of Nuclear Reactor Regulation
 
Mr. Michael Young, President Texas A&M University 1246 TAMU College Station, TX 77843-1246  Dr. M. Katherine Banks, Vice Chancellor and Dean Dwight Look College of Engineering  3126 TAMU College Station, TX 77843-3126 Dr. Dimitris Lagoudas, Deputy Director Texas A&M Engineering Experiment Station 3470 TAMU College Station, TX 77843-3577 Dr. Costas Georghiades, Associate Agency Director Texas A&M Engineering Experiment Station 3470 TAMU College Station, TX 77843-3577 Dr. Yassin Hassan, Department Head Nuclear Engineering Texas A&M University Nuclear Engineering Department 3133 TAMU College Station, TX 77843-3133
 
Dr. John Hardy Reactor Safety Board Chairman Texas A&M University 3255 TAMU College Station, TX 77843-3255


Dr. Latha Vasudevan Radiological Safety Officer Texas A&M University Environmental Health and Safety 1111 Research Parkway College Station, TX 77843-4472 Mayor, City of College Station P.O. Box Drawer 9960 College Station, TX 77840-3575  
cc:
 
Mr. William Dean, Office Director        Mayor, City of College Station United States Nuclear Reactor Commission P.O. Box Drawer 9960 Office of Nuclear Reactor Regulation    College Station, TX 77840-3575 Mr. Michael Young, President            Governors Budget and Policy Office Texas A&M University 1246 TAMU          P.O. Box 12428 College Station, TX 77843-1246          Austin, TX, 78711-2428 Dr. M. Katherine Banks, Vice Chancellor Radiation Program Officer and Dean                              Bureau of Radiation Control Dwight Look College of Engineering      Dept. of State Health Services 3126 TAMU                                Division for Regulatory Services College Station, TX 77843-3126          1100 West 49th St., MC 2828 Austin, TX 78756-3189 Dr. Dimitris Lagoudas, Deputy Director Texas A&M Engineering Experiment Station Technical Advisor 3470 TAMU                                Office of Permitting, Remediation &
Governor's Budget and Policy Office P.O. Box 12428 Austin, TX, 78711-2428  Radiation Program Officer Bureau of Radiation Control Dept. of State Health Services Division for Regulatory Services 1100 West 49th St., MC 2828 Austin, TX 78756-3189  
College Station, TX 77843-3577            Registration Texas Commission on Environmental Dr. Costas Georghiades, Associate Agency  Quality Director                              P.O. Box 13087, MS 122 Texas A&M Engineering Experiment Station Austin, TX 78711-3087 3470 TAMU College Station, TX 77843-3577          Test, Research and Training Reactor Newsletter Dr. Yassin Hassan, Department Head      P.O. Box 118300 Nuclear Engineering                    University of Florida Texas A&M University                    Gainesville, FL 32611-8300 Nuclear Engineering Department 3133 TAMU                                Mr. Jerry Newhouse, College Station, TX 77843-3133          NSC Assistant Director Texas A&M Engineering Experiment Station Dr. John Hardy                          3575 TAMU Reactor Safety Board Chairman Texas A&M  College Station, TX 77843-3575 University 3255 TAMU                                Mr. Scott Miller, College Station, TX 77843-3255          NSC Manager of Reactor Operations Texas A&M Engineering Experiment Station Dr. Latha Vasudevan                      3575 TAMU Radiological Safety Officer              College Station, TX 77843-3575 Texas A&M University Environmental Health and Safety          Mr. Jeremy Osborn 1111 Research Parkway                    AGN-201M Reactor Supervisor College Station, TX 77843-4472          Texas A&M University Nuclear Engineering Department 3133 TAMU College Station, TX 77843-3133 Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 3                                                                                Tel. (979) 845-7551
 
Technical Advisor Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087, MS 122 Austin, TX 78711-3087 Test, Research and Training Reactor Newsletter P.O. Box 118300 University of Florida Gainesville, FL 32611-8300 Mr. Jerry Newhouse, NSC Assistant Director Texas A&M Engineering Experiment Station 3575 TAMU College Station, TX 77843-3575 Mr. Scott Miller, NSC Manager of Reactor Operations Texas A&M Engineering Experiment Station 3575 TAMU College Station, TX 77843-3575 Mr. Jeremy Osborn AGN-201M Reactor Supervisor Texas A&M University Nuclear Engineering Department 3133 TAMU College Station, TX 77843-3133 4Nuclear Science Center1095NuclearScienceRoad,3575TAMUCollegeStation,TX778433575Tel. (979) 845-7551Supplemental Information to License Amendment Request dated October 14, 2015, Facility License R-83, Docket Number 50-128. (ADAMS Accession No. ML15287A148)
Relocation and storage of a nuclear reactor is a rare occurrence. To assist with preparations to relocate and store the AGN-201M reactor, Texas A&M University/Texas A&M Engineering Experiment Station (TAMU/TEES) has reviewed a similar possession approval requested and granted to the Oregon State University (OSU) facility for storage of its AGN-201 fuel in their TRIGA Reactor Fuel Storage Vault. The planned activity includes requesting the AGN-201M special nuclear material (SNM) be received, possessed, but not used in the NSC Fuel Storage Vault. This requires approval of the October 14, 2015 License Amendment. The duration of the storage of the fuel and special nuclear materials in the NSC Fuel Storage Vault will be no longer than 5 years, to allow for approval of the Construction Permit and completion of construction of a new building adjacent to the NSC site. Once the new facility is completed, and pending receipt of Commission approval, the AGN-201M reactor will be assembled in its new licensed location. TAMU AGN-201M fuel and other SNM contained in the TEES NSC Fuel Storage Vault will be relocated to the new AGN-201M reactor facility for installation. This will reconstitute the original reactor licensing basis.
 
The following information has been generated to supplement the Amendment Request of October 14, 2015. Information obtained from experts in this field and discussions with NRC Staff have led to the conclusion that enhancement is required to ensure the docket is complete and easily reviewable by the NRC staff. The SAR will be updated to reflect this information upon approval of the October 14, 2015, amendment request to address the receipt, possession, but not for use, of the AGN-201M fuel, special nuclear materials and components. The current AGN-201M Safety Analysis Report uses multiple terms when referring to the reactor fuel and the control rods. This will be addressed further in the next revision to the SAR and in coordination with the License and Technical Specifications.


Supplemental Information to License Amendment Request dated October 14, 2015, Facility License R-83, Docket Number 50-128.
(ADAMS Accession No. ML15287A148)
Relocation and storage of a nuclear reactor is a rare occurrence. To assist with preparations to relocate and store the AGN-201M reactor, Texas A&M University/Texas A&M Engineering Experiment Station (TAMU/TEES) has reviewed a similar possession approval requested and granted to the Oregon State University (OSU) facility for storage of its AGN-201 fuel in their TRIGA Reactor Fuel Storage Vault. The planned activity includes requesting the AGN-201M special nuclear material (SNM) be received, possessed, but not used in the NSC Fuel Storage Vault. This requires approval of the October 14, 2015 License Amendment. The duration of the storage of the fuel and special nuclear materials in the NSC Fuel Storage Vault will be no longer than 5 years, to allow for approval of the Construction Permit and completion of construction of a new building adjacent to the NSC site. Once the new facility is completed, and pending receipt of Commission approval, the AGN-201M reactor will be assembled in its new licensed location. TAMU AGN-201M fuel and other SNM contained in the TEES NSC Fuel Storage Vault will be relocated to the new AGN-201M reactor facility for installation. This will reconstitute the original reactor licensing basis.
The following information has been generated to supplement the Amendment Request of October 14, 2015. Information obtained from experts in this field and discussions with NRC Staff have led to the conclusion that enhancement is required to ensure the docket is complete and easily reviewable by the NRC staff. The SAR will be updated to reflect this information upon approval of the October 14, 2015, amendment request to address the receipt, possession, but not for use, of the AGN-201M fuel, special nuclear materials and components. The current AGN-201M Safety Analysis Report uses multiple terms when referring to the reactor fuel and the control rods. This will be addressed further in the next revision to the SAR and in coordination with the License and Technical Specifications.
The purpose of the October 14, 2015 License Amendment is to allow the TEES NSC facility to receive, possess, but not use the AGN-201M fuel, SNM, and components currently authorized under license R-23, Docket 50-59. The storage of all components will be in accordance with the current NSC license basis. Enclosures 1A and 1B are the current and proposed NSC License pages. Enclosures 2A and 2B are the current and proposed NSC Technical Specification pages that address receipt, possession, but not use, of the AGN-201M fuel, SNM, and components. The following sections contain additional clarification for issues associated with receipt, possession, but not use, of the AGN-201M fuel, SNM and components at the NSC facility.
The purpose of the October 14, 2015 License Amendment is to allow the TEES NSC facility to receive, possess, but not use the AGN-201M fuel, SNM, and components currently authorized under license R-23, Docket 50-59. The storage of all components will be in accordance with the current NSC license basis. Enclosures 1A and 1B are the current and proposed NSC License pages. Enclosures 2A and 2B are the current and proposed NSC Technical Specification pages that address receipt, possession, but not use, of the AGN-201M fuel, SNM, and components. The following sections contain additional clarification for issues associated with receipt, possession, but not use, of the AGN-201M fuel, SNM and components at the NSC facility.
Security Plan:
Security Plan:
TEES has reviewed the NSC (TEES) Security Plan and finds that the proposed changes to allow TEES to receive, possess, but not use the AGN-201M fuel, SNM and components at the NSC facility does not constitute a change or decrease of the safeguards effectiveness of the NSC (TEES) Security Plan in accordance with 10 CFR 50.54 (p)(1,2), and does not require prior NRC review and approval. TEES will maintain all records of any proposed changes to the NSC Security Plan in accordance with 10 CFR 50.54 (p)(1,2). Accordingly, no changes to the NSC (TEES) Security Plan are required.
TEES has reviewed the NSC (TEES) Security Plan and finds that the proposed changes to allow TEES to receive, possess, but not use the AGN-201M fuel, SNM and components at the NSC facility does not constitute a change or decrease of the safeguards effectiveness of the NSC (TEES) Security Plan in accordance with 10 CFR 50.54 (p)(1,2), and does not require prior NRC review and approval. TEES will maintain all records of any proposed changes to the NSC Security Plan in accordance with 10 CFR 50.54 (p)(1,2). Accordingly, no changes to the NSC (TEES)
5Emergenc TEES hasallow TEEcomponenthe event no change Use of the TEES is p(ADAMS Adated Novinformationstorage vaconservati unnecessain the origdefense-inreactivity im
Security Plan are required.
Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 4                                                                                                Tel. (979) 845-7551


Figure 1. y Plan: s reviewed tES to receivnts does not of a radiologes to the currterm borateproviding theAccession November 2, 2n pertains toault and the vely calculaary for the saginal NSC fun-depth provmpact from tNominathe NSC (Te, possess,result in redgical emergrent NSC (Ted aluminume following o. ML15322A2015 (ADAMo Item 1 conuse of a borted for the tafe storage uel storage ision in the sthis materialal configuratiEES) Emerg but not usducing the caency, in accEES) Emergm is not discuinformation A354) to theMS Accessionncerning rearated aluminwo 5-gallonof the AGNvault designstorage druml is not crediion of the stogency Plan se the AGN-apability to pcordance witgency Plan aussed in the supplemene NRC Staffn No. ML15activity of thenum neutronSNM storag-201M fuel. n, borated ams in a manted in the reorage drumsand finds t-201M fuel, perform an eth 10 CFR 5are requiredSAR: ntal to the Nf Request fo5302A018). Me stored AGn absorber. Gge drums, thSimilar to thaluminum wners shown eactivity calcs to be used1095NucCthat the prospecial nucemergency p50.54 (q) (iv. November 1or AdditionaMore specifiGN-201M fueGiven the lohe use of bohe use of thill be utilizeschematicaculations shod for SNM stoNuclear SciencclearScienceRoad,3CollegeStation,TX7Tel. (979)posed chanclear materplanning funcv) (3). Accor8, 2015 resl Informationically, the foel in the NSow reactivity orated alumie cadmium d as an addally in Fig.1, own below.orage. ce Center3575TAMU778433575845-7551nges to ial and ction in rdingly, sponse n (RAI) ollowing SC fuel values inum is sheets ditional but the 6Nominal sthicknessecylinder fitinformationpossession TEES is presponse clocation. Aborated al storage co14.3" outsgasket. Thone at 310drum. 
Emergency Plan:
TEES has  s reviewed the t    NSC (TEES) Emerg      gency Plan and finds tthat the proposed chan                nges to allow TEE ES to receive, possess, but not us      se the AGN--201M fuel, special nucclear material and componen  nts does not result in red ducing the ca  apability to pperform an e emergency p  planning funcction in the event of a radiolog  gical emergency, in acc  cordance witth 10 CFR 5    50.54 (q) (ivv) (3). Accorrdingly, no change  es to the currrent NSC (TEES) Emerg    gency Plan a  are required.
Use of the term borate ed aluminum  m is not discu ussed in the SAR:
TEES is providing p          thee following information supplemen      ntal to the N November 18, 2015 ressponse (ADAMS Accession A          No o. ML15322A  A354) to the e NRC Stafff Request fo    or Additional Information            n (RAI) dated Nov  vember 2, 2015 2      (ADAMMS Accession    n No. ML15  5302A018). M  More specifiically, the fo        ollowing informationn pertains to o Item 1 con  ncerning rea  activity of thee stored AG GN-201M fue    el in the NS      SC fuel storage va ault and the use of a borrated alumin  num neutron  n absorber. G  Given the lo ow reactivity values conservatively calculated for the two 5-gallon SNM storag        ge drums, th he use of bo  orated alumiinum is unnecessa  ary for the saafe storage of the AGN-201M fuel. Similar to th      he use of the cadmium sheets in the origginal NSC fu uel storage vault design  n, borated a  aluminum will be utilized as an add              ditional defense-in n-depth provision in the storage s            ms in a man ners shown schematica drum                                        ally in Fig.1, but the reactivity im mpact from this t    materiall is not credited in the re eactivity calcculations sho own below.
Figure 1.        Nomina al configuratiion of the stoorage drumss to be used  d for SNM sto    orage.
Nuclear Scienc    ce Center 1095 Nucclear Science Road, 33575 TAMU C
College Station, TX 7778433575 5                                                                                                      Tel. (979) 845-7551


Figure 2.
Nominal specification s              s for the inserts inclu ude aluminu  um containin ng 16% (or greater) B4C at thicknessees ranging fromf      approxximately 1/88 to 3/8, TTop and bo  ottom absorrber plates, and a cylinder fittted to the in nside wall off the drum (Fig.
(    1). Thee NSC SAR will be upd    dated to refle        ect this information n upon app  proval of thhe October 14, 2015 a    amendmentt request to    o address rreceipt, possession  n, but not usse, of the AG GN-201M fue  el special nu uclear materials and com  mponents.
TEES is providing p          thee following information supplementa s          al to the Noovember 18, 2015 RAI Item 1 response concerning c          calculation c            of o reactivity of the stored d AGN-201M  M fuel in the e NSC fuel sstorage location. As A noted ab  bove, TEES will not tak    ke credit fo r the prese ence of the neutron-abssorbing borated aluminum lining that will be placed inside the 5      5-gallon storage contain    ners. The 5      5-gallon storage coontainers (bo  olted-ring dru ums) have th he following nominal sppecifications (refer to Fig        gure 2):
14.3 outside diamete  er, 10.4 outtside height,, with 20 ga auge wall thhickness, an  nd a 3/8 dia          ameter gasket. Thhe fuel plates will be separated into  o 2 roughly eequal stackss for packag  ging (one at 312 g, one at 310  0 g). Note that the core  e thermal fuuse containinng 0.4 g 2355U will be pllaced in the 310 g drum.
Figure 2.         Design drawing of the t 5-gallon drums to be  e used for SNNM storage..
Nuclear Scienc    ce Center 1095 Nucclear Science Road, 33575 TAMU C
College Station, TX 7778433575 6                                                                                                    Tel. (979) 845-7551


specificationes ranging ftted to the inn upon appn, but not usproviding theconcerning cAs noted abuminum liniontainers (boide diametehe fuel plate0 g). Note tDesign s for the ifrom approxnside wall ofproval of thse, of the AGe following icalculation obove, TEES ng that will olted-ring druer, 10.4" outs will be sehat the coredrawing of tnserts incluximately 1/8f the drum (he October GN-201M fuenformation sof reactivity will not takbe placed ums) have thtside height,parated intoe thermal futhe 5-gallon ude aluminu8" to 3/8", T(Fig. 1). The14, 2015 ael special nusupplementaof the storedke credit foinside the 5he following, with 20 gao 2 roughly euse containindrums to beum containinTop and boe NSC SAR amendmentuclear materal to the Nod AGN-201Mr the prese5-gallon sto nominal spauge wall thequal stacksng 0.4 g 235e used for SN1095NucCng 16% (oottom absor will be updt request toials and comovember 18M fuel in theence of the rage containpecifications hickness, ans for packag5U will be plNM storage.Nuclear SciencclearScienceRoad,3CollegeStation,TX7Tel. (979)r greater) Brber plates, dated to refleo address rmponents. , 2015 RAIe NSC fuel sneutron-absners. The 5(refer to Fignd a 3/8" diaging (one at laced in the. ce Center3575TAMU778433575845-7551B4C at and a ect this receipt, Item 1 storage sorbing 5-gallon gure 2): ameter 312 g,  310 g 7Nuclear Science Center1095NuclearScienceRoad,3575TAMUCollegeStation,TX778433575Tel. (979) 845-7551Description of storage drums and proposed storage layout   A nominal quantity of 312 grams of fissile AGN-201M fuel has been modeled in one of these drums under the following conditions: in air and reflected by 12" of concrete, and   reflected by 12" of water and by 12" of concrete. The results are presented in the following table. An additional calculation for 9 fuel plates (as described in the SAR and discussed in the November 18, 2015 response to RAI item 1) in a single right cylindrical stack, reflected by 12" of water and 12" of concrete was also performed with a resulting keff = 0.8945. This result approximates the outcome of stacking two drums containing all of the AGN-201M fuel plates without an air gap. The reactivity calculations performed represent very conservative bounding estimates, as demonstrated by an estimate of the reactivity of the nine fuel plates in the AGN-201M reactor with all control rods inserted. The resulting reactivity value (keff = 1.0760) is very conservative relative to the excess reactivity margin described in the Safety Evaluation Report (keff = 1.005), and is the result of simplifying assumptions used for the SCALE/KENO-VI calculations. This includes using a fuel concentration averaged over the external volume of the stacked fuel plates without modeling the voids for control rod drive mechanisms and the glory hole penetration.
Description of storage drums and proposed storage layout A nominal quantity of 312 grams of fissile AGN-201M fuel has been modeled in one of these drums under the following conditions:
Scenario       # configuration keff +/- 1 312 g fuel in can, 12" air 0.5339 0.0018 2 312 g fuel in can, with 12" water +12" concrete 0.6665 0.0024 3 9 fuel plates, single stack, 12" water + 12" concrete (represents stacked drums) 0.8945* 0.0023 TEST 665 g fuel (all control rods inserted) in Al core tank, with graphite reflector, lead shield, Fe reactor tank, and water-filled Fe outer shield tank 1.0760 0.0019
in air and reflected by 12 of concrete, and reflected by 12 of water and by 12 of concrete.
* The Hazard Summary Report for the AGN-201 reactor predicts a 5% to 10% reduction in reactivity from a     nominal 2" air gap between the upper and lower core halves. (ANL-6510, page 9). Given the stacked drums have the potential to exceed the reactivity limit of keff = 0.8 specified in Technical Specification 5.6, item 1, the two drums will be placed in opposite corners of the NSC fuel storage vault with and secured to the lower TRIGA fuel storage tubes (empty) using cable, chain, or similar methods, and locked.
The results are presented in the following table. An additional calculation for 9 fuel plates (as described in the SAR and discussed in the November 18, 2015 response to RAI item 1) in a single right cylindrical stack, reflected by 12 of water and 12 of concrete was also performed with a resulting keff = 0.8945. This result approximates the outcome of stacking two drums containing all of the AGN-201M fuel plates without an air gap.
The reactivity calculations performed represent very conservative bounding estimates, as demonstrated by an estimate of the reactivity of the nine fuel plates in the AGN-201M reactor with all control rods inserted. The resulting reactivity value (keff = 1.0760) is very conservative relative to the excess reactivity margin described in the Safety Evaluation Report (keff = 1.005), and is the result of simplifying assumptions used for the SCALE/KENO-VI calculations. This includes using a fuel concentration averaged over the external volume of the stacked fuel plates without modeling the voids for control rod drive mechanisms and the glory hole penetration.
Scenario   configuration                                                                               keff             +/-
1         312 g fuel in can, 12 air                                                                 0.5339           0.0018 2         312 g fuel in can, with 12 water +12 concrete                                             0.6665           0.0024 3         9 fuel plates, single stack, 12 water + 12 concrete (represents stacked drums)           0.8945*         0.0023 TEST       665 g fuel (all control rods inserted) in Al core tank, with graphite reflector, lead     1.0760          0.0019 shield, Fe reactor tank, and water-filled Fe outer shield tank
* The Hazard Summary Report for the AGN-201 reactor predicts a 5% to 10% reduction in reactivity from a nominal 2 air gap between the upper and lower core halves. (ANL-6510, page 9).
Given the stacked drums have the potential to exceed the reactivity limit of keff = 0.8 specified in Technical Specification 5.6, item 1, the two drums will be placed in opposite corners of the NSC fuel storage vault with and secured to the lower TRIGA fuel storage tubes (empty) using cable, chain, or similar methods, and locked.
Horizontal spacing of the two drums has been further evaluated using the solid angle assessment method presented in TID-7016, Rev 2, Nuclear Safety Guide. Using a conservative keff of 0.7 and the nominal drum dimensions, the allowed solid angle must be <2 steradians and is met with the drums even at very close distances (e.g., with an air gap < 1 foot). A revised proposed minimum center-to-center separation distance of 10 feet is sufficient to consider the storage drums uncoupled for nuclear safety considerations and allows flexibility for drum inspections.
Horizontal spacing of the two drums has been further evaluated using the solid angle assessment method presented in TID-7016, Rev 2, Nuclear Safety Guide. Using a conservative keff of 0.7 and the nominal drum dimensions, the allowed solid angle must be <2 steradians and is met with the drums even at very close distances (e.g., with an air gap < 1 foot). A revised proposed minimum center-to-center separation distance of 10 feet is sufficient to consider the storage drums uncoupled for nuclear safety considerations and allows flexibility for drum inspections.
Figure 3 illustrates the proposed positions of SNM-bearing components in the NSC fuel storage vault, with the exception of the 239PuBe source. To maintain personnel exposures ALARA, this source will be stored in a neutron-attenuating shield and placed in a location within the fuel storage vault, as approved by site Radiation Safety Officer.
Figure 3 illustrates the proposed positions of SNM-bearing components in the NSC fuel storage vault, with the exception of the 239PuBe source. To maintain personnel exposures ALARA, this source will be stored in a neutron-attenuating shield and placed in a location within the fuel storage vault, as approved by site Radiation Safety Officer.
8Figure 3.
Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 7                                                                                                            Tel. (979) 845-7551
Authorizat The requeexplicitly aAGN-201Mcontained This requeAGN-201Mactivated cstorage at Photogion to posseest to possesauthorize fisM fuel, 239Puin the startuest does notM Facility Ocomponents the NSC sitgraph of the ess AGN-201ss AGN-201sion producuBe startup up source cat have a parperating Lic(e.g., the we. NSC fuel sto1M byproducM componects and activsource, fueapsule and trallel requescense R-23, water shield torage vault wct material ents under Nvation produel-bearing che mechanicst to remove as it is TAMtank and its where the ANSC Facilityucts as maycontrol rod ecal portions  the byprodMU's intent contained c1095NucCAGN-201M Sy Operating y be presenends, and aof the contruct materialto retain pocomponent) Nuclear SciencclearScienceRoad,3CollegeStation,TX7Tel. (979)SNM will be sLicense R-8nt in the irraactivation prrol rod assem possessionossession ounder R-23 ce Center3575TAMU778433575845-7551stored. 83 is to adiated roducts mblies. n in the of other during 9  THE FOLLOWING PAGES INCLUDE THE ORIGINAL AND PROPOSED REPLACEMENT PAGES FOR THE LICENSE AND  TECHNICAL SPECIFICATIONS   
 
Figure 3.        Photog graph of the NSC fuel sto orage vault wwhere the A AGN-201M S    SNM will be sstored.
Authorization to posse  ess AGN-201  1M byproduc ct material The reque  est to posses ss AGN-201M compone    ents under N  NSC Facilityy Operating License R-8          83 is to explicitly authorize a          fission produc cts and activvation produ ucts as mayy be presen  nt in the irra        adiated AGN-201M  M fuel, 239Pu uBe startup source, fue  el-bearing ccontrol rod eends, and a  activation prroducts contained in the startu up source ca apsule and the mechaniccal portions of the contrrol rod assem            mblies.
This reque est does nott have a parrallel reques st to remove the byproduct material possession            n in the AGN-201M  M Facility Operating Lic  cense R-23, as it is TAM  MUs intent to retain po  ossession o      of other activated components c              (e.g., the water w    shield tank t    and its contained ccomponent) under R-23 during storage at the NSC site.
Nuclear Scienc    ce Center 1095 Nucclear Science Road, 33575 TAMU C
College Station, TX 7778433575 8                                                                                                  Tel. (979) 845-7551


10Enclosure 1A  TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein "the facility"] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein "the licensee"], located on the campus of Texas A&M University at College Station, Texas, and described in the licensee's application for license renewal, dated February 27, 2003, as supplemented. B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows: 1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license. 2. Pursuant to the Act and 10 CFR Part 70, the following activities are included: a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel; b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and, 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. 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, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which can not be separated except for byproduct material produced in reactor experiments.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.
THE FOLLOWING PAGES INCLUDE THE ORIGINAL AND PROPOSED REPLACEMENT PAGES FOR THE LICENSE AND TECHNICAL SPECIFICATIONS 9
11Enclosure 1B  PROPOSED LICENSE CHANGE FOR THE NSC FACILITY TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 As Amended Through Amendment No. XX A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein "the facility"] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein "the licensee"], located on the campus of Texas A&M University at College Station, Texas, and described in the licensee's application for license renewal, dated February 27, 2003, as supplemented. B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows: 1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license. 2. Pursuant to the Act and 10 CFR Part 70, the following activities are included: a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel; b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and, 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 as AGN-201M <20% enriched 235U reactor fuel, and actinides and activation products for up to 5 years from the date of issuance of license amendment xx. e. To receive, possess, but not use up to 0.020 kilograms of 239Pu as a 239PuBe sealed neutron start-up source in connection with storage of the AGN-201M reactor for up to 5 years from the date of issuance of license amendment xx. _______________        Date-2016 123. 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,  
A TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.
: c. 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.  
B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:
: d. to receive, possess, but not use, byproduct materials including contaminated or activated AGN-201M reactor components for up to 5 years from the date of issuance of amendment xx. __________ Date-2016 13Enclosure 2A  CURRENT TECHNICAL SPECIFICATION FOR THE TEES NSC FACILITY The current NSC reactor Technical Specification affected is Section 5.6 titled, "Fuel Storage" which follows. The proposed new Technical Specification has a vertical line indicating the changes made to the existing Technical Specification: 5.6 Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core. Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature. Specification 1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.  
: 1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.
: 2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values. Basis The limits imposed by Specifications 5.6.1 and 5.6.2 are conservative and ensure safe storage.
: 2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:
14Enclosure 2B  Proposed Technical Specification Change TEES recommends the following replacement Technical Specification change containing wording to support this LAR is as follows:
: a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;
5.6 Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core. This includes the combined 235U fissile mass of no more than 0.7 kilograms, actinides and activation products, and the 239PuBe neutron start-up source with a 239Pu fissile mass of no more than 20 grams, from the TAMU AGN-201M reactor.
: b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,
Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.
: 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.
Specification 1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection. 2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.  
: 3. Pursuant to the Act and 10 CFR Part 30, the following activities are included:
: 3. Possession of the AGN-201M fuel, and actinides and activation products and neutron start-up source is restricted to receipt, possession, but not use in the operation of the NSC reactor. Specification 2, above, is not applicable to these materials. Basis The limits imposed by Specifications 5.6.1, 5.6.2, and 5.6.3 are conservative and ensure safe storage. __________ Date-2016 __________ Date-2016 __________ Date-2016}}
: 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, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which can not be separated except for byproduct material produced in reactor experiments.
: 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.
10 B
PROPOSED LICENSE CHANGE FOR THE NSC FACILITY TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 As Amended Through Amendment No. XX A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility]
TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.
B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:
: 1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.
: 2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:
: a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;
: b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,
: 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 as AGN-201M <20% enriched 235U reactor fuel, and actinides and activation products for up to 5 years from the date of issuance of license amendment xx.
: e. To receive, possess, but not use up to 0.020 kilograms of 239Pu Date-2016 as a 239PuBe sealed neutron start-up source in connection with storage of the AGN-201M reactor for up to 5 years from the date of issuance of license amendment xx.
11
: 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, 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.
: d. to receive, possess, but not use, byproduct materials including contaminated or activated AGN-201M reactor components for                     __________
up to 5 years from the date of issuance of amendment xx.
Date-2016 12 A
CURRENT TECHNICAL SPECIFICATION FOR THE TEES NSC FACILITY The current NSC reactor Technical Specification affected is Section 5.6 titled, Fuel Storage which follows. The proposed new Technical Specification has a vertical line indicating the changes made to the existing Technical Specification:
5.6     Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core.
Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.
Specification
: 1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.
: 2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.
Basis The limits imposed by Specifications 5.6.1 and 5.6.2 are conservative and ensure safe storage.
13 B
Proposed Technical Specification Change TEES recommends the following replacement Technical Specification change containing wording to support this LAR is as follows:
5.6   Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core.
This includes the combined 235U fissile mass of no more than 0.7 kilograms, actinides                         __________
and activation products, and the 239PuBe neutron start-up source with a 239Pu fissile mass Date-2016 of no more than 20 grams, from the TAMU AGN-201M reactor.
Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.
Specification
: 1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.
: 2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.
: 3. Possession of the AGN-201M fuel, and actinides and activation products and neutron                         __________
start-up source is restricted to receipt, possession, but not use in the operation of the Date-2016 NSC reactor. Specification 2, above, is not applicable to these materials.
Basis The limits imposed by Specifications 5.6.1, 5.6.2, and 5.6.3 are conservative and ensure safe Date-2016 storage.
14}}

Latest revision as of 04:27, 5 February 2020

Texas A&M Univ. - Supplement to License Amendment Request Dated October 14, 2015
ML16063A264
Person / Time
Site: 05000128
Issue date: 03/03/2016
From: Mcdeavitt S
Texas A&M Univ
To: Alexander Adams, Patrick Boyle
Document Control Desk, Office of Nuclear Reactor Regulation
References
2016-0011
Download: ML16063A264 (14)
v • d • e


Text

NUCLEAR SCIENCE CENTER Dr. Sean M. McDeavitt Director, TEES Nuclear Science Center Texas A&M University Texas A&M Engineering Experiment Station 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 March 3, 2016 2016-0011 Ref: 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

SUBJECT:

SUPPLEMENT TO LICENSE AMENDMENT REQUEST DATED OCTOBER 14, 2015, FACILITY LICENSE R-83, DOCKET NUMBER 50-128.

(ADAMS ACCESSION NO. ML15287A148)

Attn: Mr. Alexander Adams, Jr., Chief, Research and Test Reactors Branch Office of Nuclear Reactor Regulation Mr. Patrick M. Boyle, Project Manager, Research and Test Reactors Branch Office of Nuclear Reactor Regulation The purpose of this letter is to provide supplemental information to clarify and enhance the October 14, 2015 license amendment request (LAR) and revised License and Technical Specification pages (ADAMS Accession No. ML15287A148), the subsequent Request for Additional Information (RAI) dated November 2, 2015 (ADAMS Accession No. ML15302A018),

and the Texas A&M Engineering Experiment Station (TEES) response dated November 18, 2015 (ADAMS Accession No. ML15322A354). The October 14, 2015 license amendment request was submitted to change the licensing basis for the NSC Facility and amend the License and Technical Specifications to allow the receipt, possession, but not use of the AGN-201M SNM in the NSC Fuel Storage Vault. Information provided in the RAI response and this supplement does not change the conclusions reached relative to the significant hazards consideration and the environmental impact.

Movement of the AGN-201M will occur in two distinct phases: the first is to relocate the fuel and other special nuclear material (SNM) from the current AGN location to the NSC Fuel Storage Vault and the second is to remove all remaining AGN-201M components to the NSC site for long term storage while the project plan to construct a new reactor facility to house the reconstructed AGN-201 M reactor is implemented. The fuel and other SNM, together with associated byproduct material (e.g., fission and activation products in the fuel), will be received, possessed, but not used under the NSC Facility Operating License No. R-83. Byproduct material not contained in or on fuel-bearing components will continue to be possessed under the AGN-201M Facility Operating License R-23 during storage on the NSC site. This point is Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 1 Tel. (979) 845-7551

addressed further in the LAR for the AGN-201 M Facility Operating License No. R-23 submitted on November 11 , 2015 (ADAMS Accession No. ML 1531 A027) .

TEES is seeking approval of the October 14, 2015 license amendment request by the end of March 2016. TEES believes this short time to review the License and Technical Specification Change Request is achievable as this request contains no increased risk or impact above the currently designed, analyzed, and approved NSC reactor license. TEES notes that the proposed receipt, possession, but not use, of the AGN-201 M fuel and other SNM at the TEES NSC facility does not constitute a concern to public health and safety.

Prior to undertaking efforts to support the engineering, design and construction of a new building to house the reconstructed AGN-201 M, several important actions must be completed .

One action to be resolved in the near term is bringing closure to the July 30, 2013 Confirmatory Action Letter No. EA-2013-154 (ADAMS Accession No. ML13189A058). Secondly, the ongoing License Renewal efforts should be put on hold until the efforts associated with the new building can be merged with the License Renewal completion efforts. Third, the AGN-201 M License and the NSC Facility License each have a Safety Analysis Report (SAR) which is required to be updated to reflect the current configuration of each reactor. Once the AGN-201 M has been relocated to the NSC Facility site, both SARs shall be revised to reflect the changes, as required by 10 CFR 50.71(e).

Should you have any questions regarding the information provided in this submittal, please contact me or Mr. Jerry Newhouse at (979) 845-7551 or via email at mcdeavitt@tamu.edu or newhouse@tamu.edu.

Oath of Affirmation I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Sinc7 1y,

/

/0--/71.

/.

Sean M. McDeavitt, PhD.

Director, TEES Nuclear Science Center

Attachment:

Supplemental Information

Enclosures:

1A Current License 1B Proposed License Changes 2A Current Techn ical Specification 28: Proposed Technical Specification Changes Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 2 Tel. (979) 845-7551

cc:

Mr. William Dean, Office Director Mayor, City of College Station United States Nuclear Reactor Commission P.O. Box Drawer 9960 Office of Nuclear Reactor Regulation College Station, TX 77840-3575 Mr. Michael Young, President Governors Budget and Policy Office Texas A&M University 1246 TAMU P.O. Box 12428 College Station, TX 77843-1246 Austin, TX, 78711-2428 Dr. M. Katherine Banks, Vice Chancellor Radiation Program Officer and Dean Bureau of Radiation Control Dwight Look College of Engineering Dept. of State Health Services 3126 TAMU Division for Regulatory Services College Station, TX 77843-3126 1100 West 49th St., MC 2828 Austin, TX 78756-3189 Dr. Dimitris Lagoudas, Deputy Director Texas A&M Engineering Experiment Station Technical Advisor 3470 TAMU Office of Permitting, Remediation &

College Station, TX 77843-3577 Registration Texas Commission on Environmental Dr. Costas Georghiades, Associate Agency Quality Director P.O. Box 13087, MS 122 Texas A&M Engineering Experiment Station Austin, TX 78711-3087 3470 TAMU College Station, TX 77843-3577 Test, Research and Training Reactor Newsletter Dr. Yassin Hassan, Department Head P.O. Box 118300 Nuclear Engineering University of Florida Texas A&M University Gainesville, FL 32611-8300 Nuclear Engineering Department 3133 TAMU Mr. Jerry Newhouse, College Station, TX 77843-3133 NSC Assistant Director Texas A&M Engineering Experiment Station Dr. John Hardy 3575 TAMU Reactor Safety Board Chairman Texas A&M College Station, TX 77843-3575 University 3255 TAMU Mr. Scott Miller, College Station, TX 77843-3255 NSC Manager of Reactor Operations Texas A&M Engineering Experiment Station Dr. Latha Vasudevan 3575 TAMU Radiological Safety Officer College Station, TX 77843-3575 Texas A&M University Environmental Health and Safety Mr. Jeremy Osborn 1111 Research Parkway AGN-201M Reactor Supervisor College Station, TX 77843-4472 Texas A&M University Nuclear Engineering Department 3133 TAMU College Station, TX 77843-3133 Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 3 Tel. (979) 845-7551

Supplemental Information to License Amendment Request dated October 14, 2015, Facility License R-83, Docket Number 50-128.

(ADAMS Accession No. ML15287A148)

Relocation and storage of a nuclear reactor is a rare occurrence. To assist with preparations to relocate and store the AGN-201M reactor, Texas A&M University/Texas A&M Engineering Experiment Station (TAMU/TEES) has reviewed a similar possession approval requested and granted to the Oregon State University (OSU) facility for storage of its AGN-201 fuel in their TRIGA Reactor Fuel Storage Vault. The planned activity includes requesting the AGN-201M special nuclear material (SNM) be received, possessed, but not used in the NSC Fuel Storage Vault. This requires approval of the October 14, 2015 License Amendment. The duration of the storage of the fuel and special nuclear materials in the NSC Fuel Storage Vault will be no longer than 5 years, to allow for approval of the Construction Permit and completion of construction of a new building adjacent to the NSC site. Once the new facility is completed, and pending receipt of Commission approval, the AGN-201M reactor will be assembled in its new licensed location. TAMU AGN-201M fuel and other SNM contained in the TEES NSC Fuel Storage Vault will be relocated to the new AGN-201M reactor facility for installation. This will reconstitute the original reactor licensing basis.

The following information has been generated to supplement the Amendment Request of October 14, 2015. Information obtained from experts in this field and discussions with NRC Staff have led to the conclusion that enhancement is required to ensure the docket is complete and easily reviewable by the NRC staff. The SAR will be updated to reflect this information upon approval of the October 14, 2015, amendment request to address the receipt, possession, but not for use, of the AGN-201M fuel, special nuclear materials and components. The current AGN-201M Safety Analysis Report uses multiple terms when referring to the reactor fuel and the control rods. This will be addressed further in the next revision to the SAR and in coordination with the License and Technical Specifications.

The purpose of the October 14, 2015 License Amendment is to allow the TEES NSC facility to receive, possess, but not use the AGN-201M fuel, SNM, and components currently authorized under license R-23, Docket 50-59. The storage of all components will be in accordance with the current NSC license basis. Enclosures 1A and 1B are the current and proposed NSC License pages. Enclosures 2A and 2B are the current and proposed NSC Technical Specification pages that address receipt, possession, but not use, of the AGN-201M fuel, SNM, and components. The following sections contain additional clarification for issues associated with receipt, possession, but not use, of the AGN-201M fuel, SNM and components at the NSC facility.

Security Plan:

TEES has reviewed the NSC (TEES) Security Plan and finds that the proposed changes to allow TEES to receive, possess, but not use the AGN-201M fuel, SNM and components at the NSC facility does not constitute a change or decrease of the safeguards effectiveness of the NSC (TEES) Security Plan in accordance with 10 CFR 50.54 (p)(1,2), and does not require prior NRC review and approval. TEES will maintain all records of any proposed changes to the NSC Security Plan in accordance with 10 CFR 50.54 (p)(1,2). Accordingly, no changes to the NSC (TEES)

Security Plan are required.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 4 Tel. (979) 845-7551

Emergency Plan:

TEES has s reviewed the t NSC (TEES) Emerg gency Plan and finds tthat the proposed chan nges to allow TEE ES to receive, possess, but not us se the AGN--201M fuel, special nucclear material and componen nts does not result in red ducing the ca apability to pperform an e emergency p planning funcction in the event of a radiolog gical emergency, in acc cordance witth 10 CFR 5 50.54 (q) (ivv) (3). Accorrdingly, no change es to the currrent NSC (TEES) Emerg gency Plan a are required.

Use of the term borate ed aluminum m is not discu ussed in the SAR:

TEES is providing p thee following information supplemen ntal to the N November 18, 2015 ressponse (ADAMS Accession A No o. ML15322A A354) to the e NRC Stafff Request fo or Additional Information n (RAI) dated Nov vember 2, 2015 2 (ADAMMS Accession n No. ML15 5302A018). M More specifiically, the fo ollowing informationn pertains to o Item 1 con ncerning rea activity of thee stored AG GN-201M fue el in the NS SC fuel storage va ault and the use of a borrated alumin num neutron n absorber. G Given the lo ow reactivity values conservatively calculated for the two 5-gallon SNM storag ge drums, th he use of bo orated alumiinum is unnecessa ary for the saafe storage of the AGN-201M fuel. Similar to th he use of the cadmium sheets in the origginal NSC fu uel storage vault design n, borated a aluminum will be utilized as an add ditional defense-in n-depth provision in the storage s ms in a man ners shown schematica drum ally in Fig.1, but the reactivity im mpact from this t materiall is not credited in the re eactivity calcculations sho own below.

Figure 1. Nomina al configuratiion of the stoorage drumss to be used d for SNM sto orage.

Nuclear Scienc ce Center 1095 Nucclear Science Road, 33575 TAMU C

College Station, TX 7778433575 5 Tel. (979) 845-7551

Nominal specification s s for the inserts inclu ude aluminu um containin ng 16% (or greater) B4C at thicknessees ranging fromf approxximately 1/88 to 3/8, TTop and bo ottom absorrber plates, and a cylinder fittted to the in nside wall off the drum (Fig.

( 1). Thee NSC SAR will be upd dated to refle ect this information n upon app proval of thhe October 14, 2015 a amendmentt request to o address rreceipt, possession n, but not usse, of the AG GN-201M fue el special nu uclear materials and com mponents.

TEES is providing p thee following information supplementa s al to the Noovember 18, 2015 RAI Item 1 response concerning c calculation c of o reactivity of the stored d AGN-201M M fuel in the e NSC fuel sstorage location. As A noted ab bove, TEES will not tak ke credit fo r the prese ence of the neutron-abssorbing borated aluminum lining that will be placed inside the 5 5-gallon storage contain ners. The 5 5-gallon storage coontainers (bo olted-ring dru ums) have th he following nominal sppecifications (refer to Fig gure 2):

14.3 outside diamete er, 10.4 outtside height,, with 20 ga auge wall thhickness, an nd a 3/8 dia ameter gasket. Thhe fuel plates will be separated into o 2 roughly eequal stackss for packag ging (one at 312 g, one at 310 0 g). Note that the core e thermal fuuse containinng 0.4 g 2355U will be pllaced in the 310 g drum.

Figure 2. Design drawing of the t 5-gallon drums to be e used for SNNM storage..

Nuclear Scienc ce Center 1095 Nucclear Science Road, 33575 TAMU C

College Station, TX 7778433575 6 Tel. (979) 845-7551

Description of storage drums and proposed storage layout A nominal quantity of 312 grams of fissile AGN-201M fuel has been modeled in one of these drums under the following conditions:

in air and reflected by 12 of concrete, and reflected by 12 of water and by 12 of concrete.

The results are presented in the following table. An additional calculation for 9 fuel plates (as described in the SAR and discussed in the November 18, 2015 response to RAI item 1) in a single right cylindrical stack, reflected by 12 of water and 12 of concrete was also performed with a resulting keff = 0.8945. This result approximates the outcome of stacking two drums containing all of the AGN-201M fuel plates without an air gap.

The reactivity calculations performed represent very conservative bounding estimates, as demonstrated by an estimate of the reactivity of the nine fuel plates in the AGN-201M reactor with all control rods inserted. The resulting reactivity value (keff = 1.0760) is very conservative relative to the excess reactivity margin described in the Safety Evaluation Report (keff = 1.005), and is the result of simplifying assumptions used for the SCALE/KENO-VI calculations. This includes using a fuel concentration averaged over the external volume of the stacked fuel plates without modeling the voids for control rod drive mechanisms and the glory hole penetration.

Scenario configuration keff +/-

1 312 g fuel in can, 12 air 0.5339 0.0018 2 312 g fuel in can, with 12 water +12 concrete 0.6665 0.0024 3 9 fuel plates, single stack, 12 water + 12 concrete (represents stacked drums) 0.8945* 0.0023 TEST 665 g fuel (all control rods inserted) in Al core tank, with graphite reflector, lead 1.0760 0.0019 shield, Fe reactor tank, and water-filled Fe outer shield tank

  • The Hazard Summary Report for the AGN-201 reactor predicts a 5% to 10% reduction in reactivity from a nominal 2 air gap between the upper and lower core halves. (ANL-6510, page 9).

Given the stacked drums have the potential to exceed the reactivity limit of keff = 0.8 specified in Technical Specification 5.6, item 1, the two drums will be placed in opposite corners of the NSC fuel storage vault with and secured to the lower TRIGA fuel storage tubes (empty) using cable, chain, or similar methods, and locked.

Horizontal spacing of the two drums has been further evaluated using the solid angle assessment method presented in TID-7016, Rev 2, Nuclear Safety Guide. Using a conservative keff of 0.7 and the nominal drum dimensions, the allowed solid angle must be <2 steradians and is met with the drums even at very close distances (e.g., with an air gap < 1 foot). A revised proposed minimum center-to-center separation distance of 10 feet is sufficient to consider the storage drums uncoupled for nuclear safety considerations and allows flexibility for drum inspections.

Figure 3 illustrates the proposed positions of SNM-bearing components in the NSC fuel storage vault, with the exception of the 239PuBe source. To maintain personnel exposures ALARA, this source will be stored in a neutron-attenuating shield and placed in a location within the fuel storage vault, as approved by site Radiation Safety Officer.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 7 Tel. (979) 845-7551

Figure 3. Photog graph of the NSC fuel sto orage vault wwhere the A AGN-201M S SNM will be sstored.

Authorization to posse ess AGN-201 1M byproduc ct material The reque est to posses ss AGN-201M compone ents under N NSC Facilityy Operating License R-8 83 is to explicitly authorize a fission produc cts and activvation produ ucts as mayy be presen nt in the irra adiated AGN-201M M fuel, 239Pu uBe startup source, fue el-bearing ccontrol rod eends, and a activation prroducts contained in the startu up source ca apsule and the mechaniccal portions of the contrrol rod assem mblies.

This reque est does nott have a parrallel reques st to remove the byproduct material possession n in the AGN-201M M Facility Operating Lic cense R-23, as it is TAM MUs intent to retain po ossession o of other activated components c (e.g., the water w shield tank t and its contained ccomponent) under R-23 during storage at the NSC site.

Nuclear Scienc ce Center 1095 Nucclear Science Road, 33575 TAMU C

College Station, TX 7778433575 8 Tel. (979) 845-7551

THE FOLLOWING PAGES INCLUDE THE ORIGINAL AND PROPOSED REPLACEMENT PAGES FOR THE LICENSE AND TECHNICAL SPECIFICATIONS 9

A TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:

1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.
2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:
a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;
b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,
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.
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, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which can not be separated except for byproduct material produced in reactor experiments.
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.

10 B

PROPOSED LICENSE CHANGE FOR THE NSC FACILITY TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 As Amended Through Amendment No. XX A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility]

TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:

1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.
2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:
a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;
b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,
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 as AGN-201M <20% enriched 235U reactor fuel, and actinides and activation products for up to 5 years from the date of issuance of license amendment xx.
e. To receive, possess, but not use up to 0.020 kilograms of 239Pu Date-2016 as a 239PuBe sealed neutron start-up source in connection with storage of the AGN-201M reactor for up to 5 years from the date of issuance of license amendment xx.

11

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, 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.
d. to receive, possess, but not use, byproduct materials including contaminated or activated AGN-201M reactor components for __________

up to 5 years from the date of issuance of amendment xx.

Date-2016 12 A

CURRENT TECHNICAL SPECIFICATION FOR THE TEES NSC FACILITY The current NSC reactor Technical Specification affected is Section 5.6 titled, Fuel Storage which follows. The proposed new Technical Specification has a vertical line indicating the changes made to the existing Technical Specification:

5.6 Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core.

Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.

Specification

1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.
2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.

Basis The limits imposed by Specifications 5.6.1 and 5.6.2 are conservative and ensure safe storage.

13 B

Proposed Technical Specification Change TEES recommends the following replacement Technical Specification change containing wording to support this LAR is as follows:

5.6 Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core.

This includes the combined 235U fissile mass of no more than 0.7 kilograms, actinides __________

and activation products, and the 239PuBe neutron start-up source with a 239Pu fissile mass Date-2016 of no more than 20 grams, from the TAMU AGN-201M reactor.

Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.

Specification

1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.
2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.
3. Possession of the AGN-201M fuel, and actinides and activation products and neutron __________

start-up source is restricted to receipt, possession, but not use in the operation of the Date-2016 NSC reactor. Specification 2, above, is not applicable to these materials.

Basis The limits imposed by Specifications 5.6.1, 5.6.2, and 5.6.3 are conservative and ensure safe Date-2016 storage.

14

NUCLEAR SCIENCE CENTER Dr. Sean M. McDeavitt Director, TEES Nuclear Science Center Texas A&M University Texas A&M Engineering Experiment Station 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 March 3, 2016 2016-0011 Ref: 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

SUBJECT:

SUPPLEMENT TO LICENSE AMENDMENT REQUEST DATED OCTOBER 14, 2015, FACILITY LICENSE R-83, DOCKET NUMBER 50-128.

(ADAMS ACCESSION NO. ML15287A148)

Attn: Mr. Alexander Adams, Jr., Chief, Research and Test Reactors Branch Office of Nuclear Reactor Regulation Mr. Patrick M. Boyle, Project Manager, Research and Test Reactors Branch Office of Nuclear Reactor Regulation The purpose of this letter is to provide supplemental information to clarify and enhance the October 14, 2015 license amendment request (LAR) and revised License and Technical Specification pages (ADAMS Accession No. ML15287A148), the subsequent Request for Additional Information (RAI) dated November 2, 2015 (ADAMS Accession No. ML15302A018),

and the Texas A&M Engineering Experiment Station (TEES) response dated November 18, 2015 (ADAMS Accession No. ML15322A354). The October 14, 2015 license amendment request was submitted to change the licensing basis for the NSC Facility and amend the License and Technical Specifications to allow the receipt, possession, but not use of the AGN-201M SNM in the NSC Fuel Storage Vault. Information provided in the RAI response and this supplement does not change the conclusions reached relative to the significant hazards consideration and the environmental impact.

Movement of the AGN-201M will occur in two distinct phases: the first is to relocate the fuel and other special nuclear material (SNM) from the current AGN location to the NSC Fuel Storage Vault and the second is to remove all remaining AGN-201M components to the NSC site for long term storage while the project plan to construct a new reactor facility to house the reconstructed AGN-201 M reactor is implemented. The fuel and other SNM, together with associated byproduct material (e.g., fission and activation products in the fuel), will be received, possessed, but not used under the NSC Facility Operating License No. R-83. Byproduct material not contained in or on fuel-bearing components will continue to be possessed under the AGN-201M Facility Operating License R-23 during storage on the NSC site. This point is Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 1 Tel. (979) 845-7551

addressed further in the LAR for the AGN-201 M Facility Operating License No. R-23 submitted on November 11 , 2015 (ADAMS Accession No. ML 1531 A027) .

TEES is seeking approval of the October 14, 2015 license amendment request by the end of March 2016. TEES believes this short time to review the License and Technical Specification Change Request is achievable as this request contains no increased risk or impact above the currently designed, analyzed, and approved NSC reactor license. TEES notes that the proposed receipt, possession, but not use, of the AGN-201 M fuel and other SNM at the TEES NSC facility does not constitute a concern to public health and safety.

Prior to undertaking efforts to support the engineering, design and construction of a new building to house the reconstructed AGN-201 M, several important actions must be completed .

One action to be resolved in the near term is bringing closure to the July 30, 2013 Confirmatory Action Letter No. EA-2013-154 (ADAMS Accession No. ML13189A058). Secondly, the ongoing License Renewal efforts should be put on hold until the efforts associated with the new building can be merged with the License Renewal completion efforts. Third, the AGN-201 M License and the NSC Facility License each have a Safety Analysis Report (SAR) which is required to be updated to reflect the current configuration of each reactor. Once the AGN-201 M has been relocated to the NSC Facility site, both SARs shall be revised to reflect the changes, as required by 10 CFR 50.71(e).

Should you have any questions regarding the information provided in this submittal, please contact me or Mr. Jerry Newhouse at (979) 845-7551 or via email at mcdeavitt@tamu.edu or newhouse@tamu.edu.

Oath of Affirmation I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Sinc7 1y,

/

/0--/71.

/.

Sean M. McDeavitt, PhD.

Director, TEES Nuclear Science Center

Attachment:

Supplemental Information

Enclosures:

1A Current License 1B Proposed License Changes 2A Current Techn ical Specification 28: Proposed Technical Specification Changes Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 2 Tel. (979) 845-7551

cc:

Mr. William Dean, Office Director Mayor, City of College Station United States Nuclear Reactor Commission P.O. Box Drawer 9960 Office of Nuclear Reactor Regulation College Station, TX 77840-3575 Mr. Michael Young, President Governors Budget and Policy Office Texas A&M University 1246 TAMU P.O. Box 12428 College Station, TX 77843-1246 Austin, TX, 78711-2428 Dr. M. Katherine Banks, Vice Chancellor Radiation Program Officer and Dean Bureau of Radiation Control Dwight Look College of Engineering Dept. of State Health Services 3126 TAMU Division for Regulatory Services College Station, TX 77843-3126 1100 West 49th St., MC 2828 Austin, TX 78756-3189 Dr. Dimitris Lagoudas, Deputy Director Texas A&M Engineering Experiment Station Technical Advisor 3470 TAMU Office of Permitting, Remediation &

College Station, TX 77843-3577 Registration Texas Commission on Environmental Dr. Costas Georghiades, Associate Agency Quality Director P.O. Box 13087, MS 122 Texas A&M Engineering Experiment Station Austin, TX 78711-3087 3470 TAMU College Station, TX 77843-3577 Test, Research and Training Reactor Newsletter Dr. Yassin Hassan, Department Head P.O. Box 118300 Nuclear Engineering University of Florida Texas A&M University Gainesville, FL 32611-8300 Nuclear Engineering Department 3133 TAMU Mr. Jerry Newhouse, College Station, TX 77843-3133 NSC Assistant Director Texas A&M Engineering Experiment Station Dr. John Hardy 3575 TAMU Reactor Safety Board Chairman Texas A&M College Station, TX 77843-3575 University 3255 TAMU Mr. Scott Miller, College Station, TX 77843-3255 NSC Manager of Reactor Operations Texas A&M Engineering Experiment Station Dr. Latha Vasudevan 3575 TAMU Radiological Safety Officer College Station, TX 77843-3575 Texas A&M University Environmental Health and Safety Mr. Jeremy Osborn 1111 Research Parkway AGN-201M Reactor Supervisor College Station, TX 77843-4472 Texas A&M University Nuclear Engineering Department 3133 TAMU College Station, TX 77843-3133 Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 3 Tel. (979) 845-7551

Supplemental Information to License Amendment Request dated October 14, 2015, Facility License R-83, Docket Number 50-128.

(ADAMS Accession No. ML15287A148)

Relocation and storage of a nuclear reactor is a rare occurrence. To assist with preparations to relocate and store the AGN-201M reactor, Texas A&M University/Texas A&M Engineering Experiment Station (TAMU/TEES) has reviewed a similar possession approval requested and granted to the Oregon State University (OSU) facility for storage of its AGN-201 fuel in their TRIGA Reactor Fuel Storage Vault. The planned activity includes requesting the AGN-201M special nuclear material (SNM) be received, possessed, but not used in the NSC Fuel Storage Vault. This requires approval of the October 14, 2015 License Amendment. The duration of the storage of the fuel and special nuclear materials in the NSC Fuel Storage Vault will be no longer than 5 years, to allow for approval of the Construction Permit and completion of construction of a new building adjacent to the NSC site. Once the new facility is completed, and pending receipt of Commission approval, the AGN-201M reactor will be assembled in its new licensed location. TAMU AGN-201M fuel and other SNM contained in the TEES NSC Fuel Storage Vault will be relocated to the new AGN-201M reactor facility for installation. This will reconstitute the original reactor licensing basis.

The following information has been generated to supplement the Amendment Request of October 14, 2015. Information obtained from experts in this field and discussions with NRC Staff have led to the conclusion that enhancement is required to ensure the docket is complete and easily reviewable by the NRC staff. The SAR will be updated to reflect this information upon approval of the October 14, 2015, amendment request to address the receipt, possession, but not for use, of the AGN-201M fuel, special nuclear materials and components. The current AGN-201M Safety Analysis Report uses multiple terms when referring to the reactor fuel and the control rods. This will be addressed further in the next revision to the SAR and in coordination with the License and Technical Specifications.

The purpose of the October 14, 2015 License Amendment is to allow the TEES NSC facility to receive, possess, but not use the AGN-201M fuel, SNM, and components currently authorized under license R-23, Docket 50-59. The storage of all components will be in accordance with the current NSC license basis. Enclosures 1A and 1B are the current and proposed NSC License pages. Enclosures 2A and 2B are the current and proposed NSC Technical Specification pages that address receipt, possession, but not use, of the AGN-201M fuel, SNM, and components. The following sections contain additional clarification for issues associated with receipt, possession, but not use, of the AGN-201M fuel, SNM and components at the NSC facility.

Security Plan:

TEES has reviewed the NSC (TEES) Security Plan and finds that the proposed changes to allow TEES to receive, possess, but not use the AGN-201M fuel, SNM and components at the NSC facility does not constitute a change or decrease of the safeguards effectiveness of the NSC (TEES) Security Plan in accordance with 10 CFR 50.54 (p)(1,2), and does not require prior NRC review and approval. TEES will maintain all records of any proposed changes to the NSC Security Plan in accordance with 10 CFR 50.54 (p)(1,2). Accordingly, no changes to the NSC (TEES)

Security Plan are required.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 4 Tel. (979) 845-7551

Emergency Plan:

TEES has s reviewed the t NSC (TEES) Emerg gency Plan and finds tthat the proposed chan nges to allow TEE ES to receive, possess, but not us se the AGN--201M fuel, special nucclear material and componen nts does not result in red ducing the ca apability to pperform an e emergency p planning funcction in the event of a radiolog gical emergency, in acc cordance witth 10 CFR 5 50.54 (q) (ivv) (3). Accorrdingly, no change es to the currrent NSC (TEES) Emerg gency Plan a are required.

Use of the term borate ed aluminum m is not discu ussed in the SAR:

TEES is providing p thee following information supplemen ntal to the N November 18, 2015 ressponse (ADAMS Accession A No o. ML15322A A354) to the e NRC Stafff Request fo or Additional Information n (RAI) dated Nov vember 2, 2015 2 (ADAMMS Accession n No. ML15 5302A018). M More specifiically, the fo ollowing informationn pertains to o Item 1 con ncerning rea activity of thee stored AG GN-201M fue el in the NS SC fuel storage va ault and the use of a borrated alumin num neutron n absorber. G Given the lo ow reactivity values conservatively calculated for the two 5-gallon SNM storag ge drums, th he use of bo orated alumiinum is unnecessa ary for the saafe storage of the AGN-201M fuel. Similar to th he use of the cadmium sheets in the origginal NSC fu uel storage vault design n, borated a aluminum will be utilized as an add ditional defense-in n-depth provision in the storage s ms in a man ners shown schematica drum ally in Fig.1, but the reactivity im mpact from this t materiall is not credited in the re eactivity calcculations sho own below.

Figure 1. Nomina al configuratiion of the stoorage drumss to be used d for SNM sto orage.

Nuclear Scienc ce Center 1095 Nucclear Science Road, 33575 TAMU C

College Station, TX 7778433575 5 Tel. (979) 845-7551

Nominal specification s s for the inserts inclu ude aluminu um containin ng 16% (or greater) B4C at thicknessees ranging fromf approxximately 1/88 to 3/8, TTop and bo ottom absorrber plates, and a cylinder fittted to the in nside wall off the drum (Fig.

( 1). Thee NSC SAR will be upd dated to refle ect this information n upon app proval of thhe October 14, 2015 a amendmentt request to o address rreceipt, possession n, but not usse, of the AG GN-201M fue el special nu uclear materials and com mponents.

TEES is providing p thee following information supplementa s al to the Noovember 18, 2015 RAI Item 1 response concerning c calculation c of o reactivity of the stored d AGN-201M M fuel in the e NSC fuel sstorage location. As A noted ab bove, TEES will not tak ke credit fo r the prese ence of the neutron-abssorbing borated aluminum lining that will be placed inside the 5 5-gallon storage contain ners. The 5 5-gallon storage coontainers (bo olted-ring dru ums) have th he following nominal sppecifications (refer to Fig gure 2):

14.3 outside diamete er, 10.4 outtside height,, with 20 ga auge wall thhickness, an nd a 3/8 dia ameter gasket. Thhe fuel plates will be separated into o 2 roughly eequal stackss for packag ging (one at 312 g, one at 310 0 g). Note that the core e thermal fuuse containinng 0.4 g 2355U will be pllaced in the 310 g drum.

Figure 2. Design drawing of the t 5-gallon drums to be e used for SNNM storage..

Nuclear Scienc ce Center 1095 Nucclear Science Road, 33575 TAMU C

College Station, TX 7778433575 6 Tel. (979) 845-7551

Description of storage drums and proposed storage layout A nominal quantity of 312 grams of fissile AGN-201M fuel has been modeled in one of these drums under the following conditions:

in air and reflected by 12 of concrete, and reflected by 12 of water and by 12 of concrete.

The results are presented in the following table. An additional calculation for 9 fuel plates (as described in the SAR and discussed in the November 18, 2015 response to RAI item 1) in a single right cylindrical stack, reflected by 12 of water and 12 of concrete was also performed with a resulting keff = 0.8945. This result approximates the outcome of stacking two drums containing all of the AGN-201M fuel plates without an air gap.

The reactivity calculations performed represent very conservative bounding estimates, as demonstrated by an estimate of the reactivity of the nine fuel plates in the AGN-201M reactor with all control rods inserted. The resulting reactivity value (keff = 1.0760) is very conservative relative to the excess reactivity margin described in the Safety Evaluation Report (keff = 1.005), and is the result of simplifying assumptions used for the SCALE/KENO-VI calculations. This includes using a fuel concentration averaged over the external volume of the stacked fuel plates without modeling the voids for control rod drive mechanisms and the glory hole penetration.

Scenario configuration keff +/-

1 312 g fuel in can, 12 air 0.5339 0.0018 2 312 g fuel in can, with 12 water +12 concrete 0.6665 0.0024 3 9 fuel plates, single stack, 12 water + 12 concrete (represents stacked drums) 0.8945* 0.0023 TEST 665 g fuel (all control rods inserted) in Al core tank, with graphite reflector, lead 1.0760 0.0019 shield, Fe reactor tank, and water-filled Fe outer shield tank

  • The Hazard Summary Report for the AGN-201 reactor predicts a 5% to 10% reduction in reactivity from a nominal 2 air gap between the upper and lower core halves. (ANL-6510, page 9).

Given the stacked drums have the potential to exceed the reactivity limit of keff = 0.8 specified in Technical Specification 5.6, item 1, the two drums will be placed in opposite corners of the NSC fuel storage vault with and secured to the lower TRIGA fuel storage tubes (empty) using cable, chain, or similar methods, and locked.

Horizontal spacing of the two drums has been further evaluated using the solid angle assessment method presented in TID-7016, Rev 2, Nuclear Safety Guide. Using a conservative keff of 0.7 and the nominal drum dimensions, the allowed solid angle must be <2 steradians and is met with the drums even at very close distances (e.g., with an air gap < 1 foot). A revised proposed minimum center-to-center separation distance of 10 feet is sufficient to consider the storage drums uncoupled for nuclear safety considerations and allows flexibility for drum inspections.

Figure 3 illustrates the proposed positions of SNM-bearing components in the NSC fuel storage vault, with the exception of the 239PuBe source. To maintain personnel exposures ALARA, this source will be stored in a neutron-attenuating shield and placed in a location within the fuel storage vault, as approved by site Radiation Safety Officer.

Nuclear Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 778433575 7 Tel. (979) 845-7551

Figure 3. Photog graph of the NSC fuel sto orage vault wwhere the A AGN-201M S SNM will be sstored.

Authorization to posse ess AGN-201 1M byproduc ct material The reque est to posses ss AGN-201M compone ents under N NSC Facilityy Operating License R-8 83 is to explicitly authorize a fission produc cts and activvation produ ucts as mayy be presen nt in the irra adiated AGN-201M M fuel, 239Pu uBe startup source, fue el-bearing ccontrol rod eends, and a activation prroducts contained in the startu up source ca apsule and the mechaniccal portions of the contrrol rod assem mblies.

This reque est does nott have a parrallel reques st to remove the byproduct material possession n in the AGN-201M M Facility Operating Lic cense R-23, as it is TAM MUs intent to retain po ossession o of other activated components c (e.g., the water w shield tank t and its contained ccomponent) under R-23 during storage at the NSC site.

Nuclear Scienc ce Center 1095 Nucclear Science Road, 33575 TAMU C

College Station, TX 7778433575 8 Tel. (979) 845-7551

THE FOLLOWING PAGES INCLUDE THE ORIGINAL AND PROPOSED REPLACEMENT PAGES FOR THE LICENSE AND TECHNICAL SPECIFICATIONS 9

A TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility] TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:

1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.
2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:
a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;
b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,
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.
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, and use, in connection with operation of the facility, such byproduct material as may be produced by operation of the reactor, which can not be separated except for byproduct material produced in reactor experiments.
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.

10 B

PROPOSED LICENSE CHANGE FOR THE NSC FACILITY TEXAS ENGINEERING EXPERIMENT STATION/TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128 FACILITY OPERATING LICENSE License No. R-83 As Amended Through Amendment No. XX A. This license applies to the Texas Engineering Experiment Station/Texas A&M University System Nuclear Science Center [herein the facility]

TRIGA-type nuclear research reactor owned by the Texas Engineering Experiment Station/Texas A&M University System [herein the licensee], located on the campus of Texas A&M University at College Station, Texas, and described in the licensees application for license renewal, dated February 27, 2003, as supplemented.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Texas Engineering Experiment Station/Texas A&M University System as follows:

1. Pursuant to subsection 104c of the Act and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location in accordance with the procedures and limitations described in the application and set forth in this license.
2. Pursuant to the Act and 10 CFR Part 70, the following activities are included:
a. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 15 kilograms of contained uranium-235 enriched to less than 20 percent in the form of TRIGA-type reactor fuel;
b. to receive, possess, and use, but not separate, in connection with the operation of the facility, up to 40 grams total of special nuclear material, of any enrichment, in the form of detectors, fission plates, foils, and solutions; and,
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 as AGN-201M <20% enriched 235U reactor fuel, and actinides and activation products for up to 5 years from the date of issuance of license amendment xx.
e. To receive, possess, but not use up to 0.020 kilograms of 239Pu Date-2016 as a 239PuBe sealed neutron start-up source in connection with storage of the AGN-201M reactor for up to 5 years from the date of issuance of license amendment xx.

11

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, 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.
d. to receive, possess, but not use, byproduct materials including contaminated or activated AGN-201M reactor components for __________

up to 5 years from the date of issuance of amendment xx.

Date-2016 12 A

CURRENT TECHNICAL SPECIFICATION FOR THE TEES NSC FACILITY The current NSC reactor Technical Specification affected is Section 5.6 titled, Fuel Storage which follows. The proposed new Technical Specification has a vertical line indicating the changes made to the existing Technical Specification:

5.6 Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core.

Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.

Specification

1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.
2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.

Basis The limits imposed by Specifications 5.6.1 and 5.6.2 are conservative and ensure safe storage.

13 B

Proposed Technical Specification Change TEES recommends the following replacement Technical Specification change containing wording to support this LAR is as follows:

5.6 Fuel Storage Applicability This specification applies to the storage of reactor fuel at times when it is not in the reactor core.

This includes the combined 235U fissile mass of no more than 0.7 kilograms, actinides __________

and activation products, and the 239PuBe neutron start-up source with a 239Pu fissile mass Date-2016 of no more than 20 grams, from the TAMU AGN-201M reactor.

Objective The objective is to ensure that fuel that is being stored will not become critical and will not reach an unsafe temperature.

Specification

1. All fuel elements and fueled devices shall be stored in a geometrical array for which the k-effective is less than 0.8 for all conditions of moderation and reflection.
2. Irradiated fuel elements and fueled devices shall be stored in an array, which will permit sufficient natural convection cooling by water or air such that the fuel element or fueled device temperature will not exceed design values.
3. Possession of the AGN-201M fuel, and actinides and activation products and neutron __________

start-up source is restricted to receipt, possession, but not use in the operation of the Date-2016 NSC reactor. Specification 2, above, is not applicable to these materials.

Basis The limits imposed by Specifications 5.6.1, 5.6.2, and 5.6.3 are conservative and ensure safe Date-2016 storage.

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