ML16063A264

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 M Texas A&M Univ
To:	Alexander Adams, Patrick Boyle Document Control Desk, Office of Nuclear Reactor Regulation
References
2016-0011
Download: ML16063A264 (14)

Text

NUCLEAR SCIENCE CENTER 1Nuclear Science Cente r 1095NuclearScienceRoad,3575TAMU CollegeStation,TX77843 3575Tel. (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

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 addressed furthe r in the LAR fo r the AGN-201 M Facility Operati n g License No. R-23 submitted on Novembe r 11 , 2015 (ADAMS Accession No. ML 1 531 A027). TEES is seek i ng approval of the October 14 , 20 1 5 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 c ontains no increased risk or impact above the currently des i gned , analyzed , and approved NSC reactor license. TEES notes that the proposed receipt , possess i on , 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 , severa l i mportant actions must be completed. One action to be resolved in the near term is bringing closure to the July 30 , 2013 Confirmatory Ac t ion Letter No. EA-2013-154 (ADAMS Accession No. ML 13189A058). Secondly , the ongoing License Renewal efforts shou l d 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 Faci l ity License each have a Safety Analysis Report (SAR) which is required to be updated to reflect the current configuration of each r eactor. Once the AGN-201 M h as been relocated to the NSC Facility site , bo t h SARs shall be revised to reflect the changes , as required by 10 CFR 50.71(e). Should you have any questions regard i ng the informat i on provided i n th i s submittal , please contact me or Mr. Jerry Newhouse at (979) 845-7551 or via ema i l at mcdeavitt@tamu.edu or newhouse@tamu

.edu. Oath o f Affirmat i on I declare under p e nalty of perjury that the foregoing is true and correct to the bes t of my k nowledge. S i nc 7 1y, /0--/71. / /. Sean M. McDeavitt , PhD. Director , TEES Nuclear Scienc e Center

Attachment:

Supplemental Information Enclosures

1A Current License 1 B Proposed License Changes 2A Curr e nt Te chn i cal Specification 28: Proposed Technical Specifica t ion Changes 2 Nucl e ar S c i e n ce C en t e r 1095 Nu c l ear Science Road, 3575 TAMU Co ll ege Stat i on, TX 77843-3575 Tel. (9 79) 845-755 1 3Nuclear Science Cente r 1095NuclearScienceRoad,3575TAMU CollegeStation,TX77843 3575Tel. (979) 845-7551cc:

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 49 th 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 Cente r 1095NuclearScienceRoad,3575TAMU CollegeStation,TX77843 3575Tel. (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.

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.

5Emergenc TEES ha sallow TE E compone n the event

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unnecess a in the ori g defense-i n reactivity i m

Figure 1.

y Plan: s reviewed t ES to recei v n ts does not of a radiolo g es to the cur rterm borat e providing th e Accession N o vember 2, 2 n pertains t o ault and the vely calcula ary for the s a g inal NSC f u n-depth prov m pact from t Nomin a t he NSC (Te, possess, result in re d g ical emerg r ent NSC (T e d aluminu m e following

o. ML15322 A 2015 (ADA M o Item 1 co nuse of a bo r ted for the t afe storage u el storage ision in the s t his materia l a l configurat iEES) Emer g but not u s d ucing the c aency, in ac cEES) Emer g m is not disc uinformation A354) to th e M S Accessio n n cerning re a rated alumi n w o 5-gallonof the AGNvault desig n storage dru m l is not credi ion of the st o gency Plan se the AGN-apability to p cordance wi t g ency Plan a u ssed in the supplemen e NRC Staf f n No. ML1 5 activity of th e num neutro n SNM stora g-201M fuel.

n , borated a m s in a manted in the r e o rage drum sand finds t-201M fuel, p erform an eth 10 CFR 5 a re requiredSAR: ntal to the N f Request f o 5302A018).

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specification e s ranging f tted to the i n n upon ap p n, but not u s p roviding th e concerning c A s noted a buminum lini ontainers (b oide diamet e he fuel plate 0 g). Note t Design s for the i f rom appro x nside wall o f proval of t h se, of the A G e following i calculation o bove, TEES ng that will olted-ring dr u er, 10.4" ou ts will be sehat the cor e drawing of tnserts incl u ximately 1/

8 f the drum (h e October G N-201M fu enformation s of reactivity will not ta k be placed u ms) have t h t side height

, parated int o e thermal f u the 5-gallon ude alumin u 8" to 3/8", T (Fig. 1). Th e14, 2015 a e l special n u s upplement aof the store d ke credit foinside the 5 h e following

, with 20 g a o 2 roughly e use containi n drums to b e u m containi n T op and b o e NSC SAR a mendment u clear mater al to the N o d AGN-201 Mr the prese 5-gallon sto nominal s p auge wall t h e qual stack s ng 0.4 g 235 e used for S N 1095Nu c Cng 16% (o o ttom abso r will be up d t request t o ials and co m ovember 18 M fuel in th e ence of the rage contai n pecifications hickness, a n s for packa g 5 U will be pl NM storage.Nuclear Scien c c learScienceRoad,3 C ollegeStation,TX7Tel. (979) r greate r) B rber plates, dated to refl e o address r mponents. , 2015 RAI e NSC fuel sneutron-ab s ners. The 5(refer to Fi g nd a 3/8" di a ging (one at l aced in the

. ce Cente r 3 575TAMU 7 7843 3575845-7551 B 4 C at and a ect this receipt, Item 1 storage sorbing 5-gallon gure 2): ameter 312 g, 310 g 7Nuclear Science Cente r 1095NuclearScienceRoad,3575TAMU CollegeStation,TX77843 3575Tel. (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 k eff = 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 (k eff = 1.0760) is very conservative relative to the excess reactivity margin described in the Safety Evaluation Report (k eff = 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 shield, Fe reactor tank, and water-filled Fe outer shield tank 1.0760 0.0019

• 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 k eff = 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 k eff 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.

8Figure 3.

A uthorizat The requ e explicitly a AGN-201 M contained This requ e AGN-201 M activated c storage at

Photo g i on to poss e est to posse s a uthorize fi s M fuel, 239 P uin the start u est does no t M Facility O c omponents the NSC sit g raph of the ess AGN-20 1 s s AGN-201sion produ c uBe startup up source c a t have a pa r perating Li c (e.g., the w e. NSC fuel st o 1 M byprodu c M compon e cts and acti v source, fu e a psule and t r allel reque s cense R-23, water shield t o rage vault w c t material e nts under N v ation prod u el-bearing c he mechani c st to remove as it is TA M tank and its w here the A NSC Facilit y ucts as ma y control rod e cal portions the byprodMU's intent contained c 1095Nu c C AGN-201M S y Operating y be prese n e nds, and aof the cont r uct materialto retain p o c omponent) Nuclear Scien c c learScienceRoad,3 C ollegeStation,TX7Tel. (979)

S NM will be sLicense R-8 n t in the irr a a ctivation p r r ol rod asse m possessio n ossession ounder R-23 ce Cente r 3 575TAMU 7 7843 3575845-7551stored. 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

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.

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 235 U 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 239 Pu 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,

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.

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.

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.

14Enclosure 2B 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 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 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 Cente r 1095NuclearScienceRoad,3575TAMU CollegeStation,TX77843 3575Tel. (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

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 addressed furthe r in the LAR fo r the AGN-201 M Facility Operati n g License No. R-23 submitted on Novembe r 11 , 2015 (ADAMS Accession No. ML 1 531 A027). TEES is seek i ng approval of the October 14 , 20 1 5 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 c ontains no increased risk or impact above the currently des i gned , analyzed , and approved NSC reactor license. TEES notes that the proposed receipt , possess i on , 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 , severa l i mportant actions must be completed. One action to be resolved in the near term is bringing closure to the July 30 , 2013 Confirmatory Ac t ion Letter No. EA-2013-154 (ADAMS Accession No. ML 13189A058). Secondly , the ongoing License Renewal efforts shou l d 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 Faci l ity License each have a Safety Analysis Report (SAR) which is required to be updated to reflect the current configuration of each r eactor. Once the AGN-201 M h as been relocated to the NSC Facility site , bo t h SARs shall be revised to reflect the changes , as required by 10 CFR 50.71(e). Should you have any questions regard i ng the informat i on provided i n th i s submittal , please contact me or Mr. Jerry Newhouse at (979) 845-7551 or via ema i l at mcdeavitt@tamu.edu or newhouse@tamu

.edu. Oath o f Affirmat i on I declare under p e nalty of perjury that the foregoing is true and correct to the bes t of my k nowledge. S i nc 7 1y, /0--/71. / /. Sean M. McDeavitt , PhD. Director , TEES Nuclear Scienc e Center

Attachment:

Supplemental Information Enclosures

1A Current License 1 B Proposed License Changes 2A Curr e nt Te chn i cal Specification 28: Proposed Technical Specifica t ion Changes 2 Nucl e ar S c i e n ce C en t e r 1095 Nu c l ear Science Road, 3575 TAMU Co ll ege Stat i on, TX 77843-3575 Tel. (9 79) 845-755 1 3Nuclear Science Cente r 1095NuclearScienceRoad,3575TAMU CollegeStation,TX77843 3575Tel. (979) 845-7551cc:

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 49 th 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 Cente r 1095NuclearScienceRoad,3575TAMU CollegeStation,TX77843 3575Tel. (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.

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.

5Emergenc TEES ha sallow TE E compone n the event

no chang e Use of the

TEES is p(ADAMS A dated No vinformatio n storage v a conservati

unnecess a in the ori g defense-i n reactivity i m

Figure 1.

y Plan: s reviewed t ES to recei v n ts does not of a radiolo g es to the cur rterm borat e providing th e Accession N o vember 2, 2 n pertains t o ault and the vely calcula ary for the s a g inal NSC f u n-depth prov m pact from t Nomin a t he NSC (Te, possess, result in re d g ical emerg r ent NSC (T e d aluminu m e following

o. ML15322 A 2015 (ADA M o Item 1 co nuse of a bo r ted for the t afe storage u el storage ision in the s t his materia l a l configurat iEES) Emer g but not u s d ucing the c aency, in ac cEES) Emer g m is not disc uinformation A354) to th e M S Accessio n n cerning re a rated alumi n w o 5-gallonof the AGNvault desig n storage dru m l is not credi ion of the st o gency Plan se the AGN-apability to p cordance wi t g ency Plan a u ssed in the supplemen e NRC Staf f n No. ML1 5 activity of th e num neutro n SNM stora g-201M fuel.

n , borated a m s in a manted in the r e o rage drum sand finds t-201M fuel, p erform an eth 10 CFR 5 a re requiredSAR: ntal to the N f Request f o 5302A018).

M e stored A G n absorber.

G ge drums, t hSimilar to t h aluminum w ners shown e activity cal c s to be used 1095Nu c C that the prospecial nu c emergency p 5 0.54 (q) (i

v. November 1 or Additiona More specif i GN-201M fu e G iven the l o he use of b o he use of thill be utilizeschematic a culations sh o d for SNM st oNuclear Scien c c learScienceRoad,3 C ollegeStation,TX7Tel. (979)posed cha n clear mater p lanning fun c v) (3). A cco r8, 2015 re sl Informatio n ically, the f o el in the N S ow reactivity o rated alum i e cadmium d as an ad d ally in Fig.1, own below.o rage. ce Cente r 3 575TAMU 7 7843 3575845-7551 nges to ial and ction in rdingly, sponse n (RAI) ollowing S C fuel values inum is sheets ditional but the 6Nominal s thickness ecylinder fi t informatio npossessio n TEES is p response c location.

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specification e s ranging f tted to the i n n upon ap p n, but not u s p roviding th e concerning c A s noted a buminum lini ontainers (b oide diamet e he fuel plate 0 g). Note t Design s for the i f rom appro x nside wall o f proval of t h se, of the A G e following i calculation o bove, TEES ng that will olted-ring dr u er, 10.4" ou ts will be sehat the cor e drawing of tnserts incl u ximately 1/

8 f the drum (h e October G N-201M fu enformation s of reactivity will not ta k be placed u ms) have t h t side height

, parated int o e thermal f u the 5-gallon ude alumin u 8" to 3/8", T (Fig. 1). Th e14, 2015 a e l special n u s upplement aof the store d ke credit foinside the 5 h e following

, with 20 g a o 2 roughly e use containi n drums to b e u m containi n T op and b o e NSC SAR a mendment u clear mater al to the N o d AGN-201 Mr the prese 5-gallon sto nominal s p auge wall t h e qual stack s ng 0.4 g 235 e used for S N 1095Nu c Cng 16% (o o ttom abso r will be up d t request t o ials and co m ovember 18 M fuel in th e ence of the rage contai n pecifications hickness, a n s for packa g 5 U will be pl NM storage.Nuclear Scien c c learScienceRoad,3 C ollegeStation,TX7Tel. (979) r greate r) B rber plates, dated to refl e o address r mponents. , 2015 RAI e NSC fuel sneutron-ab s ners. The 5(refer to Fi g nd a 3/8" di a ging (one at l aced in the

. ce Cente r 3 575TAMU 7 7843 3575845-7551 B 4 C at and a ect this receipt, Item 1 storage sorbing 5-gallon gure 2): ameter 312 g, 310 g 7Nuclear Science Cente r 1095NuclearScienceRoad,3575TAMU CollegeStation,TX77843 3575Tel. (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 k eff = 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 (k eff = 1.0760) is very conservative relative to the excess reactivity margin described in the Safety Evaluation Report (k eff = 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 shield, Fe reactor tank, and water-filled Fe outer shield tank 1.0760 0.0019

• 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 k eff = 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 k eff 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.

8Figure 3.

A uthorizat The requ e explicitly a AGN-201 M contained This requ e AGN-201 M activated c storage at

Photo g i on to poss e est to posse s a uthorize fi s M fuel, 239 P uin the start u est does no t M Facility O c omponents the NSC sit g raph of the ess AGN-20 1 s s AGN-201sion produ c uBe startup up source c a t have a pa r perating Li c (e.g., the w e. NSC fuel st o 1 M byprodu c M compon e cts and acti v source, fu e a psule and t r allel reque s cense R-23, water shield t o rage vault w c t material e nts under N v ation prod u el-bearing c he mechani c st to remove as it is TA M tank and its w here the A NSC Facilit y ucts as ma y control rod e cal portions the byprodMU's intent contained c 1095Nu c C AGN-201M S y Operating y be prese n e nds, and aof the cont r uct materialto retain p o c omponent) Nuclear Scien c c learScienceRoad,3 C ollegeStation,TX7Tel. (979)

S NM will be sLicense R-8 n t in the irr a a ctivation p r r ol rod asse m possessio n ossession ounder R-23 ce Cente r 3 575TAMU 7 7843 3575845-7551stored. 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

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.

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 235 U 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 239 Pu 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,

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.

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.

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.

14Enclosure 2B 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 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 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