ML20059G030

Safety Evaluation Supporting Amend 13 to License R-83

ML20059G030
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Site:	05000128
Issue date:	10/26/1993
From:	Office of Nuclear Reactor Regulation
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ML20059G001	List: ML20059F997 ML20059G012 ML20059G030
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NUDOCS 9311050228
Download: ML20059G030 (6)

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t UNITED STATES

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'y NUCLEAR REGULATORY COMMISSION-2 WASHINGTON, D.C. 20556-0001

,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 13 T_0 FACILITY OPERATING LICENSE NO. R-83 TEXAS ENGINEERING EXPERIMENT STATION TEXAS A&M UNIVERSITY SYSTEM DOCKET NO. 50-128

1.0 INTRODUCTION

By letter dated March 25, 1993, the Texas Engineering Experiment Station (TEES)/ Texas A&M University System (the licensee), as supplemented on August 24, 1993, requested that the scope of the reactor license (No. R-83)~ be expanded to permit possession and use of certain additional nuclear materials !

in the support of research anc' ievelopment within the Nuclear Science Center (HSC), which is part of the TEES. This request was prompted by the fact _that the licensee would like to improve the administrative procedures in the facility and also by the fact that the Texas Department of Health (TDH), the licensing authority for the State of Texas (Agreement State), believes that material within' the confines-of the perimeter fence surrounding the NSC should be under the reactor license.

2.0 EVALUATION The Texas A&M University System holds License No. SNM 1518, which contains, among other materials, certain SNM materials that the NSC uses. Also, the NSC possesses and uses other nuclear materials that were licensed by a sublicense from ' a Office of Radiological Safety (ORS) at Texas A&M. The ORS had a lice- -

',e the material from the TDH.

The 11cu a, and more specifically the NSC, would like to remove the Special Nuclear Material that it uses under SNM 1518 from that license and place it under the reactor license.

By so doing the uncertainties that arise as to what license is responsible for violations while the material is on the NSC site would be eliminated. Moreover, tracking of the material.on the NSC site would be more efficient.

The State of Texas believes that material within the NSC perimeter should be wholly the ~ responsibility of the reactor licensee,- and therefore does not want to license material within the NSC' boundary.

Therefore the licensee proposes to transfer' material previously licensed by the State to the reactor license.

Also, this.would, as in the case above, make tracking.of material within the-NSC site more-efficient.

• See Figtra 1 and letter from TDH, October 23, 1992.

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.- 4 A discussion of each license condition change oriaddition follows:

a. License condition II.B.(2) has been changed to delete possession and use of "200 grams of contained uranium-235 in one MTR type fuel element." The licensee no longer has this material.

b. License condition II.B.(3) has been broadened to include possession and use of byproduct material in amounts required without restriction to chemical or physical form, for analysis or instrument calibration. This license condition was previously limited to a twenty (20) curie encapsulated plutonium-beryllium neutron source and a three (3) curie encapsulated americium-beryllium neutron source. The change to this license condition makes it similar to a license condition in power reactors and provides more flexibility to the licensee in the support of the reactor program. The August 24, 1993 letter, submitted by the licensee, omitted a clause in this license condition which read as follows: "but not to separate such byproduct material as may be produced by operations of the reactor."

In a telephone conversation of September 13, 1993, between T. Michaels (NRC) and B. Carlisle (NSC), the licensee agreed to have this clause reinserted in the license condition.

c. A new license condition II.B.(4) adds certain SNM material which is under NRC License No. SNM 1518, into the reactor license. The licensee has agreed, in a telecon of September 15, 1993, T. Michaels to B. Carlisle, to remove the material being placed under the reactor license from License No. SNM 1518 when Amendment No. 13 to License No. R-83 is approved.

d. A new license condition II.B.(5) allows the licensee to receive, possess and use not more than fifteen (15) pounds of source material.

e. A new license condition II.B.(6) defines the boundary within which material under the reactor license will be maintained and accounted for until such time as it leaves the site boundary and is transferred to another license.

f. License condition II.C. has been changed to add Section 40.41 of 10 CFR Part 40 because the license now allows possession and use of source material.

1 The staff finds these changes acceptable.

4 The indemnity agreement is being revised to. assure that all buildings and area j

hiside the chain link fence, (see Figure 1), are covered by this agreement.

This change was necessary because the laboratory building within the chain link fence (perimeter) was not covered by the existing indemnity agreement.

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3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change to administrative requirements. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

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4.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that:

(1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously evaluated, or create the possibility of a new or different kind of accident from any accident previously evaluated, and does not involve a significant reduction in a margin of safety, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will no be endangered.by the proposed activities, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or the health and safety of the public.

Principal Contributor: Theodore S. Michaels Date: October 26, 1993

Enclosures:

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Figure 1 2.

October 23, 1992 letter i

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i Texas Department of Health Devid R. Santh. M.D.

Cornminioner I100 wes: 49th Sueet Robert A. Macte.an. M.D.

Ausda, Texas 78756-3189 Deputy Comminioner -

i (512) 458-7111 Radiadon Coouol (512) 8344688 i

October 23,1992 Robert J. Doda i

State Agreements Program U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 l

Arlingto,n, Texas 76011

Dear Mr. Doda:

r We continue to review the licensing jurisdiction situation with regard to radioactive ma in and around the Texas A and M University Nucicar Science Center, located in Texas. Our staff recently completed a site visit with a U.S. Nuclear Regulatory Com (NRC) Regional Inspector, wherein operations and the physical plant were reviewed a character of other operations conducted on or near the site was ascertained.

Review of the material and discussions with staff have also led to furth which have been fruitful. -It now appears possible to come to some conclusions rel nature and interactions of various operations, to ascertain Agency intent with regard to th facilities, and to propose solutions to our mutualjurisdictional problems in this instance.

First, there seems to be amule indication that as a non-power reactor facility, the si defined onl across the r"y as a whole. Th'is is borne out in the spread of directly related reactor oper

.itire physical plant site, to include outlying storage and control of irradiated par fuel, location of vital systems for cooling and mechanical support in outlying build siting on the property of the waste water tank farm and solid waste storage, and s ventilation and reactor control ties to the Laboratory Building. This site definition is also c in the August 1967 Safety Analysis Report for the Nuclear Science Center (NS

,..the entire area inside the perimeter fence of the NSC is designated as a ' Restricted Are Second, discussions and a meeting held in Austin in the past to resolve this is established the intent of both our agencies to give primary consideration to a physi responsibility at the site fence line, with some minor modifications (see your. me 1988, attached). Subsequent implementation of the recommendations of the m Agency in the form of guidance to NRC inspectors is entirely consistent with this posi emphasizes that other sites may need special consideration. The generic guidance to w i

second version refers (Inspection Manual Chapter 2882, Appendices I and 2, issue date 5,1983, also attached) is also consistent with this positio facility is cited, and Paragraph 4, Page A21, where use relating to on-site func is cited).

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,w October 23,1992 Pave Two be the site boundary as described by the SAR, that i for this can be quickly described.

c on problem also appears to First, ventilation interconnectic t with the 1.abora has the potential for allowing contarnination incidents in outlyi operations, m the matter that an incident in the chemistry laboratory i ng locations to effect reactor few years ago (see letter of January e

calibration procedure using 100 Ci of '33 conducted in the Reacto

. Second, experiments

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licensure of these operations, interaction with the re e Pan 50 license. With state specifications simply cannot be addressed.

a ety systems, and its technical Agency has alreadv taken a step in that direction by a th u

l the distnbution of stradiated gemstones ed. Your I

u or z ng separately, under an "E" license,

. This same approach, t.c. specific licensure, needs to Some operations have sigm5 cant on-going radiologie j

c es conducted at this site. ;

necessary for the fission fragment production of filter media as the high radiation areas and requires care in analysis and surveillance. contamination from t l

u ng room and air monitors i, One *on-site

• area will need to be addressed that may require acti i

of the Cahbration Range Building is coincident with and substitutes f on of a different sort. The front building however. extends away from the reactor, in a direction off site. Acc or the site fence, but the Originally established to provide in door storage of sources for an range, the building now is also ir,volved with temporary storage of high l

(because it has appropriate shielded lockers and sorting p u w oor calibration 1

y rradiated samples reactor operauons waste (gloves, clean.up) materials and the lik )rocessing, a i

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the site restncted area, but (calibration range sources)stosed within the building is material from the reac for support of operations completely outsklc those of the re Separation of operations physically fother locations could be us d f ra alternative as is provision of separate access to the building outsid encompassed all of the teactor and laboratory opera e

o waste processing)is an 1

should be included on such a license, if minimum disruption of curren l

on to any license which l

important.

censee activities is

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Our staff would be available to meet with any of you ns that we have described.

resolution. For our part, prudence would seem to dictate that weur discretion to authontauons on the Texas tssued license, which does not include activitie i

the site. please contact Mr. Jon R. Sharp of my staff if nside the fence line of matter.

you have any questions regarding this Yo truly.

M &et o w.

David K.

. ckMhi Bureau of Radiatica Control

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Enctosures 0

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