ML22146A194

Regents of the University of California - RAI Regarding License Renewal Application for the University of California - Davis/Mccellan Nuclear Research Center

ML22146A194
Person / Time
Site:	University of California-Davis
Issue date:	06/03/2022
From:	Geoffrey Wertz NRC/NRR/DANU/UNPL
To:	Mohapatra P McClellan Nuclear Research Center
Wertz G
References
EPID L-2020-NFR-0002
Download: ML22146A194 (7)

Text

P. Mohapatra Dr. Prasant Mohapatra Vice Chancellor for Research Department of Computer Science University of California Davis, CA 95616

SUBJECT:

REGENTS OF THE UNIVERSITY OF CALIFORNIA - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE RENEWAL APPLICATION FOR THE UNIVERSITY OF CALIFORNIA - DAVIS/MCCLELLAN NUCLEAR RESEARCH CENTER (EPID NO. L-2020-NFR-0002)

Dear Dr. Mohapatra:

By letter dated June 11, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18179A501), the Regents of the University of California submitted a license renewal application (LRA) for a 20-year renewal of the Class 104c Facility Operating License No. R-130, Docket No. 50-607, for the University of California - Davis McClellan Nuclear Research Center Training, Research, Isotope, General Atomics nuclear reactor. By letter dated July 6, 2020 (ML20188A368), the licensee updated its LRA to reflect its decision to reduce the licensed thermal operating power level from 2.3 megawatt thermal (MWt) to 1.0 MWt, and to eliminate pulsing capability and irradiation of explosive materials in the reactor tank.

The U.S. Nuclear Regulatory Commission (NRC) staff identified additional information needed to continue its review of the LRA, as described in the enclosed request for additional information (RAI). As discussed with Dr. Wesley Frey of your staff, by telephone on May 16, 2022, provide a response to the RAI or a written request for additional time to respond, including the proposed response date and a brief explanation of the reason, 30 days from the date of this letter.

Following receipt of the complete response to the RAI, the NRC staff will continue its review of the LRA.

The response to the RAI must be submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.4, Written communications, and pursuant to 10 CFR 50.30(b), Oath or affirmation, be executed in a signed original document under oath or affirmation. Information included in the response that you consider sensitive or proprietary, and seek to have withheld from public disclosure, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Any information related to safeguards should be submitted in accordance with 10 CFR 73.21, Protection of Safeguards Information:

Performance Requirements.June 3, 2022 If you have any questions regarding the NRC staffs review or if you intend to request additional time to respond, please contact me at (301) 415-0893, or by electronic mail at Geoffrey.Wertz@nrc.gov.

Sincerely, Geoffrey Wertz, Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No. 50-607 License No. R-130

Enclosure:

As stated cc: See next page Signed by Wertz, Geoffrey on 06/03/22

University of California-Davis/McClellan Docket No. 50-607

cc:

David Reap, Radiation Safety Officer 5335 Price Avenue, Bldg. 258 McClellan, CA 95652-2504

California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814

Radiologic Health Branch California Department of Public Health P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414

Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115

Dr. Wesley D. Frey, Reactor Director McClellan Nuclear Research Center University of California, Davis 5335 Price Avenue, Building 258 McClellan, CA 95652-2504

ML22146A194 NRR-088 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME GWertz NParker JBorromeo GWertz DATE 6/2/2022 6/2/2022 6/3/2022 6/3/2022 OFFICE OF NUCLEAR REACTOR REGULATION

REQUEST FOR ADDITIONAL INFORMATION

REGARDING RENEWAL OF FACILITY OPERATING LICENSE NO. R-130

UNIVERSITY OF CALIFORNIA-DAVIS/MCCLELLAN NUCLEAR RESEARCH CENTER

DOCKET NO. 50-607

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the license renewal application for compliance with Title 10 of the Code of Federal Regulations (10 CFR) using the following guidance and standard(s):

The regulation, 10 CFR 20.1301, Dose limits for individual members of the public, which states (a) Each licensee shall conduct operations so that - (1) The total effective dose equivalent to individual members of the public from licensed operations does not exceed 0.1 rem (1 mSv) in a year, and, (d) A licensee or license applicant may apply for prior NRC authorization to operate up to an annual dose limit for an individual member of the public of 0.5 rem (5 mSv). The licensee or license applicant shall include the following information in this application: (1)

Demonstration of the need for and the expected duration of operations in excess of the limit in paragraph (a) of this section; (2) The licensee's program to assess and control dose within the 0.5 rem (5 mSv) annual limit; and (3) The procedures to be followed to maintain the dose as low as is reasonably achievable.

NUREG-1537 Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, issued February 1996 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML042430055)

NUREG-1537 Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Standard Review Plan and Acceptance Criteria, issued February 1996 (ML042430048)

Interim Staff Guidance for the Streamlined Research Reactor License Renewal Process, A. Adams to K. Brock, October 15, 2009 (ML092240256 and ML092240244)

The NRC staff review of the University of California Davis (UCD), McClellan Nuclear Research Center (MNRC) loss-of-coolant accident (LOCA) used the guidance in NUREG-1537, Part 2, Chapter 13, Accident Analyses, Loss of Coolant, which states that licensees should analyze potential LOCAs, and states, in part, that a LOCA could cause the uncovered reactor core to constitute an unshielded gamma ray source.

The NRC staff review finds that the radiation dose rates, as stated in Section 13.2.3.2.2.3, Radiation Levels from the Uncovered Core for the LOCA scenario, Table 13-11, Scattered Radiation Dose Rates at the MNRC Fence Line After a Loss of Pool Water Accident Following

Enclosure

1 MW Operations, of the UCD/MNRC SAR (redacted version ML20238B984) appear to represent the highest radiation dose that a member of the public could receive following a LOCA. The NRC staff also finds the dose rates provided in Table 13-11 would result in a radiation dose to a member of the public, located outside the controlled area boundary of the UCD/MNRC fence, in excess of the annual radiation limit specified in 10 CFR 20.1301(a)(1) of 100 millirem (mrem), within a few hours of exposure following the LOCA.

Further, the NRC staff review of the licensees SAR did not identify any systems or equipment credited to potentially mitigate or reduce the dose rates following a LOCA. Also, the NRC staff review of the licensees Emergency Plan, Revision 9, dated June 2018 (redacted version ML20238B990), did not find any protective actions to remove or evacuate members of the public from the areas outside the controlled area boundary of the UCD/MNRC fence, in order to mitigation the potential radiation dose.

In order to continue with its review, the NRC staff requires the following additional information:

1. As necessary to demonstrate compliance with 10 CFR Part 20 dose limits and consistent with the guidance in NUREG-1537, provide a comprehensive updated description of the UCD/MNRC LOCA scenario, including a timeline of the major activities or assumptions, the postulated cause of the leak, the drain-down rate, the assumed time for the core to become uncovered, and any changes to the calculated dose rates, if identified.

2. As necessary to demonstrate compliance with 10 CFR Part 20 dose limits and consistent with the guidance in NUREG-1537, provide the proposed plans to reduce or mitigate the potential radiation exposure to a member of the public such that the postulated LOCA scenario would not result in any member of the public receiving an annual dose in excess of 100 mrem, as required by 10 CFR 20.1301, such as:

2.1. operator actions and/or facility equipment planned to be used to mitigate the consequences of the LOCA, and whether the equipment should be included in the technical specifications.

2.2. procedures or processes to mitigate the consequences of the LOCA, including any changes to the UCD/MNRC Emergency Plan.

2.3. support needed from any off-site local support agencies, officials, or emergency response organizations, including the use of any signed agreements.

2.4. any other planned actions credited to mitigate the consequences of the LOCA.

3. The regulation, 10 CFR 20.1301(d) states that [a] licensee or license applicant may apply for prior NRC authorization to operate up to an annual dose limit for an individual member of the public of 0.5 rem (5 mSv). The licensee or license applicant shall include the following information in this application:

(1) Demonstration of the need for and the expected duration of operations in excess of the limit in paragraph (a) of this section;

(2) The licensee's program to assess and control dose within the 0.5 rem (5 mSv) annual limit; and

(3) The procedures to be followed to maintain the dose as low as is reasonably achievable.

If an increase of the annual dose limit for an individual member of the public is being requested, provide the information stated in 10 CFR 20.1301(d)(1)-(3), listed above.