ML22111A330
| ML22111A330 | |
| Person / Time | |
|---|---|
| Site: | Pennsylvania State University, 07000113 |
| Issue date: | 04/20/2022 |
| From: | Weiss L Pennsylvania State Univ, University Park, PA |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML22111A329 | List: |
| References | |
| Download: ML22111A330 (5) | |
Text
"PennState Lora G. Weiss, Ph.D.
Senior Vice President for Research 814-865-6332 Lora.Weiss@psu.edu The Pennsylvania State University www.research.psu.edu 304 Old Main University Park, PA 16802-1504 US Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 April 20, 2022 To Whom It May Concern, Attached please find a request for the amendment of the Penn State Breazeale Reactor operating license, number R-2. The proposed amendment increases the allowable inventory of 235 U enriched to less than 20% in the form of fuel elements from 9.0 kg to 9.9 kg, in order to ensure that the facility can receive an adequate supply of fuel to support an anticipated increase in burnup without a need to ship spent fuel off site for approximately two more years. The Safety Analysis Report (SAR) and Technical Specifications (TS) are unaffected by this change and will not be revised.
Penn State requests approval of this amendment request by the first quarter of 2024 in order to schedule new fuel shipments and ensure continued full-power operation without interruption.
Questions regarding this request may be directed to Dr. Jeffrey Geuther, Associate Director for Operations, jag671@psu .edu.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 20, 2022 Sincerely, Commonwealth of Pennsylvania Signed and sworn to before me
- /H~ County of Centre On By 4/'J..0/J,O'J.'J Lora e1 $*j nonwealth of Pennsylvania
- Notary Seal
- l-m,ly K. Fessler, Notary Public Lora Weiss i , Centre County
! ';**. * *~n miss_io~ expires February 4, 2026 Senior Vice President for Research ... , ,0mm1ss1on number 1413538
. '.ibe r, Pennsylvania Association of Notaries
~ ~1~
Notary Public
Enclosures:
Proposed License R-2, Rev. 41, Page 2 (clean copy)
Commonwealth of Pennsylvania
- Notary Seal Proposed License R-2, Rev. 41, Page 2 (markup copy) Emily K. Fessler, Notary Public Centre County My commission expires February 4, 2026 Commission number 1413538 Member, Pennsylvania Association of Notaries
Introduction The PSU Breazeale Reactor at the Radiation Science and Engineering Center is used for university research, critical industrial service activities, teaching, training, and education. From 1965 - 2018, the neutron beam port alignment was not optimized for a TRIGA core, which limited the ability of researchers to conduct beam port experiments. A DOE NEUP grant enabled the facility to modify the D2O tank and beam port design in order to more efficiently utilize the neutrons from the core, and increased the number of available beam ports from two to five. One of the five new beam ports will house a cold neutron source, with three individual beam lines that can be used for a variety of experiments previously unavailable at the RSEC. This beam port modification greatly increases the ability of the Breazeale reactor to perform research and service work. A beam lab expansion will further enhance the ability of laboratory users to conduct cutting-edge scientific research and support critical infrastructure through industrial service.
The Breazeale Reactor has been operating as a TRIGA reactor since 1965. In that time, the amount of fissile material inventory in the form of spent nuclear fuel has gradually increased. In 2018, sixty-four fuel elements were selected for disposal and were inspected for shipment to Idaho National Laboratory.
However, the State of Idaho is currently not allowing spent TRIGA fuel to be shipped into the state, so the spent fuel remains at PSU, consuming 2.0 kg of U-235 inventory room on the R-2 license. This restriction on fuel disposal is outside of PSU's control and may soon affect our ability to maintain sufficient fissile material in the form of fresh fuel to maintain criticality at full power, especially during long operations when xenon poisoning becomes a factor. PSU and DOE have been in communication regarding the importance of shipping spent fuel and have discussed alternatives for meeting the fresh fuel needs at PSU.
While disposal of the spent fuel remains the preferred option for increasing room for new fuel, PSU is seeking a license amendment to buy time and as a good faith effort to assist DOE in being able to meet our needs for fuel while DOE and Idaho work toward the resumption of fuel shipment for storage.
PSU has been working to install new beam lab equipment in the expanded neutron beam laboratory. The centerpiece of the new beam lab is a Small Angle Neutron Spectrometer (SANS), which is expected to shift the Breazeale Reactor toward a paradigm of longer days of full power operations every week, necessitating an increase in fuel consumption. PSU estimates that fuel consumption may reach ~10 fuel elements each year (based on 12-weight percent fuel). To prepare for the possibility that the State of Idaho may still prohibit shipping of spent fuel from PSU when the SANS is operational and burnup has increased, PSU seeks to increase the license limit to allow for approximately two years of operation at a burnup of ~10 fuel elements per year before requiring a shipment of spent fuel. PSU currently has one fresh standard fuel element (in addition to several fresh instrumented elements) and room for ten more before reaching the license limit of 9.0 kg. Therefore, at an increased burn up of 10 elements per year, we will be reactivity limited in just over one year following the SANS installation unless our license inventory limit is increased.
Proposed Change to License PSU proposes to amend its license as follows (change underlined):
- 2. B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Pennsylvania State University:
- 2. Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material," to receive, possess, and use in connection with operation of the reactor:
- a. up to 9. 9 kilograms of contained uranium-235 enriched to less than 20% in the form of fuel elements and up to 50 grams of contained uranium-235 of any enrichment in forms such as fission detectors or fission foils.
Drop-in replacements (clean and mark-up} for the affected pages are enclosed.
This change does not affect the facility SAR, Technical Specifications, or other documents reviewed or approved by the Commission.
Expected Timeline It is expected that new fuel inventory above the current license limit will be needed by the 2nd quarter of 2024, according to the following timeline. Note that this timeline is estimated and may change based on SANS installation time and actual versus projected fuel usage.
3rd Quarter 2022 - SANS shipment to PSU.
4th Quarter 2022 - SANS will be installed and tested at PSU. The initial testing is not expected to result in a significant increase in fuel consumption.
1st - 2nd Quarter 2023-SANS usage for experiments will begin. A gradual increase to full usage is expected during this time.
3rd Quarter 2023 - Full SANS usage expected, increasing reactor burnup to approximately 36 MWh per week.
2nd Quarter 2024 - New fuel beyond the existing license limit of 9.00 kg needs to be received by this time in order to ensure continued operation at full power with full SANS usage.
3rd Quarter 2024- The Breazeale reactor may be reactivity limited by this time if the SANS is operated 36 MWh per week, based on a projected use of 10 elements per year, assuming that the R-2 license limit for U-235 inventory remains 9.0 kg.
Safety Evaluation The facility Safety Analysis Report considers the radioactivity and decay heat in spent fuel in two accidents:
the failure of a single fuel element in air (the maximum hypothetical accident, MHA} and the loss of coolant accident (LOCA} exposing the core following extended operations at the licensed steady state power limit. The safety analysis for these two accidents considers the radioactive material contained in fuel and the fuel temperature due to decay products immediately after sustained, high-power operations.
The inventory of radioisotope in stored fuel is not considered in either scenario, so the consequences of the SAR Ch. 13 accident analysis would be unaffected by the increase the license limit for possession of TRIGA fuel.
Storage of Fuel During Core Off-Load There is sufficient room to safely store up to sixteen additional fuel elements in the pool storage racks while still allowing for a full core off-load for maintenance based on the current rack inventory. The storage racks can also accommodate an additional fifteen new elements by offloading graphite and dummy elements currently stored in the racks. Sixteen 12 weight percent elements would have a total U-235 mass of approximately 900 g. Therefore, the fuel racks in the Breazeale reactor pool have sufficient room to accommodate thirty one new elements. This is more than enough to store the new fuel that could fit under a revised license limit of 9.9 kg. There are mounting locations for an additional four storage racks in the reactor pool.
The fuel will be stored in the standard TRIGA fuel racks already installed at the facility, which guarantees that the TS related to stored fuel are satisfied:
TS 5.4 Fuel Storage Specifications
- a. All fuel elements SHALL be stored in a geometrical array where the kett is less than 0.8 for all conditions of moderation.
- b. Irradiated fuel elements SHALL be stored in an array which SHALL permit sufficient natural convection cooling by water such that the fuel element temperature SHAL NOT reach the safety limit as defined in TS 2.1.
Safeguards Considerations Per 10CFR74.4, "Special Nuclear Material of Low Strategic Significance" means "Less than 10,000 grams of) uranium-235 (contained in uranium enriched to 10 percent or more but less than 20 percent in the U235 isotope)." An increase in the license limit to allow possession and use of up to 9.9 kg in the form of 20% enriched TRIGA fuel would not exceed the limit of 10,000 g (10.000 kg) for Special Nuclear Material of Low Strategic Significance.
All additional nuclear fuel received as a result of the increase in the license inventory limit will be stored in the fuel storage racks in the reactor pool. This is inside the security boundary of the RSEC, which has an NRC-approved physical security plan which meets the requirements of 10CFR73. Physical protection of the new fuel will be accomplished in the same manner as the existing fuel inventory, as the new fuel will be located in the same storage location. Therefore, the addition of 900 g of U-235 does not affect the security of the special nuclear material stored at the Breazeale reactor.
Emergency Planning The addition of 900 grams of fuel inventory does not affect the emergency plan. The total fuel mass or number of fuel elements are not parameters considered in any emergency event at the PSU RSEC. Fission
product release from a single fuel element is the maximum hypothetical accident (MHA) in the SAR, and the Emergency Plan does include facility evacuation due to airborne radioactivity. However, the source term for this event is based on the fission product inventory of a single fuel element. The total number of fuel elements and total fuel mass do not affect the MHA evaluation or the expected airborne radioactivity levels during an emergency.
Conclusion PSU requests a license possession limit increase to allow possession of up to 9.9 kg of U-235 in the form of TRIGA fuel. This amount of fuel does not affect facility safety and remains within the definition of special nuclear material of low strategic significance. This change will help the facility maintain operation without interruption and provide important research and education services with the new SANS equipment and other capabilities at the reactor.