ML25240B526
| ML25240B526 | |
| Person / Time | |
|---|---|
| Site: | Texas A&M University |
| Issue date: | 08/28/2025 |
| From: | Joel Jenkins Texas A&M Univ |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 2025-013 | |
| Download: ML25240B526 (1) | |
Text
Nuclear Engineering & Science Center 1095 Nuclear Science Road, 3575 TAMU College Station, TX 77843-3575 Tel. (979) 845-7551 August 28, 2025 2025-013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Facility License No. R-23 Docket No. 050-00059 Internal Document Number: AGN-R23-LAR-2025-01
Subject:
License Amendment Request for Facility Operating License No. R-23 (Docket No. 50-59) - Revision to Technical Specification 6.4.3 Audit Frequency
References:
- 1. Facility Operating License No. R-23, Amendment 16 (ADAMS ML17019A003).
Pursuant to 10 CFR 50.90, the Texas A&M Engineering Experiment Station (TEES), as the designated licensee for the AGN-201M Reactor (Facility Operating License No. R-23),
hereby requests an amendment to the Technical Specifications (TS) incorporated in the license. This amendment would revise TS 6.4.3 to change the frequency of audits performed under the cognizance of the Reactor Safety Board from quarterly to annually.
This change resolves an internal inconsistency in the TS and aligns with the guidance in ANSI/ANS-15.1-2007, "The Development of Technical Specifications for Research Reactors," which the NRC has endorsed for non-power reactors.
The AGN-201M Reactor is currently disassembled and stored at the Nuclear Science Center Facility, with no operations conducted. The proposed amendment involves no significant hazards consideration, as evaluated in accordance with 10 CFR 50.92(c). Additionally, the amendment qualifies for categorical exclusion from environmental review under 10 CFR 51.22(c)(9). This administrative change has no impact on reactor safety or public health.
Enclosed are:
- 1. Evaluation of the Proposed Change.
- 2. Marked-up TS pages.
- 3. Retyped TS pages.
Due to the very low safety significance of the requested license amendment, and the fact that the request is purely administrative, TEES requests NRC approval of this LAR within
AGN-R23-LAR-2025-01 2/2 August 28, 2025 four months of submittal, with implementation within 90 days of issuance. If you have any questions, please contact Jere Jenkins at 979.845.7551 or jere@tamu.edu.
I declare under penalty of perjury that the foregoing is true and correct. Executed on August 05, 2025.
Jere Jenkins Director, Nuclear Engineering & Science Center Texas A&M Engineering Experiment Station
Enclosures:
As stated above.
cc: Reactor Files Jere H.
Jenkins Digitally signed by Jere H.
Jenkins Date: 2025.08.28 11:21:18
-05'00'
ENCLOSURE 1 EVALUATION Facility License No. R-23 Docket No. 050-00059 Internal Document Number: AGN-R23-LAR-2025-01
Subject:
License Amendment Request for Facility Operating License No. R-23 (Docket No.
50-59) - Revision to Technical Specification 6.4.3 Audit Frequency
AGN-R23-LAR-2025-001 1/3 2025-08-28 : Evaluation of the Proposed Change 1.0 Summary Description This evaluation supports a request to amend Facility Operating License No. R-23 for the Texas A&M University AGN-201M Reactor. The proposed change revises TS 6.4.3 to change the frequency of audits performed under the cognizance of the Reactor Safety Board from quarterly to annually. This resolves an inconsistency where the introductory sentence specifies quarterly audits, but subsections a and b require audits at least annually or every two years, respectively.
The change aligns with ANSI/ANS-15.1-2007, endorsed by the NRC for research reactors.
2.0 Detailed Description The current TS 6.4.3 reads:
"Audits of facility activities shall be performed quarterly under the cognizance of the Reactor Safety Board but in no case by the personnel responsible for the item audited.
These audits shall examine the operating records and encompass but shall not be limited to the following:
- a. The conformance of the facility operation to the Technical Specifications and applicable license conditions, at least annually.
- b. The Facility Emergency Plan and implementing procedures, at least every two years."
The proposed change revises the introductory sentence to:
"Audits of facility activities shall be performed annually under the cognizance of the Reactor Safety Board but in no case by the personnel responsible for the item audited.
These audits shall examine the operating records and encompass but shall not be limited to the following:"
Subsection 6.4.3 items a and b remain unchanged.
This legacy quarterly requirement originated in previous TS revisions but was not updated to align with modern standards for non-power reactors, the requirements of sub-parts a and b, nor did it fit the current status of the reactor. The reactor is disassembled and non-operational, making quarterly audits unnecessary and burdensome.
3.0 Technical Evaluation The AGN-201M Reactor is a low-power (5 watt maximum) research reactor that has been disassembled and stored since 2016 at the Nuclear Science Center Facility under controlled conditions per TS 3.5 and 4.5. No reactor operations occur, and the core components are secured with no reactivity changes possible. Audits under TS 6.4.3 verify conformance with TS, license conditions, and the Emergency Plan.
AGN-R23-LAR-2025-001 2/3 2025-08-28 The quarterly frequency is inconsistent with subsections a (annual) and b (biennial), creating ambiguity. Changing the frequency requirement to annually resolves this and reduces administrative burden without affecting safety, as the reactor poses minimal risk in its stored state. This aligns with ANSI/ANS-15.1-2007, Section 6.2 ("Review and Audit"), which recommends annual audits for research reactor review committees to ensure effective oversight. NRC endorses ANSI/ANS-15.1 via Regulatory Guide 2.5, "Quality Assurance Program Requirements for Research and Test Reactors," and NUREG-1537, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors."
No physical changes to the facility, procedures, or equipment are involved. The change is administrative and maintains adequate oversight for a non-operating reactor.
4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria The proposed change complies with 10 CFR 50.36(c)(5), which requires TS to include administrative controls for non-power reactors. It aligns with NRC-endorsed ANSI/ANS-15.1-2007 for research reactor TS content. No other Part 50 requirements (e.g., Appendix A GDC, not applicable to research reactors per 10 CFR 50.34) are affected. The change does not impact 10 CFR 50.59 evaluations, as no facility changes occur.
4.2 Precedent No direct precedent for this specific change was identified in other AGN-201M reactors.
However, the revision aligns with the NRC-endorsed ANSI/ANS-15.1-2007 standard, which has been referenced in TS amendments for other research reactors (e.g., Reed College Reactor Amendment No. 13, ADAMS ML22082A221, issued March 23, 2022, where administrative controls were updated to match ANSI/ANS-15.1, including review and audit functions). This ensures consistency with NRC guidance for non-power reactors.
4.3 No Significant Hazards Consideration Determination TEES has evaluated the proposed change against the criteria of 10 CFR 50.92(c):
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
No. The change is administrative and affects audit frequency for a disassembled reactor.
No accidents are possible in the current configuration, and oversight remains adequate.
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
No. No physical or operational changes are made; the reactor remains non-operational.
Does the proposed change involve a significant reduction in a margin of safety?
AGN-R23-LAR-2025-001 3/3 2025-08-28 No. Annual audits maintain safety margins per ANSI/ANS-15.1-2007, consistent with NRC guidance.
TEES concludes that the proposed change presents no significant hazards consideration.
4.4 Conclusions The proposed change is acceptable and complies with applicable regulations.
5.0 Environmental Consideration The proposed change qualifies for categorical exclusion under 10 CFR 51.22(c)(9), as it is a TS administrative change with no significant hazards consideration, no significant change in effluents, and no significant increase in individual or cumulative occupational radiation exposure. No environmental impact statement or assessment is required.
6.0 References
- 1. ANSI/ANS-15.1-2007, "The Development of Technical Specifications for Research Reactors."
- 2. NRC Regulatory Guide 2.5, "Quality Assurance Program Requirements for Research and Test Reactors."
- 3. NUREG-1537, Part 1, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content."
- 4. Facility Operating License No. R-23, Amendment 16 (ADAMS ML17019A003).
- 5. NRC Regulatory Issue Summary 2001-18, "Requirements for Oath or Affirmation."
ENCLOSURE 2 TECHNICAL SPECIFICATION MARKUP Facility License No. R-23 Docket No. 050-00059 Internal Document Number: AGN-R23-LAR-2025-01
Subject:
License Amendment Request for Facility Operating License No. R-23 (Docket No.
50-59) - Revision to Technical Specification 6.4.3 Audit Frequency
Amendment 16 Date: January 19, 2017
- c. Proposed tests or experiments which are significantly different from previous approved tests or experiments, or those that involve an unreviewed safety question as defined in 10 CFR 50 Section 50.59.
- d. Proposed changes in Technical Specifications or licenses.
- e. Violations of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
- f.
Significant operating abnormalities or deviations from normal and expected performance of facility equipment that affect nuclear safety.
- g. Reportable occurrences.
- h. Audit reports.
6.4.3 Audits Audits of facility activities shall be performed at least quarterly annually under the cognizance of the Reactor Safety Board but in no case by the personnel responsible for the item audited. These audits shall examine the operating records and encompass but shall not be limited to the following:
- a. The conformance of the facility operation to the Technical Specifications and applicable license conditions, at least annually.
- b. The Facility Emergency Plan and implementing procedures, at least every two years.
6.4.4 Authority The Reactor Safety Board shall report to the President and shall advise the Head of the Department of Nuclear Engineering on those areas of responsibility outlined in section 6.1.6 of these Technical Specifications.
6.4.5 Minutes of the Reactor Safety Board The Chairman of the Reactor Safety Board shall direct the preparation, maintenance, and distribution of minutes of its activities. These minutes shall include a summary of all meetings, actions taken, audits, and reviews.
ENCLOSURE 3 TECHNICAL SPECIFICATION CLEAN Facility License No. R-23 Docket No. 050-00059 Internal Document Number: AGN-R23-LAR-2025-01
Subject:
License Amendment Request for Facility Operating License No. R-23 (Docket No.
50-59) - Revision to Technical Specification 6.4.3 Audit Frequency
Amendment 16 Date: January 19, 2017
- c. Proposed tests or experiments which are significantly different from previous approved tests or experiments, or those that involve an unreviewed safety question as defined in 10 CFR 50 Section 50.59.
- d. Proposed changes in Technical Specifications or licenses.
- e. Violations of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
- f.
Significant operating abnormalities or deviations from normal and expected performance of facility equipment that affect nuclear safety.
- g. Reportable occurrences.
- h. Audit reports.
6.4.3 Audits Audits of facility activities shall be performed at least annually under the cognizance of the Reactor Safety Board but in no case by the personnel responsible for the item audited. These audits shall examine the operating records and encompass but shall not be limited to the following:
- a. The conformance of the facility operation to the Technical Specifications and applicable license conditions, at least annually.
- b. The Facility Emergency Plan and implementing procedures, at least every two years.
6.4.4 Authority The Reactor Safety Board shall report to the President and shall advise the Head of the Department of Nuclear Engineering on those areas of responsibility outlined in section 6.1.6 of these Technical Specifications.
6.4.5 Minutes of the Reactor Safety Board The Chairman of the Reactor Safety Board shall direct the preparation, maintenance, and distribution of minutes of its activities. These minutes shall include a summary of all meetings, actions taken, audits, and reviews.