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MONTHYEARML0917402832009-07-10010 July 2009 University of Missouri at Columbia - Request for Additional Information License Renewal Project stage: RAI ML0936200962009-12-30030 December 2009 University of Missouri at Columbia, RAI, Environmental Report Project stage: RAI ML0936200822009-12-30030 December 2009 University of Missouri at Columbia, RAI, License Renewal References Project stage: RAI ML1003300732010-01-29029 January 2010 Written Communication as Specified by 10 CFR 50.4(b)(1) Regarding the Response to the University of Missouri at Columbia - Request for Additional Information License Renewal Environmental Report, Dated December 30, 2009 Project stage: Request ML1010407262010-04-20020 April 2010 University of Missouri at Columbia, Request for Additional Information Regarding License Renewal, National Historic Preservation Act Project stage: RAI ML1011602442010-05-0606 May 2010 University of Missouri at Columbia - Request for Additional Information License Renewal, Safety Analysis Report, Complex Questions Project stage: RAI ML1011602662010-06-0101 June 2010 University of Missouri at Columbia - Request for Additional Information License Renewal, Safety Analysis Report, 45-Day Response Questions Project stage: RAI ML1020900052010-08-0404 August 2010 University of Missouri- Request for Additional Time to Respond to NRC Request for Additional Information Regarding License Renewal Project stage: RAI ML1025700552010-09-27027 September 2010 University of Missouri - Request for Additional Time to Respond to NRC Request for Additional Information Regarding License Renewal Project stage: RAI ML1028001182010-10-13013 October 2010 University of Missouri - Request for Additional Time to Respond to NRC Request for Additional Information Regarding License Renewal Project stage: RAI ML1030600202010-10-29029 October 2010 University of Missouri-Columbia Research Reactor - Amended Facility License Project stage: Other ML1034403972010-12-13013 December 2010 University of Missouri - Request for Additional Time to Respond to NRC Request for Additional Information Regarding License Renewal Project stage: RAI ML1102403272011-01-14014 January 2011 University of Missouri - Request for Additional Time to Respond to NRC Request for Additional Information Regarding License Renewal Project stage: Request ML1102700732011-02-0101 February 2011 University of Missouri - Request for Additional Time to Respond to NRC Request for Additional Information Regarding License Renewal (Tac No. MD3034) Project stage: RAI ML1118110712011-07-0505 July 2011 University of Missouri - Request for Additional Time to Respond to NRC Request for Additional Information Regarding License Renewal (TAC No. M3034) Project stage: RAI ML12010A1862012-01-0606 January 2012 University of Missouri - Columbia Research Reactor, Written Communication as Specified by 10 CFR 50.4(b)(1) Regarding Responses to the University of Missouri at Columbia - Request for Additional Information License Renewal, Safety Analysis Project stage: Request 2010-05-06
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Category:Letter
MONTHYEARIR 05000186/20232022023-12-12012 December 2023 the Curators of the University of Missouri - U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000186/2023202 ML23198A0232023-08-29029 August 2023 Examination Result Letter No. 50-186/OL-23-02, University of Missouri-Columbia ML23198A0222023-08-29029 August 2023 Examination Report Letter No. 50-186/OL-23-02, University of Missouri - Columbia ML23221A1172023-08-0303 August 2023 Written Communication as Specified by 10 CFR 50.4(b)(4) Regarding the Submittal of the Physical Security Plan for the University of Missouri Research Reactor as a Part of the Process to Renew Amended Facility Operating License R-103 ML23213A0592023-08-0101 August 2023 Written Communication as Specified by University of Missouri Research Reactor Technical Specification 6.6.2(d) Regarding a Permanent Change in the Facility Organization Involving the Executive Director IR 05000186/20232012023-07-31031 July 2023 the Curators of the University of Missouri U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000186/2023201 ML23186A2132023-07-31031 July 2023 Examination Confirmation Letter No. 50-186/OL-23-03, University of Missouri - Columbia ML23124A0422023-05-0808 May 2023 Examination Confirmation Letter 50-186/OL-23-02, University of Missouri - Columbia ML23103A0742023-04-10010 April 2023 University of Missouri, Columbia Research Reactor, Shipment of Radioactive Material Shipment Identifier MURR 23-01 Highway Route Controlled Quantity ML23024A2772023-04-0707 April 2023 Cover Letter for the Security Inspection Report for the University of Missouri (Public) - October 2022 ML23087A1142023-03-29029 March 2023 Examination Results Letter No. 50-186/OL-23-01, University of Missouri - Columbia ML23089A3162023-03-29029 March 2023 Letter Notifying Univ. of Missouri That Us Dept. of Energy Funding Will Not Be Available in Fiscal Year 2023 to Complete the Conversion of MURR to LEU Fuel ML23087A1132023-03-29029 March 2023 Examination Report No. 50-186/OL-23-01, University of Missouri-Columbia ML23055B1372023-02-24024 February 2023 Submittal of Annual Operating Report for the University of Missouri-Columbia Research Reactor as Required by MURR Technical Specification 6.6.e IR 05000186/20222022023-02-23023 February 2023 the Curators of the University of Missouri - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000186/2022202 - Cover Letter and Enclosure ML23031A0132023-02-14014 February 2023 Examination Confirmation Letter No. 50-186/OL-23-01, University of Missouri-Columbia ML23017A2072023-01-13013 January 2023 Written Communication as Required by University of Missouri Research Reactor Technical Specification 6.6.c(3) Regarding a Deviation from Technical Specification 6.1.f ML22349A0422022-12-0808 December 2022 Written Communication as Specified in 10 CFR 50.54(b)(5) Regarding Changes to the University of Missouri-Columbia Research Reactor Facility Emergency Plan Without Prior Commission Approval Pursuant to 10 CFR 50.54(q)(3) ML22314A2102022-11-0909 November 2022 Written Communication as Required by Technical Specification 6.6.d(2), Other Reports, Regarding a Change in University of Missouri-Columbia Research Reactor Organization Involving the Reactor Facility Director ML22304A0042022-10-27027 October 2022 University of Missouri - Columbia, Shipment of Radioactive Material, Highway Route Controlled Quantity ML22291A0322022-10-14014 October 2022 University of Missouri Written Communication as Required by 10 CFR 73, Appendix G Regarding a Deviation from the MURR Physical Security Plan ML22290A0042022-10-12012 October 2022 University of Missouri-Columbia Research Reactor, Reportable Event Report Pursuant to 20.2201(a)(ii) Regarding Loss of Licensed Material During Shipment IR 05000186/20222012022-06-14014 June 2022 the Curators of the University of Missouri - U.S. NRC Routine Inspection Report No. 05000186/2022201 ML22158A0792022-06-0606 June 2022 Submittal of Revised Annual Operating Report for the University of Missouri-Columbia Research Reactor as Required by MURR Technical Specification 6.6.e ML22097A0592022-04-0707 April 2022 Approval for Spent Nuclear Fuel Highway Route Application - NRC Route No. 182D - Docket Number 050-0186 ML22088A0782022-03-25025 March 2022 Univ. of Missouri, Federal Funding for the Conversion of the Columbia Research Reactor from Highly-Enriched Uranium Fuel to Low-Enriched Uranium Fuel IR 05000186/20212032022-03-0202 March 2022 the Curators of the University of Missouri U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000186/2021203 ML22056A5162022-02-25025 February 2022 Submittal of Annual Operating Report for the University of Missouri-Columbia Research Reactor as Required by MURR Technical Specification 6.6.e ML22038A6012022-02-0808 February 2022 Acceptance for Spent Nuclear Fuel Highway Route Application NRC No. 182D-Docket No. 050-0186 ML22013B1412022-01-21021 January 2022 Examination Confirmation Letter No. 50-186-OL-22-02, University of Missouri-Columbia ML21327A3042021-11-23023 November 2021 Written Communication as Required by University of Missouri Research Reactor Technical Specification 6.6.c(3) Regarding a Deviation from Technical Specification 3.2.f.6 ML21298A1972021-10-25025 October 2021 University of Missouri-Columbia Research Reactor - Written Communication as Required by University of Missouri Research Reactor Technical Specification 6.6.c(3) Regarding a Deviation from Technical Specification 3.2.g.6 ML21253A2482021-09-23023 September 2021 Examination Confirmation Letter No. 50-186/OL-22-01, University of Missouri Columbia ML21221A3252021-08-0909 August 2021 University of Missouri-Columbia Research Reactor, Written Communication as Required by Technical Specification 6.6.c(3) Regarding a Deviation from Technical Specifications 3.2.a ML21217A2982021-08-0505 August 2021 University of Missouri-Columbia Research Reactor - Reportable Event Report Pursuant to 20.2203(a)(2)(iv) ML21215A4982021-07-0707 July 2021 Univ of Missouri, Submittal of Revised Road Transportation Security Plan for the Shipment of Irradiated Reactor Fuel ML21098A1992021-06-10010 June 2021 the Curators of the University of Missouri Issuance of Amendment No. 40 to Renewed Facility Operating License No. R 103 to Amend Technical Specifications 6.2 and 6.4 for the University of Missouri Columbia Research Reactor IR 05000186/20212022021-05-28028 May 2021 the Curators of the University of Missouri - U.S. Nuclear Commission Routine Inspection Report No. 05000186/2021202 IR 05000186/20212012021-05-27027 May 2021 University of Missouri-Columbia U. S. Nuclear Regulatory Commission Security Inspection Report No. 05000186/2021201 - Non-OUO-Sri Cover Letter ML21118A9682021-04-28028 April 2021 Examination Confirmation Letter No. 50-186/OL-21-01, University of Missouri-Columbia ML21092A1712021-04-0202 April 2021 University of Missouri-Columbia Research Reactor - Federal Funding for the Conversion of the University of Missouri-Columbia Research Reactor from Highly-Enriched Uranium Fuel to Low-Enriched Uranium Fuel ML21078A5002021-03-19019 March 2021 University of Missouri-Columbia Research Reactor Written Communication as Specified by 10 CFR 20.1007 Regarding a Reportable Event Pursuant to 20.2203(a)(2)(iv) ML21075A2922021-03-16016 March 2021 Written Communication as Specified by 10 CFR 50.4(b)(l) Requesting U.S. Nuclear Regulatory Commission Approval to Revise the Technical Specifications Appended to Renewed Facility Operating License No. R-103 Pursuant to 10 CFR 50.90 IR 05000186/20202022021-03-12012 March 2021 University of Missouri - Columbia - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000186/2020202 - Cover Letter and Enclosure ML21050A2512021-02-19019 February 2021 Submittal of Annual Operating Report for the University of Missouri-Columbia Research Reactor as Required by MURR Technical Specification 6.6.e ML21041A5402021-02-10010 February 2021 Univ. of Missouri-Columbia Research Reactor - Written Communication as Specified by Univ. of Missouri Research Reactor Tech Spec 6.6.d(2) Regarding a Permanent Change in the Facility Organization Involving the Office of the Chancellor ML20295A4242020-11-16016 November 2020 Notification of Mailing Address Change Regarding Submittal of Fingerprint Cards ML20287A5432020-10-0909 October 2020 University of Missouri, Columbia Research Reactor - Written Report, in Accordance with IO CFR 71.1, as Required by IO CFR 71. 9 5(b) for NRC Docket 71-9338), Regarding Conditions in the Certificate of Compliance for the Safkeg-HS 3977A, Us ML20238C0812020-09-28028 September 2020 Examination Report Letter No. 50-186/OL-20-01, University of Missouri-Columbia IR 05000186/20202012020-07-10010 July 2020 University of Missouri-Columbia - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000186/2020-201 - Cover Letter and Enclosure 2023-08-03
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML17284A0432017-11-0101 November 2017 University of Missouri at Columbia - Request for Additional Information License Amendment Request to Implement Selective Gas Extraction Target Experimental Facility at the University of Missouri Research Reactor (CAC A11010/05000186/L-2017- ML17234A7332017-09-0707 September 2017 University of Missouri at Columbia - Request for Additional Information License Amendment Request to Implement Selective Gas Extraction Target Experimental Facility at the University of Missouri Research Reactor ML16239A4252016-09-0707 September 2016 University of Missouri at Columbia - Request for Additional Information Regarding the Proposed Technical Specifications for the Renewal of Facility Operating License No. R-103 for the University of Missouri at Columbia Research Reactor ML16216A1222016-08-24024 August 2016 University of Missouri at Columbia - Request for Additional Information Financial Information for Renewal of Facility Operating License No. R-103 for the University of Missouri at Columbia Research Reactor ML16083A0252016-03-23023 March 2016 University of Missouri at Columbia - Clarifications Needed to Nuclear Regulatory Commission Staff Request for Additional Information Regarding the Renewal of Facility Operating License No. R-103 ML16028A2552016-02-0808 February 2016 University of Missouri at Columbia; Request for Additional Information Updated Financial Information for Renewal of Facility Operating License No. R-103 for the University of Missouri at Columbia Research Reactor (Tac No. Me1580) ML16008A9052016-01-12012 January 2016 MURR Iodine La RAI Proprietary Determination Letter ML15337A1752015-12-17017 December 2015 University of Missouri at Columbia Clarifications Needed to NRC Staff Request for Additional Information Regarding the Renewal of Facility Operating License No. R-103 for the University of Missouri at Columbia Research Reactor ML15307A0752015-11-19019 November 2015 Enclosuuniversity of Missouri at Columbia - Attachment Public Request for Additional Information ML15307A0732015-11-19019 November 2015 University of Missouri at Columbia - Cover Letter Request for Additional Information Regarding the License Amendment Request to Modify the Technical Specifications to Produce Radiochemical Sodium Iodine at the University of Missouri at Colu ML15280A3142015-10-28028 October 2015 University of Missouri at Columbia Research Reactor Request for Additional Information Regarding the Proposed Technical Specifications for the Murr License Renewal Review ML15098A6482015-04-17017 April 2015 University of Missouri at Columbia - Request for Additional Information Regarding the Renewal of Facility Operating License No. R-103 for the University of Missouri at Columbia Research Reactor ML14324A7072014-12-0303 December 2014 Request for Additional Information Regarding the MURR License Renewal Review (Updated Info 11/19/2014) ML1210101092012-04-12012 April 2012 University of Missouri, Columbia - Request for Additional Information, License Amendment Dated August 24, 2011 Safety Limits ML1117515642011-07-0101 July 2011 University of Missouri - Columbia - Request for Additional Information License Amendment, Center Test Hole (TAC N0. ME1876) ML1035606622010-12-27027 December 2010 University of Missouri - Columbia - Request for Additional Information License Amendment Center Test Hole ML1011602662010-06-0101 June 2010 University of Missouri at Columbia - Request for Additional Information License Renewal, Safety Analysis Report, 45-Day Response Questions ML1011602442010-05-0606 May 2010 University of Missouri at Columbia - Request for Additional Information License Renewal, Safety Analysis Report, Complex Questions ML1010407262010-04-20020 April 2010 University of Missouri at Columbia, Request for Additional Information Regarding License Renewal, National Historic Preservation Act ML0936200962009-12-30030 December 2009 University of Missouri at Columbia, RAI, Environmental Report ML0936200822009-12-30030 December 2009 University of Missouri at Columbia, RAI, License Renewal References ML0917402832009-07-10010 July 2009 University of Missouri at Columbia - Request for Additional Information License Renewal ML0823907242008-08-26026 August 2008 University of Missouri at Columbia - Request for Additional Information License Amendment on Fueled Experiment Conditions ML0722203632007-08-10010 August 2007 University of Missouri at Columbia - Request for Additional Information License Amendment on Fueled Experiment Conditions (TAC MD 5782) ML0527104062005-10-0707 October 2005 RAI Letter - Security Measures - Butler ML0402204892004-01-28028 January 2004 University of Missouri at Columbia - Request for Additional Information License Amendment on Definitions, Limiting Conditions for Operations and Reporting Requirements ML0316401192003-06-23023 June 2003 Univ of Missouri - Columbia -- Request for Additional Information Security Plan 2017-09-07
[Table view] |
Text
May 6, 2010 Mr. Ralph Butler, Director Research Reactor Center University of Missouri-Columbia Research Park Columbia, MO 65211
SUBJECT:
UNIVERSITY OF MISSOURI AT COLUMBIA C REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE RENEWAL, SAFETY ANALYSIS REPORT, COMPLEX QUESTIONS (TAC NO. MD3034)
Dear Mr. Butler:
We are continuing our review of your renewal request for Amended Facility Operating License No. R-103 for the University of Missouri - Columbia Research Reactor which you submitted on August 31, 2006, as supplemented. During our review of your renewal request, questions have arisen for which we require additional information and clarification. The enclosure is a partial request for additional information containing complex questions. We are requesting a response within 120 days of the date of this letter. There is an additional request for information containing our remaining questions being sent under separate cover. In accordance with Title 10 of the Code of Federal Regulations Section 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your renewal request.
If you have any questions regarding this review, please contact me at (301) 415-1127.
Sincerely,
/RA/
Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-186
Enclosure:
As stated cc w/encl: See next page
ML101160244 TEMPLATE # NRR-088 OFFICE PRLB:PM PRPB:LA PRLB:BC PRLB:PM NAME AAdams GLappert KBrock AAdams DATE 5/4/2010 5/3/2010 5/5/2010 5/6/2010
cc:
University of Missouri Associate Director Research Reactor Facility Columbia, MO 65201 Homeland Security Coordinator Missouri Office of Homeland Security P.O. Box 749 Jefferson City, MO 65102 Planner, Dept of Health and Senior Services Section for Environmental Public Health 930 Wildwood Drive, P.O. Box 570 Jefferson City, MO 65102-0570 Deputy Director for Policy Department of Natural Resources 1101 Riverside Drive Fourth Floor East Jefferson City, MO 65101 A-95 Coordinator Division of Planning Office of Administration P.O. Box 809, State Capitol Building Jefferson City, MO 65101 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611
OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE RENEWAL REQUEST FOR THE UNIVERSITY OF MISSOURI-COLUMBIA RESEARCH REACTOR LICENSE NO. R-103; DOCKET NO. 50-186 The purpose of these questions is to assist the staff in determining that the renewal application from the University of Missouri, Missouri University Research Reactor (MURR) meets the requirements of the regulations, in particular the regulations in Title 10 of the Code of Federal Regulations Parts 20 and 50. The questions are based on a review of your application using the U. S. Nuclear Regulatory Commission (NRC) staffs standard review plan in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Part 2, Standard Review Plan and Acceptance Criteria.
We have split our questions into two groups, complex questions that have a 120-day requested response time and the remaining questions with a 45-day response time. Because of this, the numbering of the questions below is not consecutive. Both groups of questions considered together result in a complete set of consecutively numbered questions.
CHAPTER 4 4.14 Section 4.5.3, Operating Limits.
- d. Page 4-40 and Technical Specification (TS) 3.2 b. Discuss how the one inch limit restricts flux tilting to ensure power peaking factors.
4.15 Section 4.6, Thermal Hydraulic Design, Page 4-43. It is unclear what the thermal design limit and the operating limit are. Provide further clarification for the temperature limit of the fuel cladding. Discuss the effect of fuel oxide layer build-up on the results of the analyses.
4.16 Section 4.6.1, Natural Convective Cooling Analysis, TS 2.1 c., Safety Limits, and TS 2.2 c., Limited Safety Systems Settings. The TS and Safety Analysis Report (SAR) do not include a limitation on inlet or bulk coolant temperature. Explain the effect of coolant temperature on the analysis and justify why a limit on inlet or bulk coolant temperature should not be required.
ENCLOSURE
CHAPTER 13 13.2 Section 13.2.2.1, Accident initiating events and scenarios, Page 13-17.
- a. From Fig. 13.4 (page 13-22), the DNB limiting power is about 17 megawatt (MW) thermal (t). What is the basis for the burnout power of 25.23 MW(t)? What is the corresponding peak fuel temperature?
- b. The SAR states it was assumed that the MURR core could withstand the prompt power burst associated with the rapid step insertion of positive reactivity. Please provide the bases for this assumption. Please discuss the results of the analysis if parameter initial conditions are at TS or license limits. Please discuss the results for reactor operation in Mode II or III.
- c. The SAR discusses other step insertions (i.e., up to 0.003 k/k). Please discuss the results of the analysis if parameter initial conditions are at TS or license limits.
Please discuss the results for reactor operation in Mode II or III.
- d. Please discuss the effect of build up of an oxide layer on the fuel cladding.
13.3 Section 13.2.2.1.2, Continuous Control Blade Withdrawal. Justify why the regulating blade is not part of this evaluation. Explain if reactor operation in Mode II or III changes the results of the evaluation.
13.4 Section 13.2.3, Loss of Primary Coolant.
- a. Explain why initial conditions of the analysis are not TS and license limits or provide an analysis at TS and license limits.
- b. Please describe any benchmarking that has been performed on the RELAP model and conclusions as to the accuracy of the models results. Please discuss the effect on the analysis of oxide layer build up on the fuel cladding.
- c. It is not clear from the SAR which version of RELAP is used for the loss of primary coolant calculations. However, RELAP5/MOD3.3 had a fundamental error in the point kinetics model that has recently been fixed. Does the version of the code used in the loss of coolant analysis have the fixes implemented? If not, confirm that the analysis model is giving results consistent with the accident, e.g.
by checking results as a function of time step or with another stand-alone point kinetics model.
13.6 Section 13.2.4, Loss of Primary Coolant Flow. Explain why loss of pressurizer pressure is the most limiting initiating event for this class of event. Please discuss the effect on the analysis of fuel burnup and oxide layer build-up on the cladding.
13.9 Section 13.2.6, Experiment Malfunction.
- a. The release path for the failure of fueled experiments is different than the MHA.
The containment of fission products afforded by the primary system is not present for the failure of a fueled experiment in the reactor pool. Please provide dose calculations for the failure of a fueled experiment in the pool.
- b. Please provide an example of a calculation of an irradiation container that meets the requirement for containing the pressure by at least a factor of two from the detonation of 25 milligrams of TNT-equivalent material.
CHAPTER 16 16.1 Section 16.1.1, Fuel and Fuel Cladding, TS 3.8, Reactor Fuel, and TS 4.5, Reactor Fuel.
- a. The bases for TS 3.8 b. states that the TS assures that fuel elements found to be defective are no longer used for reactor operation. The TS contains a limit on dimensional changes of coolant channel between fuel plates of 10 mils. What is the basis for the 10 mils and what is the impact of this amount of fuel channel dimensional change on thermal-hydraulic and accident analysis?
- b. TS 4.5 requires one of eight fuel elements that have reached their end-of life to be inspected. However, SAR 16.1.1 states that fuel elements are visually inspected during each refueling. Explain this difference between the SAR and proposed TSs. How can unacceptable dimensional changes be found while a fuel element is in service if fuel elements are only inspected at end-of-life?
APPENDIX B B.1 Appendix B should provide the methodology and calculation of off-site doses at the location of the nearest residence and at the location of highest public dose. Due to the elevated nature of calculated plumes for stable Pasquill Stability Classes (E and F), the chosen location at 150 meters cannot be assured to be at the location of maximum offsite dose. The dose at the nearest residence (760 meter) is dominated by the dose from Pasquill Classes D, E, and F, but at 150 meters, the hypothetical plume has not reached ground level. Further, the methodology to weight the atmospheric dispersion conditions will not work for the non-linear calculation of dispersion if only a single receptor distance is used. Provide a revised calculation of off-site dose from Ar-41 that determines the maximum offsite dose.
APPENDIX C C.2 Section C.2.1, RELAP5 Application. RELAP5/MOD3.3 had a fundamental error in the point kinetics model that has recently been fixed. Does the version of the code used in the thermal-hydraulic analysis have the fixes implemented? If not, confirm that the analysis model is giving results consistent with the transient, e.g. by checking results as a function of time step or with another stand-alone point kinetics model.
C.3 Section C.2.2, Modeling of the MURR. Please explain why initial conditions of the analysis are not TS and license limits. Please discuss the effect on the analysis of fuel burnup and oxide layer build up on the fuel cladding.