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Written Communication as Specified by 10 CFR 50.4(b)(1) Regarding Responses to the University of Missouri at Columbia - Request for Additional Information Regarding the License Amendment Request to Modify the Technical Specifications to Pro
	ML16004A150
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Site:	University of Missouri-Columbia
Issue date:	12/30/2015
From:	Rhonda Butler, Fruits J; Univ of Missouri - Columbia
To:	; Office of Nuclear Reactor Regulation
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UNWVERSITY of MISSOURI RESEARCH REACTOR CENTER December 30, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001

REFERENCE:

Docket 50-186 Univers~ity of MissoUri-Columbia Research Reactor Amended Facility License No. R-103

SUBJECT:

Written communication as specified by 10 CFR 50.4(b)(1) regarding responses to the "University of Missouri at Columbia - 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 Columbia Research Reactor (TAC No. MF65 14)," dated November 19, 2015 By letter dated July 20, 2015, the University of Missouri-Columbia Research Reactor (MURR) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to amend the Technical Specifications (TSs), which are appended to Amended Facility License No. R-103, in order to produce the radiochemical sodium iodide (1-131).

There are currently no competing modalities for its use as a therapy for thyroid dysfunctions and no current supplier within the U.S. This license amendment request would allow MURR to continue to perform a key role in the supply of critical medical radioisotopes, both domestically and internationally.

On November 19, 2015, the NRC requested additional informationi and clarification regarding the proposed lic~nse amendment request in the form of fourteen (14) questioris. Those questions, and MUJRR's responses to those questions, including sujlporting documentation, are attached. Also attached, as Attachment No. 14, are the newly proposed and revised TS pages.

If there are questions regarding this request, please contact me at (573) 882-5319. I declare under penalty of perjury that the foregoing is true and correct.

1513 Research Park Drive Columbia, MO 65211 Phone: 573-882-4211 Fax: 573-882-6360 Web: www.murr.missouri.edu Fighting Cancer with Tomorrow's Technology

ENDORSEMENT:

Sincerely, Reviewed and Approved John L. Fruits Ralph A. Butler, P.E. state of I "'t!'J1 A}

Reactor Manager Director County of *a,2'l JACUELNE

. BHM nd s~ mt01ob9refoi~tiii xc: Reactor Advisory Committee STATE OF MISSOURI aeelr mN [*Di Commissioned for Howard County c)~~,o8yPbl Reactor Safety Subcommittee My Commission Expires: Matrch 26, 2019 FMyCommjssNo E.xpi$e: Mdaic 28, 2019 Dr. Garnett S. Stokes, ProvostComsin#5640 Dr. Mark McIntosh, Vice Chancellor for Research, Graduate Studies and Economic Development Mr. Alexander Adams Jr., U.S. Nuclear Regulatory Commission Mr. Geoffrey A. Wertz, U.S. Nuclear Regulatory Commission Mr. Johnny Eads, U.S. Nuclear Regulatory Commission

References:

1. MicroShield 8.02 - Computer program used to estimate dose rates due to a specific external radiation source

2. Isotopes Technologies Dresden GmbH Document - "Targetcontainer-ITD-02-l1519-00_000000-PDF_2013.12.18"

3. StandAct - MURR spreadsheet program designed to perform standard activity calculations

4. Isotopes Technologies Dresden GmbH Document - "A 12-021_IMU-J131lQuotation_2013 18"

5. COMPLY Computer Code - Screening tool for evaluating radiation exposure from atmospheric releases of radionuclides

6. Federal Guidance Report FGR No. 11, "Limiting Values of Radionuclide Intake And Air Concentration and Dose Conversion Factors For Inhalation, Submersion, And Ingestion"

7. International Commission on Radiological Protection ICPR Publication 30, "Limits for Intakes of Radionuclides by Workers"

8. U.S. Nuclear Regulatory Commission Regulatory Guide 1.4, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Pressurized Water Reactors"

9. Oak Ridge National Laboratory ORiNL/TM-6607, "A Literature Survey of Methods to Remove Iodine from Off-Gas Streams Using Solid Sorbents," Jubin, R. T., March, 1979

10. American Society for Testing and Materials ASTM D3803, "Standard Test Method for Nuclear-Grade Activated Carbon" (R20 14)

11. U.S. Nuclear Regulatory Commission Regulatory Guide 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants" (September 2012, Rev. 4) 2 of 62

12. U.S. Nuclear Regulatory Commission Regulatory Guide 1.140, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Normal Atmospheric Systems in Light-Water-Cooled Nuclear Power Plants" (June 2001, Rev. 2)

13. MUIRR Technical Specifications

14. MURR Reactor Utilization Request 440, " * - To Produce I-131"

15. Institute of Environmental Sciences IiES-RP-CC-008-84, "Recommended Practice for Gas-Phase Adsorber Cells"

16. American National Standard ANSI/ANS-15.1-2007, "The Development of Technical Specifications for Research Reactors"

17. MUIRR Emergency Plan

18. MURR Emergency Plan Implementing Procedures (TOC-17)

19. MUJRR Good Manufacturing Procedure GMP-PRC-5 04, "Iodine Response Procedures" Attachments:

1. MicroShield 8.02 Analysis - MURR Transfer Cask Dose

2. MicroShield 8.02 Analysis - ITD Transfer Cask Dose

3. MicroShield 8.02 Analysis - BHI-C and PHC Doses

4. MicroShield 8.02 Analysis - DHC Dose

5. MicroShield 8.02 Analysis - HIHC Waste Dose

6. MicroShield 8.02 Analysis - Type B Safekeg-HS Model 3977A Shipping Cask Dose

7. MicroShield 8.02 Analysis - PHC 150 Curie Distributed 1- 131 Dose

8. MicroShield 8.02 Analysis -PHC 150 Curie 1-131 Dose

9. MicroShield 8.02 Analysis - PHC U Dose

10. MicroShield 8.02 Analysis - Ductwork Dose

11. MicroShield 8.02 Analysis - Filter Banks

12. MURR Drawing No. 1125 (Sheet 5 of 5), "MIB East Addition Exhaust Schematic"

13. Map of MUJRR Site - Emergency Planning Zone and Site Boundaries

14. Newly Proposed and Revised Technical Specification Pages 3 of 62

1. The amendment request appears to contain a numbering discrepancy as it contains two Sections numbered 6.0O, and Sections 5.1 and 5.2 follow after Section 6.0O. Indicate if the second occurrence of Section 6.0 should be numbered Section 7.0, and ifSections 5.1 and 5.2 should be numbered 6.1 and 6.2, or advise ifotherwise.

Yes, there is a numbering discrepancy in the original license amendment request. Sections 5.1 and 5.2 should be Sections 6.1 and 6.2, respectively. The second Section 6.0 should be Section 7.0.

The following are the correct Sections and Titles:

6.1 Dose Consequences in the Restricted Area 6.2 Dose Consequences in the Unrestricted Area 7.0 Comparison to Current Fueled Experiment Technical Specifications

2. NUREG-1537, "Guidelinesfor Preparingand Reviewing Applications for the Licensing of Non-Power Reactors," Part 1, Section 11.1.1, "Radiation Sources," provides guidance that licensees shouldprovide conservative estimates of external radiationfields in occupied or accessible areas.

a. For normal operation of the proposed experiment, provide estimates of external doses to personnel that will occur during movement of irradiatedtargetsfrom the irradiationposition to the handling hot cell (HHC).

The transfer process from the irradiation position to the Handling Hot Cell (HiHC) is performed in two (2) steps. First, an in-house MURR transfer cask, a versatile, robust cask used to move a variety of irradiated targets within the facility, is used to move the irradiated targets from the reactor pool to hot cell HC-0 1, which is located in the Laboratory Building basement. There the target is removed from the MURR transfer cask and placed into an Isotopes Technologies Dresden GmbH (ITD) transfer cask specifically designed to mate with the bottom of the IHHC. The ITD transfer cask is then moved from HC-0 1 to the HIHC, which is located in the Iodine-i131 Processing Area (Room 299U). Shielding calculations are based upon nominal, best estimates of radioactivity.

Using the computer program MicroShield 8.02 (Ref. 1), the dose rates at the surface and at a distance of 1 meter (3.28 fi) from the transfer casks were calculated. The in-house MURIR transfer cask contains 5 inches (12.7 cm) of lead in the radial direction from the target. Dimensions for the ITD transfer cask come from ITD document "Targetcontainer-ITD-02-1519-00_000000-PDF_2013.12.18" (Ref. 2) whose primary shield is 6 inches (15.24 cm) of lead. Isotopic abundances of 1-131, all isotopes and sodium-24 from the activation of the aluminum encapsulation material were included in the source term description in MicroShield. The and aluminum isotopes were calculated using StandAct (Ref. 3) and the Bateman equation assuming four (4) targets irradiated at flux of for followed by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of decay. The 1-131 activity was assumed to be per target, or total for four (4) targets.

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The dose on the surface of the MUIRR transfer cask was calculated to be 141 mR/hr and at 1 meter (3.28 ft) to be 3.0 mR/hr (Attachment 1). The ITD transfer cask has a surface dose rate of 30 mR/hr and 0.8 mR/hr at 1 meter (3.28 ft) (Attachment 2). Assuming that staff would be an average of 1 meter (3.28 ift) from the source for approximately 15 minutes each, this results in doses of 0.75 mIR and 0.2 mR for the two casks, or a total dose to personnel of approximately 1 mR.

Reference 3: StandAct is an abbreviated term used at MUIRR to indicate a spreadsheet program designed to perform standard activity calculations. These calculations use the general form of the standard activity equation:

A =N cr4)b(1-e-XT) where, A = activity (Curies);

N = #of atoms; ay neutron absorption cross section (barns);

4) neutron flux (rdcm 2/s);

2* = decay constant (s-l);

T = irradiation time (seconds);

and can include the decayed activity term (e-*t) where t =decay time post irradiation (seconds).

The neutron absorption cross sections can include the different energy classifications of thermal, epithermal (resonance), and fast. These absorption cross sections are usually referenced from the most current edition of the Nuclides and Isotopes - Chart of the Nuclides but other references may also be utilized if deemed appropriate.

b. For normal operation of the proposed experiment, provide estimates of external dose rates in accessible areas near the HCC, the processing hot cell (PHC), and the dispensing hot cell (DHC,). Provide estimates of the timefr'ames over which these dose rates will exist.

Normal operations will involve four (4), targets which will typically be processed at approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months post irradiation. All targets would reside in the Handling Hot Cell (HIHC) at one time and then moved individually to the Processing Hot Cell (PHC) for processing.

Processing could take up to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months for the four (4) targets. Subsequently, all resulting 1-131 product would be moved to the Dispensing Hot Cell (DHC). Shielding calculations are based upon nominal, best estimates of radioactivity.

The ILHC and the PHC have 200 mm (7.87 in) of lead on all sides. Since processors will be present on the front side of the cells for the longest period of time, the dose to these individuals was calculated using MicroShield at a position 0.5 meters (1.64 ift) from the front face of either the IHHC or the PHC. The resulting dose rate is estimated to be 0.09 mR/hr with all four (4) targets in the hot cell (Attachment 3).

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For the DHC, the lead shielding is 100 mm (3.94 in) on all sides. In the case of the HIHC and the PUC, the dose is driven by the 774 (50%) and 852 keV (27%) gammas from *, thus the additional shielding. For the DHC Micro Shield calculation the source represents only the processed 1-131. The dose rate was again calculated at 0.5 meters (1.64 fi) from the front face and is estimated to be 0.09 mRihr for the I-131 activity from all four (4) targets (Attachment 4).

Assuming eight (8) hour shifts split with six (6) hours in front of the I-IHC and the PHC and two (2) hours in front of the DHC, the total dose per week would be 0.72 mR.

The interior dimensions of the HHC, PHC and DHC, taken from ITD document "A12-021_MU-J131 Quotation_2013-09-18" (Ref. 4), are 1200 mm (47.24 in) in depth, 1600 mm (62.99 in) in height, 1500 mm (59.06 in) in width, with 200 mm (7.87 in) of lead on the processor side of the HIHC and the PHC and 100 mm (3.94 in) for the DHC. The geometry in MicroShield assumed a point source with the source approximately two-thirds of the way back in the cell (i.e., 800 mam),

200 mm (7.87 in) or 100 mm (3.94 in) of lead depending upon the cell, and dose points at both the front face and 500 mm (19.69 in) from the front face (assumed position of the processor). The radioisotope activities were taken from StandAct and assumes four (4), targets irradiated at a flux of for followed by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of decay. The I-131 activity was assumed to be per target or total. MicroShield predicts 0.2 mR/hr on the surface and 0.09 mR/hr at 0.5 meters (1.64 ft) for the I-HC and the PHC (Attachment 3). For the DHC, the doses are 0.21 mR/hr on the surface and 0.09 mR/hr at 0.5 meters (1.64 ft)

(Attachment 4).

Note: This calculated dose is consistent with scale up runs where the measured maximum dose rate on the face of the HIHC and the PHC was in the 0.006 to 0.0 15 mR range for a single, 20 to 30 Curie target.

c. Provide estimates of the external dose ratesfrom 1-131 processing waste stored in the HHC and PHC.

The long-lived isotopes (t112 > 15 days) include * , * , * ,

and *. For these isotopes, the equilibrium activity can be calculated from the "production" of these isotopes per week (i.e., activity added to the waste inventory per week), divided by the decay constant. These values were calculated assuming nominal radioactivities. This calculation also assumes that no waste material is ever removed from the 1I-IG. The only significantly abundant and energetic gamma from these isotopes is 159 keV (84%) for * . also has the largest equilibrium activity of 657 Guries, so it dominates the dose.

MicroShield was used to calculate the dose at 0.5 meters (19.69 in) from the exterior of the HI-I with equilibrium activities of these five (5) isotopes in waste cans placed in the middle of the hot cell. The resulting dose rate was 2.7E-6 mR/hr (Attachment 5). Thus, the dose rate from waste is dominated by the short-lived isotope (30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ), which is 0.09 mR/hr at the time 6 of 62

of processing (see response to Question 2.b) and thus is decaying over the next few days post process.

Target activities were taken from StandAct for a target irradiated at a flux of followed by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of decay. All isotopes with half-lives greater than 15 days were included.

The calculation of equilibrium activities is given by the equation A,, = AI[u, where .A is the rate at which activity is "produced" each week in units of Curies/day introduced into the waste stream and the decay constant is in 1/day.

d. For normal operation of the proposed experiment, provide estimates of external doses to personnel that will occur during handling of the final product solutionfollowing its removal from the DHC.

The final product solution is first loaded into a shipping container insert within the Dispensing Hot Cell (DHC) which is then subsequently loaded into a depleted uranium (DU) shipping containment vessel (CV) coupled directly to the bottom of the DHC. The CV is part of a U.S. Department of Transportation (DOT) and U.S. Nuclear Regulatory Commission (NRC) approved shipping cask (Type B Safekeg-HS Model 3977A). As noted in the response to Question 2.b, there is essentially no dose (0.09 mRibr) to the processors when the product solution is in the hot cell. For the product solution in the CV, MicroShield calculations predict 0.47 mR/hr at 0.5 meters (19.69 in) from the surface (Attachment 6). Assuming a 15-minute operation in close proximity (0.5 m) to the CV results in a personnel dose of 0.12 mR. For this calculation, the 1-131 activity in the CV is assumed to be a nominal at time of shipment due to the decay of 1-131 between the time of processing and shipping.

It was assumed that a maximum of two vials, each containing of 1-131 for a total of *

, would be placed in the insert. The MicroShield calculation uses the Safekeg-HS Model 3977A CV dimensions specified in Croft's "03 Licensing drawings" document - the primary shield being 4.765 cm (1.88 in) of DU. The thin-walled stainless steel (SS) insert was modelled not accounting for the effect of the SS. A poly shim was assumed to hold the vial in place. If the Tungsten insert was used then the dose would be even less.

e. Discuss the compliance of the values providedfor items a. through d., above, with the limits in Title 10 of the Code ofFederalRegulations (JO CFR) Part20.

From the responses to Questions 2.a through 2.d, the following dose estimates were determined for processing four (4) targets. Since only one processing day per week will typically be undertaken, these represent weekly doses.

Question 2.a: Transport of targets to the HIIC 1.0 mRem Question 2.b: Operator dose during processing 0.72 mRem 7 of 62

Question 2.c: Waste disposal in the EI-IC 0.0 mRem Question 2.d: Product solution handling 0.12 mRem Assuming 50 working weeks per year, MUIRR processing personnel will receive dose from the transportation of the targets of 1.0 x 50 =50 nmRem. This is likely spread over several individuals, but a single individual could conservatively receive this maximum hypothetical dose.

I-131 processing personnel will be involved in the remaining activities resulting in 0.84 x 50 = 42 miRem per year. Four (4) processing personnel could theoretical obtain this dose. All expected annual doses are significantly below the limits in 10 CFR 20.

3. NUREG-1537, Part 1, Section 11.1.1.1, "Airborne Radiation Sources," provides guidance that licensees should estimate the release of airborne radionuclides to the environment during normal operation, and should use these releases to determine consequences in the offsite environment.

Section 2.0 of the amendment request states that experiments have shown that less than 10 microcuries of Iodine-i31 (1-131) could escape from the dry-distillation process system "when scaled to a weekly maximum activity process."

a. Provide a basis or explanationfor the limit of 10O microcuries of 1-131.

Consideration of the results from several multi-Curie, suggest that containing the maximum feasible fraction of the 1-131 activity in the Processing Hot Cell (PHC) is the most effective approach to minimizing the release of 1-131 to the environment. To be clear, this containment approach seeks to sequester the 1-131 inventory in discrete traps and filters within the PHC and minimize release to the PHC itself even though there are multiple triethylenediamine/potassium iodide (TEDA/KI) impregnated charcoal filters within and integral to the PHC designed to trap any I-131 that is not collected in the product-collection traps.

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~is distributed to the PHC to be captured by the TEDA/KI impregnated charcoal filters in the PEC and downstream from the PEC.

Based on the results of several multi-Curie, performed prior to April 2015 with the PHC in the as-installed configuration, a 3-component iodine trap was designed to be used within the FEC to provide enhanced capture and retention of the I-131 not captured by the two (2) product-collection traps. The objective for this 3-component trap was to reduce discharge of I-131 into the full volume of the PHC; and instead capture it in discrete modules that would have active flow only during that time period constituting the actual and subsequent target cool-down period on the order of 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of those days when processing occurs. Consequently, these modules are static relative to air flow over 90% of the time which reduces desorption of the 1-131 inventory not captured by the product-collection traps. The experiment described in subsequent paragraphs incorporated a prototype of the 3-component trap on the processing-line exhaust within the confines of the FEC but was not installed on the exhaust line.

A full-size target ( ) was irradiated in graphite reflector position "El" (at a height of 15 to 19 inches) for 140.00 hours0 days 0 hours 0 weeks 0 months ending on April 27, 2015 at 00:20 and subjected to in two batches during the week of April 27, 2015. The 1-131 activity inventory and balance are summarized in Table 1 below with all activities decayed to May 1, 2015 at 17:00. The target was processed in two (2) batches. The first process used approximately 20% of the crushed target and was started on April 28, 2015 at 11:20 and concluded at 12:45. The second process, using approximately 80% of the target, started on May 1, 2015 at 10:20 and concluded at 12:50.

The predicted 1-131 activity in this target is based on a hybrid model derived from the harmonization of theoretical production calculations and measured production factors. It takes into account production from both activation products *j and ) and their decay pathways to I-131. In addition to the relevant nuclear data (thermal and resonance neutron fluxes, half-lives and neutron-capture cross sections), the neutron attenuation by the naturally-abundant, high-purity target is also considered.

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Table 1 - Predicted I-131 Activity; Measured I-131 in the Product-Collection Traps; and Measured I-13 1 Distributed in the 3-Component PHC Trap (all activities are corrected to May 1, 2015 at 17:00)

CmoetDsrpon 1-131 Activity 1-131% of 1-131% of Copnn/esrpin(mCi) Total Measured Total Predicted Predicted I- 13 1 produced 24,664 101.295 100.000 Measured I-131 activities Product-collection traps 24,300 99.800 98.524 3-component PHC trap installed on the exhaust from the product-collection traps Aqueous chemical diffuser2010.8002 trap __________

AGX-2 filter 28.39 0.116 0.115 Aqeu hmclbbl- 0.00186 7.64E-06 7.54E-06 counter trap __________________

Total I-131 measured 24,348.60186 100.000 98.762 The 3-component trap installed on the processing-line exhaust from the product-collection traps consists of, in sequence: (1)

~into which the exhaust air flow from the product-collection traps is introduced through a 0.5 micron diffuser. (2) A silver zeolite filter (AGX-2, 16-40 mesh, silver = 40.3 wt%) cartridge having a diameter of 2.25 inches and a bed depth of 1 inch (HI-Q Environmental Products Inc., San Diego, CA). (3) into which the exhaust air flow from the AGX-2 cartridge is introduced through a tube having an inner diameter of 0.125 inches. The silver zeolite cartridge is included specifically to improve the capture and retention of methyl iodide- 131 (CH31-1 31) through its conversion to the thermodynamically stable and insoluble AgI-1 31.

After a suitable decay time, the 3-component trap was removed from the PHC and the 1-131 activity was quantified in each component by high-resolution gamma-ray spectroscopy resulting in the measured activities given in Table 1 above. In addition, the AGX-2 filter was carefully subdivided into 10 more-or-less equal layers and the 1-131 activity was quantified in each individual layer. Of the 28.39 mCi of 1-131 captured by the AGX-2 filter, 28.33 mCi (99.78%) was isolated on the first 9 mm (of 25 mm) - See Figure 1 below. Only 0.00186 mCi of 1-131 was measured in the aqueous trap downstream from the AGX-2 filter.

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1-131 activity (mCi) at 5/1/2015 on AGX cartridge total 1-131 activity per AGX layer plotted at the layer midpoint (total i-131 activity on entire AGX cartridge =28.395 mCi) 10-C-

E 0

0.1 03 0.01-0.001 0 5 10 15 20 25 cartridge depth (mm) from inlet (left) to outlet (right) 0 total layer activity (mCi) plotted at midpoint Figure 1 -1I-131 Activity on AGX-2 Filter Cartridge in Discrete Sections After the is complete and the has returned to the ambient PHC temperature (room temperature) the flow through the product-collection traps and 3-component trap is discontinued. The is evacuated through a separate exhaust line to an aqueous bubble trap. Flow through this exhaust line is also discontinued when room temperature is reached in the PHC. At this point the product traps are drained and rinsed and the I-131 is isolated in a sealed vial.

In this experiment there was good agreement between the predicted I-131 activity (24,664 mCi) and the cumulative total measured from the production-collection traps and the 3-component trap (24,349 mCi). The magnitude of the negative balance (315 mCi), approximately 1.3%, can be entirely accounted for by the uncertainties in these two activities (predicted and measured).

Therefore, it is impossible to differentiate the 1-131 activity that was not captured by the combination of the product-collection traps and the modules making up the 3-component trap. The last module (the aqueous bubble-counter trap) of the 3-component trap had very little iodine activity (0.00186 mCi); however, this is not a high-efficiency trap, consequently some 1-131 may have passed through. On the other hand, the component immediately upstream from the bubble-counter trap, the silver zeolite filter, is a high efficiency filter and the penetration of 1-131 through 11 of 62

this cartridge was only 9 of the 25 millimeters where 99.78% of the 1-13 1 on this cartridge was found. Furthermore only microgram quantities of 1-131 were found on the last silver zeolite segment-layer indicating only microcurie levels of 1-131 passed into the aqueous bubble counter.

These findings indicate that only a negligible amount of 1-131 activity was exhausted through the processing-line exhaust into the full volume of the PHC. The discharge of some 1-131 to the full volume of the PHC from the exhaust line through its aqueous bubble-counter trap is likely in this experiment. Unfortunately, the 1-131 activity in this bubble-counter solution was not measured and no other direct method of assessing the activity discharged to the PHC by this route was available in this experiment.

The impact of this experiment on the release of 1-131 to the environment through the MURR ventilation exhaust stack was tracked for several days by the facility Stack Radiation Monitor - see Figure 2 below. There were small but measurable increases observed on the iodine monitor that corresponded to 1-131 releases to the environment following the two processes completed during the week of April 27, 2015. The first process using approximately 20% of the target started on April 28, 2015 at 11:20 and resulted in a peak on the Stack Radiation Monitor approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months later. The 1-131 concentration in the 24-hour period in which this peak was centered was 6.69E-12 pxCi/mi corresponding to 8.3 1iCi. The second process using approximately 80% of the target started on May 1, 2015 at 10:20 and also resulted in a peak on the Stack Radiation Monitor approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months later. This peak, centered in a 24-hour period had an 1-131 concentration of 1 .38E-1 1 pCi/ml corresponding to 17.1 1iCi. If this target had been processed in a single

~of the entire 24.349 Curies, the 1-13 1 concentration at the point of release to the environment averaged over a 24-hour period would have been 2.05E- 11 pCi/nmL (10.25% of the 10 CFR Part 20 limit) and corresponding to 25.4 jtCi of 1-131.

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3-component trap used in the scoping experiment previously discussed; and to also include this trap on the exhaust line in addition to the processing-line exhaust to further trap and retain additional 1-131 in discrete modules in the PHC and avoid releasing it to the full-volume of the PHC.

Specifically, the 3-component trap used on the product exhaust line during the processing discussed above has been redesigned to include a second AGX-2 filter cartridge in series with the existing cartridge and this identical 3-componet trap will be installed on the exhaust line as well.

Based on our measurements, approximately 8.2 fICi was exhausted to the aqueous bubble trap from the AGX-2 filter. Extrapolating from this 24.349 Ci process to the maximum-activity process of U increases the activity exhausted from the AGX-2 filter to 18.5 jiCi. The AGX-2 filters are rated at an efficiency of 95.2% if all the activity is in the form of CH3 I-1 311 and greater than 95%

for any molecular 1-131. Taking this into account, the release of 1-131 to the PHC from a process is estimated at approximately 1 jiCi from the processing-line exhaust and less than 1 1tCi from the exhaust line. This extrapolation does not assign any 1-131 trapping efficiency to the aqueous bubble-counter trap that is downstream from the AGX-2 filters.

In summary, an 1-131 activity balance based on the calculated 1-131 activity produced and that is captured in the product-collection traps and the 3-component processing-line exhaust trap account for all of the 1-131 activity within the uncertainties in the prediction model and experimental measurements. The introduction of aqueous chemical traps and a silver zeolite filter to capture and retain the 1-131 activity in discrete modules within the confines of the PHC does substantially reduce the release of 1-131 to the environment. Our measurements indicate that less than 5 *tCi are exhausted into the PHC when scaled to the maximum process. Certainly the processing of a single 1-131 target is currently sustainable with an 1-131 release to the environmental at less than 25% of the Part 20 limit of 2E-1 0 iiCi/ml. The planned improvements to further capture and retain the I-131 activity in the PHC are expected to allow for an increased through-put rate of maximum-activity targets.

1The 95.2% efficiency was measured using the ASTM D-3803-89 test method at a flow rate of 1.0 CFM, a temperature of 30 0C, a relative humidity of 95 +/--1%, and a methyl iodide loading of 1.75 mg/in 3. In comparison, the ambient temperature in the PHC will be <30 °C. The average outdoor relative humidity in Columbia ranges from 44% to 93%. For the conditioned air entering the PUC this range will be translated downward. The flow rate through the apparatus and 3-component trap during processing is 350 cm3/minute (0.01236 CFM). Assuming the processing of an target over a 240 minute period, the greatest (by a factor of at least 1E6) iodine source-term is the 0.5 ppm impurity in the used to fabricate the targets resulting in an iodine mass of 90 micrograms. Assuming a 2 ppm (mole fraction) methane concentration in air and a 1% yield (conservative by a factor of 10 based on our experimental results), the concentration of methyl iodide is 0.025 mg/in 3. Each of the parameters (temperature, relative humidity, flow rate, and methyl iodide concentration) that exist during the process are more favorable for methyl iodide capture efficiency compared to the conditions under which the AGX-2 filter material was certified via the ASTM D-3803-89 test method used. Consequently the 95.2% efficiency measured is conservative relative to the prevailing conditions.

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b. Provide an estimate of the maximum quantity of 1-131 that could be releasedfrom the process system to the PHC during normalprocessing of each irradiatedtarget, and the total quantity of1-131 that could be released to the PHC over a one-year period of normal operation of this experiment.

When processing a 1-131 target, the maximum release to the PHC from both the 3-component trap attached to the processing-line exhaust and the 3-component trap attached to the Iexhaust (See Figure 1 of original license amendment request) is expected to be less than 10

iCi of total 1-131 from these two outputs to the PHC. See response to Question 3 .a for discussion.

The maximum number of processes per week will be determined by what is sustainable relative to the 10 CFR Part 20 1-131 release limit of 2E-10 gCi/ml - See response to Question 3.a. Currently, and for the near term (first year of product-distribution to clients), we consider four (4) processes per week will be the upper limit. Based on four (4) processes per week of typical activity targets (1-13 1), 52 weeks per year, 10 jgCi released to the PHC per process results in a total 1-13 1 release to the PHC of 2,080 jiCi.

c. Provide an estimate of the quantities ofi1-131 released to the environment from normal processing of irradiated targets, and calculate the maximum predicted concentration of airborne1-13 1 in unrestrictedareas, as well as the timeframes over which this concentration will exist.

Case 1 - Annual Stack Release Concentration:

Facility Ventilation Exhaust Stack Flow Rate =30,500 ft3 /min 30,500 ft3/min x 2.83E+4 cc/ft3 x 60 mir/hr x 24 hr/day x 365 days/yr = 4.54E+-14 cc/yr Average Annual Stack Concentration = 2080 jiCi / 4.54E+14 cc

- 4.58E-12 giCi/ml This value only reflects the concentration of 1-131 being released from MUIRR at the ventilation exhaust stack and does not take into consideration any downstream dilution at the site boundaries.

The area within the MUIRR site boundaries is controlled by the University of Missouri.

Case 2 - Projected Maximum Release Concentration:

Assuming the activity measured and noted in the response to Question 3 .a. from one process if released over a one (1) day period as noted above, the predicted concentration over that time frame would be the following:

Facility Ventilation Exhaust Stack Flow Rate = 30,500 ft3/min 15 of 62

30,500 ft3/min x 2.83E4 cc/ft3 x 60 minihr x 24 hr/day x 1 day 11.24E+12 cc Average Stack Concentration during Time Frame = 57.4 gtCilprocess / 1.24E+1 2 cc As discussed above, the projected routine target activity of only reflects the concentration of 1-131 being released from MUJRR at the ventilation exhaust stack and does not take into consideration any downstream dilution at the site boundaries. The area within the MURR site boundaries is controlled by the University of Missouri. The above concentrations are averaged over a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period based on the peak of 1-131 released appearing approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months post-process. Note: As stated in the bases of Technical Specification 3.7 .a, "The normal short burst releases at the facility are five to ten seconds in duration and occur on average of ten times per day five days per week. The short bursts affect the concentration less than one percent when averaged over a one-day period."

d. Discuss the compliance of the values provided for item c., above, with the limits in 10 CFR Part20.

In both cases noted above, the resulting concentrations at the MUJRR ventilation exhaust stack are below the 10 CFR 20 limits for the unrestricted release of 1-131: 2E-1 0 iiCi/ml. Thus the percentage of Annual Release Limits would be:

Case 1 - % of Annual Effluent Limit at 10 ptCi Release per Process:

4.58E-12 / 2E-10 = 2.29%

Case 2 - % of Annual Effluent Limit at 57.4 pCi Release per Process:

4.63E-1l / 2E-10 =23.15%

Note: Maximum projected activity of 57.4 pCi is based on measured results without the additional exhaust trap and filtration improvements discussed in the response to Question 3 .a.

With expected improvements to the gas collection and trapping systems as noted in the response to Question 3.a, MURR is working towards reducing the effluent concentrations further as the process is developed and additional improvement opportuities can be found. Thus Case 2 noted above, should approach Case 1 over time and then go below the 1-131 levels noted in Case 1.

4. NUREG-153 7, Part 1, Section 13.1.6, "Experiment Malfunction," provides guidance that the licensees analyze the consequences of experiment failures. MURR 's license amendment request, Section 6.0O, states thatfailure of the proposed experiment could result in airborne releases of1-131, to the PHC. Section 5.1 of the amendment request provides estimates of external dose consequences in the restricted area due to 1-13 1 captured on charcoalfilters or passing through 16 of 62

ventilation systems following a release into the PHC. Section S.2 of the amendment request provides estimates of dose consequences in the unrestricted areafollowing a release of 1-131 into the PHC.

a. For an experimentfailure resulting in a release of 150 curies of airborne1-131 into the PHC, the license amendment request does not appearto consider the external dose consequences in accessibleportions of the restricted area near the PHC. Provide calculated dose rates near the PHCfor this scenario, and estimate the timeframes over which personnel will be exposed to these dose rates.

A release of 150 Curies (maximum hypothetical activity contained in a single target during an 1-131 processing evolution) in the Processing Hot Cell (PHC) would have negligible effect on external dose. The external dose during processing in the PHC is dominated by the 774 and 852 keV gammas from as given in the response to Question 2.b, resulting in a dose rate of 0.09 mR/hr. The dose from 1-131 from its predominate 364 keV gamma through 20 cm (7.87 in) of lead is several orders of magnitude below the dose from * . And whether the 1-131 is contained as essentially a point source in the *, or distributed evenly over the internal volume, has very little effect.

MicroShield calculated a distributed source dose (Attachment 7) at the position of a processor of only 2.8E-7 mRihr and 1E-6 mR/hr for a point source (Attachment 8). By comparison, the dose from (principally * )is 0.09 mR/hr (Attachment 9).

Based on these calculated dose rates, personnel may remain in the area for an extended period time.

However, if a failure of this magnitude would occur, a local evacuation of the 1-131 processing area would occur.

b. Estimates of external dose consequences in the restricted area due to 1-131 captured on charcoalfilters or passing through ventilation systems following a release of 1-131 to the PHC do not appear to include any contribution due to plating of 1-131 within the ventilation ductwork. Provide an estimated maximum dose rate in accessible areasfrom 1-131 plated in the hot cell ventilation ductwork, for the allowable combination of online/offline filters that will result in the highest dose rates.

The most probable location for dose to personnel from 1-131 plating out in the ventilation system ductwork is on top of the hot cells where the exhaust ducting exits the filter banks (Bank No. 2 and 3). This ductwork is approximately 2.5 m (8.2 ft) above the processors' heads and about 2.5 m (8.2 fi) long before it turns away from the work area. Assuming a 150 Curie airborne release (maximum hypothetical activity for a single target during an 1-131 processing evolution), two (2) filter banks operating at 99% efficiency and one (1) bank out-of-service, the 1-131 passing into the duct work is 0.0 15 Curies. Also conservatively assuming that all of the iodine deposits on this 2.5 m (8.2 ft) length of ducting, MicroShield calculates a dose rate of 0.5 mR/hr.

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In the remote chance that an individual was on top of the QC Laboratory (Room 299V) at the time of release (not an area that is routinely occupied), the distance between the ducting and the individual would be reduced from 2.5 m (8.2 ft). Assuming the same parameters as above, and assuming that the 1-131 passing into the ductwork travels from above the hot cells without deposit and then deposits totally in 2.5 m (8.2 ft) of ductwork on top of Room 299V, the dose rate at 0.5 m (1.6 ft) is 6.4 mR/hr and on contact is 40 mR/hr.

Estimated dose rates from the ductwork using were modeled using MicroShield as a line source and the dose point at the middle of the 2.5 m (8.2 ft) length of ductwork (Attachment 10). Distances of 2.5 m (8.2 ft), 0.5 m (1.6 ft) and 0.1 m (0.33 fi) [the latter representing a location on the surface of the ducting which would be 0.1 m (0.33 ft) from its center, line source] were modelled.

c. Assumptions used for some of the inputs in the dose estimates (using MicroShield, version 8.02) of external dose consequences in the restrictedarea due to 1-13 1 captured on charcoal filters are not clearly described. Describe how the filter specifications provided in Attachments 7 and 8, are translated to the "Source Dimensions," "Dose Points," and "Shields, " inputs usedfor the dose calculationsfor the following:

i. The CAMFIL filters used in FilterBanks Nos. 1, 2, and 3; and ii. The Flanders/CSCfilters used in FilterBank No. 4.

All MicroShield input decks are described below and include dose calculations for Questions 2 and 4, in addition to the modelling of the filter banks.

In the response to Question 2.a, calculating dose during the transition of lltargets from the reactor pooi to the Handling Hot Cell (HIHC), the MicroShield "Cylinder Volume - Side Shields" model was used. The source was assumed to be homogenized over the interior volume of the cask at the density of air (which conservatively neglects self-attenuation of gammas by the target itself) and cylindrical shells of shielding material were modelled around the source. The models for the MURR and ITD transfer casks are provided in Tables 1 and 2, respectively.

Table 1 - Micro Shield Model for Targets in MiURR Transfer Cask Soure Heght1.0 cm - Default for MicroShield one-dimensional calculation. The source is actually ~-10 cm tall and the cask is ~-90 cm tall.

Source Radius 5.08 cm - With assumed air density.

Source Length N/A Source Nuclides 1-131, all I isotopes and Na-24 from aluminum activation.

Lead Shield Thickness 12.7 cm (5 inches) - Per MURR specifications.

Dose Points Surface (17.8 cm) and 1 meter (117.8 cm).

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Table 2 - MicroShield Model for Targets in riD Transfer Cask 1.0 cm - Default for Microshield one-dimensional calculation. The SourceHeightsource is actually -10 cm tall and the cask is -'70 cm tall.

Source Radius 5.08 cm - With assumed air density.

Source Length N/A Source Nuclides 1-131, all fl isotopes and Na-24 from aluminum activation.

15.24 cm (6 inches) - Per lTD "Targetcontainer-ITD-02-15 19-LeadShild Tickess00_000000-PDF_2013.12.18."

Dose Points Surface (20.4 cm) and 1 meter (120.4 cm).

In the response to Question 2.b, calculating the dose to processors outside of the HHC, the Processing Hot Cell (PHC) and the Dispensing Hot Cell (DHC), the MicroShield point source model was utilized. For the HIIC and PHC, the source includes 1-131, all isotopes and Na-24 from the activation of the aluminum can (Na-24 does not actually enter the PHC, but its contribution to dose is small and is conservatively included). For the DHC only the 1-131 is used for the source. Being a point source, any target or product self-absorption has been conservatively omitted for the HHC and the PHC calculations. The target was assumed to be 80 cm (31.5) from the inside front face of the hot cell and the shielding thickness was 20 cm (7.9 in) thick. Dose points at 100 cm (39.4 in) and 150 cm (59.1 in) were used to calculate dose at the surface and at 0.5 m (1.6 ft) from the surface.

Table 3 - MicroShield Model for Dose to Processors from HI-IC and PHC Source Radius N/A - Point source assumption.

Radius to Inner 80 cm - Assumes the source is approximately two-thirds of the way Surface of Hot Cell back in the hot cell.

Source Nuclides 1-131 and all I isotopes.

20 cm - Per ITD document "A12-021I_MU-J 131_Quotation_2013 Lead Shield Thickness 1.

Dose Points Surface (100 cm) and 0.5 meter (150 cm).

For the DEC case, the source is assumed to be only 1-131 since it has been extracted from the target. The DHC shielding thicknesses is reduced to 10 cm (3.9 in).

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Table 4 - MicroShield Model for Dose to Processors from DHC Source Radius N/A - Point source assumption.

Radius to Inner 80 cm - Assumes the source is approximately two-thirds of the way Surface of Cell back in the hot cell.

Source Nuclides I- 131 10 cm - Per ITD document "A 12-021l_MUI-J131_Quotation_2013 Lead Shield Thickness 1.

Dose Points Surface (90 cm) and 0.5 meter (140 cm).

In the response to Question 2.c, calculating dose from radioactive waste stored in the HIHC, the same point source model described in Table 3 was used. The waste was assumed to be at an average distance of 50 cm (19.7 in) from the front face of the HHC and the inventory of*

isotopes assumes that the equilibrium accumulated activities exist within the HJHC.

Table 5 - MicroShield Model for Dose to Processors from Radioactive Waste in the iHHC Source Radius N/A - Point source assumption.

Radius to Inner 60 cm - Assumes the source is at an approximate average distance Surface of Hot Cell between the front and back of the hot cell.

Source Nuclides Equilibrium accumulated waste activity levels of U isotopes.

20 cm - per lTD document "A 12-021I_MU-J131 _Quotation_2013-Lead Shield Thickness 091" Dose Points Surface (80 cm) and 0.5 meter (130 cm).

In the response to Question 2.d, calculating dose to processors during product transfer, the MicroShield "Cylinder Volume - Side Shields" model was again used. The dimensions of the MIURR HS Shipping Cask Containment Vessel (CV) were taken from Croft's "03 Licensing drawings" document. This assumes a source that is 1.55 cm (0.6 in) in radius and is designated as water, a polyethylene insert (modelled as water with a density of 1.1 gm/cm 3), an aluminum inner wall of 0.44 cm (0.17 in) and 4.756 cm (1.87 in) of depleted uranium (Dig) as the primary shield.

The model neglects any other structural walls and materials between the source and the outer edge of the CV. The dose points were at 8.6 cm (3.4 in) (corresponding radius of the CV) and 58.6 cm (23.1 in) (corresponding to the dose at 0.5 in). 200 Curies of 1-131 was assumed as the source.

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Table 6 - MicroShield Model for Dose from of I-131 in MUJRR Shipping Cask CV Soure Heght1.0 cm - Default for Microshield one-dimensional calculation. The SourceHeightsource height is 10 cm.

Source Radius 1.55 cm - With assumed water density.

Polyethylene Insert 1.7 cm - Modelled as water with a density of 1.1.

Inner Wall 0.44 cm - Aluminum.

Shield 4.756 cm - Depleted Uranium.

Source 200 Ci of 1-131.

Dose Points Surface (8.6 cm) and 0.5 meter (58.6).

In the response to Question 4.a, calculating dose from a hypothetical release of 150 Curies of 1-131 into the PHC during processing, the MicroShield "Rectangular Volume" model was used. Per ITD document "A12-021_MU-J131_Quotation_2013-09-18," the hot cell dimensions are 120 cm (47.2 in) deep by 150 cm (59.1 in) wide by 160 cm (63 in) in height. A slab of lead shielding 20 cm (7.9 in) thick was placed on the side through which the dose is calculated. Dose points at the surface (140 cm or 55.1 in) and 0.5 m (1.6 fi) from the surface (190 cm or 74.8 in) were calculated.

Table 7 - MicroShield Model for Dose from 150 Curies of 1-131 Dispersed in PHC Source Length (Depth) 120 cm.

Source Width 150 cm.

Source Height 160 cm.

Shield 20 cm - Lead.

Source 150Ci ofI1-131.

Dose Points Surface (140 cm) and 0.5 meter (190 cm).

In the response to Question 4.b, calculating dose from a hypothetical plate-out of 1-131 in the hot cell ventilation system ductwork, the MicroShield line source was used. All I-131 activity (0.0 15 Curies) was assumed to be deposited in 2.5 m (8.2 ft) of ducting. Doses were calculated at 10 cm (3.9 in) radius (corresponding to the radius of the ventilation ducting), 50 cm (19.7 in) and 250 cm (98.4 in) from the source.

Table 8 - MicroShield Model for Dose from 0.0 15 Curies of I-131 Deposited on the Ductwork Source Radius N/A - Line source assumption.

Source Length 250 cm.

Shield N/A Source 0.015 Ci of I- 131.

Dose Points Surface (10 cm), 50 cm and 250 cm.

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In the original license amendment request, doses from the CAMFIL charcoal filters were calculated. In order to most accurately model the geometry, the predefined annular-cylinder source was selected within MicroShield. However, upon review of the input data it was discovered that values of millimeters were inserted as values of centimeters thus unintentionally skewing the calculated exposure rates. An updated version of the exposure rates due to shine from the filters at 1 foot (30.5 cm) (Tables 6, 7 and 8 in the original license amendment request) have been provided below using the assumptions in Table 9 for the "Source Dimensions" inputs for both the CAMFIL and the Flanders/CSC charcoal filters. Also, updated MicroShield outputs are included in this response as Attachment 11.

Table 9 - MicroShield Source Dimensions for the Filter Banks Description (i) Filter Bank No. 1 (i) Filter Bank No. 2 & 3 (ii) Filter Bank No. 4 1.0 cm - The height of 1.0 cm - The height of the 1.0 cm - The height of the filter is approximately filter is approximately 14 the filter is 16.8 cma; however, 1.0 cm; however, 1.0 cm was approximately 3.4925 cm was used to provide a used to provide a cm; however, 1.0 cm conservative result and conservative result and was used to provide a account for any non- account for any non- conservative result and Height uniform buildup of uniform buildup of account for any non-activity on the filter activity on the filter rather uniform buildup of rather than making the than making the activity on the filter assumption activity is assumption activity is rather than making the distributed evenly distributed evenly assumption activity is throughout. throughout, distributed evenly throughout.

30.0 cm - From the Widt N/AN/Aspecification document Width /A N/APB-2003-l1103 the filter width is 12 inches.

30.0 cm - From the specification document PB-2003-1103 the filter LenghN/ N/Adepth which is defined as length in MicroShield is 12 inches.

4.0 cm - From reference 2.9 cm - From reference 3603.40.03 specification 3603.30.00 specification Iner sheet the inner radius of sheet the inner radius of Cylinder the annular charcoal filter the annular charcoal filter N/A Radius is 4 cm [(1 8-5-5)/2 = 4]. is 2.9 cm [(1 3-3.6-3.6)/2 =

2.9].

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0.0 cm - From the filter 0.0 cm - From the filter specification sheet specification sheet Inner perforated stainless steel perforated stainless steel Cylinder casing is present casing is present however, N/A Thickness however, these these dimensions are dimensions are ignored ignored for shielding for shielding purposes. purposes.

0.0 cm - From the filter 0.0 cm - From the filter specification sheet specification sheet Outer perforated stainless steel perforated stainless steel Cylinder casing is present casing is present however, N/A Thickness however, these these dimensions are dimensions are ignored ignored for shielding for shielding purposes. purposes.

5.0 cm - From reference 3.6 cm - From reference Source 3603.40.03 specification 3603.30.00 specification N/A sheet the depth of the sheet the depth of the carbon bed is 5.0 cm. carbon bed is 3.6 cm.

0.0 cm - From the filter 0.0 cm - From the filter specification sheet specification sheet Outer perforated stainless steel perforated stainless steel Cylinder casing is present; casing is present; N/A Thickness however, these however, these dimensions are ignored dimensions are ignored for for shielding purposes. shielding purposes.

Upon review of the inputs used to determine the "Dose Points," the following coordinates have been used for dose points listed in Table 10 to ensure a conservative result.

Table 10 - Micro Shield Dose Points for the Filter Banks (i) Filter Bank No. 1 (i) Filter Bank No. 2 & 3 (ii) Filter Bank No. 4 Dose point #1 represents the 0.0 - Dose point #1 represents Dose point #1 represents the exposure rate values at the the exposure rate values at the exposure rate values at the (49,0,0) coordinate which (46.5,0,0) coordinate which (30,30,15) coordinate which corresponds to a 30 cm corresponds to a 30 cm corresponds to a centered 30 distance from the outer distance from the outer cm distance from the outer surface of the filter shielding. surface of the filter shielding. surface of the filter shielding.

See Figure 1 for a graphical See Figure 2 for a graphical See Figure 3 for a graphical representation of the representation of the representation of the MicroShield model. MicroShield model. MicroShield model.

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Dose Point "IVoid Air Z Lead Shiel Figure 1 - Graphical Representation of the MicroShield Model for Filter Bank No. 1 Dose Point Z Lead Sield Figure 2 - Graphical Representation of the MicroShield Model for Filter Banks No. 2 and 3

\ Dose Point Z \ Lead Shield Source Figure 3 - Graphical Representation of the MicroShield Model for Filter Bank No. 4 In the "Shields" table of the MicroShield outputs is a listing of inputs for the shield dimension, material, and density. The assumptions in Tables 11 through 13 were made for the selection of each of these inputs of each shield.

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Table 11 - MicroShield Shield Assumptions for (i) Filter Bank No. 1 Shield N Dimension Material Density 4 cm - From reference Air - The inner volume 0.00122 g/ cm 3 - The 3603.40.03 specification sheet of the annular charcoal density of air at the inner radius of the annular filter is modeled as air. standard temperature charcoal filter was determined This is consistent with and pressure was to be 4 cm via the following reality, populated by default equation: within Micro Shield Cylinder which uses Radius OD - 2 (Charcoal Depth) ANSIANS-6.6.1-2 1979.

Or 18 -2(5) 2 204.204 cm 3 - The total Carbon - Was selected 1.8 g/ cm 3 - The volume of the source from a predefined density of charcoal geometry calculated by material list within the was selected from the Micro Shield from the input available materials in Chart of Nuclides, l6u*

geometry parameters. This MicroShield. Carbon edition.

volume is used to calculate a most similarly specific activity in the "Source represents the atomic Source Input" table. Proof of this number (Z-value) of value can be seen by the charcoal.

following equation:

wr~,) 2j1 -2 Or gr(9) 2J1- yr(4) 2 1 ---204.204 The value for a transition Air - Is used by default 0.00 122 g/ cm 3 - The distance between the source by MicroShield for all density of air at geometry and Shield 5 is null transition space, standard temperature because it is assumed these However, for this and pressure was Transition two objects are directly geometry the value populated by default adjacent to each other. does not factor into the within MicroShield calculation, which uses ANSI/ANS-6.6. 1-1979.

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10 cm - The total thickness of Lead - was selected 11.35 g/ cm 3 - The the lead shield adjacent to the from a predefmed density of lead was charcoal filter. material list within the selected from Chart of available materials in Nuclides, 16 th edition.

Shield 5 MicroShield. Lead identically represents the atomic number (Z-value) of the lead used in the shield.

MicroShield by default Air - Is used by default 0.00 122 g/ cm 3 - The assigns an additional shield by Micro Shield for all density of air at region with air as the material air gaps between the standard temperature when there is a gap between outermost shield and and pressure was the final shield and the dose the dose point, populated by default Air Gap point. MicroShield does not within MicroShield display this value but it which uses corresponds to 30 cm which ANSI/ANS-6.6.1-represents a 1 foot exposure 1979.

rate measurement.

Table 12 -MicroShield Shield Assumptions for (i) Filter Banks No. 2 and 3 Shield N Dimension Material Density 2.9 cm - From reference Air - The inner 0.00 122 g/ cm 3 - The 3603 .30.00 specification sheet the volume of the density of air at inner radius of the annular annular charcoal standard temperature charcoal filter was determined to filter is modeled as and pressure was be 2.9 cm via the following air. This is populated by default equation: consistent with within Micro Shield Cylinder reltwhich uses Radius OD - 2(Chiarcoal;Depth) reality..6.1 2 1979.

Or 13 -2(3.6)

- 2.9' 2

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106.311 cm 3 - The total volume Carbon - Was 1.8 g/cm3 - The of the source geometry calculated selected from a density of charcoal by MicroShield from the input predefmed material was selected from the geometry parameters. This list within the Chart of Nuclides, 16th volume is used to calculate a available materials edition.

specific activity in the "Source in MicroShield.

Input" table. Proof of this value Carbon most Source can be seen by the following similarly represents equation: the atomic number (Z-value) of

.- u*r*

2 T, 2h-- W(1ij ,'*r) 2) charcoal.

Or ir(6.5) 2 1 - ir(2.9) 2 1 = 1.06.311 The value for a transition distance Air - Is used by 0.00122 g/ cm 3 - The between the source geometry and default by density of air at Shield 5 is null because it is MicroShield for all standard temperature assumed these two objects are transition space. and pressure was Transition directly adjacent to each other. However, for this populated by default geometry the value within MicroShield does not factor into which uses the calculation. ANSJIANS-6.6.1-1979.

10 cm - The total thickness of the Lead - was selected 11.35 g/ cm 3 - The lead shield adjacent to the from a predefined density of lead was charcoal filter. material list within selected from Chart of the available Nuclides, 16 u* edition.

materials in Shield 5 Micro Shield. Lead identically represents the atomic number (Z-value) of the lead used in the shield.

MicroShield by default assigns an Air - Is used by 0.00 122 g/ cm 3 - The additional shield region with air default by density of air at as the material when there is a MicroShield for all standard temperature gap between the final shield and air gaps between the and pressure was Air Gap the dose point. MicroShield does outermost shield and populated by default not display this value but it the dose point. within MicroShield corresponds to 30 cm which which uses represents a 1 foot exposure rate ANSIIANS-6.6.1-measurement. 1979.

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Table 13 - Micro Shield Shield Assumptions for (ii) Filter Bank No. 4 Shield N Dimension Material Density 900.0 cm3 - The total Carbon - was selected 1.8 g/ cm3 - The volume of the source from a predefmed density of charcoal geometry calculated by material list within the was selected from the Micro Shield from the input available materials in Chart of Nuclides, 16m geometry parameters. This MicroShield. Carbon edition.

volume is used to calculate a most similarly represents specific activity in the the atomic number (Z-Source "Source Input" table. Proof value) of charcoal.

of this value can be seen by the following equation:

Len~gth x Wz~dth x tieig~ht Or 30 x30 x1 = 900.0 0.635 cm - The total Lead - was selected from 11.35 g/ cm 3 - The thickness of the lead shield a predefined material list density of lead was adjacent to the charcoal within the available selected from Chart of Shed1 filter. materials in Micro Shield. Nuclides, 16m edition.

Shield 1Lead identically represents the atomic number (Z-value) of the lead used in the shield.

MicroShield by default Air - Is used by default 0.00122 g/ cm 3 - The assigns an additional shield by Micro Shield for all air density of air at region with air as the gaps between the standard temperature material when there is a gap outenmost shield and the and pressure was between the final shield and dose point, populated by default Air Gap the dose point. MicroShield within MicroShield does not display this value which uses but it corresponds to 30 cm ANSI/ANS-6.6. 1-which represents a 1 foot 1979.

exposure rate measurement.

Tables 14, 15 and 16 below are updates to Tables 6, 7 and 8, respectively, from the original license amendment request based on the assumptions stated above.

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Table 14 - 150 Curie Target Exposure Rates Due to Shine from Filters at 1 Foot Filter Bank Filter Bank Filter Bank jFilter Number of Filters and No. 1 No. 2 No. 3 j No.Bank 4 Decontamination Factor(mir Mitigated (4 of 4 filters - DF 1000) 2.44E-0 1 3 .20E-04 3.20E-07 1.26E-05 Mitigated (3 of 4 filters - DF 1000) 0.00E+00 3.20E-01 3.20E-04 1.26E-02 Mitigated (4 of 4 filters - DF 100) 2.42E-01 3.17E-03 3.17E-05 1.25E-02 Mitigated (3 of 4 filters - DF 100) 0.00E+00 3.17E-0l 3.17E-03 1.25E+00 Table 15 - Target Exposure Rates Due to Slime from Filters at 1 Foot Number of Filters and Decontamination Factor(mir Filter Bank No. 1 I Filter Bank No. 2 jFilter Bank IFilter Bank No. 3 J No. 4 Miiatd(4o 4fltr -D 10 _ _.3E0 1.8E-0 1.8E )____2-0 Mitigated (4 of 4 filters - DF 1000) 0.43E+00 1.88E-01 1.88E-04 7.42E-03 Mitigated (3 of 4 filters - DF 1000) 1.42E+01 1.86E-03 1.86E-05 7.35E-03 Mitigated (4 of 4 filters - DF 100) 0.00E+00 1.86E-01 1.86E-03 7.35E-01 Table 16 - Target Exposure Rates Due to Shine from Filters at 1 Foot Number of Filters and Filter Bank No. 1 fFilter Bank 1Filter Bank No. 2 J No. 3 Filter Bank No. 4 Decontamination Factor (mRihr ___

Mitigated (4 of 4 filters - DF 1000) 8.95E-02 1.17E-04 1.17E-07 4.63E-06 Mitigated (3 of 4 filters - DF 1000) 0.00E+00 1.17E-01 1.17E-04 4.63E-03 Mitigated (4 of 4 filters - DF 100) 8.87E-02 1.16E-03 1.16E-05 4.59E-03 Mitigated (3 of 4 filters - DF 100) 0.00E+00 1.16E-01 l.16E-03 4.59E-01 Tables 14, 15 and 16 indicate that the highest exposure rate is expected to be from Filter Bank No.

4 at 1.25 mR/hr with three (3) of four (4) filter banks in service during a 150 Curie process and filter Decontamination Factors (DFs) of 100. The reason for the highest exposure rates on Filter Bank No. 4 is due to the substantially thinner lead shielding thickness installed around this filter as compared to Filter Banks No. 1 through 3.

d. Dose estimates in the unrestricted area following a release of 1-131 into the PHC were providedfor the emergency planningzone (EPZ) boundary using the Pasquill-Guifford(P-G) dispersion model methodology. However, dose calculationsfor the nearest residence were performed using the COMPLY code. It is not clear how the different methodologies used may 29 of 62

affect the estimated dose results. Provide information demonstrating that the dose estimates are consistent using either methodology.

To provide clarity, MUJRR is recreating Table 15 from our original license amendment request along with two additional tables which will allow one to compare doses at the Emergency Planning Zone (EPZ) boundary, the nearest residence and the point of maximum effluent concentration [as determined by the Pasquill-Guifford (P-G) dispersion methodology] using both the computer code COMPLY (Ref. 5) and the P-G method of analysis. Tables 15 (a) through 15 (c) will also correct values that were supplied in Table 15 under the COMPLY heading at the nearest residence that were found to be in error and have since been corrected. The dose conversion factors used in the P-G method are derived from Federal Guidance Report (FGR) No. 11 (Ref. 6), which uses the International Commission on Radiological Protection (ICRP) Publication 30 (Ref. 7) values (which are also used in 10 CFR 20) for 1-131. The screening methodology which is internal to COMPLY is based on the National Council on Radiation Protection and Measurements (NCRP) Commentary No. 3, "Screening Techniques for Determining Compliance with Environmental Standards." It should be noted that COMPLY provides dose estimates which "are strictly for comparison with environmental standards and are not intended to represent actual doses to real people" according to the U.S. Environmental Protection Agency's (EPA) website regarding the use of the COMPLY code. However, both sets of doses are provided for comparison purposes to demonstrate that the methodologies are similar to each other in the cases of the EPZ boundary dose and the dose to the nearest residence and provide a reasonable estimation of potential offsite dose. The release of 150 Curies of 1-131 corresponds to a maximum iodine inventory accidental release that paralles MIJRR Technical Specification 3 .6.a for fueled experiments, represents the maximum hypothetical activity that could be released from a single i target, and is the nominal activity expected from a single target based on actual post irradiation measurements.

Table 15 (a) - Offsite Dose Consequences - Unmitigated Release (No Filtration)

Nearest Residence (760 meters North)

Activity Released COMPLY Model (EDE)

Pasquill-Guifford Model (EDE)

I{(CDE)

Pasquill-Guifford Model - Thyroid (Ci) (mrem) 150 39 34 T1,134

23 20 {665 1 14 12 416 30 of 62

Table 15 (b) - Offsite Dose Consequences - Umnitigated Release (No Filtration)

Highest Receptor Site (400 meters North)

COMPLY Pasquill-Guifford Pasquill-Guifford Activity Model Model Model - Thyroid Released (EDE) (EDE) (CDE)

(Ci) (torero) 150 52 303 10,104 1 31 178 5,928 U 19 111 3,705 Table 15 (c) - Offsite Dose Consequences - Unmitigated Release (No Filtration)

Emergency Planning Zone Boundary (150 meters North)

COMPLY Pasquill-Guifford Pasquill-Guifford Activity Model Model Model - Thyroid Released (EDE) (EDE) (CDE)

(Ci)

(mrem) 150 105 26 866 1 62 15 508 1 38 10 318 The difference in the above dose estimates can possibly be explained by the following factors:

1. The P-G model assumes that the wind direction is constant during the entire time of the release (2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) using the worst-case atmospheric stability class for the distance being modeled; i.e. the wind is blowing the entire time in the direction of the point of interest (towards the nearest resident due north). Therefore, in the 150 meter case, Stability Class 'B' predominates due to the combination of the effective stack height being high in relation to the local topography, which is close to the grade level of the facility. In the 400 meter case, Stability Class 'F' predominates due to the convergence of the effective stack height and the receptor height in relationship to the actual and effective stack heights. In the case of the nearest residence (760 meters North) the effective stack height is increasing again due to the local topography being at a lower elevation than at the 400 meter site (therefore divergence between the effective stack height and the receptor site) and the distance from the emission source in increasing at a rate which allows substantial dilution of the plume. The greatest agreement between the COMPLY output and the P-G methodology regarding offsite dose consequences occurs at the location of the nearest residence.

2. The COMPLY model uses local wind rose data that apportions the offsite dose to the nearest occupant (highest exposed compass direction) assuming the release occurs over an annual 31 of 62

basis (this is not a parameter that can be changed in COMPLY but allows a comparison for a like amount of release as noted in 1 above.) It appears that COMPLY does not take into consideration the local topography and the apparent convergence or divergence of the plume and the surrounding receptor site elevation. In fact, there is no input parameter for receptor site elevation built into COMPLY which allows user input.

It should be noted that COMPLY provides dose estimates in terms of an Effective Dose Equivalent (EDE) while the thyroid dose estimate [Committed Dose Equivalent (CDE)] was calculated from the dose conversion factors published in FGR No. 11, which is used in dose calculations with the P-G dispersion model. COMPLY does not report this thyroid dose (CDE) but uses it internally to calculate the EDE. The P-G model EDE value shown above is derived from the calculated thyroid organ dose and is thus is a product of the thyroid organ dose (CDE) multiplied by the thyroid weighting factor (0.03), as recommended in ICRP Publication 30.

The following tables represent the expected offsite doses for the above described scenarios assuming the functioning of the number of filter banks occurring in the columns with the headings of "Filter Banks." Filters were assumed to be 99% effective (DF = 100). The following tables are meant to update Tables 16 through 18 in our original license amendment request.

Table 16 (a) - Offsite Dose Consequences - Mitigated Release (Filtration)

COMPLY Model - Whole Body at Nearest Residence (760 meters North)

Activity Method 1 Filter Bank 2 Filter 3 Filter [ 4 Filter Released Banks Banks [ Banks (Ci) _________(mrem) 150 COMPLY 0.39 3.9E-3 3.9E-5 3.9E-7 Model

WB (EDE) 0.23 2.3E-3 2.3E-5 2.3E-7 I 0.14 l.4E-3 1.4E-5 l.4E-7 Table 16 (b) - Offsite Dose Consequences - Mitigated Release (Filtration)

P-G Model - Whole Body at Nearest Residence (760 meters North)

Activity Method 1 Filter Bank 2 Filter f 3 Filter [ 4 Filter Released Banks Banks Banks (Ci) (mrem) 150 P-G 0.34 3.4E-3 3.4E-5 3.4E-7 Model 1 WB (EDE) 0.20 2.0E-3 2.0E-5 2.0E-7 1 0.12 1.2E-3 1.2E-5 1.2E-7 32 of 62

Table 16 (c) - Offsite Dose Consequences - Mitigated Release (Filtration)

COMPLY Model - Highest Receptor Site (400 meters North)

Activity Released Method 1 Filter Bank ]J 2 Filter Banks 3 Filter Banks]

] 4 Filter Banks (Ci) (mrem) 150 COMPLY 0.52 5.2E-3 5.2E-5 5.2E-7 Model U WB (EDE) 0.31 3.1E-3 3.1E-5 3.1E-7 1 0.19 1.9E-3 1.9E-5 1.9E-7 Table 16 (d) - Offsite Dose Consequences - Mitigated Release (Filtration)

P-G Model - Highest Receptor Site (400 meters North)

Activity 1 Filter Bank 2 Filter 3 Filter 4 Filter Released Method Banks Banks Banks (Ci)

(mrem) 150 P-G 3.03 3.03E-2 3.03E-4 3.03E-6 Model U WB (EDE) 1.78 1.78E-2 1.78E-4 1.78E-6 U

Table 16 (e) - Offsite Dose Consequences - Mitigated Release (Filtration)

COMPLY Model - Whole Body at Emergency Planning Zone Boundary (150 meters North)

Activity Method 1 Filter Bank 2 Filter 3 Filter 4 Filter Released Banks Banks Banks (Ci) (mrem) 150 COMPLY 1.05 1.05E-2 1.05E-4 1.05E-6 Model 1 WB (EDE) 0.62 6.2E-3 6.2E-5 6.2E-7 1 0.38 3.8E-3 3.8E-5 3.8E-7 Table 16 (f) - Offsite Dose Consequences - Mitigated Release (Filtration)

P-G Model - Whole Body at Emergency Planning Zone Boundary (150 meters North)

Activity Method 1 Filter Bank j 2 Filter 3 Filter 4 Filter Released j Banks Banks Banks (Ci) (mrem) 150 P-G 0.26 2.6E-3 2.6E-5 2.6E-7 Model 1 WB (EDE) 0.15 1.5E-3 1.5E-5 1.5E-7 1 0.10 1.0E-3 1.0E-5 l.OE-7 33 of 62

Thus, as indicated by examining the above tables, it is shown that only one functioning set of charcoal filters is necessary to ensure that offsite public dose is kept below the 100 mrem limit as prescribed in 10 CFR 20.1301.

e. The offsite dose estimates do not indicate whether the calculations assumed an instantaneous release, or a release over some time period. Provide the release type and/or rate of release used in the dose calculations.

For the calculations using COMIPLY, the releases of 150, i and i Curies are assumed to occur over a one year (annual) time period. COMPLY is used to demonstrate compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAPS) radionuclide constraint and thus calculates an annual offsite dose due to air emissions at the receptor site of interest. COMPLY uses local wind rose data to distribute the dose over an annual time period based on the frequency distribution of the prevailing wind patterns.

When using the Pasquill-Gifford (P-G) dispersion model, the release is modeled to occur over a two (2) hour time frame and move north via a south wind towards the location of the nearest resident (760 meters due north). It is also assumed that the worst-case P-G atmospheric condition (Stability Class) exists during this time period for the particular receptor site being modeled, thus assuring a worst-case scenario for atmospheric dispersion.

f. The COMPLY offsite dose calculations use wind rose data from the Columbia Regional Airportfor the periodfrom 1984 to 1992. However, other inputs and assumptions used in the calculations are not provided. For the calculations,provide the following:

i. The stability class(es) used,"

ii. The release height of effective release height(s) used,"

iii. Whether, and how, topography is accountedfor' iv. Whether, and how, building wake effects are accountedfor;"

v. The exposure timeframe considered,"

vi. The inhalationrate(s) used,"

vii. The dose conversion factor(s) used," and, viii. Whether the calculated doses include committed effective dose equivalent (CEDE) from inhalation, submersion, or both.

The COMPLY computer code, which is available through the U.S. Environmental Protection Agency (EPA) website, calculates doses to offsite personnel from a facility producing radioactive emissions. It is a computer code used to ascertain regulatory compliance with the radioactive National Emission Standards for Hazardous Air Pollutants (NESHAPS) requirements of 10 CFR 1101l(d) and is accepted by the NRC to demonstrate compliance with that regulation. As such there is only limited information available as to some of the assumptions used in calculating offsite doses within the model. With regards to the items noted above, we will report what is known based on documentation available related to the COMPLY code.

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1. It is not known how or if stability classes are incorporated into the model. The only input data required for input into the computer model is locally available wind rose data which includes average annual wind speed from one of the normal 16 compass point directions; frequency of the corresponding wind speed and direction; and the percentage of time the wind is calm, both on an annualized basis.

ii. The input parameter required for release height is the actual release height of our facility stack which is nearly 70 feet (21 meters) above grade level.

iii. It is not known how or if topography is accounted for in the computer code. Based on input parameters we assume not.

iv. Building wake effects are accounted for in this program based on documentation available on line. This is collaborated by the requirement to use input parameters such has stack height, and building width, length and height.

v. As discussed in the responses to Questions 4.d and 4.e, the exposure time frame when using the COMPLY code is one year (annual dose reporting).

vi. Comply uses a default inhalation rate of 8000 m3/year.

vii. As discussed in an earlier response, COMPLY uses the methodology outlined in NCRP Commentary No. 3.

viii. COMPLY calculates an Effective Dose Equivalent (EDE) for any isotope inputs entered into the program. Internally the code converts an organ dose [Committed Dose Equivalent (CDE)] to an EDE for reporting purposes. Thus, depending on the isotope it would compute a Committed Effective Dose Equivalent (CEDE) or submersion dose. The report only provides an EDE for iodine as a printed result.

g. The P-G offsite dose calculationsspecify that D stability class and a southern wind direction are assumed, but other inputs and assumptions usedfor the calculations are not provided.

For the calculations,provide the following:

i. The wind speed(s) used,"

ii. The release height or"effective release height(s) used;"

iii. Whether, and how, topography is accountedfor;"

iv. Whether, and how, buildingwake effects are accountedfor;"

v. The inhalationrate(s) used;"and, vi. Whether calculated doses include CEDEfr'om inhalation,submersion, or both.

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The following inputs were used in calculating both the 150-meter Emergency Planning Zone (EPZ) boundary and 760 meter (nearest residence) distances using the Pasquill-Guifford (P-G) dispersion model.

i. The initial analysis indicated that Stability Class 'D' provided a worst-case scenario.

Upon reviewing the initial calculations performed, it was determined that assignment to this classification was in error. The stability class that provides the "worst-case" scenario is Stability Class 'B' for the 150-meter EPZ receptor site. This is due to a combination of average wind speed, in this particular direction being modeled, and the large effective stack height which is caused by the relatively small difference between the grade level at the MUIRR site and the receptor site 150 meters due north.

The corresponding wind speed for Stability Class 'B' is 3 meters/sec. For the 760 meter receptor site, the corresponding wind speed for the worst-case 'E' Stability Class is 4 meters/sec. Stability Class 'E' prevails at 760 meters due to the lower effective stack height at that point (16 meters).

ii. The effective stack height used for the 150-meter EPZ receptor site is 29 meters and the effective stack height used at the 760 meter receptor site (nearest resident) is 16 meters.

iii. Topography is accounted for when calculating the effective stack heights at MURR based on the atmospheric stability class. The difference in elevation between the receptor site and the release point is used as input parameter when using the Davidson Model, which we use, to calculate effective stack heights. This model produces very conservative stack height estimations when compared to other more complex models proposed by Briggs and other researchers and noted in the book "Plume Rise" by G.A. Briggs (1969).

iv. The P-G model does not account for building wake effects.

v. MUJRR uses a standard 0.5 liters/breath with 12 breaths/minute as its basis for calculating inhalation dose by individuals (3154 m3/yr). This rate is generally recognized as an at-resting breathing rate which one would assume for individuals offsite and not engaged in work activities.

vi. In the case of inhalation of 1-131, MURR considers and calculates the dose to the thyroid as a Committed Dose Equivalent (CDE). It then uses the ICRP Publication 30 reconmmended value of 0.03 to calculate the Effective Dose Equivalent (EDE) for the whole body based on the thyroid dose.

h. The P-G offsite dose calculationsspecif that the dose conversionfactors used arefrom NRC Regulatory Guide (RG) 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluation Compliance with 10 CFR S0, Appendix I."

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However, more widely-used and current dose conversionfactors are available, such as those provided in the Environmental Protection Agency Federal Guidance Report (EPA FGR) No.

11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factorsfor Inhalation, Submersion, and Ingestion." The NRC staff noted that, for 1-131 inhalation,NRC RG 1.109 lists a whole-body dose conversionfactor of 6.92E-10 Sieverts per Becquerel (Sv/Bq)," whereas, EPA FGR No. 11 lists a more conservative whole-body dose conversionfactor of 8. 89E-9 Sv/Bq. Justify the use of the less conservative dose conversion factors listed in the RG 1.109.

MIURR has switched to using the Environmental Protection Agency Federal Guidance Report (EPA FGR) No. 11 Dose Conversion Factor of 2.92E-7 Sv/Bq to calculate thyroid (organ) dose. We then use the ICRP Publication 30 recommended value of 0.03 to convert the corresponding dose to the thyroid to an Effective Dose Equivalent (EDE) to the Whole Body. The resulting product is almost identical (8.76E-9 Sv/Bc) to the 8.89E-9 Sv/Bq value from FGR No. 11 noted above. The slight discrepancy can be attributed to a rounding error in converting units from the original ICRP Publication 30 values.

i. The P-G Offsite dose calculations indicate that the D stability class provides the most conservative results. However, the NRC staff notes that depending on7 the release height or effective release height(s) usedfor the P-G calculations, the D stability class may not be most conservativefor some downwind locations. NRC RG 1.4, "Assumptions Usedfor Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Pressurized Water Reactors," recommends that for the atmospheric dispersion calculationsfor the first eight hours following a release, F stability and a windspeed of 1 meter/sec with uniform direction should be used to provide sufficiently conservative results. Additionally, the NRC staff is interested if the highest calculated doses could occur beyond the EPZ boundary (150 meters from the stack) or the nearest residence (760 meters from the stack), depending on7 stability class. Provide justi~fication (such as sample calculations performed for varying stability classes for varying locations downwind, including locations between the EPZ boundary and the nearest residence, and beyond the nearest residence) as to why the following parameterswere chosen to be most conservative:

i. D stability class, and, ii. EPZ boundary and nearest residence receptor locations (include map showing the EPZ, nearest residence, and the boundary (beyond the EPZ) under the evacuation control of the licensee, ifpossible).

As noted in the response to Question 4.d, the highest doses [Effective Dose Equivalent (EDE)]

calculated offsite using the Pasquill-Guifford (P-G) dispersion methodology were 26, 303, and 34 mrem for receptor sites located at 150, 400 and 760 meters, respectively, due north of MURR. The highest dose occurs at the 400 meter point north of the facility on University of Missouri controlled property. As stated earlier, this is due to the convergence of the local topography with the effective exhaust stack height at that location. Table 1 summarizes the corresponding doses resulting from 37 of 62

an unmitigated release of 150 Curies of 1-131 at distances with the associated P-G Stability Class for the corresponding dose.

Table 1 - Dose at Distance Using Corresponding Worst-Case Stability Class Distance from Worst-Case Corresponding Average Exhaust Stack ED oe Stability Class / Effective Wind Speed at MURR for (meters) (me)Stack Height (meters) Stability Class (mis) 150 26 B /32 3.0 400 303 F /7 2.6 760 34 E /16 4.0 As noted in the previous response, the original determination of Stability Class 'D' as the worst-case was found to be in error. This was corrected and the results presented in the table above. The classes noted in Table 1 show the worst-case stability classes for the noted distance from the exhaust stack which gives the highest offsite dose at the corresponding locations.

In contrast to this methodology used by MiURR, Regulatory Guide 1.4 (Ref. 8) suggests the use of Stability Class 'F' with a default wind speed of 1 m/s. Table 2 summarizes the corresponding doses resulting from an unmitigated release of 150 Curies of 1-131 at the noted distances using Stability Class 'F' with a default 1 m/s wind speed.

Table 2 - Dose at Distance Using Stability Class 'F' with Default 1 m/s Wind Speed Distance from Worst-Case Corresponding Wind Exas Sak EDE Dose Stability Class per (mrem) Reg. Guide 1.4 / Effective SedprRg ud .

(meters) Stack Height (meters) (mis) 150 0 F /74 1.0 400 0 F /49 1.0 760 0 F /65 1.0 In MIURR' s case and as shown in the table above, the effect of using the default wind speed of 1 m/s vastly increases the effective stack height when used with the corresponding Stability Class 'F' dispersion coefficients. The use of the default wind speed of 1 m/s effectively allows for increased injection height into the atmosphere (based on MURR's exhaust stack exit velocity of 17.7 m/s) and allows for further dispersion and dilution at sites downwind from MUIRR. Thus MURR feels its current approach is much more conservative in our situation than using the default values as suggested in Regulatory Guide 1.4. In no case was the offsite dose greater than at the 400 meter point due north of MURR.

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5. NUREG-1537, Chapter 14, 'Technical Specifications," and American Nuclear Standards Institute/American Nuclear Society (ANSI/ANS)-15. 1-2007, "The Development of Technical Specifications for Research Reactors," provides guidance that tests to establish carbon filter efficiency should be performed annually to biennially, and following major maintenance. The licensee 's proposed TS 5. 7, Specification e states, in part, that carbon filter efficiency measurements shall be performed biennially.

a. The proposed TSs do not appear to include a requirement that carbon filter efficiencies be testedfollowing major maintenance. Provide an explanation.

Proposed Technical Specification 5.7.e will be revised as follows: "The efficiency of the Iodine 131 processing hot cells charcoal filter banks shall be verified biennially or following major maintenance. It shall be verified that the charcoal filter banks have a removal efficiency of 99% or greater for iodine."

b. Attachment 8 of the amendment request stated that the lifetime of carbon filters "can be as long as "five years. While new carbonfilters are unlikely to exhibit a significant decrease in efficiency for the first two years following installation, a marked decrease in efficiency could occur between years 2 to 4, or years 4 to 6. Provide a justification to support biennial surveillance testingfor carbonfilters after two years of use.

The service history of charcoal filters and the determinants of their useful life are comprehensively discussed in ORNL/TM-6607, "A Literature Survey of Methods to Remove Iodine from Off-Gas Streams Using Solid Sorbents" (Ref. 9).

The effectiveness of a charcoal filter to capture iodine, including molecular iodine and methyl iodide, is diminished by the presence of oil vapors, solvent vapors, oxides of sulfur and nitrogen (SO 2, NO and NO 2). Efficiency is further reduced by operation at highly elevated temperatures, the presence of steam or condensed water droplets, and otherwise continuous high humidity. Operation of charcoal filters at approximately 200 °C or above limits the use of triethylenediamine (TEDA),

which is impregnated in nuclear-grade charcoal to enhance absorption and retention of radioiodines. Charcoal filter efficiency for capture and retention of iodine is directly correlated with charcoal bed depth and inversely related to iodine concentration in the incident gas stream, the cumulative loading over time and air-flow rate. The American Society for Testing and Materials (ASTM) method used to test TEDA-impregnated charcoal (ASTM-D-3803-91; reapproved 2014) uses methyl iodide as the iodine test agent because it is more challenging to capture and retain compared to molecular iodine. The specified concentration is 1.75 mg CH 3I per m3 and typically efficiencies for five (5) flow rates are provided (0.5, 1.0, 2.0, 3.0 and 4.0 SCFM) resulting in minimum retention efficiencies ranging from 94.1% to 99.8% over a 168-hour purge at a relative humidity of 95%, a temperature of 30 °C and a charcoal bed depth of 2 inches.

For each of these determinants of charcoal filter iodine-retention efficiency, the conditions under which the 1-131 processing facility at MiURR is operated are equivalent or favorable compared to 39 of 62

those found in other nuclear operations (e.g., nuclear reactor core damage scenarios) in which iodine retention is required and also favorable compared to the ASTM condition under which charcoal filters are routinely certified with the exception of flow rate. For example:

1. The MIURR facility 1-1 31 hot cells and post-hot cell filtration are dedicated exclusively to 1-131 production and will not be subjected to those agents such as oil vapors, solvent vapors, steam, SO 2 , NO, NO2 and continuous high humidity known to reduce iodine retention and/or increase desorption.

2. The air temperature in the Processing Hot Cell (PHC) will not approach charcoal ignition temperatures, which are coincident with the temperatures where TEDA is compromised.

Therefore, TEDA-impregnated charcoal can be used in the MUIRR 1-131 processing facility and will be at its maximum efficiency.

3. The average monthly relative humidity in the 1-131 processing facility, including the PHC, ranges from 30.3% to 81.7%, which is an environment that favors a higher iodine-retention efficiency compared to the 95% relative humidity used in charcoal filter certification testing.

4. The air-flow through the three (3) dedicated charcoal filter banks serving the PHC is 5.5 CFM corresponding to an iodine retention efficiency (as methyl iodide) of > 99% per filter at 40%

relative humidity and decreases to approximately 87% at 95% relative humidity. At 95%

relative humidity, the three (3) TEDA/KI-impregnated charcoal filters serving the PHC operating in series can be expected to remove > 99% of the incident 1-131 activity based on methyl iodide.

5. The total iodine loading in is hypothetically determined by the stable iodine (1-127) impurity in the target, which has been determined to be 0.47 jig/g in the used to produce the targets for the MUJRR 1-131 process. Rounding to 0.5 jig/g, this represents 90 *tg iodine per the maximum target. The total mass of the radioiodine species is negligible compared to the stable 1-127. Assuming all of the iodine present from its impurity level is during a and also assuming four (4) processes per week, each with an target, and operating 52 weeks per year will a maximum of 18,720 gtg (18.72 mag) of iodine per year. The assumption that all of the stable iodine in a target will during a process is highly conservative in that the stable iodine will largely exist in forms. In addition, we have demonstrated that greater than 95% of the iodine from a

~will be captured by the product-collection traps and the two (2) 3-component traps in the P11C. Therefore, the loading of iodine on the charcoal filter in the PHC is conservatively estimated at 90 jig/process x 0.05 4.5 jig/process corresponding to 936 jig/year. There are three (3) dedicated TEDA/KI-impregnated charcoal filters associated with the PHC having, in sequence, 3800, 1200 and 1200 grams of charcoal, respectively. Considering only the first of these three (3) filters, the annual loading of this filter is 0.000246 mg iodine per gram carbon, 40 of 62

which is negligible compared to the loading capacities to which TEDA/KI-impregnated charcoal are capable (discussed further below).

6. Assuming an air flow rate of 5.5 CFM and a processing time of approximately 60 to 120 minutes, the maximum iodine concentration during filter loading is 0.00070 mg/in 3, which is less than the loading concentration typically used in the certification testing of a charcoal filter by over three (3) orders of magnitude.

7. The charcoal bed depth of the initial PHC filter is 1.969 inches, which is the same as used in a typical certification test.

8. Greater than 99% of the radioiodine produced in the is mnthe form of molecular iodine, which is captured and retained more efficiently than the methyl iodide used in the certification testing.

In Figure 4, page 24 in the "Service History" section of ORNL/TM-6607, iodine desorption percentages of approximately 0.0015% and 0.015%, at iodine loading ranges of 0.89 to 0.96 mg Iodine/gCarbon and 0.69 to 0.91 mg Iodine/gCarbon are provided for charcoal filters that have been in service for 2.5 years and 4.7 years, respectively. The annual loading on the TEDA/KI-impregnated charcoal filter that is the first of the three (3) dedicated to the PHC is estimated to be 0.000246 mg Iodine/gCarbon, which is a factor of 2800 less than the lowest of the loadings reported in ORNL/TM-6607 indicating that a service life of five (5) years (total maximum loading of 0.00 123 mg Iodine/gCarbon) is credible under normal operating conditions of I-131 processing.

Consequently, the suggested policy of either replacing or testing TEDA/KI-impregnated filters in the 1-131 processing facility on a biennial schedule is conservative.

In addition, the 1-131 Processing Laboratory Duct Monitor samples the exhaust duct air through a charcoal cartridge prior to the exhaust air from the 1-131 processing area joining the facility main ventilation exhaust system. This monitor isolates 1-131 processing activities and provides the capability to quantify the 1-131 concentration of the 1-131 processing facility exhaust air. Tracking these 1-131 concentrations longitudinally is a sensitive diagnostic of any changes that might occur in the overall I-131 filtration efficiency as a function of the number of processes performed.

c. Section 2.0 of the amendment request states that some 1-131 could escape to the PHC during normal I-i131 processing. Provide an explanation of how long-term routine releases ofi1-131 to the carbonfilters could reduce the carbonfilter efficiency over time.

As discussed in the response to Question 5 .b, the estimated loading of iodine on the first triethylenediamine/potassium iodide (TEDA/KI) impregnated charcoal filter (Filter Bank No. 1) in the sequence of three (3) dedicated banks serving the PHC, over a 5-year service period, is 0.00 123 mng Iodine per gram Carbon based on processing four (4) targets per week, 52 weeks per year. This corresponds to a loading factor more than 500 times less than the smallest loading discussed in the "Service History" section of ORNL/TM-6607 that comprehensively discusses iodine removal using 41 of 62

solid sorbents including charcoal. Furthennore, the estimated iodine concentration in the full volume of the Processing Hot Cell (PHC) as a result of processing a maximum activity target is estimated to be 0.00070 mng Iodine/mn3 compared to 1.56 mng Iodine/mn3 specified in ASTM D3 803, "Standard Test Method for Nuclear-Grade Activated Carbon" (Ref. 10). Consequently, iodine-loading will have a negligible effect on iodine-retention by the TEDA/KI-impregnated charcoal filters dedicated to the PHC in long-term service (> 5 years).

d. Describe the process that will be used to preform carbonfilter efficiency measurements.

As stated in Section 8.0 of the original license amendment request, the guidance provided in Regulatory Guide 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants (September 2012, Rev. 4)," will be used to determine carbon filter efficiency measurements (Ref. 11). Specifically, in Section 7 of Regulatory Guide 1.52, laboratory testing of samples of activated carbon adsorber material should be performed in accordance with ASTM D3803-1991 (R20 14) and Table 2 of this guide. ASTM D3803, "Standard Test Method for Nuclear-Grade Activated Carbon," is a very stringent test method for establishing the capability of new and used activated carbon to remove radio-labeled methyl iodide from air and gas streams (Ref. 10). If a carbon sample cannot be sent to a testing facility then the filter will be replaced with a new one. Regulatory Guide 1.140, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Normal Atmospheric Systems in Light-Water-Cooled Nuclear Power Plants (June 2001, Rev. 2)," (Ref. 12) was also reviewed for guidance on carbon filter efficiency measurements. This Regulatory Guide also references ASTM D3803.

6. The amendment requests, Section 2.0, states that the non-fueled irradiation targetsfor the 1-131 production will be doubly encapsulated. However, no TS requirements have been proposed to require double encapsulation of non-fueled irradiation targets for this process. Provide an explanation.

There are no Technical Specification (TS) requirements to double encapsulate the targets (Ref. 13). The only current MURR TS that requires double encapsulation is TS 3.6.j, which states, "Corrosive materials shall be doubly encapsulated in corrosion-resistant containers to prevent interaction with reactor components and pool water."

Although only single encapsulation is required, IMUTRR, by practice, typically double encapsulates targets to further reduce the potential consequences of a leaking container. The statement on Page 1 of the original license amendment request was simply stating how MUIRR typically encapsulates the target material and in no way was implying or proposing a new TS requirement.

Because (1) the temperature of the target during irradiation does not reach the melting point U U) of the *, and (2) the target material would remain in solid form due to the insolubility of the compound, there would be minimal or no diffusion of radioiodine from the into the reactor pool and hence no release (See response to Question 8.a). However, for the

mtarget 42 of 62

scenario of a total release of all of the activity ()

irradiation (current Administrative Limit) safety analysis (Ref. 14), MURR assumed a worst-case from the target material into the reactor pooi whether it is single or double encapsulated. Using a very conservative ten (10) minute stay time [typical evacuation time is about two (2) minutes], an individual in the containment building would receive a Total Effective Dose Equivalent (TEDE) of 125.79 mrem. An individual at the point of maximum concentration in the unrestricted area would receive a TEDE of 0.006 mrem. If you ratio this activity to the maximum activity of 150 Curies of I-131 proposed by new TS 3.6.p, an individual in the containment building and at the point of maximum concentration in the unrestricted area would receive a TEDE of 214.41 mrem and 0.01 mrem, respectively. Once again, these doses are based on an unrealistic total release of 150 Curies of 1-131 and an extremely conservative stay time in containment (by a factor of 5) during the release. This analysis is bounded by the current MUJRR TSs, specifically fueled experiments.

7. The proposed MURR TS 3.11, Specification d, requires three charcoal filter banks with an efficiency of at least 99 percent to be operable when 1-1 31 is beingprocessed in the PHC.

a. It is not clear if the 99 percent requirementpertains to each individualfilter bank, or to all operable (three)filter banks collectively. Explain.

The individual CAMFIL and Flanders filters each have an iodine-retention efficiency of greater than 99% of the 1-131 activity produced during the of irradiated targets; therefore, the 99% requirement pertains to each individual filter bank.

In Reference 9, ORNL/TM-6607, the parameters listed below are identified and discussed as those that should be considered relative to the removal of radioiodine species from off-gas streams using solid iodine sorption materials including triethylenediamine (TEDA) and potassium iodide (KI) impregnated activated charcoal such as that used in the charcoal filters in service in the MiURR I-131 processing facility.

Iodine Removal Determinants:

1. Chemical Species: The radioiodine species present in the off-gas stream include predominately molecular iodine (12), which accounts for greater than 99% of the 1-131; and methyl iodide (CH1 3 I), which accounts for less-than 1% of the I-131 activity.

It is universally recognized that the efficiencies at which these two (2) radioiodine species are removed from an off-gas stream by TEDAiKI-impregnated charcoal can be significantly different depending on other determinants.

Molecular iodine is removed at high efficiency, retaining a greater-than 99% efficiency over a wider range of air flow rates and relative humidity compared to methyl iodide. This iodine-speciation determinant (12 vs CU 3I) is why the more challenging methyl iodide is used as the adsorbate in ASTM D3803-9 1 (R20 14), "Standard Test Method for Nuclear-Grade Activated 43 of 62

Carbon" to determine the iodine-removal efficiency of solid sorbents (Ref. 10). The first sentence in ASTM D3 803, under "Scope," states, "This test method is a very stringent procedure for establishing the capability of new and used activated carbon to remove radio-labeled methyl iodide from air and gas streams."

In addition to being more challenging to capture compared to molecular iodine, methyl iodide can represent substantial fractions of the radioiodine activity during fuel reprocessing activities and particularly under fuel-accident scenarios. In International Atomic Energy Agency (IAEA)

Report 148, "Control of Iodine in the Nuclear Industry," the recommendation is that ". .. filter-systems should be designed for the efficient removal of methyl iodide amounting to 10% of the iodine in the core." However, in contrast, based on measurements of the I-131 collected in the product-collection traps and the exhaust stream from the product-collection traps from the I

~of irradiated Iin the Processing Hot Cell (PHC), the CH 31-131 component of the of an irradiated I target is estimated to be less than 0.2%. A conservatively-increased methyl iodide concentration of 1% of the total 1-131 activity has been used to arrive at the estimated >99% radioiodine-removal efficiency for the TEDA/KI-impregnated filters in service in the MURR 1-131 processing facility.

2. Relative Humidity and Flow Rate: These two determinants of iodine removal from an air stream must be considered together and in conjunction with the chemical species involved, molecular iodine (12) and methyl iodide (CH 3 I), in the case of the of irradiated Itargets.

At an optimal low air flow rate, the methyl iodide retention efficiency of a TEDA/KI-impregnated charcoal filter drops precipitously as the relative humidity increases beyond approximately 90% as shown in Figure 1 derived from data in ASTM D3803-91, Annex Al.

44 of 62

Iodine retention efficiency (%) in TEDAJKI impregnated charcoal as a function of relative humidity for methyliodide (CH3 1) at 30 °C and an optimized minimal air-flow rate.

100 -

95-C.

t--

.5 90-0E a-85-I 0

80-75 45 50 55 60 65 70 75 80 85 90 95 100 relative humidity (%)

Figure 1 - Methyl Iodide Retention Efficiency of a TEDA/iKI-Jmpregnated Charcoal Filter vs. Relative Humidity Over the course of 12 months the relative humidity, averaged over 1 to 5 weeks, was recorded at three (3) locations in and around the 1-131 processing area and are representative of the air entering the PHC. The average and median relative humidity were 61.9% and 70.5%,

respectively. The range in monthly relative humidity, averaged over the 1 to 5 week recording periods and three (3) locations was 30.3% to 81.7%. The maximum average relative humidity for a single recording period in any of the locations was 90%. In summary, the relative humidity of air entering the PHC and entraining the radioiodine from the of the irradiated target will not exceed the 95% relative humidity specified in ASTM D3 803.

When air flow is increased over a range of 0.5 to 5.5 SCFM at a constant high relative humidity (95%), the retention of molecular iodine (closed circles) decreases slightly compared to methyl iodide (open squares) as shown in Figure 2. Also shown in Figure 2 is the iodine retention efficiency for the hybrid mixture of 99% molecular iodine and 1% methyl iodide (open circles) that conservatively represents the radioiodine mixture entrained in the air flow from the

~of an irradiated target. In this figure, the iodine retention efficiencies for 100% molecular iodine and the (99:1) mixture of molecular iodine and methyl iodide are shown on the scale on the left Y axis and the for 100% methyl iodide on the right Y axis.

In summary, each of the three (3) dedicated individual TEDA/KI-impreguated CAMFIL filters serving the PHC and the Flanders filter serving the entire 1-131 processing facility will retain 45 of 62

efficiencies greater than 99% for iodine removal under the relative humidity and aft-flow rates associated with a

Retention efficiency (%) at 95% relative humidity by solid sorbents at variable air flow (0.5 to 5.5 SCFM) for 12alone and for a99% 12,1% CH2 1 mixture (percent retention scale on left Y axis), and for CHI alone (percent retention scale on right Y axis)

.e 100.0 -100 X99

~98

~-99.9 97

-r96 ~

+ 9 S99.8 9

'-*92 > o 99.7 91 Ez"

-* 99.6 88 -

o 87 C'-. 86 Bg* 99.5 . . . . . . . . . . . 85 0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 5.5 6.0 air-flow rate (SCFM)

12efficiency (left Y axis) 0..o. 12& CH 2I hybrid efficiency (left Y axis) o] CH31 efficiency (right Y axis)

Figure 2 -Iodine Removal Efficiency of a TEDA/KI-Impregnated Charcoal Filter vs. Air Flow Rate

3. Temperature: Over the course of 12 months the aft temperatures, averaged over 1 to 5 weeks, were recorded in and around the 1-131 processing area and are representative of the air entering the PUC. The average temperature, standard deviation, median, minimum and maximum were 20.2 0C (68.3 °F), 0.9 °C (1.6 0F), 20 °C (68 °F), 18.5 °C (65.3 0F) and 22.8 °C (73.0 °F),

respectively. During operation of the at * ( ) the temperature in the PHIC typically increases to a range of 20 to 24 °C (70 to 75 °F). In summary, the temperature in and around the PHC varies over a narrow range and does not have an inverse impact on the iodine-retention efficiencies of the filters.

4. Iodine Loading Concentration and Cumulative Iodine Loading: Both the concentration of iodine in the aft stream impacting the solid sorbent filter material and the cumulative mass of iodine loaded over time influences iodine removal from an air stream. High iodine-loading concentrations and the increasing mass of iodine loaded over time can both reduce iodine removal efficiencies.

46 of 62

The total iodine loading in a is hypothetically determined by the stable iodine (I-127) impurity in the target, which has been determined to be 0.47 jig/g. Rounding to 0.5 pxg/g, this represents 90 jig iodine per the maximum l target. The total mass of the radioiodine species is negligible compared to the stable 1-127.

Assuming all of the iodine is during a and also assuming four (4) processes per week, each with an l target, and operating 52 weeks per year will a maximum of 18,720 jig (18.72 rag) of iodine per year. The assumption that all of the stable iodine in a I target will during a is highly conservative in that the stable iodine will largely exist in forms. In addition, we have demonstrated that greater than 95% of the iodine from a

~process will be captured by the product-collection traps and the two (2) 3-component traps in the P11C. Therefore, the loading of iodine on the charcoal ifilter in the PHC (Filter Bank No. 1) is conservatively estimated at 90 jig/process x 0.05 4.5 jig/process corresponding to 936 jig/year. There are three (3) TEDA/KI-impregnated charcoal filters associated with the PHC having, in sequence, 3800, 1200 and 1200 grams of charcoal, respectively. Considering only the first of these three (3) filter banks, the annual loading of this filter is 0.000246 mg iodine per gram carbon (mg J/g C), which is negligible compared to the loading capacities reported in the "Service History" section of ORNL/TM-6607 in which cumulative iodine loadings ranging from 0.69 mg JI/g C to 0.96 mg J/g C were present in charcoal filters having an in-service history of 2.5 and 4.7 years and while remaining effective as verified by iodine-desorption testing.

Considering a uniform release of 4.5 jig (0.0045 mag) of total iodine to the PHC during a single process of a l target (from the preceding paragraph), a flow rate of 5.5 CFM 3

(0.15574 m /min), and a process time of approximately 120 minutes, will result in an iodine loading concentration of 0.0002408 mg/rn 3, which is 0.014% of the concentration of methyl iodide used in the ASTM D3803 procedure (1.75 mg CH 3I/m 3).

In summary, neither the iodine-loading concentration nor the cumulative loading attained over many years of processing under the MUIRR 1-131 processing facility protocols will exceed commonly employed metrics for these parameters.

5. Other Determinants: Various components that can be entrained in the off-gas stream in concentrations adverse to iodine-removal efficiency by solid sorbents are discussed in the ORNL/TM-6607 report. These include gases such as SO 2, NO and NO2; hydrocarbon vapors from fuels and lubricants; other organic vapors from paints, sealants and solvents; and steam and condensed aerosols. None of these exist in significant concentrations in the MURR 1-131 processing facility.

In summary, the three (3) individual dedicated TEDA/KI-impregnated CAMFIL charcoal filters in sole-service to the PHC, and the Flanders filter serving the entire 1-131 processing facility, under the conditions associated with the of irradiated l targets, will each have an iodine-removal efficiency of greater-than 99% for the radioiodine species and their relative 47 of 62

distributions as discussed in the preceding sections; therefore, the 99% requirement pertains to each individual filter bank.

b. It is not clear if the 99 percent requirementpertains to a mechanical efficiency, a chemical adsorption efficiency, or a total (mechanical plus chemical) decontamination efficiency.

Explain.

Where filter-efficiency percentages are cited they are in reference to iodine unless otherwise stated.

Furthermore, the iodine efficiencies take both molecular iodine (12) and methyl iodide (CH 3I) into consideration at the relative humidity (95%) specified in the ASTM D3803 testing protocol, and this is conservative relative to the lower median relative humidity (70%) in the MUTRR 1-131 processing facility, which increases filter efficiency compared to 95% relative humidity. The iodine removal efficiency (>99%) is cited for the air flow rate through the triethylenediamine/potassium iodide (TEDA/KI) impregnated charcoal filters serving the Processing Hot Cell (PHC) and the temperature range during the (20 to 24

°C) is comparable, relative to filter efficiency, to the temperature (30 °C) used in the ASTM D3803 testing protocol.

c. It is not clear what form(s) of 1-i 31 (elemental, organic, or particulate) the 99 percent requirement pertains to, and whether these form(s) are representative of what would be expected for 1-131 absorbed on the carbon filters following a release ofi1-131 to the PHC.

Explain.

Molecular iodine (12) is the predominant form (>99%) of iodine from the of

(*) at its melting point (*. In addition methyl iodide (CH 3 I) is also formed (<1%) through the high-temperature reaction of iodine with ambient methane (approximately 2 ppm mole ratio) present in air. The triethylenediamine/potassium iodide (TEDA/KI) impregnated charcoal filter efficiency we cite (>99%) takes both molecular iodine and methyl iodide into consideration. Furthermore, we employ silver zeolite filter cartridges on both the exhaust from the product-collection traps (processing line exhaust) and the exhaust line in the Processing Hot Cell (PHC) to minimize the discharge of CH 3I-1 31 into the P11G.

d. It is not clear what temperature and humidity the 99 percent requirementpertains to, and whether this temperature and humidity is representativeof what would be expected for 1-131-contaiminatedairpassing through the carbonfiltersfollowing a release ofi1-131 to the PHC.

Explain.

Over the course of 12 months the air temperature and relative humidity, averaged over 1 to 5 weeks, were recorded at three (3) locations in and around the 1-131 processing area and are representative of the air entering the Processing Hot Cell (PHC). The average temperature, standard deviation, median, minimum and maximum in the 3 locations were 20.2 °C (68.3 °F), 0.9

°C (1.6 0F), 20 °C (68 0F), 18.5 °C (65.3 °F) and 22.8 °C (73.0 °F), respectively. During operation of the at the temperature in the PHC typically increases to a range of 20 to 24 °C 48 of 62

(70 to 75 °F). During this same recording period the average and median relative humidity were 61.9% and 70.5%, respectively. The range in monthly relative humidity, averaged over the 1 to 5 week recording periods and at the three (3) locations was 30.3% to 81.7%. The maximum average relative humidity for a single recording period in any of the 3 locations was 90% and will not exceed 95% during any 1-13 1 processing period.

The temperature in and around the PHC varies over a narrow range and does not have an inverse impact on the iodine-removal efficiencies of the filters. Relative humidity in and around the MURR 1-131 processing facility varies over a much wider range compared to temperature; and must be considered in conjunction with air-flow rate and the two iodine species (molecular iodine and methyl iodide) as discussed in the response to Question 7.a. When these determinants (temperature, relative humidity, air-flow rate and iodine speciation) are accounted for, the iodine-removal efficiency of the triethylenediamine/potassium iodide (TEDA/KI) impregnated filters is greater than 99%.

e. MURR 's license amendment request, Attachment 8, specifies that the Flanders/CSCfilters used in FilterBank No. 4 have a mechanical efficiency of at least 99.9 percent. However, the NRC staff is not clear how this value compares to the total (mechanical plus chemical) efficiency of these filters for their use as described in MURR 's license amendment request.

Explain.

The 99.9% stated on Attachment 8 of the original license amendment request is a Flanders specification that their adsorbers (filters) shall exhibit a minimum mechanical efficiency (the percentage of air that actually contacts the activated carbon in a system without penetrating voids or cracks) of 99.9% when tested in accordance with Institute of Environmental Sciences (IES) document JES-RP-CC-008-84, "Recommended Practice for Gas-Phase Adsorber Cells" (Ref. 15).

The iodine-retention efficiency of solid sorption materials such as the triethylenediamine/potassium iodide (TEDAiKI) impregnated. charcoal used in the Flanders filter is determined by a two-step mechanism in which the adsorbate must first make contact with the sorption material's surface. In the second step of the mechanism, a chemical reaction occurs that binds the adsorbate to the charcoal matrix. For example, CH 3 I reacts with TEDA to form a thermodynamically-stable quaternary ammonium salt as shown by the following reaction:

C 6H 12N2 + 2CH 31 -* {[C6H 12N2(CH 3) 212+[2I-]}

The second step in the mechanism has the mechanical efficiency as its upper limit. The so called chemical efficiency can be limited by relative humidity, when excessive, and/or air flow rate as discussed in the response to Question 7.a.

f. MURR 's license amendment request, Attachment 7, provides specificationsfor the CAMFIL filters used in FilterBank Nos. 1, 2, and 3. However, the NRC staff is not clear if the vendor 49 of 62

provides efficiency ratings (mechanical, chemical, or total) for the CAMFIL filters for their use as describedin MURR '.s license amendment request. Explain.

The vendor certifies that the CAMFIIL filters have a mechanical efficiency of 99.9%. These are triethylenediamine/potassium iodide (TEDA/KI) impregnated, nuclear-grade charcoal filters and will have an iodine-removal efficiency determined by the actual operating conditions and iodine speciation, which, in the case of the MIURR I- 131 processing facility translates to an iodine removal efficiency of >99% as discussed in the responses to Questions 7.a. through 7.e.

g. NRC RG 1.52, "Design, Inspection, and Testing Criteriafor Air Filtration and Adsorption Units of Post-Accident Engineered Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," provides guidance that a 99 percent carbon filter decontamination credit should be taken, provided that carbon filters comply with certain criteria. Clarify if these criteria are being met by providing the following additional inform ationfor the carbonfilters used in FilterBanks 1 through 4:

i. Total bed depth; ii. Ratedflow;"and, iii. Residence time associatedwith the ratedflow rate.

The below flow diagram (Figure 1) provides the amount of carbon, total bed depth, air flow rate and residence time for each charcoal filter bank. These values are specific to the Processing Hot Cell (PHC) because of the established air flow rate through this hot cell, but are typical of the other two (2) hot cells - Handling Hot Cell (HI-IC) and Dispensing Hot Cell (DHC).

50 of 62

iKesioence i mreLatcUlasipn Iot II-ICUeranK .

Residence Time = Net Screen Area x Bed Depthl Flow = (2.545 sq ft) (1.375 In) (1 ft/12 in) (60 sec/min)/1(47 cu ft/min)

-0.37 sec I 1.1 liters of Carbon Residence Time 0.42 se Bed Depth 1.417 inches Flow 5.5 cfm j 1.1 lIters of Carbon1 Residence Time 0.42 sec Bed Depth 1.417 inches Flow 5.5 cfm IBask No.2 j Residence Time CalIulatio~n fr Filter Ranks V .2&

Residence Time 1.27 sec Residence Time 1.27 sec J (0.00100003 cu meters/iiter) 160 sec/min) (1/5.5 cu JBed3.3Depth liters 1.969 of Carbon inches J3.3 liters 1.969 Bed Depth of Carbon inches Residence ft/min)

Time = (35.3147 Volume Carbon/

cu ft/cu Flow = (3.3 liters) meter)

Fiow 5.5dcm Fiow 5.5dcm = 0.42 seconds I TBan No.1 j HC-11B HC-11B Figure 1 - Flow Diagram Depicting Total Bed Depth, Rated Flow Rate and Residence Time Associated with Rated Flow Rate

8. The amendment request discusses the possible consequences of an accidental release of I-131 to the PHC. However, 1-131 releases"outside of the hot cells do not appear to be discussed in the amendment request.

a. Discuss whether any experiment failure could cause an 1-131 release during target irradiation.

The following analyses discuss a loss of target containment during irradiation of a target using realistic assumptions. Also presented at the end is a worst-case analysis of complete release of 150 Curies of 1-131 using extremely conservative, bounding assumptions.

Initial Conseqiuence (Gaseous 1-131 Release): The maximum temperature attained by a target having a diameter of 22 mm and length of 86 mm; and irradiated at the maximum 51 of 62

experiment ()

thermal flux permitted under the Reactor Utilization Request (RUR) (Ref. 14) governing this for a time adequate to reach thermal equilibrium; and having cumulative gaps (target-to-secondary encapsulation can and secondary encapsulation can-to-primary encapsulation can) no greater than a total of 0.2 mm measured on the radius; will not attain the melting temperature of * ). Under these conditions, the emanation of 1-131 from the target when the two (2) irradiation cans are punctured in a closed system under vacuum was measured to be 0.000025%. Therefore, if the two encapsulation cans were both to develop leaks during irradiation at the point when the maximum activity I-1 31) had been attained, a total I-131 activity of 14 1iCi could be released to and dissipated in the reactor pool.

Second Consecien u(Areous Leaching of I-131 from the Tageg_: 1-131 was water-leached from a sample (Can No. 127) from a full-size target irradiated (30 minutes) at peak flux in graphite reflector irradiation position "HI ." The results were extrapolated to a full-size target irradiated for at its peak 1-131 activity ( *). The leaching time was 16.75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months at 0 0 approximately 25 C (77 F). There were four (4) distinct dissimilarities in experimental leaching conditions compared to those that would be experienced in the case of a leak-induced flooded target can. These are:

1. Temperature: The leaching experiment was carried out at approximately 25 °C (77 "F) and the temperature of the water in a flooded can both during irradiation and post-irradiation are variable and unknown.

2. Leaching Time: The leaching time from submersion of the test sample to sampling the leachate was 16.75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months and is not determinable in a flooded can.

3. The leaching experiment was done with a finely ground sample having an estimated surface area of 50 m2/g. The target ingot has a surface of 0.042 m2/g. This difference in surface area would be expected to substantially enhance I-131 leaching from the powdered test sample compared to the target ingot. Nevertheless, no correction was made for this difference in surface area.

4. The test sample powder was completely submerged in water in the leaching experiment.

Because of the small void (=2 cm 3) in the secondary encapsulation can, only a fraction of the target ingot will be in contact with the water. No correction was made for this difference in water-* contact.

Based on the experiment described above, and not correcting for the dissimilarities between the leaching experiment and the actual target environment (Items 1 through 4), the estimated I-131 activity leached from a full-size target in a flooded can at its peak 1-131 activity of ll is not expected to exceed 0.35 mCi and would be expected to be dissolved in the water in the form of 1, IO- and IO3~, the distribution among these species dependent on pH.

52 of 62

In summary, a gaseous release of 1-131 followed by 1-131 leaching from an accidentally flooded target at its maximum 1-131 activity during irradiation would not result in a significant radiation exposure to MiURR staff or the general public.

Additionally, as discussed in the response to Questions 6, the safety analysis for a target irradiation (current Administrative limit) (Ref. 14), MUIRR assumed a worst-case scenario of a total release of all of the theoretical activity () from the target material into the reactor pool whether it is single or double encapsulated. Using a very conservative ten (10) minute stay time (typical evacuation time is about 2 minutes), an individual in the containment building would receive a Total Effective Dose Equivalent (TEDE) of 125.79 mrem. An individual at the point of maximum concentration in the unrestricted area would receive a TEDE of 0.00 6 mrem. If you ratio this activity to the maximum activity of 150 Curies of 1-131 proposed by new Technical Specification (TS) 3.6.p, an individual in the containment building and at the point of maximum concentration in the unrestricted area would receive a TEDE of 214.41 mrem and 0.01 mrem, respectively. Once again, these doses are based on an unrealistic total release of 150 Curies of I-131 and an extremely conservative stay time (by a factor of 5) in containment during the release.

This analysis is bounded by the current MUJRR TSs, specifically fueled experiments.

b. Discuss whether any experiment failure could cause an 1-131 release during movement of irradiatedtargetsfrom the irradiationposition to the HHC.

A credible scenario where any experiment failure could cause an 1-131 release during movement of the irradiated targets from the irradiation position (reactor pool) to the Handling Hot Cell (ITHC) is unable to be identified as all movement occurs in a dedicated, robust and sealed transfer cask which has been in use at MUJRR for over 30 years without incident. However, the release of 1-131 was measured in a full-size target by puncturing the sealed primary and secondary irradiation cans in a closed system under vacuum - See the response to Question 8.a. When extrapolated to a target having the maximum normal operational 1-131 activity () and a fraction available for release of 2.5E-7 [based on the gaseous release fraction described in the response to Question 8.a, Initial Conseqiuence (Gaseous 1-131 Release)], a total of 14 piCi is available to be released to the restricted area within the MIURR as the target is being transferred to the EHHC which corresponds to personnel radiation exposures to well within annual 10 CFR 20 limits in even the most conservative assumptions.

c. The NRC staff noted, in Attachment 25, Section 6.4, of the licensee's letter dated January 28, 2015 (ADAMS ML15034A474), an evaluation for a spill of 1-131 solution outside the hot cells. However, this accident does not appear to be discussed in the amendment request.

Provide an explanation.

The product solution is transferred to its transportation container remotely through a series of air lock seals via the floor port of the Dispensing Hot Cell (DHC). Therefore, there is no credible accident scenario where a spill of the product solution onto the laboratory floor exists as discussed in Attachment 25, Section 6.4 of the licensee's letter dated January¢ 28, 2015 (ADAMS 53 of 62

ML15034A474). That analysis was performed as an original scoping study to determine what quantities of 1-131 could safely be handled outside of the hot cells, if desired. The only product solution from this experiment handled outside of the hot cell is that used for U.S. Food and Drug Administration (FDA) quality analysis which is administratively controlled per the MURR Project Authorization process to activity levels inherently safe within the restricted and unrestricted areas without the presence of engineered safety features.

d. Discuss whether any experimentfailure, other than those indicated in items a., b., or c., above, or in responses to those items, could cause an 1-131 release outside of the hot cells.

No credible experiment failures other than those indicated in items a., b. and c. have been identified that can cause a release of I-131 outside of the hot cells.

9. Accidental airborne releases of any radioactive materials other than 1-131 (such as other isotopes of iodine, or activation products of target impurities), or toxic materials, inside or outside the hot cells do not appear to be discussed in the amendment request. Discuss whether otherfailures exist that could cause these releases to occur at any point during the experiment.

The following response (in Part 1) addresses the expected release of radioactive Xe-131im, which will occur under normal of the irradiated targets. This is not an "accidental airborne release" but is included here in response to verbal discussion of the RAIs including NRC and MURR staff on December 7, 2015, during which the release of Xe-131im was discussed. In Part 2 of this response, potentially activation products from impurities in the

~targets, are discussed.

Part 1: Xenon-131m Production from Decay of 1-131 Xe-i131 m (half-life =11.84 days) is produced through a minor pathway (shown below) from the decay of I-131. The maj or pathway for the decay of I-131 produces stable Xe-1 31 directly.

.023 da B3f Ct2) I84 11.X da C1oD%)

Published values for the f2 branching ratio for the decay of 1-131 into Xe-131im are in the range of 0.39% to 1.3% and are summarized in Table 1 below along with the respective source for each.

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Table 1 - Branching Ratio Values (%) for the I-131 to Xe-i131 m Minor Decay Pathway from Seven Different Sources Branching Ratio (f2 %) Source 0.39 IAEA/Nuclear Data sheets 0.43 Table of Isotopes 0.48 INEL/GECAT 1.0 Personal communication *, ITD) 1.1 Idaho Isotopes Inc. Datasheet 1.2 Applied Radiation & Isotopes, 68 1846-54 (2010) 1.3 World Health Organization The Xe-i131 m activity produced when a target is irradiated for the maximum irradiation time (*) at the maximum neutron flux () was calculated using f2 =1.0% and the results are shown in Figure 1 below. The Xe-131im activities at the end of the irradiation (EOI), at the anticipated processing time (EOI+24 hours), and at its peak activity (EOI+l191 hours) are 0.201 Curies, 0.217 Curies and 0.263 Curies, respectively.

These calculated activities are conservative compared to the peak Xe-i331 m activity (0.207 Curies) measured experimentally using a 100 microgram target and then scaled to the parameters under which the calculated maximum Xe-i13 lm activity (0.263 Curies) was obtained.

At the Xe-i131 m calculated activity (0.217 Curies) at the time of anticipated

~(EOI+24 hours) the requirements of Technical Specifications 3.6.c and 3.7.a are satisfied and would continue to be satisfied if processing occurred at the peak Xe-i131 m calculated activity (0.263 Curies), which occurs at 191 hours0.00221 days 0.0531 hours 3.158069e-4 weeks 7.26755e-5 months following the end of the irradiation.

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Xe-I 31 m activity (Ci) from a maximum-activity target atpeak neutron flux) 0.30 0.25 5 0.20 e0.15 E

o*0.10 0.05 0.00 0 100 200 300 400 500 600 700 total lapsed time (hours) from start of irradiation (0 hours0 days 0 hours 0 weeks 0 months ) start processing (eoi+24 hours) 0.217 Ci

-- peak Xe-I131 m activity (eoi+1 91 hours0.00105 days 0.0253 hours 1.50463e-4 weeks 3.46255e-5 months ) 0.263 Ci Figure 1 - Xe-135m Activity from a Target Part 2: Activation Products from an Impurity Prior to selecting material from which targets would be fabricated, test samples were obtained from five (5) suppliers and these were analyzed for 24 trace-element constituents by a combination of Neutron Activation Analysis (NAA) and Inductively-Coupled-Plasma Mass Spectroscopy (ICP-MS). From these in-house analyses, the certificates of analysis for the five (5) products were confirmed. The highest purity (99.995%) was selected for producing the targets to be used in producing I-131.

a. Iodine-128: In the five (5) products analyzed, iodine ranged from 0.47 F.g/g in the product selected to 1.45 gg/g in one of the products rejected. All stable iodine is 1-127, which forms 1-128 (half-life =24.99 minutes) by the following nuclear reaction: 1-127 (n,'y) I-128. For the maximum iodine impurity concentration measured (1.45 *tg/g) in the maximum target mass (I) at the maximum irradiation time *) and the maximum neutron flux (), the peak 1-128 activity (0.0331 Curies) occurs at EOI and will have decayed completely (1.5E-l19 Curies) at the anticipated time of processing (EOI+24 56 of 62

hours). If all the 1-128 activity were released to the environment at EOI, the release limits imposed by Technical Specifications (TSs) 3.6.c or 3.7.a. would be satisfied.

b. Selenium-75: Selenium is potentially under the dry-distillation conditions. Selenium forms radioactive Se-75, half-life 119.8 days through the following nuclear reaction: Se-74 (n,y) Se-75.

The selenium concentration in the five (5) different products tested ranged from <0.5 jig/g, in the 99.995% product selected, to 1.4 *tg/g in a source listed as having a purity of 99+% that was rejected.

Assuming the worst-case selenium concentration of the products tested (1.4 jgg/g), a irradiation of a target, the maximum thermal neutron flux ( *

), and no neutron attenuation by the target, the maximum Se-75 activity produced would be 0.0002 12 Curies. Assuming the entire amount of Se-75 activity were released (100%

~of the activated Se-75 impurity, and no retention by the in-line separator, aqueous traps or charcoal filters) would not result in a Se-75 release in excess of the limits imposed by TSs 3.6.c or 3.7.a. Experimentally, we have not observed any Se-75 activity in the 3-component trap attached to the exhaust line from the product-collection traps in the Processing Hot Cell (PHC). Consequently, no release of Se-75 to the environment is anticipated under normal conditions.

10. The NRC staff noted that the proposed MURR TS 3.6, Specification p, limits the 1-131 inventory of a non-fueled experiment to 150 curies. However, the current MURR TS 3.6, Specification c, appears to limit non-fueled experiments to "that amount of material such that the airborne concentration of radioactivity averaged over a year will not exceed the limits of Appendix B, Table I of 10 CFR Part 20. Exception: Fueled experiments (See Specification 3. 6a)." Explain how the limits of TS 3.6, Specification c, and proposed TS 3.6, Specificationp, are satisfiedfor the proposed Iodine production.

Current MIURR Technical Specification (TS) 3.6.c will be revised to read, "Where the possibility exists that the failure of an experiment could release radioactive gases or aerosols to the reactor bay or atmosphere, the experiment shall be limited to that amount of material such that the airborne concentration of radioactivity averaged over a year will not exceed the limits of Appendix B, Table I of 10 CFR Part 20. Exception: Fueled and non-fueled experiments that produce iodine 131 through 135 (See Specifications 3.6.a and 3.6.p)."

This revision to TS 3 .6.c will satisfy the radioactive airborne concentration limits of the proposed iodine processing facility.

11. The proposed TS 3.11, Specifi cation c, lists Radiation Monitoring Channels in a table, with item no.

2 identified as the Iodine-131 ProcessingHot Cells Radiation Monitor. The amendment request, Section 5.0O, "Radiation Monitoring Equipment," refers to a 1-131 ProcessingLaboratory Exhaust 57 of 62

Duct Monitor for each hot cell, and also describes the ALMO-6 Hot Cell Dose Rate Radiation Monitor, which is a six detector system that includes one detector location at the operator's work station of each of the three hot cells, and one detector located in each of the bays above the three hot cells.

a. Clarify whether the 1-131 ProcessingLaboratoiy Exhaust Duct Monitorsfor each of the three hot cells are the same as the three detectors "located in each of the bays above the three hot cells. "

The "1-131 Processing Laboratory Duct Monitor" (singular) is NOT the "Iodine-131 Processing Hot Cells Radiation Monitor" as listed in proposed Technical Specification 3.11l.c.2. As described in the third paragraph of Section 5.0 (page 14) of the original license amendment request, "The I-131 Processing Laboratory Exhaust Duct Monitor consists of a radiation detection system designed to measure airborne concentrations of radioactive iodine in the exhaust air that is sampled by a shrouded probe in the ventilation ducting immediately downstream of all of the 1-131 hot cell and room filtration systems. The system is capable of measuring real-time exhaust flow rate as its basis for release concentrations. A pitot tube measurement device and flow transmitter provides input to the system. The radiation monitor can be seen in the upper section of Figure 6."

The 1-131 Processing Laboratory Duct Monitor samples the combined air from a single, common duct downstream of all three (3) hot cells, not each individual cell. The 1-131 Processing Laboratory Duct Monitor is similar to the facility Stack Radiation Monitor; however, it only has a single detector that measures radioactive iodine whereas the facility Stack Radiation Monitor has three (3) detectors that measure particulate, iodine and noble gas. The 1-131 Processing Laboratory Duct Monitor is pointed out in MUIRR Drawing No. 1125, Sheet 5 of 5 (Attachment 12). No proposed TS requirement is being imposed upon this piece of equipment.

b. Clarify whether the Iodine-131 ProcessingHot Cell Radiation Monitor in proposed TS 3.11, Specification c, item no. 2, refers to the detector "located in each of the bays above the three hot cells, "for the PHC only, to the detectors "located in each of the bays above the three hot cells, "for all three hot cells, or to the entire six-detector AL*MO-6 Hot Cell Dose Rate Radiation Monitorsystem.

The "Iodine-i131 Processing Hot Cells Radiation Monitor" proposed by new Technical Specification (TS) 3.11 .c.2 refers to the entire six-detector ALMO-6 Hot Cell Dose Rate Radiation Monitor system. The ALMO-6 monitors all three (3) of the 1-131 hot cells [Handling Hot Cell (HIHC); Processing Hot Cell (PHC) and Dispensing Hot Cell (DHC) with two (2) detectors for each hot cell as described in detail below].

The Iodine- 131 Processing Hot Cells Radiation Monitor listed in proposed TS 3.11 .c.2 is a single-channel radiation monitoring system that incorporates six (6) detectors. As described in Section 3.0 and 5.0 of the original license amendment request, "The ALMO-6 Hot Cell Dose Rate Radiation Monitor, as described in Section 3.0, consists of a six (6) detector radiation monitoring system 58 of 62

designed to provide radiation dose level information to the process operators. Three (3) of the detectors (G-M) are located at the operator's work station where the hot cell manipulators are located. These detectors provide real time dose rate information to the operators when they are performing a process. The remaining three (3) detectors (G-M) are located next to the first in a series of charcoal filters (Bank No. 2 and No. 3) located in each of the bays above the three (3) hot cells. These are designed to give the process operators real time information related to the capture and loading of I- 131 onto the first charcoal filter in each external bank of the individual cells. This allows the process operators to monitor the condition of the charcoal filters and will alert them of the need to change to a bank of alternately available filters. The ALMO-6 radiation monitor shall be in operation when processing, as required by the proposed TSs. It is referred to as the "Iodine-131 Processing Hot Cells Radiation Monitor" in the TSs."

c. Provide a basis for the TS requirement of one, rather than two, operable radiationmonitors above each hot cell.

As stated in the "Exception" to proposed Technical Specification (TS) 3.11 .c.2, "When the required radiation monitoring channel becomes inoperable, then other radiation detection instruments may be substituted for the normally installed monitor in specification 3.11 .c.2 within one (1) hour of discovery for a period not to exceed one (1) week." Should any one of the detectors fail on the Iodine-1 31 Processing Hot Cell Radiation Monitor, then a portable instrument may be substituted for the normally installed detector. See the Response to Question 12 below for further information regarding the functionality of a replacement instrument. As stated above, one of the two purposes of the Iodine-i131 Processing Hot Cell Radiation Monitor is to provide the process operators real time information related to the capture and loading of 1-131 onto the first charcoal filter in each external bank of the individual cells. MUIIRR feels that this "Exception" provides sufficient redundancy for this purpose.

Additionally, the facility Stack Radiation Monitor, as described in proposed TS 3.11 .c.2, also provides information regarding hot cell filtration loading by monitoring all of the air exiting the MURR facility through the ventilation system exhaust stack for airborne radioactivity.

Finally, as discussed in the response to Question l1l.a, the 1-131 Processing Laboratory Duct Monitor also samples the air from a single, common duct downstream of all of the hot cells for radioactive iodine. All three (3) of these radiation monitoring systems ensure that the air effluents of all three (3) 1-131 hot cells are continuously monitored for radioactive iodine.

12. The proposed TS 3.11, Specification c, Exception, provides information which allows the use of a portable monitor as a substitute for the monitors listed in the accompanying table. It is not clearly described in the TS or Basis how a portable monitor will be capable of providing all the functions of the permanently installed monitors as described in Section 5.0 of the amendment request, e.g.,

audible and visual alarms, display and record of output, etc. Explain.

59 of 62

IVIURR will utilize portable radiation monitors, if needed, with the same safety functions that the "Iodine-13 1 Processing Hot Cells Radiation Monitor" provides. For example, one potential substitute currently available for MUJRR is electronic alarming dosimeters with installed telemetry modules which are capable of providing all of the same functions (e.g. audible and visual alarms, and display and record of the detector outputs) of the permanently installed "Iodine-i131 Processing Hot Cells Radiation Monitor" as described in Section 5.0 of the original license amendment request. It is also noted that, under administrative control, processing personnel are required to wear electronic alarming dosimeters and ambient room air will be continuously monitored for radioactivity.

13. The proposed TS S. 7, Specifications c and d, require that the radiationmonitors listed in proposed TS 3.11, Specifi cation c, be calibrated semi-annually and tested monthly. Provide a basisfor these surveillance requirements.

Section 4, Surveillance reciuirements, of American National Standard ANSIIANS-15. 1-2007, "The Development of Technical Specifications for Research Reactors," establishes surveillance intervals for radiation monitoring systems and effluents (Ref. 16). For operability, including, where possible, source checks, the frequency is monthly to quarterly. For calibrations, the frequency is annually to biennially. The proposed surveillance intervals for the Iodine 131 Processing Hot Cells radiation monitoring equipment are as often or more frequent than specified in ANSI/ANS-l 5.1-2007.

Current MIURR Technical Specifications (TSs) 5.4.a and 5.4.b state, "All instruments, as required by these specifications, shall be calibrated on semi-annual intervals" and "Radiation monitoring instrumentation as required by these specifications shall be checked for operability with a radiation source at monthly intervals," respectively. Any radiation monitoring instrumentation required by the current TSs falls into the category of "all instruments."

The "Stack Radiation Monitor" mentioned in proposed TS 3.11 .c. 1 is the same "Stack Radiation Monitor" as required by current TS 3.4.a. As described in Section 5.0, "Radiation Monitoring Equipment," of the original license amendment request, the "Stack Radiation Monitor" monitors all of the air exiting the MURR facility through the ventilation system exhaust stack for airborne radioactivity. This includes the containment and laboratory buildings as well as all of the facility hot cells, fume hoods and gloveboxes. The intent was to create specifications specific to the Iodine-131 Processing Hot Cells to avoid confusion with other TSs; hence, proposed TSs 5.7.c and 5.7.d for the "Stack Radiation Monitor" are the same surveillance frequencies as current TS 5.4.a and 5.4.b since it is the same instrument.

The "Iodine-131 Processing Hot Cells Radiation Monitor" mentioned in proposed TS 3.1 1.c.2 is the "ALMO-6 Hot Cell Dose Rate Radiation Monitor" described in Section 5.0 of the original license amendment request. It is a single-channel radiation monitor with six (6) detectors, measuring radiation dose in front of each hot cell as well as the exhaust filtration system on top of each hot cell. The ALMO-6 Operating Manual (Attachment 1 of the original license amendment request) 60 of 62

does not provide a calibration procedure or frequency. In Section 8 of the manual (page 66) it states that the instrument does not require any particular maintenance. The vendor was also contacted and confirmed that the instrument does not require periodic calibration. However, following the guidance of ANSI/ANS-l15.1-2007 and the frequency of calibration of other TS-required radiation monitoring instrumentation, the "Iodine-i131 Processing Hot Cells Radiation Monitor" will be calibrated on a semiannual basis and checked for operability with a radiation source at monthly intervals, as stated in proposed TSs 5.7.c and 5.7.d. As stated in the bases of these proposed surveillance TSs, "Semiannual channel calibration of the radiation monitoring instrumentation will assure that long-term drift of the channels will be corrected" and "Experience has shown that monthly verification of operability of the radiation monitoring instrumentation is adequate assurance of proper operation over a long time period."

14. The current revision of the MURR Emergency Plan is Revision 17, dated October 17, 2014. Given the changes to the facility as described in the amendment request, discuss whether any changes are needed to the MURR Emergency Plan.

On page 1, third paragraph of the MUJRR Emergency Plan (EP) (Revision 17, dated October 17, 2014) (Ref. 17), it states, "The plan contains a description of the elements of advance planning to cope with emergency situations connected with operation of MUIIRR and the conduct of experiments at M7URR. The plan focuses primarily on handling of situations that may cause or threaten to cause radiological hazards affecting the health and safety of University of Missouri staff or the public. It outlines the objectives to be met by the emergency procedures and defines the authority and responsibilities to achieve these objectives." Additionally, on page 9, under Section 3.3 Alert, it states, "Situations that may lead to this class include: ... .2. Significant releases of radioactive materials as a result of experiment failures."

MURR feels that these statements adequately envelop the experiment described in the original license amendment submittal and that no changes to the MURR EP are required. MURR EP implementing procedure EP-RO-006, "Radiological Emergency," was revised to address any radiological emergencies associated with the Iodine-i131 Processing Hot Cells (Ref. 18).

Furthermore, eighteen (18) response procedures have been developed to safeguard personnel and equipment associated with operation of the Iodine-13 1 Processing Hot Cells (Ref. 19).

Additionally, Attachment 13 shows the Emergency Planning Zone (150 meters from the facility ventilation exhaust stack) and the site boundary. Definition 9.19, Site Boundarv, of the MIURR EP states, "The site boundary is that boundary listed in the on-site definition, not having restrictive barriers, surrounding the operations boundary wherein the reactor administrator may directly initiate emergency activities. The area within the site boundary may be frequented by people unacquainted with the reactor operations." Definition 9.13, Onsite, of the MUJRR EP states, "The part of the University owned and controlled grounds that lie within the following site boundaries:

south of Stadium Boulevard; west of Route K (Providence Road); north of the MU Recreation Trail; east of the MKT Nature and Fitness Trail. The University of Missouri owned and controlled grounds extend beyond these boundaries but are not included in our definition of "on-site"."

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Additionally, the bases for proposed Technical Specification (TS) 3.11 .c and the wording of proposed TS 5.7.b were revised based on the discussion the NRC and MIURR staff had on December 7, 2015.

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Case Summary of MURR Transfer Cask Pg l off 3 Page ATTACHMENT 1 MicroShield 8.02 University of Missouri (8.00-0000)

D~ate I By IChecked Filename I Run Date IRun Time IDuration MURR Transfer Cask.msd December 8, 2015 3:11:54 PM 00:00:00 J Project Info Geometr 10 - Cylinder Surface - External Dose Point Source Dimensions Height I1.0 cm (0.4 in)I Radius 5.08 cm (2.0 in)

Dose Points A X Y Z

1 17.8 cm (7.0 in) I0.0 cm (0 in) j0.0 cm (0 in) )

2 117.8 cm (3 ft 10.4 in) 0.0 cm (0 in) 0.0 cm (0 in)

Shields ______7____

Cyl. Radius 5.08 cm Air 0.00122 Shield 1 12.7 cm Lead 11.32 Transition ________ Air 0.00122 Air Gap _______ Air 0.00122 SouceInpt:Grouping Method - Standard Indices Number of Groups: 25 Lower Energy Cutoff: 0.015 Photons < 0.015: Included Grove 1-lieI131

__________Library:

C* m2 a~i/i z i cmji Na-24 8.1100~e-003 3.0007e+008 2.5408e+002 9.4011 e+006 2.6500e+001 9.8050e+011I 8.3024e+005 3.0719e+010 5.6700e+000 2.0979e+011 1.7764e+005 6.5727e+009 1 .9500e+002 7.21 50e+012 6.1093e+006 2.2604e+011I 1.1600e+001 4.2920e+011 3.6342e+005 1.3447e+010 2 .5000e-004 i 9.2500~e+006 7.8324e+000 2.8980e+005 7.1700e+000 2.6529e+011 2.2463e+005 8.3115e+009 2.6100e+-001 9.6570e+01 1 8.1771e+005 3.0255e+010 Buildup: The material reference is Shield 1 Integration Parameters Y Direction (axial) I 20 I

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Case Summary of MURR Transfer CaskPae2o3 Page 2 of 3 ATTACHMENT 1 Circumferential I 20

____________ ~Results - Dose Point # 1 - (17.8,0,0) cm ______

Fiuence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2/sec MeV/cm 2 /sec nmR/hr mR/hr No Buildup With Buildup No Buildup With Buildup 0.015 2.336e+11 0.000e+/-00 8.379e-21 0.000e+00 7.187e-22 0.03 1.560e+12 0.000e+00 1.151le-19 0.000e+00 1.140e-21 0.04 1.362e+10 0.000e+00 1.376e-21 0.000e+00 6.088e-24 0.06 1.623e+09 8.159e-283 2.660e-22 1.621 e-285 5.283e-25 0.08 2.563e+11 1.632e-128 6.276e-20 2.582e-131 9.93 le-23 0.1 7.933e+-10 0.000e+00 7.705e-04 0.000e+00 1.179e-06 0.15 8.911le+l1I 2.713e-114 9.961 e-18 4.467e-117 1.640e-20 0.2 1.987e+l11 1.593e-53 1.464e-19 2.81 le-56 2.583e-22 0.3 6.642e+ -11 2.975e- 17 5.526e- 17 5.644e-20 1.048e- 19 0.4 6.715e+12 5.251e-06 1.221e-05 1.023e-08 2.379e-08 0.5 7.058e+ 10 1.068e-03 2.925e-03 2.097e-06 5.742e-06 0.6 7.229e+1 1 1.872e+00 5.528e+00 3.653e-03 1.079e-02 0.8 1.038e+12 4.923e+02 1.651 e+03 9.363e-01 3.141 e+00 1.0 3.176e+11 2.169e+03 7.755e+03 3.999e+00 1.430e+01 1.5 2.103e+10 3.018e+03 1.113e+04 5.077e+00 1.873e+01 2.0 3.962e+ 10 1.799e+04 6.688e+04 2.782e+01 1.034e+02 3.0 2.997e+08 3.420e+02 1.236e+03 4.640e-01 1.677e+00 4.0 1.923e+05 3.036e-01 1.060e+00 3.756e-04 1.31 le-03 Totals 1.282e+13 2.401le+04 8.867e+04 3.830e+01 1.413e+02

____________ ~ Results - Dose Point # 2 - (117.8,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm 2 /sec mR/hr mR/hr

_________ ______________No Buildup With Buildup No Buildup With Buildup 0.015 2.336e+11 0.000e+00 1.763e-22 0.000e+00 1.512e-23 0.03 1.560e+ 12 0.000e+00 2.421 e-2 1 0.000e+00 2.399e-23 0.04 1.362e+ 10 0.000e+00 2.896e-23 0.000e+00 1.281 e-25 0.06 1.623e+09 2.158e-284 5.596e-24 4.286e-287 1.1 12e-26 0.08 2.563e+11 3.347e-130 1.320e-21 5.297e- 133 2.089e-24 0.1 7.933e+ 10 0.000e+00 1.621 e-05 0.000e+00 2.480e-08 0.15 8.91le~l 1 5.546e-116 2.096e-19 9.133e-119 3.451 e-22 0.2 1.987e+ 11 3.385e-55 3.080e-21 5.974e-58 5.435e-24 0.3 6.642e+11 6.415e-19 1.190e-18 1.217e-21 2.258e-21 0.4 6.715e+12 1.118e-07 2.598e-07 2.178e-10 5.063e-10 0.5 7.058e+ 10 2.260e-05 6.187e-05 4.435e-08 1.215e-07 0.6 7.229e+11I 3.946e-02 1.165e-01 7.703e-05 2.275e-04 0.8 1.038e+12 1.034e+01 3.469e+01 1.967e-02 6.598e-02 1.0 3.176e+ 11 4.548e+01 1.625e+02 8.384e-02 2.996e-01 1.5 2.103e+10 6.313e+01 2.328e+02 1.062e-01 3.916e-01 2.0 3.962e+10 3.763e+02 1.398e+03 5.819e-01 2.162e+00 file :///Z:/MicroShield/MURR%20Transfer%20Cask.html12805 12/8/2015

Case Summary of MURR Transfer CaskPae3o3 Page 3 of 3 ATTACHMENT 1 3.0 2.997e+08 7.156e+O0 2.585e+01 9.708e-03 3.507e-02 4.0 I 1.923e+05 6.357e-03 2.218e-02 7.864e-06 2.744e-05 Totals I 1.282e+13 5.024e+02 1.854e+03 8.014e-01 2.955e+00 file :///Z:/MicroShield/M URR%20Transfer%20Cask.html12805 12/8/2015

Case Summary of ITD Transfer Cask Pg 1 off 3 Page ATTACHMENT 2 D~ate By ICheckedJ Filename IRun Date I Run Time IDuration]

lTD TransferCask.msd December 8, 2015 3:10:44 PM 00:00:00 J Project Info Case Title ITD Transfer Cask Description Geometr 10 - Cylinder Surface - External Dose Point Source Dimensions Height I1.0 cm (0.4 in)I Radius 5.08 cm (2.0 in)

Dose Points

1/

2 20.4 cm (8.0 in) 120.4 cm (3 ft 11.4 in)

I0.0 cm (0 in) 0.0 cm (0 in) 0.0 cm (0 in)v 0.0 cm (0 in)

_,4 Shields _____ 7_____

Shield N Dimension Material Dest Cyl. Radius 5.08 cm Air 0.00122 Shield 1 15.24 cm Lead 11!.32 Transition ________ Air 0.00122 Air Gap _______ Air 0.00122 Source Input: Grouping Method - Standard Indices Number of Groups: 25 Lower Energy Cutoff: 0.015 Photons < 0.015: Included

___________Library: Grove Na-24 8.1100~e-003 3.0007e+008 2.5408e+002 9.4011 e+006 Sl 2.6500e+001 9.8050e+011 8.3024e+005 3.0719e+010 5.6700e+000 2.0979e+011 1.7764e+005 6.5727e+009 1.9500e+/-002 7.2150e+012 6.1093e+006 2.2604e+011I 1 .1600e+001 4.2920e+01 1 3.6342e+005 1.3447e+010 2.5000e-004 9.2500e+006 7.8324e+000 2.8980e+005 7.1 700e+000 2.6529e+01 1 2.2463e+005 8.311 5e+009 2.6100e+00I 9.6570e+/-01 1 8.1771 e+005 3.0255e+010 Buildup: The material reference is Shield 1 Integration Parameters Y Direction (axial) I 20 I

file:///Z :/MicroShieldiITD%*20TransferCask.html12805 12/8/2015

Case Summary of lTD Transfer CaskPae2o3 Page 2 of 3 ATTACHMENT 2 2.400lc I CRrcumf-Doereonti#1-a 2 Results Dose Point # 1 (20.4,0,0) cm Fluence Rate Fluence Rate [Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm 2/sec mR/hr mR/hr

_______________________No Buildup With Buildup No Buildup With Buildup 0.015 2.336e+/- 1 0 .000e+00 6.249e-21 0.000e+00 5.360e-22 0.03 1.560e+12 0.000e+00 8.582e-20 0.000e+00 8.505e-22 0.04 1.362e+10 0.000e+00 1.027e-21 0.000e+00 4.540e-24 0.06 1.623e+09 0.000e+00 1.984e-22 0.000e+00 3.940e-25 0.08 2.563e+1 1 2.579e-155 4.681e-20 4.081e-158 7.407e-23 0.1 7.933e+10 0.000e+00 5.746e-04 0.000e+00 8.791e-07 0.15 8.91 le+l1I 2.017e-138 7.430e-18 3.322e-141 1.223e-20 0.2 1.987e+/-11I 1.944e-65 1.092e-19 3.430e-68 1.927e-22 0.3 6.642e+11I 4.253e-22 6.652e-19 8.068e-25 1.262e-21 0.4 6.715e+12 7.458e-09 1.808e-08 1.453e-11 3.523e-11 0.5 7.05 8e+1 0 1.006e-05 2.922e-05 1.975e-08 5.736e-08 0.6 7.229e+11I 4.633e-02 1.463e-01 9.042e-05 2.856e-04 0.8 1.038e+12 3.157e+01 1.155e+02 6.005e-02 2.197e-01 1.0 3.176e+11 2.224e+02 8.805e+02 4.100e-01 1.623e+00 1.5 2.103e+10 5.116e+02 2.150e+03 8.607e-01 3.616e+00 2.0 3.962e+10 3.592e+/-03 1.538e+04 5.555e+00 2.378e+01 3.0 2.997e+08 7.528e+01 3.185e+02 1.021e-01 4.322e-01 4.0 1.923e+05 6.730e-02 2.781 e-01 8.325e-05 3.441 e-04 Totals 1.282e+13 4.433e+03 1.884e+04 6.988e+00 2.967e+01

____________ ~ Results - Dose Point # 2 - (120.4,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2/sec MeV/cm 2/sec mR/hr mR/hr

__No__Buildup___With Buildup NoBuldupL With Buildup 0.015 2.336e+11I 0.000e+00 1.687e-22 0.000e+00 1.447e-23 0.03 1.560e+12 0.000e+00 2.317e-21 0.000e+00 2.297e-23 0.04 1.362e+ 10 0.000e+00 2.772e-23 0.000e+00 1.226e-25 0.06 1.623e+09 0.000e+00 5.3 57e-24 0.000e+00 1.064e-26 0.08 2.563e+ 11 6.692e- 157 1.264e-21 1.059e- 159 2.000e-24 0.1 7.933e+ 10 0.000e+00 1.552e-05 0.000e+00 2.374e-08 0.15 8.91 le-fl11 5.213e-140 2.006e-19 8.584e-143 3.304e-22 0.2 1.987e+1 1 5.211le-67 2.948e-21 9.197e-70 5.203e-24 0.3 6.642e+ 11 1.168e-23 1.796e-20 2.216e-26 3.407e-23 0.4 6.715e+12 2.029e-10 4.920e-10 3.954e-13 9.586e-13 0.5 7.058e+10 2.724e-07 7.913e-07 5.346e-10 1.553e-09 0.6 7.229e+1 11 1.251 e-03 3.952e-03 2.442e-06 7.7 14e-06 0.8 1.038e+12 8.500e-01 3.110e+00 1.617e-03 5.915e-03 1.0 3.176e+11 5.977e+00 2.366e+01 1.102e-02 4.361 e-02 1.5 2.103e+ 10 1.372e+01 5.763e+01 2.308e-02 9.695e-02 2.0 3.962e+10 9.631e+01 4.121e+02 1.489e-01 6.373e-01 file :/!Z :/M icroShield/ITD%20TransferCask.htm I1//01 12/8/2015

Case Summary of ITD Transfer CaskPae3o3 Page 3 of 3 ATTACHMENT 2 3.0 2.997e+08 2.019e+f00 8.540e+00 2.739e-03 1.159e-02 I 4.0 1 I.923e+05 I1 .806e-03 I7.460e-03 I2.234e-06 I9.229e-06 Totals 1.282e+13 1.189e+02 5.051e+02 1.874e-01 7.954e-01 fi le:/i/Z :/M icroShield/ITD%20TransferCask.html12801 12/8/2015

Case Summary of HHC and PHC Dose Page Pg 1 off 2 ATTACHMENT 3

~MicroShield University of Missouri8.02 (8.00-0000)

Date I By IChecked Filename IRun Date I Run Time I Duration PHC lDose.msd December 29, 2015 2:04:29 PM 00:00:00 Project Info Case Title HHC and PHC Dose Description Nominal Dose to Operators Geometr 1 - Point Dose Points AI X YZ

1 100.0 cm (3 ft 3.4 in) I0.0 cm (0 in) I0.0 cm (0 in)

2 150.0 cm (4 ft 11.1 in) 0.0 cm (G in) 0.0 cm (G in) hields_______

S______ _____

Shield N Shield 1 Shield 2 1

J Dimension J 20.0 cm 80.0 cm I Material Air Lead Density 0.00 122 11.32 Air Gap J____ ___ Air 0.00122 _ _________

Source Input: Grouping Method - Standard Indices Number of Groups: 25 Lower Energy Cutoff: 0.015 Photons < 0.015: Included Library: Grove Nuclide_____Ci Bg Na-24 __8.0000e-003 2.9600e+008

____2.6500e+001 9.8050e+01 1 5.6700e+000 2.0979e+011I

____1.9500e+002 7.2150e+012 1.1600e+001 4.2920e+011I

____2.5000e-004 9.2500e+006 l7.1700e+000 2.6529e+01 1 2.6100~e+$001 9.6570e+011I Buildup: The material reference is Shield 2

____________ ~ Results - Dose Point #11 - (100,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm 2 /sec mR/hr mR/hr

_______________________No Buildup With Buildup No Buildup With Buildup 0.015 2.336e+11I 0.000e+00 2.442e-22 0.000e+00 2.094e-23 0.03 1.560e+12 0.000e+00 3.353e-21 0.000e+00 3.323e-23 file:///Z:/MicroShield/HHC%20&%20PHC%20Dose.html 1/921 12/29/2015

Case Summary of H-HC and PHIC DosePae2o2 Page 2 of 2 ATTACHMENT 3 0.04 1 .362e+10 0 .000e+00 4.011le-23 0.000e+00 1.774e-25 0.06 1 .623e+09 0.000e+00 7.752e-24 0.000e+00 1.540e-26 0.08 2.563e+1 1 1.921e-205 1.829e-21 3.040e-208 2.894e-24 0.1 7.933e+10 0.000e+00 2.245e-05 0.000e+00 3.435e-08 0.15 8.911e+11 1.381e-183 2.903e-19 2.274e-186 4.780e-22 0.2 1.987e+11I 5.695e-88 4.266e-21 1.005e-90 7.529e-24 0.3 6.642e+11I 1.282e-31 2.599e-20 2.431le-34 4.930e-23 0.4 6.715e+12 9.328e-15 2.390e-14 1.818e-17 4.657e-17 0.5 7.058e+10 3.618e-10 1.142e-09 7.101e-13 2.241e-12 0.6 7.229e+11I 8.954e-06 3.101e-05 1.748e-08 6.053e-08 0.8 1.038e+12 3.071e-02 1.263e-01 5.841e-05 2.402e-04 1.0 3.176e+11 4.684e-01 2.125e+00 8.635e-04 3.917e-03 1.5 2.102e+10 2.404e+00 1.207e+01 4.044e-03 2.031e-02 2.0 3.962e+10 2.177e+01 1.131e+02 3.367e-02 1.750e-01 3.0 2.956e+08 5.229e-01 2.751e+00 7.095e-04 3.733e-03 4.0 1.897e+05 4.727e-04 2.478e-03 5.848e-07 3.065e-06 Totals 1.282e+13 2.520e+01 1.302e+02 3.934e-02 2.032e-01 Results - Dose Point # 2 - (150,0,0) cm Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm 2/sec mR/hr mR/hr No___Buildup___With Buildup NoBilu With Buildup 0.0 15 2.336e+1 1 0.000e+00 1.085e-22 0.000e+00 9.308e-24 0.03 1.560e+12 0.000e+00 1.490e-21 0.000e+00 1.477e-23 0.04 1.362e+10 0.000e+00 1.783e-23 0.000e+00 7.885e-26 0.06 1.623e+09 0.000e+00 3.445e-24 0.000e+00 6.843e-27 0.08 2.563e+11 8.454e-206 8.128e-22 1.338e-208 1.286e-24 0.1 7.933e+10 0.000e+00 9.979e-06 0.000e+00 1.527e-08 0.15 8.91l1e+ll 6.088e-184 1.290e-19 1.002e-186 2.125e-22 0.2 1.987e+11I 2.512e-88 1.896e-21 4.434e-91 3.346e-24 0.3 6.642e+11 5.660e-32 1.155e-20 1.074e-34 2.191e-23 0.4 6.715e+12 4.122e-15 1.056e-14 8.031e-18 2.058e-17 0.5 7.058e+10 1.599e-10 5.049e-10 3.140e-13 9.910e-13 0.6 7.229e+1 1 3.960e-06 1.372e-05 7.730e-09 2.677e-08 0.8 1.038e+12 1.359e-02 5.590e-02 2.585e-05 1.063e-04 1.0 3.176e+11 2.074e-01 9.410e-01 3.823e-04 1.735e-03 1.5 2.102e+10 1.065e+00 5.348e+00 1.792e-03 8.999e-03 2.0 3.962e+10 9.650e+00 5.016e+01 1.492e-02 7.757e-02 3.0 2.956e+08 2.319e-01 1.220e+00 3.146e-04 1.656e-03 4.0 1.897e+05 2.097e-04 1.100~e-03 2.594e-07 1.360e-06 Totals 1.282e+13 1.1 17e+01 5.773e+01 1.744e-02 9.006e-02 file:///Z:/MicroShield/HHC%20&%20PHC%20Dose.html129/05 12/29/2015

Case Summary of DHC I- 131 Pg 1 off 2 Page ATTACHMENT 4 MicroShield 8.02 University of Missouri (8.00-0000)

FDate I By IChecked EFilename DIC-IC 1-3 1 Dose.msd IRun Date December 8, 2015 I Run Time 3:03:57 PM IDuration 00:00:00 Project Info Case Title DHC I-1331 Description II- 131 Dose to Operators Geometr 1 - Point Dose Points IA X Y Z

11 90.Ocm (2 ft11.4 in) I0.0Ocm (0 in) I0.0Ocm (0in)

2 140.0 cm (4 ft 7.1 in) 0.0 cm (0 in) 0.0 cm (0 in)

______Shields____________

Shield N Shield 1 j Shield2j Dimension 80.0 cm 10.0 c m j I Material Air Lead 10.00 Dest 11.32 122 Air Gap ________ Air [0.00122 ___________

Source Input: Grouping Method - Actual Photon Energies Nuclide /Ci Bq

[ Buildup: The material reference is Shield 2 Integration Parameters Results - Dose Point # 1 - (90,0,0) cm Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm 2 /sec mR/hr mR/hr

_______ _______No__ BidpWith Buildup NoBuldup With Buildup 0.0041 4.477e+1 0 0.000e+00 1.583e-23 0.000e+00 1.1 80e-23 0.0295 1.096e+1 1 0.000e+00 2.851 e-22 0.000e+00 2.984e-24 0.0298 2.034e+11I 0.000e+00 5.353e-22 0.000e+00 5.423e-24 0.0336 7.231 e+l10 0.000e+00 2.171 e-22 0.000e+00 1.544e-24 0.0802 2.131le+1 1 7.975e-100 1.884e-21 1.261le-102 2.979e-24 0.1772 2.1 56e+ 10 1.790e-58 5 .260e-22 3 .072e-6 1 9.028e-25 0.2843 4.926e+/-1 1 2.333e-15 4.013e-15 4.393e-18 7.557e-18 0.3258 2.041e+10 1.346e-11 2.513e-11 2.578e-14 4.813e-14 0.3294 1.875e+10 2.729e-1 1 5.1 36e-11I 5.233e-14 9.849e-14 0.3645 6.607e+12 5.458e-06 1.110e-05 1.057e-08 2.150e-08 0.503 2.935e+10 6.024e-03 1.513e-02 1.182e-05 2.970e-05 0.637 5.910e+l 11 1.547e+01 4.214e+01 3.008e-02 8.193e-02 0.6427 1.787e+10 5.395e-01 1.474e+00 1.048e-03 2.865e-03 fi le://iZ:/MicroShield/DHC%201-131I%20Dose.html 1//01

! 2/8/2015

Case Summary of DHC 1-13 1Pae2o2 Page 2 of 2 ATTACHMENT 4 I 0.7229 [ 1.467e+11 I2.364e+01 I 6.723e+01 I 4.546e-02 I 1.293e-01 Totals I 8e+23.966e+01 I,.109e+02 I7.660e-02 I2.141e-01

____________ ~Results - Dose Point # 2 - (140,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) iActivity (Photons/sec) MeV/cm 2/sec MeV/cm 2/sec mR/hr mR/hr

_________ ______________No Buildup With Buildup No Buildup With Buildup 0.0041 4.477e+10 0.000e+/-00 6.542e-24 0.000e+00 4.877e-24 0.0295 1.096e+11I 0.000e+00 1.178e-22 0.000e+00 1.233e-24 0.0298 2.034e+1 1 0.000e+00 2.2 12e-22 0.000e+00 2.241e-24 0.0336 7.231e+10 0.000e+00 8.973e-23 0.000e+00 6.382e-25 0.0802 2.131e+1I 3.264e-100 7.786e-22 5.160e-103 1.231e-24 0.1772 2.1 56e+1 0 7.339e-59 2.1 74e-22 1.260e-61 3.731le-25 0.2843 4.926e+11I 9.578e-1 6 1.648e-1 5 1.804e-I18 3.1 03e-1 8 0.3258 2.041e+10 5.527e-12 1.032e-11 !.059e-14 1.977e-14 0.3294 1.875e+10 1.121e-ll 2.109e-1I 2.149e-14 4.045e-14 0.3645 6.607e+12 2.242e-06 4.562e-06 4.340e-09 8.830e-09 0.503 2.935e+10 2.476e-03 6.220e-03 4.861e-06 1.221e-05 0.637 5.910e+11 6.363e+00 1.733e+01 1.237e-02 3.370e-02 0.6427 1.787e+10 2.219e-0l 6.065e-01 4.312e-04 1.178e-03 0.7229 1.467e+1 1 9.726e+00 2.767e+01 !.870e-02 5.321e-02 Totals 8.588e+12 1.631e+01 4.561e+01 3.151le-02 8.810e-02 file://!Z:iM icroShield/DHC%20I- 131 %20Dose.html12805 ! 2/8/2015

Case Summary of Waste in HHC Pg Page 1 off 2 ATTACHMENT 5 MicroShield 8.02 University of Missouri (8.00-0000)

[D ate By IChecked Filename IRun Date I Run Time I Duration]

HHC Waste.msd December 1, 2015 4:50:48 PM 00:00:00 J Project Info Case Title Waste in HHC Description At Equilibrium Activities offl Isotopes Geometr 1 - Point Dose Points Aj X Y Z

11 80.0 cm (2 ft 7.5 in) I0.0 cm (0 in) I0.0 cm (0 in)

2 130.0 cm (4 ft 3.2 in) 0.0 cm (0 in) 0.0 cm (0 in)

______Shields _____7_

Shield N Shield 1 Shield 2 j Dimension 60.0 cm 20.0 cm Material Air Lead 10.00 Dest 11.32 122 Air Gap j _______ Air 0.00122 ___________

Source Input: Grouping Method - Standard Indices Number of Groups: 25 Lower Energy Cutoff: 0.015 Photons < 0.015: Included

__________________Library: Grove Nuclide Ci Bg

___ _1 .4900e+001 5.51 30e+/-0l11

____6.5700e+002 2.4309e+/-01 3

____6.7900e+001 2.5123e+012

_____2.6060e+002 9.6422e+0 12 15.0200e+001 1.8574e+012 Buildup: The material reference is Shield 2 Integration Parameters

____________ ~ Results - Dose Point # 1 - (80,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm2 /sec mR/hr mR/hr

_________ ______________No Buildup With Buildup No Buildup With Buildup 0.015 3.355e+ 12 0.000e+00 5.479e-21 0.000e+00 4.699e-22 0.03 1.941 e+ 13 0.000e+/-00 6.51 8e-20 0.000e+00 6.459e-22 0.04 1.637e+11 0.000e+00 7.535e-22 0.000e+00 3.333e-24 0.06 3.790e+ 10 0.000e+00 2.828e-22 0.000e+00 5.616e-25 0.08 3.017e+l10 3.547e-206 3.364e-22 5.613e-209 5.324e-25 0.1 9.844e+09 0.000e+00 4.353e-06 0.000e+00 6.660e-09 file:///Z:/MicroShield/H HC%20Waste.html12805 12/8/2015

Case Summary of Waste in HHCPae2o2 Page 2 of 2 ATTACHMENT 5 0.15 2.044e+1 3 4.967e- 182 1.041le-17 8.179e- 185 1.714e-20 0.5 1.051e-Ill 8.439e-10 2.664e-09 1.656e-12 j5.228e-12 0.6 j 5.069e+11I 9.830e-06 3.404e-05 1.919e-08 6.645e-08 0.8 1.990e+10 9.209e-04 3.788e-03 I1.752e-06 7.205e-06 Totals 4.408e+13 9.308e-04 3.826e-03 1.771e-06 7.278e-06

____________ ~ Results - Dose Point # 2 - (130,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/see) MeV/cm 2 /sec MeV/cm 2 /sec mR/hr mR/hr

__________No Buildup With Buildup No Buildup With Buildup 0.015 3.355e+12 0.000e+00 2.075e-21 0.000e+00 1.780e-22 0.03 1.941e+13 0.000e+00 2.468e-20 0.000e+00 2.446e-22 0.04 1.637e+11I 0.000e+00 2.854e-22 0.000e+00 1.262e-24 0.06 3.790e+10 0.000e+00 1.071e-22 0.000e+00 2.127e-25 0.08 3.017e+10 1.330e-206 1.274e-22 2.105e-209 2.016e-25 0.1 9.844e+09 0.000e+00 1.649e-06 0.000e+00 2.522e-09 0.15 2.044e+13 1.866e-182 3.941e-18 3.072e-185 6.490e-21 0.5 1.051e+ll 3.179e-10 1.003e-09 6.240e-13 1.970e-12 0.6 5.069e+11 3.704e-06 1.283e-05 7.231e-09 2.504e-08 0.8 1.990e+10 3.473e-04 1.428e-03 6.605e-07 2.717e-06 Totals 4.408e+13 3.510e-04 1.443e-03 6.677e-07 2.745e-06 file:///Z:/MicroShield/1H HC%20Waste.html 1//01 12/8/20 ! 5

Case Summary of Shipping Cask Dose Pg Page l off 2 ATTACHMENT 6 MicroShield 8.02 University of Missouri (8.00-0000)

[D ate By IChecked

[Filename I 2 RunuDate I Run Time I Duration

[ HS Cask with .msd December 2, 015 11:43:03 AM 00:00:00J Project Info Case Title Shipping Cask Dose Descrptionof 1-131 in SS Insert and DU CV Geometr 7 - Cylinder Volume - Side Shields Source Dimensions Hei~ght I1.0 cm (0.4 in)

Radius 1.55 cm (0.6 in)

Dose Points 8.6 0. 0. m( n

1 8.6cm (3.4 in) 00cm (0 in) 0. m( n

2 58.5 cm (1 ft 11.0 in) 0.0 cm (0 in) 0.0 cm (G in)

_______Shields ..

Shield N Dimension Material DensityZ Source 7.548 cm 3 Water 1H Shieldi1 1.7 cm Water 1.1 Shield 2 .44 cm Aluminum 2.7 Shield 3 4.756 cm Uranium 19.1 Transition ________ Air 0.00122 Air Gap _______ Air 0.00122 Source Input: Grouping Method - Actual Photon Energies Nuclide ICi IBq I *Ci/cm 3 I Bq/cm 3 I

Buildup: The material reference is Shield 3 Integration Parameters Radial I 10 Circumferential I 10 Y Direction (axial) 20 Results - Dose Point # I - (8.6,0,0) cm Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm 2 /sec mR/hr mR/hr No__Buildup With Buildu NoBilu With Buildup 0.0041 4.070e+ 10 0.000e+00 1.595e-21I 0.000e+00 1.1 89e-21I 0.0295 9.966e+10 0.000e+I00 2.816e-20 0.000e+00 2.947e-22 0.0298 1i.849e+1 1 0.000e+00 5.284e-20 0.000e+00 5.354e-22 ....

0.0336 6.573e+ 10 0.000e+00 2.135e-20 0.000e+00 1.519e-22 fi le:///Z:/MicroShield/HS%*20Cask%*20with%*20200%*20Ci.html12805 12/8/2015

Case Summary of Shipping Cask DosePae2o2 Page 2 of 2 ATTACHMENT 6 0.0802 1.937e+11I 1.864e-1 14 1.736e-19 2.947e-1 17 2.745e-22 0.1772 1.960e+I0 6.698e-60 6.283e-15 1.150e-62 1.078e-17 0.2843 4.479e+-1 1 I.258e-1 4 2.001 e- 14 2.369e-1 7 3.768e-1 7 ,,,

0.3258 1.855e+10 1.861e-10 3.066e-10 3.565e-13 5.873e-13 0.3294 1.705e+10 4.031e-10 6.673e-10 7.730e-13 1.280e-12 0.3645 6.006e+ 12 1.382e-04 2.412e-04 2.674e-07 4.668e-07 0.503 2.668e+10 4.529e-01 9.227e-01 8.890e-04 1.811le-03 0.637 5.373e+11 1.810e+03 3.914e+03 3.519e+00 7.611le+00 0.6427 1.625e+10 6.388e+01 1.385e+02 1.241e-01 2.692e-01 0.7229 1.334e+11 3.191 e+/-03 7.176e+03 6.137e+00 1.380e+i01 Totals 7.808e+12 5.065e+03 1.123e+04 9.781e+00 2.168e+01

____________ ~ Results - Dose Point # 2 - (58.5,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2/sec MeV/cm 2/sec mR/hr mR/hr

______________No Buildup With Buildup No Buildup With Buildup 0.0041 4.070e+ 10 0.000e+00 3.407e-23 0.000e+00 2.540e-23 0.0295 9.966e+ 10 0.000e+00 6.016e-22 0.000e+00 6.296e-24 0.0298 1.849e+$- 11 0.000e+00 1.129e-21 0.000e+00 1.144e-23 0.0336 6.573e+10 0.000e+00 4.562e-22 0.000e+00 3.245e-24 0.0802 1.937e+1 1 6.31 le-1 16 3.709e-21 9.979e-1 119 5.865e-24 0.1772 1.960e+10 1.897e-61 1.342e-16 3.255e-64 2.304e-19 0.2843 4.479e+11I 2.968e-16 4.721e-16 5.590e-19 8.890e-19 0.3258 1.855e+1-0 4.278e-12 7.047e-12 8.195e-15 1.350e-14 0.3294 1.705e+10 9.250e-12 1.531e-11 1.774e-14 2.935e-14 0.3645 6.006e+ 12 3.125e-06 5.454e-06 6.049e-09 1.056e-08 0.503 2.668e+1 0 9.962e-03 2.029e-02 1.955e-05 3.982e-05 0.637 5.373e+11I 3.939e+0 1 8.51 6e+0 I 7.659e-02 1.656e-01 0.6427 1.625e+ 10 1.390e+00 3.013e+00 2.701 e-03 5.854e-03 0.7229 1.334e+11 6.919e+01 1.555e+02 1.331e-01 2.991e-01 Totals 7.808e+12 1.100e+02 2.437e+02 2.124e-01 4.706e-01 fi le :/!/Z:/MicroShieldiH S%20Cask%20with%20200%20Ci .htmi 2821 12/8/2015

Case Summary of PHC 150 Ci Release Pg Page 1 off 2 ATTACHMENT 7 MicroShield 8.02 University of Missouri (8.00-0000)

/D ate I By I Checked Filename I Run Date I Run Time IDuration]

PHC 150 Ci Distributed 1-131 .msd December 8, 2015 10:51:20 AM 00:00:01j Project Info Case Title PHC 150 Ci Release Description I-131 Only¢ Geometry 13 - Rectangular Volume Source Dimensions Length I120.0 cm (3 ft 11.2 in)

Width I150.0 cm(4 ft11.1 in)

Height 160.0 cm (5 ft 3.0 in)

Dose Points l jA X Y Z I#1I 140.0 cm (4 ft 7.1 in) j75.0 cm (2 ft 5.5 in) I80.0 cm (2 ft 7.5 in)

I#2 190.0 cm (6 ft 2.8 in) 75.0 cm (2 ft 5.5 in) 80.0 cm (2 ft 7.5 in)

Shields______

Shield N Dimension ] Material Density7 Source 2.88e+06 cm 3 Air 0.00122Z Shield 1 20.0 cm Lead 11.32 Air Gap Air 0.00122 I

Source Input: Grouping Method - Actual Photon Energies Nuclide ICi IBg I ttCi/cm3 BqH/cm 3 1-131 1.5000e+002 5.5500e+012 5.2083e+001 1.9271 e+006 Buildup: The material reference is Shield 1 Integration Parameters X Direction 10 Y Direction I 20 Z Direction 20

____________ ~ Results - Dose Point # 1 - (140,75,80) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2/sec MeV/cm 2 /sec mR/hr mR/hr

________ _____________No Buildup With Buildup No Buildup With Buildup 0.0041 3 .053e+ 10 0.000e+00 1.1 68e-23 0.000e+00 8.705e-24 0.0295 7.475e+10 0.000e+00 2.103e-22 0.000e+00 2.201e-24 0.0298 1.387e+1 11 0.O00e-+00 3.948e-22 0.000e+00 4.000e-24 0.0336 4.930e++/-10 0.000e+00 1.602e-22 0.000e+00 1.139e-24 0.0802 1.453e+11 1.210e-206 I.390e-21! 1.913e-209 2.197e-24 0.1772 1.470e++/-10 4.419e- 123 3.880e-22 7.584e- 126 6.659e-25 file:///Z:/MicroShield/PH-C%*201 50%*20Ci%*20Distributed%*20I-1 31 .html12805 12/8/2015

Case Summary of PHC 150 Ci ReleasePae2o2 Page 2 of 2 ATTACHMENT 7 0.2843 3.359e+1 1 5.977e-38 1.584e-20 1.126e-40 2.983e-23 0.3258 1.392e+10 5.533e-29 8.598e-22 1.060e-31 1.647e-24 0.3294 1.279e+ 10 2.502e-28 8.086e-22 4.798e-3 1 1.551 e-24 0.3645 4.505e+12 3.111e-20 3.949e-19 6.022e-23 7.645e-22 0.503 2.001e+10 1.046e-ll 3.343e-ll 2.053e-14 6.561e-14 0.637 4.030e+11I 3.666e-06 !.334e-05 7.127e-09 2.593e-08 0.6427 1.218e+10 1.477e-07 5.403e-07 2.869e-10 1.050e-09 0.7229 1.000e+ll 3.491e-05 1.381e-04 6.714e-08 2.655e-07 Totals 5.856e+12 3.872e-05 1.519e-04 7.455e-08 2.925e-07

____________ ~ Results - Dose Point # 2 - (190,75,80) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2/seci MeVlcm 2 lsec mR/hr mR/hr

_______________No__ BidpWith Buildup NoBuldupL. With Buildup 0.0041 3.053e+10 0.O00e+00 4.902e-24 0.000e+00 3.654e-24 0.0295 7.475e+I10 0.000e+t00 8.830e-23 0.000e+00 9.240e-25 0.0298 1.387e+1 1 0.000e+00 1.658e-22 0.000e+00 1.679e-24 0.0336 4.930e+ 10 0.000e+00 6.724e-23 0.000e+00 4.782e-25 0.0802 1.453e+11 1.149e-206 5.834e-22 1.817e-209 9.225e-25 0.1772 1.470e+10 4.321e-123 1.629e-22 7.416e-126 2.796e-25 0.2843 3.359e+11 5.958e-38 6.650e-21 1.122e-40 1.252e-23 0.3258 1.392e+10 5.509e-29 3.610e-22 1.055e-31 6.914e-25 0.3294 1.279e+10 2.491e-28 3.395e-22 4.777e-31 6.510e-25 0.3645 4.505e+t12 3.094e-20 1.884e-19 5.988e-23 3.647e-22 0.503 2.001e+10 l.032e-11 3.299e-ll 2.026e-14 6.475e-14 0.637 4.030e+11I 3.575e-06 1.300e-05 6.951le-09 2.527e-08 0.6427 1.218e+10 1.439e-07 5.263e-07 2.797e-10 1.023e-09 0.7229 1.000e+llI 3.375e-05 1.333e-04 6.491e-08 2.564e-07 Totals 5.856e+I12 3.747e-05 1.469e-04 7.215e-08 2.827e-07 file:/i/Z:/MicroShield/PHC%20 150%20Ci%20Distributed%20I- 131 .html12805 12/8/2015

Case Summary of PHC 150Ci 1- 131 Only Page Pg 1 off 2 ATTACHMENT 8 MicroShield 8.02 University of Missouri (8.00-0000)

D~ate By IChecked Filename I Run Date I Run Time IDuration]

PHC 150 Ci 1-131 Dose.msd December 9, 2015 11:41:20 AM 00:00:00j Project Info Case Title PHC 150Ci 1-131 OnI*

Description I150 Ci Hycpothetical Accident 1-131 Dose to Operators Geometr 1 - Point Dose Points Al X Y

11 100.0 cm (3 ft 3.4 in) I0.0 cm (0 in) 0.0 cm (0 in)

2 150.0 cm (4 ft 11.1 in) 0.0 cm (0 in) 0.0 cm (0 in)

Shields _X Shield N Shield 1 Shield 2 Dimension 80.0 cm 20.0 cm Material Air Lead 10.00

[

Density 11.32 122 Air Gap ____ ___ Air [0.00122 __________

Source Input: Grouping Method - Actual Photon Energ~ies Nuclide ICi Bg 1-131 1.5000e+002 5.5500e+012 I Buildup: The material reference is Shield 2 Integration Parameters Results - Dose Point # 1 - (100,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/see) MeV/cm 2 /sec MeV/cm 2/sec mR/hr mR/hr

_______________________No Buildup With Buildup No Buildup With Buildup 0.0041 3 .053e+1 0 0.000e+/-00 8.742e-24 0.000e+00 6.51 7e-24 0.0295 7.475e+10 0.000e+00 1.575e-22 0.000e+00 1.648e-24 0.0298 1.387e+11I 0.000e+00 2.956e-22 0.000e+00 2.995e-24 0.0336 4.930e+ 10 0.000e+00 1.1 99e-22 0.000e+00 8.529e-25 0.0802 1.453e+1 1 2.125e-204 1.041e-21 3.361e-207 1.645e-24 0.1772 1.470e+10 4.773e-121 2.905e-22 8.191e-124 4.986e-25 0.2843 3.359e+11 2.208e-36 1.186e-20 4.158e-39 2.233e-23 0.3258 1.392e+10 I.547e-27 6.437e-22 2.963e-30 1.233e-24 0.3294 1.279e+10 6.845e-27 6.054e-22 1.313e-29 1.161 e-24 0.3645 4.505e+12 7.023e-19 1.628e-18 1.359e-21 3.151e-21 0.503 2.001e+10 1.394e-10 4.416e-10 2.736e-13 8.667e-13 0.637 4.030e+i11 3.601 e-05 1.291e-04 7.002e-08 2.511le-07 0.6427 1.218e+10 1.436e-06 5.177e-06 2.790e-09 1.006e-08 file:///Z:/MicroShield/PHC%20 150%20Ci%20%20I- 131 %20Dose.html12905 12/9/2015

Case Summary of PHC 150Ci 1-131 OnlyPae2o2 Page 2 of 2 ATTACHMENT 8 I 0.7229 I 1.000e+1l I 2.984e-04 I 1.158e-03 I 5.738e-07 I 2.227e-06 I Totals J 5.856e+12 Results 1 3.358e-04 I1.292e-03

- Dose Point #

j 2 - (150,0,0) cm 6.466e-07 [ 2.4,,e-06 Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2/sec MeV/cm 2/sec mR/hr mR/hr

______________No Buildup With Buildup No Buildup With Buildup 0.0041 3.053e+10 0.000e+00 3.885e-24 0.000e+00 2.897e-24 0.0295 7.475e+10 0.000e+00 6.999e-23 0.000e+00 7.324e-25 0.0298 1.387e+11 0.000e+00 1.314e-22 0.000e+00 1.331e-24 0.0336 4.930e+ 10 0.000e+00 5 .330e-23 0.000e+00 3.791 e-25 0.0802 1.453e+1 1 9.354e-205 4.625e-22 1.479e-207 7.3 12e-25 0.1772 1.470e+10 2.105e-121 1.291e-22 3.612e-124 2.216e-25 0.2843 3.359e+11 9.748e-37 5.271e-21 1.836e-39 9.926e-24 0.3258 1.392e+10 6.832e-28 2.861e-22 1.309e-30 5.480e-25 0.3294 1 .279e+ 10 3 .023e-27 2.691 e-22 5 .797e-30 5.1 60e-25 0.3645 4.505e+12 3.102e-19 7.192e-19 6.005e-22 1.392e-21 0.503 2.001e+10 6.162e-ll 1.952e-10 1.210e-13 3.832e-13 0.637 4.030e+11 1.593e-05 5.713e-05 3.097e-08 1.1lie-07 0.6427 1.21 8e+1 0 6.351 e-07 2.290e-06 1.234e-09 4.450e-09 0.7229 1.000e+/-ll 1.320e-04 5.124e-04 2.539e-07 9.853e-07 Totals 5.856e+ 12 1.486e-04 5.7 18e-04 2.86 1e-07 1.101le-06 file :///Z:/MicroShield/PHC%20 150%20Ci%20%201- 131 %20Dose.html12905 12/9/2015

Case Summary of PHCfl Only Pg Page i off 2 ATTACHMENT 9 MicroShield 8.02 University of Missouri (8.00-0000)

FDate I By IChecked FFilename PHC lDose.msd IRun Date December 8, 2015 I Run Time 10:26:11 AM Duration 00:00:00 Project Info Case Title PH-CE Only Description INominal Te Dose to Operators Geometr 1 - Point Dose Points

2 1000c

1 1000 ft3.

cm ( ft 3. n) 150.0Ocm(4 ft 11.1 in) n)(Z~

0.0 cm (0 in) 0.0Ocm (0in)

I0.0 cm ( n 0.0 cm (0 in)J

______Shields ________

Shield N Dimension IMaterial Densit Shield 1 80.0 cm Air 0.00 122 Shield 2 20.0 cm j Lead j 11.32 Air Gap _______[ Air [0.00122 Source Input: Grouping Method - Standard Indices Number of Groups: 25 Lower Energy Cutoff: 0.015 Photons < 0.015: Included

_________________Library:_Grove Nuclide Ci Bq

____2.6500e+001 9.8050e+01 1 5.6700e+000 2.0979e+011I

_____I.9500e+002 7.21 50e+/-0 12 1.1600e+001 4.2920e+01 1

____2.5000e-004 9.2500e+006

____7.1700e+000 2.6529e+0l11 2.6100e+001 9.6570e+01 1 I Buildup: The material reference is Shield 2 Results Integration Parameters

- Dose Point # 1 - (100,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cmn2/sec MeV/cm 2 /sec mR/hr mR/hr

______________No Buildup With Buildup No Buildup With Buildup 0.015 1.888e+/-+ 11 0.000e+00 1.974e-22 0.000e+00 1.693e-23 0.03 1.175e+ 12 0.000e+00 2.525e-21 0.000e+00 2.503e-23 0.04 1.362e+10 0.000e+00 4.011le-23 0.000e+00 1.774e-25 0.06 1.623e+09 0.000e+00 7.752e-24 0.000e+00 1.540e-26 file://!Z :/M icroShield!PHC%20Te%20Dose.html 12/8/2015 1//01

Case Summary of PHC Te OnlyPae2o2 Page 2 of 2 ATTACHMENT 9 0.08 4.320e+1 0 3.237e-206 3 .082e-22 5.123e-209 4.877e-25 0.1 7.933e+10 0.000e+00 2.245e-05 0.000e+00 3.435e-08 0.15 8.911le+1 1 1.381e-1 83 2.903e-19 2.274e-1 86 4.780e-22 0.2 1.772e+11 5.077e-88 3.803e-21 8.961e-91 6.712e-24 0.3 1.324e+11 2.554e-32 5.180e-21 4.846e-35 9.826e-24 0.4 1.078e+11 1.498e-16 3.839e-16 2.919e-19 7.479e-19 0.5 4.123e+10 2.114e-10 6.671e-10 4.149e-13 1.309e-12 0.6 1.141e+ll 1.413e-06 4.893e-06 2.758e-09 9.550e-09 0.8 8.917e+1 1 2.637e-02 1.085e-01 5.015e-05 2.063e-04 1.0 3.176e+11 4.684e-01 2.125e+/-00 8.635e-04 3.917e-03 1.5 2.073e+10 2.370e+00 1.190e+01 3.987e-03 2.002e-02 2.0 3.962e+10 2.177e+01 1.131e+/-02 3.367e-02 1.750e-01 Totals 4.235e+12 2.464e+01 1.273e+02 3.857e-02 1.991e-01 Results - Dose Point # 2 - (150,0,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeVcm 2/seci MeV/cm 2/sec mR/hr mR/hr

__No___Bui~ldup With Buildup NoBildup With Buildup 0.015 1.888e+1 1 0.000e+00 8.773e-23 0.000e+00 7.525e-24 0.03 1.175e+12 0.000e+00 1.122e-21 0.000e+00 1.112e-23 0.04 1.362e+10 0.000e+00 1.783e-23 0.000e+00 7.885e-26 0.06 1.623e+09 0.000e+00 3.445e-24 0.000e+00 6.843e-27 0.08 4.320e+10 1.425e-206 1.370e-22 2.254e-209 2.168e-25 0.1 7.933e+10 0.000e+00 9.979e-06 0.000e+00 1.527e-08 0.15 8.911e+11 6.088e-184 1.290e-19 1.002e-186 2.125e-22 0.2 1.772e+11 2.240e-88 1.690e-.21 3.953e-91 2.983e-24 0.3 1.324e+11I 1.128e-32 2.302e-21 2.140e-35 4.367e-24 0.4 1.078e+11 6.620e-17 1.696e-16 1.290e-19 3.305e-19 0.5 4.123e+10 9.344e-ll 2.949e-l0 1.834e-13 5.789e-13 0.6 1.141e+llI 6.248e-07 2.164e-06 1.220e-09 4.224e-09 0.8 8.917e+1 1 1.167e-02 4.800e-02 2.219e-05 9.131e-05 1.0 3.176e+11 2.074e-01 9.410e-01 3.823e-04 1.735e-03 1.5 2.073e+10 1.050e+00 5.273e+00 1.767e-03 8.872e-03 2.0 3.962e+10 9.650e+00 5.016e+01 1.492e-02 7.757e-02 Totals 4.235e+12 1.092e+01 5.642e+01 1.709e-02 8.827e-02 file :///Z:/MicroShield/PHC%20Te%20Dose.html12805 12/8/2015

Case Summary of Ductwork Plateout Page 1 off 2 Pg ATTACHMENT 10 MicroShield 8.02 University of Missouri (8.00-0000)

[D ate By IChecked]

[Filename Duct Work Dose.msd IRun Date December 7, 2015 I Run Time 1:43:23 PM IDuration]

00:00:00 J Project Info Case Title Ductwork Plateout Description I150 Ci, two filters at 99%, 3rd out of service Geometr 2 - Line

[ Source Dimensions

[ Length I250.0 cm (8 ft 2.4 in)y

[ Angle 90.00° Dose Points AJ X Y Z

11 250.0Ocm(8 ft2.4 in) 125.0Ocm (4 f 1.2 in) 0.0 cm (0in)

21 50.0 cm (1 ft 7.7 in) 125.0 cm (4 ft 1.2 in) 10.0 cm (0 in)

31 10.0 cm (3.9 in) 125.0 cm (4 ft 1.2 in) 10.0 cm (0 in)

S ldNShields zX ShelNDimension IMaterial IDensity Air Gap Air 0.00 122 Source Input: Grouping Method - Actual Photon Energies Nuclide ICi IBg I Ci/cm I Bg/cm I-131 1.5000e-002 5.5500e+008 6.0000e+t001 2.2200e+006 Buildup: The material reference is Air Gap

__________________ __Inte__ration_

Parameters_______________

Len th Se ments [ 20

___________Results - Dose Point # 1 - (250,125,0) cm Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm 2 /sec mR/hr mR/hr

______________No Buildup With Buildup No Buildup With Buildup 0.0041 3 .053e+06 9.1 42e-03 1.020e-02 6.81 5e-03 7.601 e-03 0.0295 7.475e+06 2.339e-01 2.627e-01 2.448e-03 2.749e-03 0.0298 1.387e+07 4.394e-01I 4.936e-01I 4.452e-03 5.001 e-03 0.0336 4.930e+06 1.791 e-01 2.012e-01 1.274e-03 1.431 e-03 0.0802 1.453e+07 1.307e+00 1.436e+00 2.067e-03 2.271 e-03 0.1772 1.470e+06 2.954e-01 3.124e-01 5.070e-04 5.362e-04 0.2843 3.359e+07 1.089e+01 1.133e+01 2.052e-02 2.133e-02 0.3258 1.392e+06 5.181 e-01 5.369e-01 9.923e-04 1.028e-03 0.3294 1.279e+06 4.814e-01 4.987e-01 9.231e-04 9.563e-04 0.3645 4.505e+08 l.879e+02 1.941e+02 3.637e-01 3.758e-01 file ://Z :!MicroShield/Duct%20Work%20Dose.html12801 12/8/2015

Case Summary of Ductwork PlateoutPae2o2 Page 2 of 2 ATTACHMENT 10 0.503 2.001le+06 1.156e+00 1.186e+00 2.269e-03 2.328e-03 0.637 4.030e+07 2.956e+01 3.021e+01 J5.748e-02 5.873e-02 0.6427 1.218e+06 j9.020e-01 9.216e-01 1.753e-03 1.791e-03 0.7229 1.000e+07 8.341 e+00 8.506e+00 1.604e-02 1.636e-02 Totals 5.856e+08 j2.422e+02 2.500e+02 4.812e-01 4.979e-01

____________ ~ Results - Dose Point # 2 - (50,125,0) cm ______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2/sec MeV/cm 2/sec mR/hr mR/hr

_______________________No Buildup With Buildup No Buildup With Buildup 0.0041 3 .053e+06 1.673e-01 1.722e-0 1 1.247e-0 1 1.284e-0 1 0.0295 7.475e+06 3.244e+00 3.346e+00 3.395e-02 3.502e-02 0.0298 1.387e+07 6.088e+00 6.279e+00 6.168e-02 6.362e-02 0.0336 4.930e+06 2.452e+00 2.529e+00 1.744e-02 1.799e-02 0.0802 1.453e+07 1.742e+01 1.786e+01 2.754e-02 2.824e-02 0.1772 1.470e+06 3.905e+00 3.964e+00 6.703e-03 6.804e-03 0.2843 3.359e+07 1.434e+02 1.449e+02 2.700e-01 2.729e-01 0.3258 1.392e+06 6.811e+00 6.876e+00 1.305e-02 1.317e-02 0.3294 1.279e+06 6.328e+00 6.388e+/-00 1.21 3e-02 1 .225e-02 0.3645 4.505e+08 2.468e+03 2.489e+03 4.776e+00 4.81 8e+00 0.503 2.001 e+06 1.51 4e+0 1 1.525e+01I 2.972e-02 2.992e-02 0.637 4.030e+07 3.864e+02 3.887e+02 7.513e-01 7.557e-01 0.6427 1.218e+06 1.179e+01 1.186e+01 2.291e-02 2.304e-02 0.7229 1.000e+07 1.089e+02 1.095e+02 2.095e-01 2.106e-01 Totals 5.856e+08 3.180e+03 3.207e+03 6.357e+00 6.416e+00

____________ ~ Results - Dose Point # 3 - (10,125,0) cm ______

Fiuence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2/sec MeV/cm 2/sec mR/hr mR/hr

________________No__ BidpWith Buildup NoBildupL. With Buildup 0.0041 3.053e+06 1.144e+00 1.154e+00 8.526e-01 8.602e-01 0.0295 7.475e+06 2.070e+01 2.090e+01 2.167e-01 2.188e-01 0.0298 1.387e+07 3.883e+01 3.921e+01 3.934e-01 3.972e-01 0.0336 4.930e+06 1.560e+01 1.575e+01 1.109e-01 1.120e-01 0.0802 1.453e+07 1.100e+02 1.109e+02 1.740e-01 1.754e-01 0.1772 1.470e+06 2.462e+01 2.474e+01 4.226e-02 4.246e-02 0.2843 3.359e+07 9.031e+02 9.061e+02 1.701e+00 1.706e+00 0.3258 1.392e+/-06 4.288e+0 1 4.301 e+0 1 8.21 4e-02 8.238e-02 0.3294 1.279e+06 3.984e+01 3.996e+01 7.640e-02 7.662e-02 0.3645 4.505e+08 1.553e+04 1.557e+04 3.006e+01 3.015e+01 0.503 2.001e+I06 9.523e+01 9.544e+01 1.869e-01 1.873e-01 0.637 4.030e+07 2.429e+03 2.434e+03 4.724e+00 4.732e+00 0.6427 1.21 8e+06 7.41 2e+01I 7.425e+0 1 1.440e-01 1I.443e-0 1 0.7229 1.000e+07 6.846e+02 6.857e+02 1.31 7e+00 1.31 9e+00 Totals 5.856e+08 2.001e+04 2.007e+04 4.008e+01 4.020e+01 file:!i/Z :/MicroShield/Duct%20Work%20Dose.html12805 12/8/2015

Case Summary of Updated Pg 1 off 2 Page ATTACHMENT 11 MicroShield 8.02 Nathan Hogue (8.00-0000)

Date By IChecked Filename IRun Date I Run Time I Duration ]

Filter 1.msd December 29, 2015 10:22:33 PM 00:00:00 j

' , ~~Project Info ,,',

Case Title Updated Description I150 Ci Target-Mitigated (4 of 4 filters-DF 1000)-Filter No. 1 Geometr 12 - Annular Cylinder - External Dose Point Source Dimensions Heigt

..... 1.0 cm (0.4 in)

InnerCyl Rdius4.0 cm (1 "6 in)

Inner Cyl Thickness 0.0 cm (0 in)

Outer Cyl Thickness 0.0 cm (0 in)

Source 5.0 cm (2.,0 in)

AIDose Points * .,.-

t#1 49.0 cm (1 ft 7.3 in) 0.0 cm O0in) 0.0 cm O0in)j Shields Shield N' Dimension ,Material Density ClRais4.0 cm Air 0.00122 Source 204.204 cm 3 Carbon 1.8 Transition Air 0.00122 Shield 5 10.0 cm Lead 1I1.35 Air Gap ____ ___ Air 0.00122

...Nuclide ......

Source Input: Grouping Method - Actual Photon Energies Ci IBg *iCi/cm 3 Bq/cm 3 I111 .4985e+002 5.5445e+012 7.3383e+005 2.7152e+010 J Buildup: The material reference is Shield 5 Integration Parameters Radial 10 Circumferential I 20 Y Direction (axial) 20

_____________ ~~~~Results_____ ___ _______

Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) lMeV/cm 2 /sec MeV/cm 2 /sec mR/hr mRlhr No Buildup With Buildup NBuldup With Buildup 0.0041 ......... 3.050e+10 O.O00e+O0 3.712e-23 O.O00e+O0 2.767e-23 0.0295 ... 7.467e+10 O.O00e+O0 6.686e-22 O.O00e+O0 6.998e-24

.....0.0298 1.385'e+l 1 0OiO00e+O0 ...... l.255e-21 O.O00e+O0 1.272e-23 file:///C:/ProgramV20FilesV20(x86)/MicroShield%*208/Examples/CaseFiles/HTML/Filt... 12/29/2015

Case Summary of UpdatedPae2o2 Page 2 of 2 ATTACHMENT 11 0.0336 4.925e+1 0 0.000e+00 5.092e-22 0.O00e+O0 3 .622e-24 0.0802 1.452e+1 1 1.382e-100 4.418e-21 ... 2.185e-103 ...6.986e-24 0.1772 ___1.468e+10 5.996e-59 1.234e-21 1.029e-61 2.117e-24 0.2843 .... 3.356ie+i i 1.594e-15 2.750e-15 3.001e-18 5.1 79e-18...

0.3258 ___1.390e+10 1.034e-11 1.938e-11 1.980e-14 3.712e-14 0.3294 1.277e+10 2.11 3e-I 1 3.995e-1 1 4.053e-14 7.661 e-14 0.3645 4.500e+12 4.538e-06 9.287e-06 8.784e-09 1.798e-08 0.503 1.999e-i-0 5.945e-03 1.515e-02 1.167e'05 2.973e-05

....0.637 4.026e+11I 1.678e+01 '4.664e+01 3.262e-02 9.069e-02 0.6427 ' 1.217e+10 5.870e-01 i1638e+00 1.141e-03 3.182e-03...

...0.7229 9.994e+10 2.679e+01 7.815e+O1.... 5.153e-02 " 1.503e-01 Totals 5.850e+12 4'.416e+O1 1.264e+02 8.530e-02 2.442e-01 file :///C:/Proram%*20Files%*20(x86)iMicroShield%*208/gxamples/CaseFiles/HTML/Filt... 12/29/2015

Case Summary of Updated Pg Page 1 off 2 ATTACHMENT 11

[ Date MicroShield 8.02 Nathan Hogue (8.00-0000)

By Checked]

r Filename IRun Date I Run Time I Duration]

'Filter I1.msd ... December 29, 2015 10:16:27 PM 00:00:00 J Project Info case Title .. ... Updated Description . 150 Ci Target-Mitigated (4 of 4 filters-DF 100)-Filter No. 1 G~eomet* 12 - Annular Cylinder - External Dose Point Source Dimensions Height 1.0 cm (0.4 in)

Inner CylI Radius 4.0 cm (1.6 in)

Inner Cyl Thickness 0.0 cm (0 in)

Outer Cyl Thickness 0...00 cm (0 in)

Source 5.0 cm (2.0 in)

Dose Points ,m l.,*.X Al X Y Z z

1 49.0 cm (1 ft 7.3 in) 0.0 cm Oi n) 0.0 cm (0in)

Shields_____

Shield N Dimension Material Density Cyl. Radius 4.0 cm Air 0.00122 Source 204.204 cm 3 Carbon 1.8 Transition ________ Air 0.00122 Shield 5 10.0 cm Lead 11.35 Air___Gap___ Air 0.00122 Source Input: Grouping Method - Actual Photon Energies .............

Nuclide ICi IBq ptCi/cm 3 Bg/cm 3 I- 13 1 1.4850e+002 5.4945e+012 7.2722e+005 2.6907e+010 Buildup: The material reference is Shield 5

. .... .Integration Parameters Radial 10 Circumferential I 20 Y Direction (axial) 20

_________________Results

......... Fluence Rate Fluence Rate Exposure Rate Expo'sure Rate Energy (MeV) Activity" (Photons/sec) MeV/cm2 /sec MeV/cm2 /sec mR/hr mR/hr

_______ ___________No Buildup With Buildup NoBuldup.. With Buildup 0.0041 3.022e+ 10 0.000e+O0 3.679e-23 0.000e+00 2.742e-23 0........00295 -" 7.400e+1 0 0.000e+00 6.626e-22 0.000e+00 6.935e-24 0.0298 1.373e+11I 0.000e+00 1.244e-21 0.000e+00 1.260e-23 file:!//C:/Program%*20Files%*20(x86)/MicroShield%*208/Examples/CaseFiles/HTML/Filt... 12/29/2015

Case Summary of UpdatedPae2o2 Page 2 of 2 ATTACHMENT 11 0.0336 4.881le+10 O.O00e+O0 5 .046e-22 0.000e+00 3.589e-24 0.0802 ___1.439e+11I 1.369e-100 4.378e-21 2.165e-103 6.923e-24 0.1772 1.455e+10O ... 5.942e-59 i'.222e-21 ]'.020e-61 '2.098e-24 0.2843 3.325e+11 1.579e-15 2.725e-15 2.974e-18 5.132e-18 0.3258 __...... 1.378e+10 1.024e-11 1.921e-1 1 1.962e-14. 3.679e-14 0.3294 1.266e+10 2.094e-11 3.959e. I 4.016e-14 7.592e-14 0.3645

......... 4.460e+12 4.497e-06 9.204e'06 8.705e-09 I1.782e-08 0.1503 ... 1.981e+10 ... 5.892e-03 1.501e-02 1.156e-05 2.946e-05 0.637 ..... J989e+ll 1.662e+01 "4.622e+01 3.232e-02 8.987e-02 0.6427 1.206e+ 10 5.817e-01 1.623e+I00 1.130e-03 3.153e-03 0.7229 9.904e+10 2.655e+01 7.744e+01 5.106e-02 1.489e-01 Totals ... 5.797e+12 4.376e+O1 1.253e+02 8.453e-02 2.420e-O1 fie :///C:/Program%2OFiles%20(x86)/MicroShield%2O8I*xamples/CaseFiles/HTML/Filt.. 12/29/2015

Case Summary of Updated Pg 1 off 2 Page ATTACHMENT 11 MicroShield 8.02 Nathan Hogue (8.00-0000)

.......Filename Run Date ... Run Time Duration ]

Filter 2.msd

...... I December 29, 2015 I 10:23 :43 PM I 00:00:00 j

........... Pro ect Info Case Title ....... Updated Description I150 Ci Target-Mitigated (4 of 4 filters-DF 1000O)-Fil!ter No.2 Geometr 12 - Annular Cylinder - External Dose Point Source Dimensions Height 1.0 cm (0.4 in) ....

Inner Cyl Radius ... 2.9 cm (1.1 in)

Inner Cyl Thickness 0.0 cm (0 in)

Outer Cyl Thickness 0.0 cm (0 in)

..... Source 3.6 cm (1.4 in)

1 46.5 cm (1ft 6.3 in) 0.0 cm O0in) 0.0 cm (0in)]

Shields_____

Shield N Dimension Material ... Density "

Cyl. Radius 2.9 cm Air 0.00122 Source 106.311 cm3 -Carbon 1..18 ..

Transition Air 0.00122 Shield 5 10.0 cm Lead 11.35 Air Gap Air 0.00122 Source Input: Grouping Method - Actual Photon Energies Nuclide ICi IBq I aCi/cm3 I Bq/cm 3 I-131 1.4985e-001 5.5445e+009 1.4095e+003 5.2153e+007 Buildup: The material reference is Shield 5

...... Integration Parameters Radial 10 Circumferential ... 20 ..

...... Y Direction (axial) 20 Results______________

............ Fluence Rate Fluence Rate Exposure Rate Exposure Ratei Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm'/sec mR/hr mR/hr

_____________No Buildup With Buildup No Buildup With Buildup 0.0041 3.050e+07 0.000e+O0 4.086e-26 0O.0e+00 3.046e-26

.....0.0295 7.467e+07 0...O,000e+00 7.361 e-25 0O.0e+00 7.703e-27 0.0298 1.385e+08 0.000e+00 1.382e-24 0O.0e+00 1.400e-26 file:///C:/Program%*20Files%¥20(x86)/MicroShield%*208/Examples/CaseFiles/HTMLiFilt... 12/29/2015

Case Summary of UpdatedPae2o2 Page 2 of 2 ATTACHMENT 11 0.0336 4.925e+07 0.000e+00 5 .605e-25 0.000e+00 3.987e-27 0.0802 1.452e+08 2.448e-103 _4.864e-24 .......3.870e-106 7.690e-27 0.1772 1.468e+-07 9.937e-62 1.358e-24 1.705e-64 2.331e-27

' 0.2843

... "- 3.356e+08 2,333e-18 .... 4.024e-18 4.393e-21 7.577e-21 0.3258 "1.390e+07 1.476e-14 2.764e-14 2.826e-17 5.295e,17 0.3294 1.277e+07 3.012e-14 5.688e-14 5.775e-1 7 1.091e-16 0.3645 4.500e+09 6.367e-09 1.302e-08 1.232e-1 1 2.519e-llI 0.503 i1.999e+07 ... 8.033e-06' 2.041le-05 1.577e-08 1.. 4.006e-08 0.637 4.026e+08 2.221e-02 6.150e-02 4.318e-05 1.!96e-04 0.6427 1.217e+07 7.766e-04 2.158e-03 1.509e-06 4.193e-06 0.7229 9.994e+07 3.514e-02 1.020e-01 ...... 6.757e-05 1,961e,04 Totals 5.850e+09 ... 5.813e-02 1.656e-01 1.123e-04 3.199e-04 ....

file :///C :/Program%1/420Files%*20(x86)/MicroShield%*208/Examples/CaseFiles/HTML/Filt... 12/29/2015

Case Summary of Updated Pg Page 1 off 2 ATTACHMENT 11 K Date IBy MicroShield 8.02 Nathan Hogue (8.00-0000)

................ Checked. . .

Fienm Run Date I Run Time I Duration Filter 4.msd December 29, 2015 10:24:47 PM 00:00:00

~~~Project Info........

Case Title .... Updated Description I150 Ci Target-Mitigated (4 of 4 filters DF 1000)-Filter NO.4 Geometr........ 13 - Rectangular Volume Source Dimensions Length ... 30.0 cm (11.8 in)

Width I30.0 cm(11.,,,8 in)

Heig~ht 1.0 cm (0.4 in)

Dose Points Y~ *'"-

A IX I V I Z

1 60.635 cm (1 ft 11.9 in) 0.0Ocm (0in) 15.0cm (5.9 in) Z Shields Shield N Dimension Material Densit Source 900.0 cm3 I Carbon 1.8 Shield 1 1 .635 cm 1 Lead I 11.35 Air Gap) Air 0.00122 Source Input: Grouping Method - Actual Photon Energies 1- 131 1.4985e-007 I 5.5445e+0)3' 1.6650e-004 610 +0 Buildup: The material reference is Shield I Inte ration Parameters X Direction 10 Y Direction ........ 20 Z Direction 20 Results r, , Fluence Rate Fluence Rate Exposure Rate Exposure Rate Energy (MeV) Activity (Photons/sec) MeV/cm 2 /sec MeV/cm 2 /sec mR/hr mR/hr No Buildup With Buildup No Buildup With Buildup 0.0041 3.050e+01 0.000e+00 4.499e-32 0.000e+00 3.354e-32 0.0295 7.467e+01 1.172e-101 8.104e-31 1.227e-103 8.481e-33 0.0298 1.385e+02 1.135e-98 1.521e-30 1.149e-100 1.541e-32 0.0336 4.925e+0 1 .......... 1.471 e-73 6.171 e-31 ...I.046e-75 4.389e-33 0.0802 1.452e+02 1.354e-1 1 1.599e-11I 2.140e-14 2.529e-14 0.1772 1.468e+01 1.976e-09 2.900e-09 3.391e-12 4.977e-12 0.2843 3.356e+02 .... 4.272e-05 5.43 le-05 8.045e-08 1.023e-07 file:///C:/Program%2OFiles%20(x86)/MicroShield%208/Examples/CaseFiles/HITML/Filt... 12/29/2015

Case Summary of UpdatedPae2o2 Page 2 of 2 ATTACHMENT 11 0.3258 1.390e+01 4.543e-06 5.893e-06 8.701 e-09 1.129e-08 0.3294 ___1.277e+01 4.456e-06 5.789e-06 8.545e-09 1.110~e-08 0.3645 4.500e+03 2.695e-03 3 .544e-03 5.21 6e-06 6.860e-06 0.503

..... ..... 1.999e+01 4.035e-05 5.53 3e-05 7.920e-08 1.086e-07 0.637 4.026e+02 1.503e-03 2.1 00e-03 2.922e-06 4.082e-06

...0.6427 .... 1.217e+01 4.638e-05 6.486e-05 9.013e-08 i.260e-07 0.7229 9.994e+01 4.930e-04 6.961le-04 9.482e-07 1.339e-06 Totals 5.850e+03 4.829e-03 6.526e-03 9.353e-06 1.264e-05 file:///C :/Program%2OFiles%20(x86)Iq*icroShield%208/Examples/CaseFiles/HTML/Filt... 12/29/2015

ATTACHMENT 14 UNIVERSITY OF MISSOURI

TECHNICAL SPECIFICATION RESEARCH REACTOR FACILITY Number 3.6 Page 4 of 5 Date _______

Amendment No._____

SUBJECT:

Experiments (continued)

o. Fueled experiments containing inventories of Iodine 131 through 135 greater than 1.5 Curies or Strontium 90 greater than 5 millicuries shall be in irradiation containers that satisfy the requirements of specification 3 .6.i or be vented to the exhaust stack system through HEPA and charcoal filters which are continuously monitored for an increase in radiation levels.

p. Each non-fueled experiment shall be limited such that the inventory of Iodine 131 is not greater than 150 Curies.

q. Non-fueled experiments that are intended to produce Iodine 131 shall be processed in hot cells that are vented to the exhaust stack system through charcoal filters which are continuously monitored for an increase in radiation levels.

Bases

a. Specification 3.6.a restricts the generation of hazardous materials to levels that can be handled safely and easily. Analysis of fueled experiments containing a greater inventory of fission products has not been completed, and therefore their use is not permitted.

b. Specification 3.6.b is intended to reduce the likelihood of accidental voiding in the core or water annulus surrounding the center test hole by restricting materials which could generate or accumulate gases or vapors.

c. The limitation on experiment materials imposed by specification 3.5.c assures that the limits of Appendix B of 10 CFR 20 are not exceeded in the event of an experiment failure.

d. Specification 3.6.d is intended to reduce the likelihood of damage to reactor or pool components resulting from detonation of explosive materials.

e. Specification 3.6.e is intended to limit the experiments that can be moved in the center test hole while the reactor is operating, to those that will not introduce reactivity transients more severe than one that can be controlled without initiating safety system action (Ref. Add. 5 to HSR).

ATTACHMENT 14

UNIVERSITYSPECIFICATION TECHNICAL OF MISSOURI RESEARCH REACTOR FACILITY Number 3.6 Page 5 of 5 Date ________

Amendment No._____

SUBJECT:

Experiments (continued)

f. Specifications 3.6.f and 3.6.g provide guidance for experiment safety analysis to assure that anticipated transients will not result in radioactivity release and that experiments will not jeopardize the safe operation of the reactor.

g. Specification 3.6.h is intended to reduce the likelihood of reactivity transients due to accidental voiding in the reactor or the failure of an experiment from internal or extemnal heat generation.

h. Specification 3 .6.i is intended to reduce the likelihood of damage to the reactor and/or radioactivity releases from experiment failure.

i. Specification 3.6.j provides assurance that no chemical reaction will take place to adversely affect the reactor or its components.

j. Specification 3.6.k provides assurance that the integrity of the beamports will be maintained for all loop-type experiments.

k. Specification 3.6.1 assures that corrosive materials which are chemically incompatible with reactor components, highly flammable materials and toxic materials are adequately controlled and that this information is dissem-inated to all reactor users.

1. The extremely low temperatures of the cryogenic liquids present structural problems which enhance the potential of an experiment failure. Specifica-tion 3.6.m provides for the proper review of proposed experiments con-taining or using cryogenic materials.

m. Specifications 3.6.p and 3.6.q provide assurance that the processing of Iodine 131 can be performed safely and that equipment necessary for accident mitigation has been installed.

ATTACHMENT 14 UNIVERSITY OF MISSOURI

TECHNICAL SPECIFICATION RESEARCH REACTOR FACILITY Number 3.11 Page 1 of 2 Date _______

Amendment No._____

SUBJECT:

Iodine 131 Processing Hot Cells Applicability This specification shall apply to the limiting conditions of operation on the equipment needed to safely process Iodine 131.

Objective The objective of this specification is to reasonably assure that the health and safety of the staff and public is not endangered as a result of processing Iodine 131.

Specification

a. The facility ventilation exhaust system shall be operable when processing Iodine 131 in the Iodine 131 processing hot cells.

b. The facility ventilation exhaust system shall maintain the Iodine 131 processing hot cells at a negative pressure with respect to the surrounding areas when processing Iodine 131.

c. Processing of Iodine 131 shall not be performed in the Iodine 131 processing hot cells unless the following minimum number of radiation monitoring channels are operable.

Radiation Monitoting Channel,:: -, Number

1. Stack Radiation Monitor 1

2. Iodine-131 Processing Hot Cells Radiation Monitor 1 Exception: When the required radiation monitoring channel becomes inoperable, then portable instruments may be substituted for the normally installed monitor in specification 3.11 .c.2 within one (1) hour of discovery for a period not to exceed one (1) week.

ATTACHMENT 14 UNIVERSITY OF MISSOURI I* TECHNICAL SPECIFICATION RESEARCH REACTOR FACILITY Number 3.11 Page 2 of 2 Date _______

Amendment No._____

SUBJECT:

Iodine 131 Processing Hot Cells (continued)

d. At least three (3) charcoal filter banks each having an efficiency of 99% or greater shall be operable when processing Iodine 131 in the Iodine 131 processing hot cells.

Bases

a. Operation of the facility ventilation exhaust system when processing Iodine 131 in the Iodine 131 processing hot cells ensures proper dilution of effluents to prevent exceeding the limits of 10 CFR 20 Appendix B.

b. Maintaining the Iodine 131 processing hot cells at a negative pressure with respect to the surrounding areas ensures safety for the facility staff.

c. The radiation monitors provide information to operating personnel regarding routine release of radioactivity and any impending or existing danger from radiation. Their operation will provide sufficient time to take the necessary steps to prevent the spread of radioactivity to the surroundings. The Stack Radiation Monitor continuously monitors the air exiting the facility through the exhaust stack for airborne radioactivity.

The Iodine-131 Processing Hot Cells Radiation Monitor is a six (6) detector system; two (2) detectors serving each one of the three (3) hot cells. For each hot cell, one (1) detector is located at the processor's work area where the hot cell manipulators are installed and the other is located in the bay above the hot cell next to the exhaust charcoal filters.

d. The potential radiation dose to staff and individuals at the Emergency Planning Zone boundary and beyond have been calculated following an accidental release of Iodine 131 activity. These calculations are based on the facility ventilation exhaust system directing all Iodine 131 processing hot cell effluents through charcoal filtration with an efficiency of 99% or greater prior to being released through the facility exhaust stack.

ATTACHMENT 14 UNIVERSITY OF MISSOURI

TECHNICAL SPECIFICATION RESEARCH REACTOR FACILITY Number 5.7 Page 1 of 2 Date _______

Amendment No._____

SUBJECT:

Iodine 131 Processing Hot Cells Applicability This specification shall apply to the surveillance of the equipment needed to safely process Iodine 131.

Objective The objective of this specification is to reasonably assure proper operation of the equipment needed to safely process Iodine 131.

Specification

a. An operability test of the facility ventilation exhaust system shall be performed monthly.

b. The operability of the facility ventilation exhaust system to maintain the Iodine 131 processing hot cells at a negative pressure with respect to the surrounding areas shall be verified daily prior to any process (channel check).

c. The radiation monitors as required by specification 3.1 1.c shall be calibrated on a semi-annual basis.

d. The radiation monitors as required by specification 3.11 .c shall be checked for operability with a radiation source at monthly intervals.

e. The efficiency of the Iodine 131 processing hot cells charcoal filter banks shall be verified biennially. It shall be verified that the charcoal filter banks have a removal efficiency of 99% or greater for iodine.

Bases

a. Experience has shown that monthly tests of the facility ventilation exhaust system are sufficient to assure proper operation.

ATTACHMENT 14 STECHNICAL SPECIFICATIO UNIVERSITY OF MISSOURI RESEARCH REACTOR FACILITY Number 5.7 Page 2 of 2 Date _______

Amendment No._____

SUBJECT:

Iodine 131 Processing Hot Cells (continued)

b. Verifying that the Iodine 131 processing hot cells are at negative pressure with respect to the surrounding areas prior to use ensures personnel safety.

c. Semiannual channel calibration of the radiation monitoring instrumentation will assure that long-term drift of the channels will be corrected.

d. Experience has shown that monthly verification of operability of the radiation monitoring instrumentation is adequate assurance of proper operation over a long time period.

e. Biennial verification of filter banks ensures that the filters will perform as analyzed.

v t e Letter Sequence Request
TAC:MF6514, (Open)
Initiation Request, Request, Request, Request, Request, Request, Request Acceptance... Administration Withholding Request Acceptance Questions 19 November 2015 19 November 2015 12 January 2016 Answers 30 December 2015 Results Approval... Other:
MONTHYEAR2015-08-18 [Table View]

ML16004A150

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