ML16004A153

Univ. of Missouri- Columbia - Transmittal of Responses to Request for Additional Information in Support of a Request to Amend the Technical Specifications Appended to License No. R-103

ML16004A153
Person / Time
Site:	University of Missouri-Columbia
Issue date:	12/30/2015
From:	Rhonda Butler Univ of Missouri - Columbia
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16004A169	List: ML16004A150 ML16004A153
References
TAC MF6514
Download: ML16004A153 (3)

Text

UNWVERSITY of MISSOURI RESEARCH REACTOR CENTER December 30, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station P1-3 7 Washington, DC 20555-0001

Reference:

Docket 50-186 University of Missouri-Columbia Research Reactor Amended Facility License No. R-103 Enclosed are two versions of responses to the Request for Additional Information (RAI) from the U.S. Nuclear Regulatory Commission (NRC), dated November 19, 2015 (TAC No. MF65 14), in support of a request to amend the Technical Specifications appended to Amended Facility License No. R-1 03. One version contains proprietary information and we request that you withhold it from public disclosure per 10 CFR 2.390. It is clearly labeled "Withhold from Public Disclosure Under 10 CFR 2.390." Attached is the affidavit, dated December 30, 2015, which explains the reasoning for this request. The second is a redacted version that can be disclosed to the public. Additionally, Attachments 1 through 6 and 9 to these responses also contains proprietary information that we request you withhold from public disclosure per 10 CFR 2.390.

Redacted versions of those attachments are also included. Attachments 7, 8 and 10 through 14 contain no proprietary information.

If you have any questions, please contact John Fruits, the facility Reactor Manager, at (573) 882-53 19.

Sincerely, CountyofI,~!.

Ralph A. Butler, P.E. y om n  : ,2g Director M omsinEqe~M~ 621 RAB/jlbJACQUELINE L.BOHM RAB/jlbNotary Public-Notary Seal STATE OF MISSOURI Commissioned for Iloward County Enclosures My Commission Expires: Mat~h 26. 2019

~Commission # 15834308 z 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

UNIVERSITY of MISSOURI RESEARCH REACTOR CENTER 10 CFR 2.390 AFFIDAVIT OF RALPH A. BUTLER AFFIDAVIT I, Ralph A. Butler, herby affirm and state as follows:

(1) I am the Executive Director, of University of Missouri Research Reactor (MURR), and I have been authorized to execute this affidavit on behalf of MURR.

(2) The information contained in the enclosed letter, dated December 30, 2015, regarding a request to amend Facility License No. R-103 contains proprietary commercial information related to MURR becoming a domestic supplier of Iodine 131. The letter is clearly labeled "Withhold from Public Disclosure Under 10 CFR 2.390." The proprietary information includes sensitive business information created by or for MURR. This information should be held in confidence by the NRC and withheld from public disclosure.

(3) In making this application for withholding of proprietary information of which it is the owner, MURR believes that the information qualifies for withholding under the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Section 552(b)(4), the Trade Secrets Act, 18 U.S.C. Section 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.390(a)(4) for trade secrets and commercial information because:

i. This information is and has been held in confidence by MURR.

ii. This information is of a type that is customarily held in confidence by MURR, and there is a rational basis for doing so because the information includes sensitive business information pertaining to the production of Iodine 131.

iii. The information is being transmitted to the NRC voluntarily and in confidence.

iv. This information is not available in public sources and could not be gathered readily from other publicly available information.

v. Public disclosure of this information would create substantial harm to the competitive position of MURR by disclosing certain business decisions MURR has made or is considering and the analysis that went behind those decisions. Development and evaluation of this commercial inforrhiation was achieved at, and disclosure could lead to additional, significant cost to MURR.

vi. Public disclosure of the information sought to be withheld is likely to cause substantial harm to MURR'S competitive position. The value of the information goes beyond the disclosure of actual information pertaining to MURR's potential business, and includes substantial time and work towards d'eveloping the project, and represents significant efforts by MURR and its associates. The research, development, engineering, and analytical costs comprise a substantial investment of time and money by MURR. The precise value of the information is difficult to quantify, but clearly is substantial.

vii. MURR's competitive advantage will be lost if its competitors are able to use the results of MURR's activities to aid their ownl commercial activities. The value of this information 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

to MURR would be lost if the information were disclosed to the public. Making such information available to other entities without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive MURR of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment.

Ralph A. Butler in and for the State of Missouri, this'_*__day of I& tk b~ii2 15l.

Witness my hand and Notarial Seal.

JACQUELINE LOI-,IOM Notar' Public-Notary Seal S'l ATE OF MISSOURI C-ommissioned fbr H~oward County My Commission Expire:s: Mai*th 26. 2019 Commission # 1563430S Notary Public My Commission Expires: o~4 ice (z~ov~i Date