ML17172A195
| ML17172A195 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 06/19/2017 |
| From: | Rhonda Butler, Meffert B Univ of Missouri - Columbia |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17172A205 | List: |
| References | |
| Download: ML17172A195 (5) | |
Text
UNIVERSITY of MISSOURI RESEARCH REACTOR CENTER June 19, 2017 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station Pl-37 Washington, DC 20555-0001
REFERENCE:
Docket No. 50-186 University of Missouri-Columbia Research Reactor Renewed Facility Operating License No. R-103
SUBJECT:
Supplemental information in support of the request to amend the University of Missouri-Columbia Research Reactor Technical Specifications, which are appended to Renewed Facility Operating License No. R-103, pursuant to 10 CFR § 50.59(c) and 10 CFR § 50.90, as submitted to the U.S. Nuclear Regulatory Commission by letter dated May 3, 2017 By letter dated May 3, 2017, the University of Missouri Research Reactor (MURR) submitted a license
. amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) in order to conduct an experiment that would produce molybdenum-99 (Mo-99) in large quantities as part of its role in supplying critical medical radioisotopes to the domestic and international community. The experiment would utilize General Atomics' (GA) Selective Gas Extraction (SGE) process, which consists of irradiating target rods containing low-enriched uranium (LEU) pellets in the reactor graphite reflector region in order to produce fission product Mo-99. The Mo-99 would then be extracted from the LEU in dedicated hot cells using the SGE technology. Included with the LAR submittal was eight (8) attachments, six (6) of which contained proprietary information which was withheld from public disclosure pursuant to 10 CPR§ 2.390.
Attached are two (2) versions of two (2) attachments of additional technical information to supplement the May 3, 2017, submittal to further assist the NRC in review of the LAR, specifically GA Design Report No. 30441R00038, "Computational Fluid Dynamics Analysis of Target Housing Design Calculation Report," and GA Design Report No. 30441R00041, "Critical Heat Flux Testing at the University of Wisconsin Final Report," Attachments 9 and 10, respectively. One version of each attachment contains proprietary information, and we request that you withhold it from public disclosure per 10 CPR § 2.390. These documents are clearly labeled "Withhold from Public Disclosure Under 10 CPR 2.390." The other two attachments are redacted versions that can be disclosed to the public. Also attached is the affidavit (executed by Christina A. Back), dated June 16, 2017, which explains the /J z_ D reasoning for the request. } RK_
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1513 Research Park Drive Columbia, MO 65211 Phone: 573-882-4211 Fax: 573-882-6360 Web: http://web.missouri.edu/-murrwww Fighting Cancer with Tomorrow's Technology
If there are any questions regarding this Jetter, please contact me at (573) 882-5118 or MeffertB@missouri.edu. I declare under penalty of perjury that the foregoing is true and correct.
ENDORSEMENT:
Sincerely, Reviewed and Approved Ralph A. Butler, P.E.
Reactor Manager Director xc: Reactor Advisory Committee Reactor Safety Subcommittee Isotope Use Subcommittee Dr. Mark Mcintosh, Vice Chancellor for Research, Graduate Studies and Economic Development Mr. Alexander Adams, U.S. Nuclear Regulatory Commission Mr. Geoffrey Wertz, U.S. Nuclear Regulatory Commission Mr. Johnny Eads, U.S. Nuclear Regulatory Commission Attachments:
- a. General Atomics Affidavit of Christina A. Back, dated June 16, 2017
- b. Attachment 9 - GA Design Report No. 30441R00038, "Computational Fluid Dynamics Analysis of Target Housing Design Calculation Report" -Redacted Version
- c. Attachment 9 - GA Design Report No. 30441R00038, "Computational Fluid Dynamics Analysis of Target Housing Design Calculation Report" - Un-redacted Version
- d. Attachment 10 - GA Design Report No. 30441R00041, "Critical Heat Flux Testing at the University of Wisconsin Final Report" - Redacted Version
- e. Attachment 10 - GA Design Report No. 30441R00041, "Critical Heat Flux Testing at the University of Wisconsin Final Report" - Un-redacted Version JACQUELINE L MAlYAS My Cormlialon Expiru Mardi 26, 2019 HIMsd County Collllllulanl15'343111 2 of2
+ GISllSIUll. A'l'OlllllCS ANO APPIUAnlO ctnnVUllllS GENERAL ATOMICS AFFIDAVIT OF CHRISTINA A. BACK I, Christina A. Back, Vice President of Nuclear Technologies and Materials, General Atomics, do hereby affirm and state:
(1) I have been delegated the function of reviewing information described in paragraph 3 which General Atomics requests be withheld from public disclosure or publication and I am authorized to execute this affidavit on behalf of General Atomics.
(2) The affidavit is submitted under the provisions of 10CFR Part 2.390 to withhold documents containing confidential commercial and proprietary information (as set forth in paragraph 3 following) of General Atomics from public disclosure or publication.
(3) General Atomics (GA) has partnered with The University of Missouri Research Reactor (MURR) and Nordio~ to develop the Reactor-Based Mo-99 Supply System (RB-MSS)
Project using its Selective Gas Extraction process. The information sought to be withheld is related to the.analysis, design, development and licensing of General Atomics' technology for deployment at MURR.
This information is contained in the following documents submitted as supporting information for MURR's "License Amendment Request to Implement Selective Gas Extraction Target Experimental Facility at the University of Missouri Research Reactor."
License Amendment Request TITLE Attachment No.
GA Report 30441 R00038: "Computational Fluid Dynamics 9
Analysis of Target Housing Design Calculation Report" GA Report 30441 R00041: "Critical Heat Flux Testing at the 10 University of Wisconsin Final Report" Nonproprietary redacted versions of these documents are being simultaneously provided where the proprietary information on each page has been appropriately redacted.
(4) In making this application for withholding of proprietary information of which it is the owner, General Atomics relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10CFR Part 9.17(a)(4). a2.390(a)(4), and 10CFR2.390(b) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential." The material for which exemption from 3550 GENERAL ATOMICS COURT,SAN DIEGO, CA 92121-1122 PD BOX 85608, SAN DIEGO, CA 921116-5608 (858) 455-3000
disclosure is hereby sought is all "confidential commercial information," and/or also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energv Project v. Nuclear Regulatory Commission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA 704F2d1280 (DC Cir. 1983).
(5) Pursuant to Paragraph (4) above, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Atomics' competitors without license from General Atomics constitutes a competitive economic advantage over other companies;
- b. Information which, if used by a competitor, would reduce his or her expenditure of resources or improve his or her comp~titive position in the design, manufacture, shipment, installation, assurance or quality, or licensing of a similar product.
- c. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
- d. The information sought to be withheld is being submitted to the NRC in confidence.
The information is of a sort customarily held in confidence by General Atomics, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by General Atomics. No public disclosure has been made, and it is not available in public sources.
- e. The information classified as proprietary was developed and compiled by General Atomics at a significant cost to General Atomics. This information is classified as proprietary because it contains detailed data and analytical results not available elsewhere. This information would provide other parties, including competitors, with information from General Atomics technical database and the results of evaluations performed by General Atomics. Release of this information would improve a competitor's position without the competitor having to expend similar resources for the development of the database. A significant effort has been expended by General Atomics to develop this information.
- f. The research, development, engineering, and analytical costs associated with General Atomics' unique selective gas extraction system and process comprise a substantial investment of time and resources by General Atomics, whose precise value is difficult to quantify, but clearly is substantial and extends beyond the original development cost. Public disclosure of the information sought to be withheld is likely to cause substantial harm to General Atomics' competitive position.
GENERAL ATOMICS Christina A Back Vice President, Nuclear Technologies and Materials A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.
State of California County of San Diego On Jun-16-2017 before me, Brenda B. Dawson. Notary Public, personally appeared Christina A. Back, who proved to me on the basis of satisfactory evidence to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.
WITNESS my hand and official seal.
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(Signature of Notary)