ML100330073

Written Communication as Specified by 10 CFR 50.4(b)(1) Regarding the Response to the University of Missouri at Columbia - Request for Additional Information License Renewal Environmental Report, Dated December 30, 2009

ML100330073
Person / Time
Site:	University of Missouri-Columbia
Issue date:	01/29/2010
From:	Rhonda Butler, Foyto L Univ of Missouri - Columbia
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD3034
Download: ML100330073 (13)

Text

Research Reactor Center Research Park Columbia, MO 65211 University of Missouri-Columbia PHONE (573) 882-4211 FAx (573) 882-6360 January 29, 2010 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001

REFERENCE:

Docket 50-186 University of Missouri - Columbia Research Reactor Amended Facility License R-103

SUBJECT:

Written communication as specified by 10 CFR 50.4(b)(1) regarding the response to the "University of Missouri at Columbia - Request for Additional Information Re: License Renewal Environmental Report (TAC No. MD3034)," dated December 30, 2009 On August 31, 2006, the University of Missouri-Columbia Research Reactor (MURR) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to renew Amended Facility Operating License R-103.

On December 30, 2009, the NRC requested additional information and clarification regarding the renewal request in the form of four (4) questions. Those questions, and the MURR's responses to those questions, are attached. If there are any questions regarding this response, please contact me at (573) 882-5276. I declare under penalty of perjury that the foregoing is true and correct.

ENDORSEMENT:

Sincerely, Reviewed and Approved, Leslie P. Foyto Ralph A. Butler, P.E.

Reactor Manager Director Enclosed: Report on Compliance with the Clean Air Act Limits for Radionuclide Emissions from the Comply Code - V1 .6, prepared April 15, 2009 xc: Reactor Advisory Committee Reactor Safety Subcommittee - )ý',

o MARGEE P.STOUT Dr. Robert Duncan, Vice Chancellor for Research -N....

-'" "*'..--

z "tPTARY My Commisso E.ores

-- March 24,2012 Mr. Craig Basset, U.S. NRC * ~ M~ontgomery County Mr. Alexander Adams, U.S. NRC ComMisso0O5 436 AN EQUAL. oppoRTuNrTy/ADA INsTITUON

.1. Your environmental report was submitted as part ofyour license renewalpackage in 2006. Please discuss any changes that have occurred since submission of the report or any additions to information needed to reflect the passage of time since submission.

The following is a list of changes and additions to information to the Environmental Report since submission in 2006.

Page 1-1 Ho-166-DOTMP is no longer produced at MURR.

Page 1-10 In the summary of results relating to the issue of "Refurbishment impacts," there is mention of a planned building addition. Construction of this new 30,300 ft2 building addition -

designated as the North Office Addition - has now been completed. The building consists of offices, some additional laboratory space and a 16 MeV cyclotron, and its support equipment. No activities associated with operation of the reactor are conducted in this building.

Page 2-6 In Section 2.4, "Operational Boundaries," it states that the operations boundary consists of the outer walls of the Research Reactor Facility (laboratory and reactor containment buildings) and the adjacent cooling tower. The operations boundary now consists of the outer walls of the Research Reactor Facility (north office addition, and laboratory and reactor containment2 buildings) and the adjacent cooling tower and shipping and receiving building. A new 3,127 ft shipping and receiving building was constructed on the 7.5 acre facility lot to enhance security at the facility. Incoming and outgoing packages are received and staged for shipment in this building such that transport vehicles are not required to enter the gated parking lot which surrounds the facility.

Page 3-3 The two (2) tube-type, water-to-shell primary coolant heat exchangers have been replaced by two (2) water-to-water plate-type heat exchangers.

Page 3-4 The two (2) lined carbon steel 7,000 gallon demineralized make-up water storage tanks have been replaced with two (2) stainless steel tanks.

Page 3-9 In Section 3.5, "Employment," there is also mention of a building addition. As described above, construction of this building has now been completed.

The Environmental Report states in several places (pages 1-14, 3-5, 4-13, 4-25 and 4-32) that there is no radioactive waste stored permanently on site. This was accurate at the time the report was prepared and we still do not intend to store waste on site permanently. However, the restriction of access to the Barnwell waste site in 2008 has left MURR with no options for disposal of Class B and C waste. Under normal circumstances MURR makes a shipment of Class B waste approximately every two years. These shipments primarily contain activated metal components produced as a result of normal reactor operations. MURR now maintains these materials in temporary long term storage within the reactor facility until permanent disposal options become available. The Texas Low Level Radioactive Waste Disposal Compact Commission is currently considering rulemaking changes that would allow for the importation of limited quantities of waste from other waste compacts. If these changes are adopted, MURR will explore the possibility of using that facility for permanent disposal.

Page 2 of 8

2. Section 4.2.8. Please provide datafor the last 10 years for annualperson-rem per group, average annual individual dose per group, and the maximum annual individual dose per group. Your groups should accountfor allpersons badged.

Year 20090), Annual Average Annual Maximum Annual Individual Dose Individual Dose Group Person-Rem (rm men Analytical Chemistry Services(2) 0.544 41.8 165 Director's Office 0.243 9.0 42 Facility Support Operations 1.327 37.9 339 Hot Cell/Shipping 3.493 436.6 832 Regulatory Assurance Group 2.247 149.8 689 Irradiations 0.089 22.3 58 Nuclear Analytical Analysis 0.349 24.9 86 Neutron Scattering 0.495 30.9 128 Reactor Operations 13.841 532.3 809 Isotope Production 1.053 210.6 353 Research"2 ' 0.257 8.0 41 Radiopharmaceutical 1.192 47.7 128 Silicon 0.744 186.0 *358 Note 1: 2009 data reflects cumulative dose through November 2009.

Note 2: Analytical Chemistry Services group was spilt into the Analytical Chemistry Services and Research groups in 2009.

Year 2008 Annual Average Annual Miximumh Annual-`

Pe.son-Ren ; Individual Dose< Individual Dose, Grou.p P er-onýR e m - (rm 6rem) (mrem ),,,

Analytical Chemistry Services 1.224 27.2 243 Director's Office 0.443 16.4 34 Facility Support Operations 1.347 35.4 117 Hot Cell/Shipping 4.854 606.8 991 Regulatory Assurance Group 2.947 .196.5 803 Irradiations 0.206 51.5 142 Nuclear Analytical Analysis 0.628 44.9 133 Neutron Scattering 0.84 49.4 303 Reactor Operations 17.571 702.8 1140 Isotope Production 1.208 302.0 399 Radiopharmaceutical 1.105 44.2 135 Silicon 2.534 332.5 686 Page 3 of 8

" Year 2007 Annual Average Annual Maximum Annual Individual Dose Individual Dose Group Person-Rem (mrem) (mrem)

Analytical Chemistry Services 0.913 24.0 237 Director's Office 0.336 14.0 60 Facility Support Operations 1.589 46.7 172 Hot Cell/Shipping 4.427 553.4 787 Regulatory Assurance Group 2.457 163.8 625 Irradiations 0.321 64.2 198 Nuclear Analytical Analysis 0.363 33.0 72 Neutron Scattering 1.089 60.5 291 Reactor Operations 18.448 709.5 1241 Isotope Production 1.423 237.2 452 Radiopharmaceutical 0.713 26.4 73 Silicon 1.497 374.3 682 Average Annual Maximum Annual Year 2006 Annual Individual Dose Individual Dose Group Person-Rem (mrem) (mrem)

Analytical Chemistry Services 0.354 11.8 51 Director's Office 0.522 22.7 158 Facility Support Operations 2.656 37.4 460 Hot Cell"*) 0.920 NA NA Regulatory Assurance Group 2.668 166.8 637 Irradiations 0.341 68.2 207 Nuclear Analytical Analysis 0.266 22.2 65 Neutron Scattering 0.426 28.4 143 Reactor Operations 18.971 729.7 1146 Isotope Production 0.647 161.8 274 Radiopharmaceutical 1.025 36.6 135 Shipping"'* 3.461 494.4 673 Silicon 1.550 387.5 768 Special Project(2 ) 0.013 1.3 10 Note 1: Hot Cell and Shipping groups were combined into one group named Shipping in August 2006.

Note 2: Special Project group ceased operation at MURR during May 2006.

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Average Annual Maximum Annual Year 2005 ,Annual Group Person-RemaIndividualDose Individual Dose (mrem) (mrem)

Analytical Chemistry Services 0.269 10.8 83 Director's Office 0.207 9.9 124 Facility Support Operations 2.165 50.3 342 Hot Cell 2.781 927.0 1296 Regulatory Assurance Group 2.371 158.1 469 Irradiationstl) 0.942 235.5 470 Nuclear Analytical Analysis 0.138 9.9 42 Neutron Scattering 0.299 17.6 234 Reactor Operations 18.187 673.6 1038 Isotope Production 0.707 235.7 235 Radiopharmaceutical 0.786 35.7 168 Shipping 1.702 283.7 664 Silicon(l) 1.019 254.8 901 Special Project 0.035 5.0 4 Note 1: Two members of the Irradiations staff were transferred to the Silicon group in 2005.

Average Aniual Maximum Annual Y 4Individual Dose Individual Dose Group Person-Rem (mrem) (mrem)

Analytical Chemistry Services 0.559 29.4 71 Director's Office 0.187 8.9 76 Facility Support Operations 1.306 29.0 224 Hot Cell 1.883 470.8 669 Regulatory Assurance Group 1.944 121.5 566 Irradiations 0.577 144.3 362 Nuclear Analytical Analysis 0.351 31.9 58 Neutron Scattering 0.653 36.3 207 Reactor Operations 16.202 600.1 1529 Isotope Production 1.029 205.8 333 Radiopharmaceutical 0.784 31.4 131 Shipping 0.931 155.2 366 Silicon 0.624 208.0 555 Page 5 of 8

Average Annual Maximum Annual Yroup 2003son-ul Group Person-Rem Individual me)(rm Dose Individual Dose (mrem) (mrem)

Analytical Chemistry Services 0.483 24.2 65 Director's Office 0.205 9.3 96 Facility Support Operations 1.759 46.3 192 Hot Cell 1.907 476.8 639 Regulatory Assurance Group 1.922 137.3 407 Irradiations 0.359 89.8 123 Nuclear Analytical Analysis 0.319 35.4 111 Neutron Scattering 0.753 57.9 302 Reactor Operations 15.267 610.7 1078 Isotope Production 1.932 386.4 675 Radiopharmaceutical 0.829 59.2 147 Shipping 0.698 139.6 243 Silicon 0.449 149.7 419 Year 2002 Annual Average Annual Maximum Annual 2002snnual Yroup Individual Dose Individual Dose Group Person-Rem(me)me)

(mrem) ,(mrem)

Analytical Chemistry Services 0.259 13.6 42 Director's Office 0.647 29.4 295 Facility Support Operations 1.387 46.2 328 Hot Cell 2.999 749.8 1127 Regulatory Assurance Group 4.766 297.9 1384 Irradiations 0.636 106.0 216 Nuclear Analytical Analysis 0.231 25.7 74 Neutron Scattering 0.528 40.6 134 Reactor Operations 17.762 634.4 1104 Isotope Production 1.863 186.3 599 Radiopharmaceutical 1.407 93.8 503 Shipping 0.888 177.6 357 Silicon 0.486 162.0 471 Page 6 of 8

Year 2001 Annual Average Annual Maximum Annual Individual .Dose Individual Dose Group Person-Rem (mrem) (mrem)

Analytical Chemistry Services 0.076 4.8 34 Director's Office 0.572 19.1 190 Facility Support Operations 2.008 57.4 440 Hot Cell"') 3.790 947.5 1330 Regulatory Assurance Group 6.255 417.0 1500 Irradiations(2) 0.761 84.6 370 Nuclear Analytical Analysis 0.248 24.8 40 Neutron Scattering 0.570 24.8 100 Reactor Operations 20.120 693.8 1640 Isotope Production 3.363 177.0 614 Radiopharmaceutical 1.975 179.5 884 Shipping(" 2.570 642.5 810 Silicon(2) 0.530 265.0 530 Note 1: Hot Cell/Shipping group was split into the Hot Cell and Shipping groups in 2001.

Note 2: Silicon group was split into the Irradiations and Silicon groups in 2001 after the topaz program was restructured.

Year 2000 Annual Average Annual Maximum Annual Yrou2000sAn-ina Individual Dose Individual Dose Group Person-Rem* me)

(mrem) .(rm (torero)

Analytical Chemistry Services 0.080 5.7 70 Director's Office 0.700 23.3 490 Facility Support Operations 2.070 64.7 480 Regulatory Assurance Group 6.310 525.8 1930 Nuclear Analytical Analysis 0.050 4.5 10 Neutron Scattering 0.510 18.2 160 Reactor Operations 19.680 787.2 1510 Isotope Production 4.460 297.3 1340 Radiopharmaceutical 2.780 308.9 830 Hot Cell/Shipping( t ) 6.500 812.5 1830 Silicon/Topaz(2) 3.540 208.2 1610 Note 1: Hot Cell and Shipping groups were combined into the Hot Cell/Shipping group in 2000.

Note 2: Silicon and Topaz groups were combined into the Silicon/Topaz group in 2000.

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3. Section 4.2.11.2, Liquid Waste. This section states that liquid waste is filtered until no suspended solids of a visible size remain prior to release to the sanitary sewer. Please discuss how this method complies with the requirements of 10 CFR 20.2003(a)(1).

10 CFR 20.2003(a)(1) states that "A licensee may discharge licensed material into sanitary sewerage if... the material is readily soluble (or is readily dispersible biological material) in water."

NRC Information Notice 94-07, "Solubility Criteria for Liquid Effluent Release to Sanitary Sewerage Under the Revised 10 CFR Part 20," was issued on January 28, 2004 to emphasize the changes in 10 CFR Part 20 with respect to liquid effluent release to sanitary sewerage and to encourage licensees to prepare for these revisions. IN No. 94-07 provided two of the more rigorous approaches to determine a chemical compound's solubility in water: (1) Direct Determination of Compound Solubility Class, Formal Solubility, or Solubility Product (Ksp), and (2) Filtration and Radiometric Analysis of Suspended Solids. IN No. 94-07 also stated "Whether one of the above approaches or a self developed alternative is used, it is a good health physics practice to document this approach in the form of a procedure. Procedures such as these annually include provisions for documentation of any models, calculations, analytical measurements, and/or quality control measures used. This information is usually maintained with the applicable release records, to demonstrate that the developed procedure will ensure compliance with the regulations."

American National Standard ANSI/ANS-15.11-1993 (reaffirmed May 27, 2004), "Radiation Protection at Research Reactor Facilities," defines soluble material as "having no significant visible turbidity or significant visible suspended solids so as not to change the characteristics as a solution, e.g., so as not to have the characteristic of a sludge."

MURR Operating Procedure OP-RO-741, "Waste Tank System Operation," provides procedural steps and precautions to operate and sample radioactive liquid waste while in retention within the MURR Waste Tank System and prior to disposal from the system. Prior to sampling, the waste water is recirculated through 0.5-micron filters for a minimum of twelve (12) hours. The water is then sampled and if any suspended or settled solids can visibly be seen in the sample, the water is recirculated again until no suspended or settled solids can be seen.

Experience shows that by filtering the waste water a minimum of twelve (12) hours through 0.5-micron filters, and then using the definition of soluble material as stated in ANSI/ANS-15.11 when sampling, we comply with the requirements of 10 CFR 20.2003(a)(1).

4. Section 5.1. This section states that the results of a run of the COMPLY code is an appendix of the environmentalreport. The appendix appears to be missing. Please provide a copy of the latest run of the COMPLY code.

Enclosed you will find the results of the most recent run of the COMPLY code, which was performed for calendar year 2008.

Page 8 of 8

COMPLY: V1.6. 4/15/2009 4.: 10 40 CFR Part 61 National Emission Standards for Hazardous Air Pollutants REPORT ON COMPLIANCE WITH THE CLEAN AIR.ACT LIMITS FOR RADIONUCLIDE EMISSIONS FROM THE COMPLY.CODE - V1.6.

Prepared by:

Research Reactor Research Reactor Columbia, MO 65211 Ron Dobey, CHP 573 882-5218 Prepared for:

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Washington, DC 20460

11 COMPLY: V1.6. 4/15/2009 4:10 University of Missouri SCREENING LEVEL 4 DATA ENTERED:

Release Rate Nuclide (curies/YEAR)

AR-41 1.250E+03 C-14 1 1.070E-02 CE-144 Y 8 .010E-06 CO-60 Y 1.820E-05 1-131 D 7 .240E-05 H-3 V 8.540E+00 K-40 D 4 .550E-05 SC-46 Y 3.060E-06 1-125 D 2.880E-06 SN-113 W 3.160E-06 ZR-95 D 8.700E-07 CS-137 D 3. 120E-07 GD-153 D 4. 640E-07 BA-140 D 2 .280E-06 CE-141 Y 3. 670E-07 1-133 D 1. 150E-04 HF-181 D 1 .750E-07 BE-7 Y 8. 330E-06 Release height 21 meters.

Building height 16 meters.

The source and receptor are not on the same building.

Building width 48 meters.

Building length 77 meters.

COMPLY: V1.6. 4/15/2009 4:10 STACK DISTANCES, FILE: E:WINDROSE Distance DIR (meters)

N 760.0 NNE 150.0 NE 150 .0 ENE 250.0 E 250 .0 ESE 850 .0 SE 800.0 SSE 800 .0 S 130.0 SSW 600.0 SW 900.0 WSW 1250.0 W 1600.0 WNW 1100.0 NW 950.0 NNW 600.0 WINDROSE DATA, FILE: E:MURRWindRose.dat Source of wind rose data: Callaway NGS Dates of coverage: 1985-1990 Wind rose location: Fulton, MO Distance to facility:- 33 miles Percent calm: 0.00 Wind Speed FROM Frequency (meters/s)

N 0.030 3.58 NNE 0.040 2.78 NE 0.040 2.41 ENE .0.036 2 .57 E 0.046 2. 86 ESE 0. 051 2.80 SE 0.095 2 .97 SSE 0.104 3.16 S 0. 110 3.48 SSW 0. 072 3.52 SW 0.066 3.36 WSW 0.044 3.23 W 0.062 3.39 WNW 0.073 3.55 NW 0.068 3.51

NNW 0.063 3.39 Distance from the SOURCE to the FARM producing VEGETABLES is 2000 meters.

COMPLY: V1.6. 4/15/2009 4:10 Distance from the SOURCE to the FARM producing MILK is 2000 meters.

Distance from the SOURCE to the FARM producing MEAT is 2000 meters.

NOTES:

The receptor exposed to the highest concentration is located 150. meters from the source in the NNE sector.

He gets his VEGETABLES from a farm located 2000. meters from the source in the NNW sector.

He gets his MEAT from a farm located 2000. meters from the source in the NNW sector.

He gets his MILK from a farm located 2000. meters from the source in the NNW sector.

Input parameters outside the "normal" range:

Stack file distance is unusually FAR.

RESULTS:

Effective dose equivalent: 4.1 mrem/yr.

Effective dose equivalent: 5.OE-05 mrem/yr due to Iodine.

Comply at level 4.

.This facility is in COMPLIANCE.

It may or may not be EXEMPT from reporting to the EPA.

You may contact your regional EPA office for more information.

• • • • • • • • • • END OF COMPLIANCE REPORT **********