ML16004A150

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
Person / Time
Site:	University of Missouri-Columbia
Issue date:	12/30/2015
From:	Butler R A, Fruits J L Univ of Missouri - Columbia
To:	Office of Nuclear Reactor Regulation
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ML16004A169	List: ML16004A150 ML16004A153
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TAC MF6514
Download: ML16004A150 (100)

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UNWVERSITY of MISSOURIRESEARCH REACTOR CENTERDecember 30, 2015U.S. Nuclear Regulatory CommissionAttention: Document Control DeskMail Station P1-37Washington, DC 20555-0001REFERENCE: Docket 50-186Univers~ity of MissoUri-Columbia Research ReactorAmended Facility License No. R-103SUBJECT: Written communication as specified by 10 CFR 50.4(b)(1) regarding responses to the"University of Missouri at Columbia -Request for Additional Information Regardingthe License Amendment Request to Modify the Technical Specifications to ProduceRadiochemical Sodium Iodine at the University of Missouri at Columbia ResearchReactor (TAC No. MF65 14)," dated November 19, 2015By letter dated July 20, 2015, the University of Missouri-Columbia Research Reactor (MURR) submitteda 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 radiochemicalsodium iodide (1-131).There are currently no competing modalities for its use as a therapy for thyroid dysfunctions and nocurrent supplier within the U.S. This license amendment request would allow MURR to continue toperform 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 theproposed lic~nse amendment request in the form of fourteen (14) questioris. Those questions, andMUJRR'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 penaltyof 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.eduFighting Cancer with Tomorrow's Technology ENDORSEMENT:Sincerely, Reviewed and ApprovedJohn L. Fruits Ralph A. Butler, P.E. state of I "'t!'J1 A}Reactor Manager Director County of JACUELNE .BHM nd s~ mt01ob9refoi~tiiixc: Reactor Advisory Committee STATE OF MISSOURI aeelr mN Commissioned for H oward County c)~~,o8yPblReactor Safety Subcommittee My Commission Expires: Matrch 26, 2019 FMy CommjssNo E.xpi$e: Mdaic 28, 2019Dr. Garnett S. Stokes, ProvostComsin#5640Dr. Mark McIntosh, Vice Chancellor for Research, Graduate Studies and Economic DevelopmentMr. Alexander Adams Jr., U.S. Nuclear Regulatory CommissionMr. Geoffrey A. Wertz, U.S. Nuclear Regulatory CommissionMr. Johnny Eads, U.S. Nuclear Regulatory CommissionReferences:1. MicroShield 8.02 -Computer program used to estimate dose rates due to a specific externalradiation source2. 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 calculations4. Isotopes Technologies Dresden GmbH Document -"A 12-021_IMU-J131 lQuotation_2013-09-18"5. COMPLY Computer Code -Screening tool for evaluating radiation exposure from atmosphericreleases of radionuclides6. Federal Guidance Report FGR No. 11, "Limiting Values of Radionuclide Intake And AirConcentration and Dose Conversion Factors For Inhalation, Submersion, And Ingestion"7. International Commission on Radiological Protection ICPR Publication 30, "Limits for Intakes ofRadionuclides by Workers"8. U.S. Nuclear Regulatory Commission Regulatory Guide 1.4, "Assumptions Used for Evaluatingthe Potential Radiological Consequences of a Loss of Coolant Accident for Pressurized WaterReactors"9. Oak Ridge National Laboratory ORiNL/TM-6607, "A Literature Survey of Methods to RemoveIodine from Off-Gas Streams Using Solid Sorbents," Jubin, R. T., March, 197910. 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 TestingCriteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-FeatureAtmosphere 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 TestingCriteria for Air Filtration and Adsorption Units of Normal Atmospheric Systems in Light-Water-Cooled Nuclear Power Plants" (June 2001, Rev. 2)13. MUIRR Technical Specifications14. MURR Reactor Utilization Request 440, " -To Produce I-131"15. Institute of Environmental Sciences IiES-RP-CC-008-84, "Recommended Practice for Gas-PhaseAdsorber Cells"16. American National Standard ANSI/ANS-15.1-2007, "The Development of TechnicalSpecifications for Research Reactors"17. MUIRR Emergency Plan18. 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 Dose2. MicroShield 8.02 Analysis -ITD Transfer Cask Dose3. MicroShield 8.02 Analysis -BHI-C and PHC Doses4. MicroShield 8.02 Analysis -DHC Dose5. MicroShield 8.02 Analysis -HIHC Waste Dose6. MicroShield 8.02 Analysis -Type B Safekeg-HS Model 3977A Shipping Cask Dose7. MicroShield 8.02 Analysis -PHC 150 Curie Distributed 1- 131 Dose8. MicroShield 8.02 Analysis -PHC 150 Curie 1-131 Dose9. MicroShield 8.02 Analysis -PHC U Dose10. MicroShield 8.02 Analysis -Ductwork Dose11. MicroShield 8.02 Analysis -Filter Banks12. MURR Drawing No. 1125 (Sheet 5 of 5), "MIB East Addition Exhaust Schematic"13. Map of MUJRR Site -Emergency Planning Zone and Site Boundaries14. Newly Proposed and Revised Technical Specification Pages3 of 62

1. The amendment request appears to contain a numbering discrepancy as it contains two Sectionsnumbered 6.0O, and Sections 5.1 and 5.2 follow after Section 6.0O. Indicate if the second occurrenceof Section 6.0 should be numbered Section 7.0, and ifSections 5.1 and 5.2 should be numbered 6.1and 6.2, or advise ifotherwise.Yes, there is a numbering discrepancy in the original license amendment request. Sections 5.1 and5.2 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 Area6.2 Dose Consequences in the Unrestricted Area7.0 Comparison to Current Fueled Experiment Technical Specifications2. NUREG-1537, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, " Part 1, Section 11.1.1, "Radiation Sources," provides guidance that licenseesshould provide conservative estimates of external radiation fields in occupied or accessible areas.a. For normal operation of the proposed experiment, provide estimates of external doses topersonnel that will occur during movement of irradiated targets from the irradiation positionto the handling hot cell (HHC).The transfer process from the irradiation position to the Handling Hot Cell (HiHC) is performed intwo (2) steps. First, an in-house MURR transfer cask, a versatile, robust cask used to move avariety of irradiated targets within the facility, is used to move the irradiated targets from thereactor pool to hot cell HC-0 1, which is located in the Laboratory Building basement. There thetarget is removed from the MURR transfer cask and placed into an Isotopes Technologies DresdenGmbH (ITD) transfer cask specifically designed to mate with the bottom of the IHHC. The ITDtransfer cask is then moved from HC-0 1 to the HIHC, which is located in the Iodine-i131 ProcessingArea (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 adistance of 1 meter (3.28 fi) from the transfer casks were calculated. The in-house MURIR transfercask contains 5 inches (12.7 cm) of lead in the radial direction from the target. Dimensions for theITD 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. Isotopicabundances of 1-131, all isotopes and sodium-24 from the activation of the aluminumencapsulation material were included in the source term description in MicroShield. Theand aluminum isotopes were calculated using StandAct (Ref. 3) and the Bateman equationassuming four (4) targets irradiated at flux of for followedby 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of decay. The 1-131 activity was assumed to be per target, ortotal for four (4) targets.4 of 62 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 30mR/hr and 0.8 mR/hr at 1 meter (3.28 ft) (Attachment 2). Assuming that staff would be an averageof 1 meter (3.28 ift) from the source for approximately 15 minutes each, this results in doses of 0.75mIR 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 programdesigned to perform standard activity calculations. These calculations use the general form of thestandard 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 (rdcm2/s);= decay constant (s-l);T = irradiation time (seconds);and can include the decayed activity term 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 themost current edition of the Nuclides and Isotopes -Chart of the Nuclides but other references mayalso be utilized if deemed appropriate.b. For normal operation of the proposed experiment, provide estimates of external dose rates inaccessible 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 processedat approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for the four (4) targets. Subsequently, all resulting 1-131product would be moved to the Dispensing Hot Cell (DHC). Shielding calculations are based uponnominal, best estimates of radioactivity.The ILHC and the PHC have 200 mm (7.87 in) of lead on all sides. Since processors will be presenton the front side of the cells for the longest period of time, the dose to these individuals wascalculated using MicroShield at a position 0.5 meters (1.64 ift) from the front face of either the IHHCor the PHC. The resulting dose rate is estimated to be 0.09 mR/hr with all four (4) targets in the hotcell (Attachment 3).5 of 62 For the DHC, the lead shielding is 100 mm (3.94 in) on all sides. In the case of the HIHC and thePUC, the dose is driven by the 774 (50%) and 852 keV (27%) gammas from thus theadditional shielding. For the DHC Micro Shield calculation the source represents only theprocessed 1-131. The dose rate was again calculated at 0.5 meters (1.64 fi) from the front face andis 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) inheight, 1500 mm (59.06 in) in width, with 200 mm (7.87 in) of lead on the processor side of theHIHC and the PHC and 100 mm (3.94 in) for the DHC. The geometry in MicroShield assumed apoint 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 thefront face and 500 mm (19.69 in) from the front face (assumed position of the processor). Theradioisotope activities were taken from StandAct and assumes four (4), targetsirradiated at a flux of for followed by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of decay. The I-131activity was assumed to be per target or total. MicroShield predicts 0.2mR/hr on the surface and 0.09 mR/hr at 0.5 meters (1.64 ft) for the I-HC and the PHC (Attachment3). 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 rateon the face of the HIHC and the PHC was in the 0.006 to 0.0 15 mR range for a single, 20 to 30Curie target.c. Provide estimates of the external dose rates from 1-131 processing waste stored in the HHCand 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 thedecay constant. These values were calculated assuming nominal radioactivities. This calculationalso assumes that no waste material is ever removed from the 1I-IG. The only significantlyabundant and energetic gamma from these isotopes is 159 keV (84%) for .alsohas 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-Iwith equilibrium activities of these five (5) isotopes in waste cans placed in the middle ofthe hot cell. The resulting dose rate was 2.7E-6 mR/hr (Attachment 5). Thus, the dose rate fromwaste is dominated by the short-lived isotope (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />), which is 0.09 mR/hr at the time6 of 62 of processing (see response to Question 2.b) and thus is decaying over the next few days postprocess.Target activities were taken from StandAct for a target irradiated at a flux offollowed by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of decay. All isotopes with half-livesgreater than 15 days were included.The calculation of equilibrium activities is given by the equation A,, = AI[u, where .A is the rate atwhich activity is "produced" each week in units of Curies/day introduced into the waste stream andthe decay constant is in 1/day.d. For normal operation of the proposed experiment, provide estimates of external doses topersonnel that will occur during handling of the final product solution following its removalfrom the DHC.The final product solution is first loaded into a shipping container insert within the Dispensing HotCell (DHC) which is then subsequently loaded into a depleted uranium (DU) shipping containmentvessel (CV) coupled directly to the bottom of the DHC. The CV is part of a U.S. Department ofTransportation (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 essentiallyno dose (0.09 mRibr) to the processors when the product solution is in the hot cell. For the productsolution in the CV, MicroShield calculations predict 0.47 mR/hr at 0.5 meters (19.69 in) from thesurface (Attachment 6). Assuming a 15-minute operation in close proximity (0.5 m) to the CVresults in a personnel dose of 0.12 mR. For this calculation, the 1-131 activity in the CV is assumedto be a nominal at time of shipment due to the decay of 1-131 between the time ofprocessing 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 Model3977A CV dimensions specified in Croft's "03 Licensing drawings" document -the primary shieldbeing 4.765 cm (1.88 in) of DU. The thin-walled stainless steel (SS) insert was modelled notaccounting for the effect of the SS. A poly shim was assumed to hold the vial in place. If theTungsten insert was used then the dose would be even less.e. Discuss the compliance of the values provided for items a. through d., above, with the limitsin Title 10 of the Code of Federal Regulations (JO CFR) Part 20.From the responses to Questions 2.a through 2.d, the following dose estimates were determined forprocessing four (4) targets. Since only one processing day per week will typically beundertaken, these represent weekly doses.Question 2.a: Transport of targets to the HIIC 1.0 mRemQuestion 2.b: Operator dose during processing 0.72 mRem7 of 62 Question 2.c: Waste disposal in the EI-IC 0.0 mRemQuestion 2.d: Product solution handling 0.12 mRemAssuming 50 working weeks per year, MUIRR processing personnel will receive dose from thetransportation 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 = 42miRem per year. Four (4) processing personnel could theoretical obtain this dose. All expectedannual 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 thatlicensees should estimate the release of airborne radionuclides to the environment during normaloperation, 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 10microcuries of Iodine-i 31 (1-131) could escape from the dry-distillation process system "whenscaled to a weekly maximum activity process. "a. Provide a basis or explanation for the limit of 10O microcuries of 1-131.Consideration of the results from several multi-Curie, suggest thatcontaining the maximum feasible fraction of the 1-131 activity in the Processing Hot Cell (PHC) isthe most effective approach to minimizing the release of 1-131 to the environment. To be clear, thiscontainment approach seeks to sequester the 1-131 inventory in discrete traps and filters within thePHC and minimize release to the PHC itself even though there are multipletriethylenediamine/potassium iodide (TEDA/KI) impregnated charcoal filters within and integral tothe PHC designed to trap any I-131 that is not collected in the product-collection traps.8 of 62

~is distributed to the PHC to be captured by the TEDA/KIimpregnated charcoal filters in the PEC and downstream from the PEC.Based on the results of several multi-Curie, performed prior to April 2015with the PHC in the as-installed configuration, a 3-component iodine trap was designed to be usedwithin 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-131into the full volume of the PHC; and instead capture it in discrete modules that would have activeflow 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 <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 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 insubsequent paragraphs incorporated a prototype of the 3-component trap on the processing-lineexhaust 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 <br />0 hours <br />0 weeks <br />0 months <br /> ending on April 27, 2015 at 00:20 andsubjected to in two batches during the week of April 27, 2015. The 1-131 activityinventory and balance are summarized in Table 1 below with all activities decayed to May 1, 2015at 17:00. The target was processed in two (2) batches. The first process used approximately20% of the crushed target and was started on April 28, 2015 at 11:20 and concluded at 12:45. Thesecond process, using approximately 80% of the target, started on May 1, 2015 at 10:20 andconcluded at 12:50.The predicted 1-131 activity in this target is based on a hybrid model derived from theharmonization of theoretical production calculations and measured production factors. It takes intoaccount production from both activation products and ) and their decaypathways 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.9 of 62 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% ofCopnn/esrpin(mCi) Total Measured Total PredictedPredicted I- 13 1 produced 24,664 101.295 100.000Measured I-131 activitiesProduct-collection traps 24,300 99.800 98.5243-component PHC trap installed on the exhaust from the product-collection trapsAqueous chemical diffuser2010.8002trap __________AGX-2 filter 28.39 0.116 0.115Aqeu hmclbbl- 0.00186 7.64E-06 7.54E-06counter trap __________________Total I-131 measured 24,348.60186 100.000 98.762The 3-component trap installed on the processing-line exhaust from the product-collection trapsconsists of, in sequence: (1)~into which the exhaust air flow from the product-collection traps is introduced througha 0.5 micron diffuser. (2) A silver zeolite filter (AGX-2, 16-40 mesh, silver = 40.3 wt%) cartridgehaving a diameter of 2.25 inches and a bed depth of 1 inch (HI-Q Environmental Products Inc., SanDiego, CA). (3)into which the exhaust air flow from the AGX-2 cartridge is introduced through a tubehaving an inner diameter of 0.125 inches. The silver zeolite cartridge is included specifically toimprove the capture and retention of methyl iodide- 131 (CH31-1 31) through its conversion to thethermodynamically stable and insoluble AgI-1 31.After a suitable decay time, the 3-component trap was removed from the PHC and the 1-131 activitywas quantified in each component by high-resolution gamma-ray spectroscopy resulting in themeasured activities given in Table 1 above. In addition, the AGX-2 filter was carefully subdividedinto 10 more-or-less equal layers and the 1-131 activity was quantified in each individual layer. Ofthe 28.39 mCi of 1-131 captured by the AGX-2 filter, 28.33 mCi (99.78%) was isolated on the first9 mm (of 25 mm) -See Figure 1 below. Only 0.00186 mCi of 1-131 was measured in the aqueoustrap downstream from the AGX-2 filter.10 of 62 1-131 activity (mCi) at 5/1/2015 on AGX cartridgetotal 1-131 activity per AGX layer plotted at the layer midpoint(total i-131 activity on entire AGX cartridge =28.395 mCi)10-C-E0030.10.01-0.0015101520250cartridge depth (mm) from inlet (left) to outlet (right)0 total layer activity (mCi) plotted at midpointFigure 1 -1I-131 Activity on AGX-2 Filter Cartridge in Discrete SectionsAfter the is complete and the has returned to the ambient PHCtemperature (room temperature) the flow through the product-collection traps and 3-component trapis discontinued. The is evacuated through a separate exhaust line to an aqueousbubble trap. Flow through this exhaust line is also discontinued when roomtemperature 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) andthe 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 beentirely 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 thecombination of the product-collection traps and the modules making up the 3-component trap. Thelast module (the aqueous bubble-counter trap) of the 3-component trap had very little iodineactivity (0.00186 mCi); however, this is not a high-efficiency trap, consequently some 1-131 mayhave 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 through11 of 62 this cartridge was only 9 of the 25 millimeters where 99.78% of the 1-13 1 on this cartridge wasfound. Furthermore only microgram quantities of 1-131 were found on the last silver zeolitesegment-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 theprocessing-line exhaust into the full volume of the PHC. The discharge of some 1-131 to the fullvolume of the PHC from the exhaust line through its aqueous bubble-counter trap is likelyin this experiment. Unfortunately, the 1-131 activity in this bubble-counter solution was notmeasured and no other direct method of assessing the activity discharged to the PHC by this routewas available in this experiment.The impact of this experiment on the release of 1-131 to the environment through the MURRventilation exhaust stack was tracked for several days by the facility Stack Radiation Monitor -seeFigure 2 below. There were small but measurable increases observed on the iodine monitor thatcorresponded to 1-131 releases to the environment following the two processes completed duringthe week of April 27, 2015. The first process using approximately 20% of the target started onApril 28, 2015 at 11:20 and resulted in a peak on the Stack Radiation Monitor approximately 24hours later. The 1-131 concentration in the 24-hour period in which this peak was centered was6.69E-12 pxCi/mi corresponding to 8.3 1iCi. The second process using approximately 80% of thetarget started on May 1, 2015 at 10:20 and also resulted in a peak on the Stack Radiation Monitorapproximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later. This peak, centered in a 24-hour period had an 1-131 concentrationof 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 theenvironment averaged over a 24-hour period would have been 2.05E- 11 pCi/nmL (10.25% of the 10CFR Part 20 limit) and corresponding to 25.4 jtCi of 1-131.12 of 62 S1.6e-ll2 1.4e-llIo 1.2e-11C'-II8.0e-12-" 8.Oe-12 III~- 4O --1-31( I/Lstartresocessg star 24.5 Cuirocessoperaionsabsen an-know voaii/le) -3 ore.Cneunltetm eurdt civover eventeperiodo(19fdays)The mximu singe-prCor trgespondingito tat 2435 Curie tprocess wl ae o -3at he imeofpro(10ng CFR e 2AiConcetrationeimint foruss131i the- preiou/m rgrpsw)huaditisna clar gefrom the pe iousdigu-retthatith entiien13cythmaivity releasedo -3 to the evrnetfoevrnetoea24hour period. orexmpeaproimatelyd to 6basae requgire forrtesodn Stac Radiation Monitorbaselin tof retore Pato 125 times) Ith i-13 bgaslinrdue thatis gene1rallyaosefrvted duringrutinectivitytrgestrtio of) aacetable baseline wiaisfor tinfluenuceini theubrofg taprgvemets tha cane processedover agiven eriod fftime 3-component trap used in the scoping experiment previously discussed; and to also include this trapon the exhaust line in addition to the processing-line exhaust to further trap and retainadditional 1-131 in discrete modules in the PHC and avoid releasing it to the full-volume of thePHC.Specifically, the 3-component trap used on the product exhaust line during the processing discussedabove has been redesigned to include a second AGX-2 filter cartridge in series with the existingcartridge 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 fromthe AGX-2 filter. Extrapolating from this 24.349 Ci process to the maximum-activity process of Uincreases the activity exhausted from the AGX-2 filter to 18.5 jiCi. The AGX-2 filters arerated at an efficiency of 95.2% if all the activity is in the form of CH3I-1 311 and greater than 95%for any molecular 1-131. Taking this into account, the release of 1-131 to the PHC from aprocess is estimated at approximately 1 jiCi from the processing-line exhaust and less than 1 1tCifrom the exhaust line. This extrapolation does not assign any 1-131 trapping efficiency tothe 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 iscaptured in the product-collection traps and the 3-component processing-line exhaust trap accountfor all of the 1-131 activity within the uncertainties in the prediction model and experimentalmeasurements. The introduction of aqueous chemical traps and a silver zeolite filter to capture andretain the 1-131 activity in discrete modules within the confines of the PHC does substantiallyreduce the release of 1-131 to the environment. Our measurements indicate that less than 5 areexhausted into the PHC when scaled to the maximum process. Certainly the processing ofa single 1-131 target is currently sustainable with an 1-131 release to the environmental atless than 25% of the Part 20 limit of 2E-1 0 iiCi/ml. The planned improvements to further captureand retain the I-131 activity in the PHC are expected to allow for an increased through-put rate ofmaximum-activity targets.1The 95.2% efficiency was measured using the ASTM D-3803-89 test method at a flow rate of 1.0 CFM, atemperature of 30 0C, a relative humidity of 95 +/--1%, and a methyl iodide loading of 1.75 mg/in3.Incomparison, the ambient temperature in the PHC will be <30 °C. The average outdoor relative humidity inColumbia ranges from 44% to 93%. For the conditioned air entering the PUC this range will be translateddownward. The flow rate through the apparatus and 3-component trap during processing is350 cm3/minute (0.01236 CFM). Assuming the processing of an target over a 240 minuteperiod, the greatest (by a factor of at least 1E6) iodine source-term is the 0.5 ppm impurity in theused to fabricate the targets resulting in an iodine mass of 90 micrograms. Assuming a 2 ppm (molefraction) methane concentration in air and a 1% yield (conservative by a factor of 10 based on ourexperimental results), the concentration of methyl iodide is 0.025 mg/in3.Each of the parameters(temperature, relative humidity, flow rate, and methyl iodide concentration) that exist during theprocess are more favorable for methyl iodide capture efficiency compared to the conditions underwhich the AGX-2 filter material was certified via the ASTM D-3803-89 test method used. Consequently the95.2% efficiency measured is conservative relative to the prevailing conditions.14 of 62

b. Provide an estimate of the maximum quantity of 1-131 that could be released from the processsystem to the PHC during normal processing of each irradiated target, and the total quantityof 1-131 that could be released to the PHC over a one-year period of normal operation of thisexperiment.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 theIexhaust (See Figure 1 of original license amendment request) is expected to be less than 10of 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 tothe 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) processesper 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 1release to the PHC of 2,080 jiCi.c. Provide an estimate of the quantities ofi1-131 released to the environment from normalprocessing of irradiated targets, and calculate the maximum predicted concentration ofairborne 1-13 1 in unrestricted areas, as well as the timeframes over which this concentrationwill exist.Case 1 -Annual Stack Release Concentration:Facility Ventilation Exhaust Stack Flow Rate =30,500 ft3/min30,500 ft3/min x 2.83E+4 cc/ft3 x 60 mir/hr x 24 hr/day x 365 days/yr = 4.54E+-14 cc/yrAverage Annual Stack Concentration = 2080 jiCi / 4.54E+ 14 cc-4.58E-12 giCi/mlThis value only reflects the concentration of 1-131 being released from MUIRR at the ventilationexhaust 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 ifreleased over a one (1) day period as noted above, the predicted concentration over that time framewould be the following:Facility Ventilation Exhaust Stack Flow Rate = 30,500 ft3/min15 of 62 30,500 ft3/min x 2.83E4 cc/ft3x 60 minihr x 24 hr/day x 1 day 1 1.24E+12 ccAverage Stack Concentration during Time Frame = 57.4 gtCilprocess / 1 .24E+1 2 ccAs discussed above, the projected routine target activity of only reflects the concentrationof 1-131 being released from MUJRR at the ventilation exhaust stack and does not take intoconsideration any downstream dilution at the site boundaries. The area within the MURR siteboundaries is controlled by the University of Missouri. The above concentrations are averaged overa 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period based on the peak of 1-131 released appearing approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> post-process. Note: As stated in the bases of Technical Specification 3.7 .a, "The normal short burstreleases at the facility are five to ten seconds in duration and occur on average of ten times per dayfive days per week. The short bursts affect the concentration less than one percent when averagedover a one-day period."d. Discuss the compliance of the values provided for item c., above, with the limits in 10 CFRPart 20.In both cases noted above, the resulting concentrations at the MUJRR ventilation exhaust stack arebelow the 10 CFR 20 limits for the unrestricted release of 1-131: 2E-1 0 iiCi/ml. Thus thepercentage 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 additionalexhaust 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 toQuestion 3.a, MURR is working towards reducing the effluent concentrations further as the processis 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 thelicensees analyze the consequences of experiment failures. MURR 's license amendment request,Section 6.0O, states that failure of the proposed experiment could result in airborne releases of 1-131,to the PHC. Section 5.1 of the amendment request provides estimates of external doseconsequences in the restricted area due to 1-13 1 captured on charcoal filters or passing through16 of 62 ventilation systems following a release into the PHC. Section S.2 of the amendment requestprovides estimates of dose consequences in the unrestricted area following a release of 1-131 intothe PHC.a. For an experiment failure resulting in a release of 150 curies of airborne 1-131 into the PHC,the license amendment request does not appear to consider the external dose consequences inaccessible portions of the restricted area near the PHC. Provide calculated dose rates nearthe PHC for this scenario, and estimate the timeframes over which personnel will be exposedto these dose rates.A release of 150 Curies (maximum hypothetical activity contained in a single target during an 1-131processing evolution) in the Processing Hot Cell (PHC) would have negligible effect on externaldose. The external dose during processing in the PHC is dominated by the 774 and 852 keVgammas from as given in the response to Question 2.b, resulting in a dose rate of 0.09mR/hr. The dose from 1-131 from its predominate 364 keV gamma through 20 cm (7.87 in) of leadis several orders of magnitude below the dose from .And whether the 1-131 is containedas essentially a point source in the or distributed evenly over theinternal volume, has very little effect.MicroShield calculated a distributed source dose (Attachment 7) at the position of a processor ofonly 2.8E-7 mRihr and 1E-6 mR/hr for a point source (Attachment 8). By comparison, the dosefrom (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 areawould occur.b. Estimates of external dose consequences in the restricted area due to 1-131 captured oncharcoal filters or passing through ventilation systems following a release of 1-131 to thePHC do not appear to include any contribution due to plating of 1-131 within the ventilationductwork. Provide an estimated maximum dose rate in accessible areas from 1-131 plated inthe hot cell ventilation ductwork, for the allowable combination of online/offline filters thatwill result in the highest dose rates.The most probable location for dose to personnel from 1-131 plating out in the ventilation systemductwork is on top of the hot cells where the exhaust ducting exits the filter banks (Bank No. 2 and3). This ductwork is approximately 2.5 m (8.2 ft) above the processors' heads and about 2.5 m (8.2fi) long before it turns away from the work area. Assuming a 150 Curie airborne release (maximumhypothetical activity for a single target during an 1-131 processing evolution), two (2) filter banksoperating at 99% efficiency and one (1) bank out-of-service, the 1-131 passing into the duct work is0.0 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.17 of 62 In the remote chance that an individual was on top of the QC Laboratory (Room 299V) at the timeof release (not an area that is routinely occupied), the distance between the ducting and theindividual would be reduced from 2.5 m (8.2 ft). Assuming the same parameters as above, andassuming that the 1-131 passing into the ductwork travels from above the hot cells without depositand 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 andthe dose point at the middle of the 2.5 m (8.2 ft) length of ductwork (Attachment 10). Distances of2.5 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 ofthe 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, version8. 02) of external dose consequences in the restricted area due to 1-13 1 captured on charcoalfilters are not clearly described. Describe how the filter specifications provided inAttachments 7 and 8, are translated to the "Source Dimensions," "Dose Points," and"Shields, " inputs used for the dose calculations for the following:i. The CAMFIL filters used in Filter Banks Nos. 1, 2, and 3; andii. The Flanders/CSC filters used in Filter Bank No. 4.All MicroShield input decks are described below and include dose calculations for Questions 2 and4, in addition to the modelling of the filter banks.In the response to Question 2.a, calculating dose during the transition of lltargets from thereactor 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 caskat 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 theMURR and ITD transfer casks are provided in Tables 1 and 2, respectively.Table 1 -Micro Shield Model for Targets in MiURR Transfer CaskSoure Heght1.0 cm -Default for MicroShield one-dimensional calculation. Thesource is actually ~-10 cm tall and the cask is ~-90 cm tall.Source Radius 5.08 cm -With assumed air density.Source Length N/ASource 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).18 of 62 Table 2 -MicroShield Model for Targets in riD Transfer Cask1.0 cm -Default for Microshield one-dimensional calculation. TheSourceHeightsource is actually -10 cm tall and the cask is -'70 cm tall.Source Radius 5.08 cm -With assumed air density.Source Length N/ASource 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, theProcessing Hot Cell (PHC) and the Dispensing Hot Cell (DHC), the MicroShield point sourcemodel was utilized. For the HIIC and PHC, the source includes 1-131, all isotopes andNa-24 from the activation of the aluminum can (Na-24 does not actually enter the PHC, but itscontribution to dose is small and is conservatively included). For the DHC only the 1-131 is usedfor the source. Being a point source, any target or product self-absorption has been conservativelyomitted for the HHC and the PHC calculations. The target was assumed to be 80 cm (31.5) fromthe inside front face of the hot cell and the shielding thickness was 20 cm (7.9 in) thick. Dosepoints at 100 cm (39.4 in) and 150 cm (59.1 in) were used to calculate dose at the surface and at 0.5m (1.6 ft) from the surface.Table 3 -MicroShield Model for Dose to Processors from HI-IC and PHCSource Radius N/A -Point source assumption.Radius to Inner 80 cm -Assumes the source is approximately two-thirds of the waySurface of Hot Cell back in the hot cell.Source Nuclides 1-131 and all I isotopes.20 cm -Per ITD document "A 12 -021I_MU-J 131_Quotation_2013-09-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 thetarget. The DHC shielding thicknesses is reduced to 10 cm (3.9 in).19 of 62 Table 4 -MicroShield Model for Dose to Processors from DHCSource Radius N/A -Point source assumption.Radius to Inner 80 cm -Assumes the source is approximately two-thirds of the waySurface of Cell back in the hot cell.Source Nuclides I- 13110 cm -Per ITD document "A 12-021l_MUI-J131_Quotation_2013-09-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, thesame point source model described in Table 3 was used. The waste was assumed to be at anaverage distance of 50 cm (19.7 in) from the front face of the HHC and the inventory isotopes assumes that the equilibrium accumulated activities exist within the HJHC.Table 5 -MicroShield Model for Dose to Processors from Radioactive Waste in the iHHCSource Radius N/A -Point source assumption.Radius to Inner 60 cm -Assumes the source is at an approximate average distanceSurface 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, theMicroShield "Cylinder Volume -Side Shields" model was again used. The dimensions of theMIURR HS Shipping Cask Containment Vessel (CV) were taken from Croft's "03 Licensingdrawings" document. This assumes a source that is 1.55 cm (0.6 in) in radius and is designated aswater, a polyethylene insert (modelled as water with a density of 1.1 gm/cm3), an aluminum innerwall 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 edgeof 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.20 of 62 Table 6 -MicroShield Model for Dose from of I-131 in MUJRR Shipping Cask CVSoure Heght1.0 cm -Default for Microshield one-dimensional calculation. TheSourceHeightsource 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 1-131into the PHC during processing, the MicroShield "Rectangular Volume" model was used. Per ITDdocument "A12-021_MU-J131_Quotation_2013-09-18," the hot cell dimensions are 120 cm (47.2in) deep by 150 cm (59.1 in) wide by 160 cm (63 in) in height. A slab of lead shielding 20 cm (7.9in) 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 PHCSource 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 hotcell ventilation system ductwork, the MicroShield line source was used. All I-131 activity (0.0 15Curies) 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 DuctworkSource Radius N/A -Line source assumption.Source Length 250 cm.Shield N/ASource 0.015 Ci of I- 131.Dose Points Surface (10 cm), 50 cm and 250 cm.21 of 62 In the original license amendment request, doses from the CAMFIL charcoal filters werecalculated. In order to most accurately model the geometry, the predefined annular-cylinder sourcewas selected within MicroShield. However, upon review of the input data it was discovered thatvalues of millimeters were inserted as values of centimeters thus unintentionally skewing thecalculated exposure rates. An updated version of the exposure rates due to shine from the filters at1 foot (30.5 cm) (Tables 6, 7 and 8 in the original license amendment request) have been providedbelow using the assumptions in Table 9 for the "Source Dimensions" inputs for both the CAMFILand the Flanders/CSC charcoal filters. Also, updated MicroShield outputs are included in thisresponse as Attachment 11.Table 9 -MicroShield Source Dimensions for the Filter BanksDescription (i) Filter Bank No. 1 (i) Filter Bank No. 2 & 3 (ii) Filter Bank No. 41.0 cm -The height of 1.0 cm -The height of the 1.0 cm -The height ofthe filter is approximately filter is approximately 14 the filter is16.8 cma; however, 1.0 cm; however, 1.0 cm was approximately 3.4925cm was used to provide a used to provide a cm; however, 1.0 cmconservative result and conservative result and was used to provide aaccount for any non- account for any non- conservative result andHeight uniform buildup of uniform buildup of account for any non-activity on the filter activity on the filter rather uniform buildup ofrather than making the than making the activity on the filterassumption activity is assumption activity is rather than making thedistributed evenly distributed evenly assumption activity isthroughout. throughout, distributed evenlythroughout.30.0 cm -From theWidt N/AN/Aspecification documentWidth /A N/APB-2003-l1103 the filterwidth is 12 inches.30.0 cm -From thespecification documentPB-2003-1103 the filterLengh N/ N/Adepth which is definedas length in MicroShieldis 12 inches.4.0 cm -From reference 2.9 cm -From reference3603.40.03 specification 3603.30.00 specificationIner sheet the inner radius of sheet the inner radius ofCylinder the annular charcoal filter the annular charcoal filter N/ARadius is 4 cm [(1 8-5-5)/2 = 4]. is 2.9 cm [(1 3-3.6-3.6)/2 =2.9].22 of 62 0.0 cm -From the filter 0.0 cm -From the filterspecification sheet specification sheetInner perforated stainless steel perforated stainless steelCylinder casing is present casing is present however, N/AThickness however, these these dimensions aredimensions are ignored ignored for shieldingfor shielding purposes. purposes.0.0 cm -From the filter 0.0 cm -From the filterspecification sheet specification sheetOuter perforated stainless steel perforated stainless steelCylinder casing is present casing is present however, N/AThickness however, these these dimensions aredimensions are ignored ignored for shieldingfor shielding purposes. purposes.5.0 cm -From reference 3.6 cm -From referenceSource 3603.40.03 specification 3603.30.00 specification N/Asheet the depth of the sheet the depth of thecarbon bed is 5.0 cm. carbon bed is 3.6 cm.0.0 cm -From the filter 0.0 cm -From the filterspecification sheet specification sheetOuter perforated stainless steel perforated stainless steelCylinder casing is present; casing is present; N/AThickness however, these however, thesedimensions are ignored dimensions are ignored forfor shielding purposes. shielding purposes.Upon review of the inputs used to determine the "Dose Points," the following coordinates havebeen 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. 4Dose point #1 represents the 0.0 -Dose point #1 represents Dose point #1 represents theexposure 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 whichcorresponds to a 30 cm corresponds to a 30 cm corresponds to a centered 30distance from the outer distance from the outer cm distance from the outersurface 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 graphicalrepresentation of the representation of the representation of theMicroShield model. MicroShield model. MicroShield model.23 of 62 Dose Point"IVoid Air Z Lead ShielFigure 1 -Graphical Representation of the MicroShield Model for Filter Bank No. 1Dose PointZ Lead SieldFigure 2 -Graphical Representation of the MicroShield Model for Filter Banks No. 2 and 3\ Dose PointZ \ Lead ShieldSourceFigure 3 -Graphical Representation of the MicroShield Model for Filter Bank No. 4In 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 ofeach of these inputs of each shield.24 of 62 Table 11 -MicroShield Shield Assumptions for (i) Filter Bank No. 1Shield N Dimension Material Density4 cm -From reference Air -The inner volume 0.00122 g/ cm3 -The3603.40.03 specification sheet of the annular charcoal density of air atthe inner radius of the annular filter is modeled as air. standard temperaturecharcoal filter was determined This is consistent with and pressure wasto be 4 cm via the following reality, populated by defaultequation: within Micro ShieldCylinder which usesRadius OD -2 (Charcoal Depth) ANSIANS-6.6.1-2 1979.Or18 -2(5)2204.204 cm3 -The total Carbon -Was selected 1.8 g/ cm3 -Thevolume of the source from a predefined density of charcoalgeometry calculated by material list within the was selected from theMicro Shield from the input available materials in Chart of Nuclides, geometry parameters. This MicroShield. Carbon edition.volume is used to calculate a most similarlyspecific activity in the "Source represents the atomicSource Input" table. Proof of this number (Z-value) ofvalue can be seen by the charcoal.following equation:wr~,)2j1-2Orgr(9)2J1- yr(4) 21 ---204.204The value for a transition Air -Is used by default 0.00 122 g/ cm3 -Thedistance between the source by MicroShield for all density of air atgeometry and Shield 5 is null transition space, standard temperaturebecause it is assumed these However, for this and pressure wasTransition two objects are directly geometry the value populated by defaultadjacent to each other. does not factor into the within MicroShieldcalculation, which usesANSI/ANS-6.6. 1-1979.25 of 62 10 cm -The total thickness of Lead -was selected 11.35 g/ cm3 -Thethe lead shield adjacent to the from a predefmed density of lead wascharcoal filter. material list within the selected from Chart ofavailable materials in Nuclides, 1 6th edition.Shield 5 MicroShield. Leadidentically representsthe atomic number (Z-value) of the lead usedin the shield.MicroShield by default Air -Is used by default 0.00 122 g/ cm3 -Theassigns an additional shield by Micro Shield for all density of air atregion with air as the material air gaps between the standard temperaturewhen there is a gap between outermost shield and and pressure wasthe final shield and the dose the dose point, populated by defaultAir Gap point. MicroShield does not within MicroShielddisplay this value but it which usescorresponds 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 3Shield N Dimension Material Density2.9 cm -From reference Air -The inner 0.00 122 g/ cm3 -The3603 .30.00 specification sheet the volume of the density of air atinner radius of the annular annular charcoal standard temperaturecharcoal filter was determined to filter is modeled as and pressure wasbe 2.9 cm via the following air. This is populated by defaultequation: consistent with within Micro ShieldCylinder reltwhich usesRadius OD -2(Chiarcoal; Depth) reality..6.12 1979.Or13 -2(3.6)-2.9'226 of 62 106.311 cm3 -The total volumeof the source geometry calculatedby MicroShield from the inputgeometry parameters. Thisvolume is used to calculate aspecific activity in the "SourceInput" table. Proof of this valuecan be seen by the followingequation:.-2 T, 2h-- W(1ij ) 2)Carbon -Wasselected from apredefmed materiallist within theavailable materialsin MicroShield.Carbon mostsimilarly representsthe atomic number(Z-value) ofcharcoal.1.8 g/cm3 -Thedensity of charcoalwas selected from theChart of Nuclides, 1 6thedition.SourceOrir(6.5)21 -ir(2.9)21 = 1.06.311The value for a transition distance Air -Is used by 0.00122 g/ cm3 -Thebetween the source geometry and default by density of air atShield 5 is null because it is MicroShield for all standard temperatureassumed these two objects are transition space. and pressure wasTransition directly adjacent to each other. However, for this populated by defaultgeometry the value within MicroShielddoes not factor into which usesthe calculation. ANSJIANS-6.6.1-1979.10 cm -The total thickness of the Lead -was selected 11.35 g/ cm3 -Thelead shield adjacent to the from a predefined density of lead wascharcoal filter. material list within selected from Chart ofthe available Nuclides, 16edition.materials inShield 5 Micro Shield. Leadidenticallyrepresents theatomic number (Z-value) of the leadused in the shield.MicroShield by default assigns an Air -Is used by 0.00 122 g/ cm3 -Theadditional shield region with air default by density of air atas the material when there is a MicroShield for all standard temperaturegap between the final shield and air gaps between the and pressure wasAir Gap the dose point. MicroShield does outermost shield and populated by defaultnot display this value but it the dose point. within MicroShieldcorresponds to 30 cm which which usesrepresents a 1 foot exposure rate ANSIIANS-6.6.1-measurement. 1979.27 of 62 Table 13 -Micro Shield Shield Assumptions for (ii) Filter Bank No. 4Shield N Dimension Material Density900.0 cm3 -The total Carbon -was selected 1.8 g/ cm3 -Thevolume of the source from a predefmed density of charcoalgeometry calculated by material list within the was selected from theMicro Shield from the input available materials in Chart of Nuclides, 16mgeometry parameters. This MicroShield. Carbon edition.volume is used to calculate a most similarly representsspecific activity in the the atomic number (Z-Source "Source Input" table. Proof value) of charcoal.of this value can be seen bythe following equation:Len~gth x Wz~dth x tieig~htOr30 x30 x1 = 900.00.635 cm -The total Lead -was selected from 11.35 g/ cm3 -Thethickness of the lead shield a predefined material list density of lead wasadjacent to the charcoal within the available selected from Chart ofShed1 filter. materials in Micro Shield. Nuclides, 16m edition.Shield 1Lead identicallyrepresents the atomicnumber (Z-value) of thelead used in the shield.MicroShield by default Air -Is used by default 0.00122 g/ cm3 -Theassigns an additional shield by Micro Shield for all air density of air atregion with air as the gaps between the standard temperaturematerial when there is a gap outenmost shield and the and pressure wasbetween the final shield and dose point, populated by defaultAir Gap the dose point. MicroShield within MicroShielddoes not display this value which usesbut 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 licenseamendment request based on the assumptions stated above.28 of 62 Table 14 -150 Curie Target Exposure Rates Due to Shine from Filters at 1 FootFilter Bank Filter Bank Filter Bank jFilter BankNumber of Filters and No. 1 No. 2 No. 3 j No. 4Decontamination Factor(mirMitigated (4 of 4 filters -DF 1000) 2.44E-0 1 3 .20E-04 3 .20E-07 1 .26E-05Mitigated (3 of 4 filters -DF 1000) 0.00E+00 3.20E-01 3.20E-04 1 .26E-02Mitigated (4 of 4 filters -DF 100) 2.42E-01 3.17E-03 3.17E-05 1.25E-02Mitigated (3 of 4 filters -DF 100) 0.00E+00 3.17E-0l 3.17E-03 1.25E+00Table 15 -Target Exposure Rates Due to Slime from Filters at 1 FootFilter Bank Filter Bank jFilter Bank IFilter BankNumber of Filters and No. 1 I No. 2 No. 3 J No. 4Decontamination Factor(mirMiiatd(4o 4fltr -D 10 _ _.3E0 1.8E-0 1.8E )____2-0Mitigated (4 of 4 filters -DF 1000) 0.43E+00 1.88E-01 1.88E-04 7.42E-03Mitigated (3 of 4 filters -DF 1000) 1.42E+01 1.86E-03 1.86E-05 7.35E-03Mitigated (4 of 4 filters -DF 100) 0.00E+00 1.86E-01 1.86E-03 7.35E-01Table 16 -Target Exposure Rates Due to Shine from Filters at 1 FootFilter Bank fFilter Bank 1Filter Bank Filter BankNumber of Filters and No. 1 No. 2 J No. 3 No. 4Decontamination Factor (mRihr ___Mitigated (4 of 4 filters -DF 1000) 8.95E-02 1.17E-04 1.17E-07 4.63E-06Mitigated (3 of 4 filters -DF 1000) 0.00E+00 1.17E-01 1.17E-04 4.63E-03Mitigated (4 of 4 filters -DF 100) 8.87E-02 1.16E-03 1.16E-05 4.59E-03Mitigated (3 of 4 filters -DF 100) 0.00E+00 1.16E-01 l.16E-03 4.59E-01Tables 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 andfilter Decontamination Factors (DFs) of 100. The reason for the highest exposure rates on FilterBank No. 4 is due to the substantially thinner lead shielding thickness installed around this filter ascompared to Filter Banks No. 1 through 3.d. Dose estimates in the unrestricted area following a release of 1-131 into the PHC wereprovided for the emergency planning zone (EPZ) boundary using the Pasquill-Guifford (P-G)dispersion model methodology. However, dose calculations for the nearest residence wereperformed using the COMPLY code. It is not clear how the different methodologies used may29 of 62 affect the estimated dose results. Provide information demonstrating that the dose estimatesare consistent using either methodology.To provide clarity, MUJRR is recreating Table 15 from our original license amendment requestalong with two additional tables which will allow one to compare doses at the Emergency PlanningZone (EPZ) boundary, the nearest residence and the point of maximum effluent concentration [asdetermined by the Pasquill-Guifford (P-G) dispersion methodology] using both the computer codeCOMPLY (Ref. 5) and the P-G method of analysis. Tables 15 (a) through 15 (c) will also correctvalues that were supplied in Table 15 under the COMPLY heading at the nearest residence thatwere 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 theInternational Commission on Radiological Protection (ICRP) Publication 30 (Ref. 7) values (whichare also used in 10 CFR 20) for 1-131. The screening methodology which is internal to COMPLYis based on the National Council on Radiation Protection and Measurements (NCRP) CommentaryNo. 3, "Screening Techniques for Determining Compliance with Environmental Standards." Itshould be noted that COMPLY provides dose estimates which "are strictly for comparison withenvironmental standards and are not intended to represent actual doses to real people" according tothe U.S. Environmental Protection Agency's (EPA) website regarding the use of the COMPLYcode. However, both sets of doses are provided for comparison purposes to demonstrate that themethodologies are similar to each other in the cases of the EPZ boundary dose and the dose to thenearest residence and provide a reasonable estimation of potential offsite dose. The release of 150Curies of 1-131 corresponds to a maximum iodine inventory accidental release that paralles MIJRRTechnical Specification 3 .6.a for fueled experiments, represents the maximumhypothetical activity that could be released from a single i target, and isthe 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)COMPLY Pasquill-Guifford Pasquill-GuiffordActivity Model Model I Model -ThyroidReleased (EDE) (EDE) {(CDE)(Ci) (mrem)150 39 34 T1,134* 23 20 {6651 14 12 41630 of 62 Table 15 (b) -Offsite Dose Consequences -Umnitigated Release (No Filtration)Highest Receptor Site (400 meters North)COMPLY Pasquill-Guifford Pasquill-GuiffordActivity Model Model Model -ThyroidReleased (EDE) (EDE) (CDE)(Ci) (torero)150 52 303 10,1041 31 178 5,928U 19 111 3,705Table 15 (c) -Offsite Dose Consequences -Unmitigated Release (No Filtration)Emergency Planning Zone Boundary (150 meters North)COMPLY Pasquill-Guifford Pasquill-GuiffordActivity Model Model Model -ThyroidReleased (EDE) (EDE) (CDE)(Ci)(mrem)150 105 26 8661 62 15 5081 38 10 318The 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 therelease (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) using the worst-case atmospheric stability class for the distance beingmodeled; 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 thelocal 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 thereceptor height in relationship to the actual and effective stack heights. In the case of thenearest residence (760 meters North) the effective stack height is increasing again due to thelocal topography being at a lower elevation than at the 400 meter site (therefore divergencebetween the effective stack height and the receptor site) and the distance from the emissionsource in increasing at a rate which allows substantial dilution of the plume. The greatestagreement between the COMPLY output and the P-G methodology regarding offsite doseconsequences occurs at the location of the nearest residence.2. The COMPLY model uses local wind rose data that apportions the offsite dose to the nearestoccupant (highest exposed compass direction) assuming the release occurs over an annual31 of 62 basis (this is not a parameter that can be changed in COMPLY but allows a comparison for alike amount of release as noted in 1 above.) It appears that COMPLY does not take intoconsideration the local topography and the apparent convergence or divergence of the plumeand the surrounding receptor site elevation. In fact, there is no input parameter for receptorsite 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 fromthe 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 tocalculate the EDE. The P-G model EDE value shown above is derived from the calculated thyroidorgan dose and is thus is a product of the thyroid organ dose (CDE) multiplied by the thyroidweighting factor (0.03), as recommended in ICRP Publication 30.The following tables represent the expected offsite doses for the above described scenariosassuming the functioning of the number of filter banks occurring in the columns with the headingsof "Filter Banks." Filters were assumed to be 99% effective (DF = 100). The following tables aremeant 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 FilterReleased Banks Banks [ Banks(Ci) _________(mrem)150 COMPLY 0.39 3.9E-3 3.9E-5 3.9E-7Model* WB (EDE) 0.23 2.3E-3 2.3E-5 2.3E-7I 0.14 l.4E-3 1.4E-5 l.4E-7Table 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 FilterReleased Banks Banks Banks(Ci) (mrem)150 P-G 0.34 3.4E-3 3.4E-5 3.4E-7Model1 WB (EDE) 0.20 2.0E-3 2.0E-5 2.0E-71 0.12 1.2E-3 1.2E-5 1.2E-732 of 62 Table 16 (c) -Offsite Dose Consequences -Mitigated Release (Filtration)COMPLY Model -Highest Receptor Site (400 meters North)Activity Method 1 Filter Bank ] 2 Filter 3 Filter ] 4 FilterReleased J Banks Banks] Banks(Ci) (mrem)150 COMPLY 0.52 5.2E-3 5.2E-5 5.2E-7ModelU WB (EDE) 0.31 3.1E-3 3.1E-5 3.1E-71 0.19 1.9E-3 1.9E-5 1.9E-7Table 16 (d) -Offsite Dose Consequences -Mitigated Release (Filtration)P-G Model -Highest Receptor Site (400 meters North)ActivityReleased(Ci)150UUMethod2 Filter 3 Filter 4 Filter1 Filter BankBanks Banks BanksP-GModelWB (EDE)(mrem)3.03 3.03E-2 3.03E-4 3.03E-61.78 1.78E-2 1.78E-4 1.78E-6Table 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 FilterReleased Banks Banks Banks(Ci) (mrem)150 COMPLY 1.05 1.05E-2 1.05E-4 1.05E-6Model1 WB (EDE) 0.62 6.2E-3 6.2E-5 6.2E-71 0.38 3.8E-3 3.8E-5 3.8E-7Table 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 FilterReleased j Banks Banks Banks(Ci) (mrem)150 P-G 0.26 2.6E-3 2.6E-5 2.6E-7Model1 WB (EDE) 0.15 1.5E-3 1.5E-5 1.5E-71 0.10 1.0E-3 1.0E-5 l.OE-733 of 62 Thus, as indicated by examining the above tables, it is shown that only one functioning set ofcharcoal filters is necessary to ensure that offsite public dose is kept below the 100 mrem limit asprescribed in 10 CFR 20.1301.e. The offsite dose estimates do not indicate whether the calculations assumed an instantaneousrelease, or a release over some time period. Provide the release type and/or rate of releaseused in the dose calculations.For the calculations using COMIPLY, the releases of 150, i and i Curies are assumed to occurover a one year (annual) time period. COMPLY is used to demonstrate compliance with theNational Emission Standards for Hazardous Air Pollutants (NESHAPS) radionuclide constraint andthus calculates an annual offsite dose due to air emissions at the receptor site of interest. COMPLYuses local wind rose data to distribute the dose over an annual time period based on the frequencydistribution 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 (StabilityClass) exists during this time period for the particular receptor site being modeled, thus assuring aworst-case scenario for atmospheric dispersion.f. The COMPLY offsite dose calculations use wind rose data from the Columbia RegionalAirport for the period from 1984 to 1992. However, other inputs and assumptions used in thecalculations 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 accounted for'iv. Whether, and how, building wake effects are accounted for;"v. The exposure timeframe considered,"vi. The inhalation rate(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 ProtectionAgency (EPA) website, calculates doses to offsite personnel from a facility producing radioactiveemissions. It is a computer code used to ascertain regulatory compliance with the radioactiveNational Emission Standards for Hazardous Air Pollutants (NESHAPS) requirements of 10 CFR1101l(d) and is accepted by the NRC to demonstrate compliance with that regulation. As such thereis only limited information available as to some of the assumptions used in calculating offsite doseswithin the model. With regards to the items noted above, we will report what is known based ondocumentation available related to the COMPLY code.34 of 62

1. It is not known how or if stability classes are incorporated into the model. The onlyinput data required for input into the computer model is locally available wind rosedata which includes average annual wind speed from one of the normal 16 compasspoint directions; frequency of the corresponding wind speed and direction; and thepercentage 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 ourfacility 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. Basedon input parameters we assume not.iv. Building wake effects are accounted for in this program based on documentationavailable on line. This is collaborated by the requirement to use input parameterssuch 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 whenusing 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 inNCRP Commentary No. 3.viii. COMPLY calculates an Effective Dose Equivalent (EDE) for any isotope inputsentered into the program. Internally the code converts an organ dose [CommittedDose Equivalent (CDE)] to an EDE for reporting purposes. Thus, depending on theisotope it would compute a Committed Effective Dose Equivalent (CEDE) orsubmersion dose. The report only provides an EDE for iodine as a printed result.g. The P-G offsite dose calculations specify that D stability class and a southern wind directionare assumed, but other inputs and assumptions used for 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 accounted for;"iv. Whether, and how, building wake effects are accounted for;"v. The inhalation rate(s) used;" and,vi. Whether calculated doses include CEDE fr'om inhalation, submersion, or both.35 of 62 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) dispersionmodel.i. The initial analysis indicated that Stability Class 'D' provided a worst-case scenario.Upon reviewing the initial calculations performed, it was determined that assignmentto 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 acombination of average wind speed, in this particular direction being modeled, andthe large effective stack height which is caused by the relatively small differencebetween 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 760meter receptor site, the corresponding wind speed for the worst-case 'E' StabilityClass is 4 meters/sec. Stability Class 'E' prevails at 760 meters due to the lowereffective stack height at that point (16 meters).ii. The effective stack height used for the 150-meter EPZ receptor site is 29 meters andthe effective stack height used at the 760 meter receptor site (nearest resident) is 16meters.iii. Topography is accounted for when calculating the effective stack heights at MURRbased on the atmospheric stability class. The difference in elevation between thereceptor site and the release point is used as input parameter when using theDavidson Model, which we use, to calculate effective stack heights. This modelproduces very conservative stack height estimations when compared to other morecomplex 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 forcalculating inhalation dose by individuals (3154 m3/yr). This rate is generallyrecognized as an at-resting breathing rate which one would assume for individualsoffsite and not engaged in work activities.vi. In the case of inhalation of 1-131, MURR considers and calculates the dose to thethyroid as a Committed Dose Equivalent (CDE). It then uses the ICRP Publication30 reconmmended value of 0.03 to calculate the Effective Dose Equivalent (EDE) forthe whole body based on the thyroid dose.h. The P-G offsite dose calculations specif that the dose conversion factors used are from NRCRegulatory Guide (RG) 1.109, "Calculation of Annual Doses to Man from Routine Releasesof Reactor Effluents for the Purpose of Evaluation Compliance with 10 CFR S0, Appendix I."36 of 62 However, more widely-used and current dose conversion factors are available, such as thoseprovided in the Environmental Protection Agency Federal Guidance Report (EPA FGR) No.11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose ConversionFactors for Inhalation, Submersion, and Ingestion." The NRC staff noted that, for 1-131inhalation, NRC RG 1.109 lists a whole-body dose conversion factor of 6.92E-10 Sieverts perBecquerel (Sv/Bq)," whereas, EPA FGR No. 11 lists a more conservative whole-body doseconversion factor of 8. 89E-9 Sv/Bq. Justify the use of the less conservative dose conversionfactors listed in the RG 1.109.MIURR has switched to using the Environmental Protection Agency Federal Guidance Report (EPAFGR) No. 11 Dose Conversion Factor of 2.92E-7 Sv/Bq to calculate thyroid (organ) dose. We thenuse the ICRP Publication 30 recommended value of 0.03 to convert the corresponding dose to thethyroid to an Effective Dose Equivalent (EDE) to the Whole Body. The resulting product is almostidentical (8.76E-9 Sv/Bc) to the 8.89E-9 Sv/Bq value from FGR No. 11 noted above. The slightdiscrepancy can be attributed to a rounding error in converting units from the original ICRPPublication 30 values.i. The P-G Offsite dose calculations indicate that the D stability class provides the mostconservative results. However, the NRC staff notes that depending on7 the release height oreffective release height(s) used for the P-G calculations, the D stability class may not be mostconservative for some downwind locations. NRC RG 1.4, "Assumptions Used for Evaluatingthe Potential Radiological Consequences of a Loss of Coolant Accident for PressurizedWater Reactors," recommends that for the atmospheric dispersion calculations for the firsteight hours following a release, F stability and a windspeed of 1 meter/sec with uniformdirection should be used to provide sufficiently conservative results. Additionally, the NRCstaff is interested if the highest calculated doses could occur beyond the EPZ boundary (150meters from the stack) or the nearest residence (760 meters from the stack), depending on7stability class. Provide justi~fication (such as sample calculations performed for varyingstability classes for varying locations downwind, including locations between the EPZboundary and the nearest residence, and beyond the nearest residence) as to why thefollowing parameters were chosen to be most conservative:i. D stability class, and,ii. EPZ boundary and nearest residence receptor locations (include map showing theEPZ, nearest residence, and the boundary (beyond the EPZ) under the evacuationcontrol 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 34mrem for receptor sites located at 150, 400 and 760 meters, respectively, due north of MURR. Thehighest dose occurs at the 400 meter point north of the facility on University of Missouri controlledproperty. As stated earlier, this is due to the convergence of the local topography with the effectiveexhaust stack height at that location. Table 1 summarizes the corresponding doses resulting from37 of 62 an unmitigated release of 150 Curies of 1-131 at distances with the associated P-G Stability Classfor the corresponding dose.Table 1 -Dose at Distance Using Corresponding Worst-Case Stability ClassDistance from Worst-Case Corresponding AverageExhaust Stack ED oe Stability Class / Effective Wind Speed at MURR for(meters) (me)Stack Height (meters) Stability Class (mis)150 26 B /32 3.0400 303 F /7 2.6760 34 E /16 4.0As 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. Theclasses noted in Table 1 show the worst-case stability classes for the noted distance from theexhaust 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 ofStability Class 'F' with a default wind speed of 1 m/s. Table 2 summarizes the corresponding dosesresulting from an unmitigated release of 150 Curies of 1-131 at the noted distances using StabilityClass 'F' with a default 1 m/s wind speed.Table 2 -Dose at Distance Using Stability Class 'F' with Default 1 m/s Wind SpeedDistance from Worst-Case Corresponding WindExas Sak EDE Dose Stability Class per(mrem) Reg. Guide 1.4 / Effective SedprRg ud .(meters) Stack Height (meters) (mis)150 0 F /74 1.0400 0 F /49 1.0760 0 F /65 1.0In MIURR' s case and as shown in the table above, the effect of using the default wind speed of 1m/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 increasedinjection height into the atmosphere (based on MURR's exhaust stack exit velocity of 17.7 m/s) andallows for further dispersion and dilution at sites downwind from MUIRR. Thus MURR feels itscurrent approach is much more conservative in our situation than using the default values assuggested in Regulatory Guide 1.4. In no case was the offsite dose greater than at the 400 meterpoint due north of MURR.38 of 62

5. NUREG-1537, Chapter 14, 'Technical Specifications," and American Nuclear StandardsInstitute/American Nuclear Society (ANSI/ANS)-15. 1-2007, "The Development of TechnicalSpecifications for Research Reactors," provides guidance that tests to establish carbon filterefficiency should be performed annually to biennially, and following major maintenance. Thelicensee 's proposed TS 5. 7, Specification e states, in part, that carbon filter efficiencymeasurements shall be performed biennially.a. The proposed TSs do not appear to include a requirement that carbon filter efficiencies betested following major maintenance. Provide an explanation.Proposed Technical Specification 5.7.e will be revised as follows: "The efficiency of the Iodine 131processing hot cells charcoal filter banks shall be verified biennially or following majormaintenance. It shall be verified that the charcoal filter banks have a removal efficiency of 99% orgreater for iodine."b. Attachment 8 of the amendment request stated that the lifetime of carbon filters "can be aslong as "five years. While new carbon filters are unlikely to exhibit a significant decrease inefficiency for the first two years following installation, a marked decrease in efficiency couldoccur between years 2 to 4, or years 4 to 6. Provide a justification to support biennialsurveillance testing for carbon filters after two years of use.The service history of charcoal filters and the determinants of their useful life are comprehensivelydiscussed in ORNL/TM-6607, "A Literature Survey of Methods to Remove Iodine from Off-GasStreams Using Solid Sorbents" (Ref. 9).The effectiveness of a charcoal filter to capture iodine, including molecular iodine and methyliodide, is diminished by the presence of oil vapors, solvent vapors, oxides of sulfur and nitrogen(SO2, NO and NO2). Efficiency is further reduced by operation at highly elevated temperatures, thepresence of steam or condensed water droplets, and otherwise continuous high humidity. Operationof 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 ofradioiodines. Charcoal filter efficiency for capture and retention of iodine is directly correlatedwith charcoal bed depth and inversely related to iodine concentration in the incident gas stream, thecumulative 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 retaincompared to molecular iodine. The specified concentration is 1.75 mg CH3I per m3 and typicallyefficiencies for five (5) flow rates are provided (0.5, 1.0, 2.0, 3.0 and 4.0 SCFM) resulting inminimum retention efficiencies ranging from 94.1% to 99.8% over a 168-hour purge at a relativehumidity 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 underwhich the 1-131 processing facility at MiURR is operated are equivalent or favorable compared to39 of 62 those found in other nuclear operations (e.g., nuclear reactor core damage scenarios) in whichiodine retention is required and also favorable compared to the ASTM condition under whichcharcoal 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 1-131production and will not be subjected to those agents such as oil vapors, solvent vapors, steam,SO2, NO, NO2 and continuous high humidity known to reduce iodine retention and/or increasedesorption.2. The air temperature in the Processing Hot Cell (PHC) will not approach charcoal ignitiontemperatures, which are coincident with the temperatures where TEDA is compromised.Therefore, TEDA-impregnated charcoal can be used in the MUIRR 1-131 processing facility andwill 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-retentionefficiency 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 CFMcorresponding 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 PHCoperating in series can be expected to remove > 99% of the incident 1-131 activity based onmethyl iodide.5. The total iodine loading in is hypothetically determined by the stableiodine (1-127) impurity in the target, which has been determined to be 0.47jig/g in the used to produce the targets for the MUJRR 1-131 process. Rounding to 0.5jig/g, this represents 90 iodine per the maximum target. The total mass ofthe radioiodine species is negligible compared to the stable 1-127. Assuming all of the iodinepresent from its impurity level is during a and also assumingfour (4) processes per week, each with an target, and operating 52 weeks peryear will a maximum of 18,720 gtg (18.72 mag) of iodine per year. The assumptionthat all of the stable iodine in a target will during a process ishighly conservative in that the stable iodine will largely exist in forms. Inaddition, 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 trapsin the P11C. Therefore, the loading of iodine on the charcoal filter in the PHC is conservativelyestimated at 90 jig/process x 0.05 4.5 jig/process corresponding to 936 jig/year. There arethree (3) dedicated TEDA/KI-impregnated charcoal filters associated with the PHC having, insequence, 3800, 1200 and 1200 grams of charcoal, respectively. Considering only the first ofthese 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-impregnatedcharcoal are capable (discussed further below).6. Assuming an air flow rate of 5.5 CFM and a processing time of approximately 60 to 120minutes, the maximum iodine concentration during filter loading is 0.00070 mg/in3, which isless than the loading concentration typically used in the certification testing of a charcoal filterby 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 atypical certification test.8. Greater than 99% of the radioiodine produced in the is mn the form ofmolecular iodine, which is captured and retained more efficiently than the methyl iodide usedin the certification testing.In Figure 4, page 24 in the "Service History" section of ORNL/TM-6607, iodine desorptionpercentages of approximately 0.0015% and 0.015%, at iodine loading ranges of 0.89 to 0.96 mgIodine/gCarbon and 0.69 to 0.91 mg Iodine/gCarbon are provided for charcoal filters that have beenin 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 be0.000246 mg Iodine/gCarbon, which is a factor of 2800 less than the lowest of the loadingsreported in ORNL/TM-6607 indicating that a service life of five (5) years (total maximum loadingof 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 inthe 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 acharcoal cartridge prior to the exhaust air from the 1-131 processing area joining the facility mainventilation exhaust system. This monitor isolates 1-131 processing activities and provides thecapability to quantify the 1-131 concentration of the 1-131 processing facility exhaust air. Trackingthese 1-131 concentrations longitudinally is a sensitive diagnostic of any changes that might occurin 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 duringnormal I-i131 processing. Provide an explanation of how long-term routine releases ofi1-131to the carbon filters could reduce the carbon filter efficiency over time.As discussed in the response to Question 5 .b, the estimated loading of iodine on the firsttriethylenediamine/potassium iodide (TEDA/KI) impregnated charcoal filter (Filter Bank No. 1) inthe sequence of three (3) dedicated banks serving the PHC, over a 5-year service period, is 0.00 123mng Iodine per gram Carbon based on processing four (4) targets per week, 52 weeks per year. Thiscorresponds 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 using41 of 62 solid sorbents including charcoal. Furthennore, the estimated iodine concentration in the fullvolume of the Processing Hot Cell (PHC) as a result of processing a maximum activity targetis estimated to be 0.00070 mng Iodine/mn3 compared to 1.56 mng Iodine/mn3 specified in ASTMD3 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-impregnatedcharcoal filters dedicated to the PHC in long-term service (> 5 years).d. Describe the process that will be used to preform carbon filter efficiency measurements.As stated in Section 8.0 of the original license amendment request, the guidance provided inRegulatory Guide 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and AdsorptionUnits 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 filterefficiency measurements (Ref. 11). Specifically, in Section 7 of Regulatory Guide 1.52, laboratorytesting of samples of activated carbon adsorber material should be performed in accordance withASTM D3803-1991 (R20 14) and Table 2 of this guide. ASTM D3803, "Standard Test Method forNuclear-Grade Activated Carbon," is a very stringent test method for establishing the capability ofnew 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 witha new one. Regulatory Guide 1.140, "Design, Inspection, and Testing Criteria for Air Filtration andAdsorption 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 efficiencymeasurements. This Regulatory Guide also references ASTM D3803.6. The amendment requests, Section 2.0, states that the non-fueled irradiation targets for the 1-131production will be doubly encapsulated. However, no TS requirements have been proposed torequire double encapsulation of non-fueled irradiation targets for this process. Provide anexplanation.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 preventinteraction with reactor components and pool water."Although only single encapsulation is required, IMUTRR, by practice, typically double encapsulatestargets to further reduce the potential consequences of a leaking container. The statement on Page1 of the original license amendment request was simply stating how MUIRR typically encapsulatesthe 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 UU) of the and (2) the target material would remain in solid form due to the insolubility of thecompound, there would be minimal or no diffusion of radioiodine from the into the reactorpool and hence no release (See response to Question 8.a). However, for the mtarget42 of 62 irradiation (current Administrative Limit) safety analysis (Ref. 14), MURR assumed a worst-casescenario of a total release of all of the activity () from the target material into the reactorpooi whether it is single or double encapsulated. Using a very conservative ten (10) minute staytime [typical evacuation time is about two (2) minutes], an individual in the containment buildingwould receive a Total Effective Dose Equivalent (TEDE) of 125.79 mrem. An individual at thepoint of maximum concentration in the unrestricted area would receive a TEDE of 0.006 mrem. Ifyou ratio this activity to the maximum activity of 150 Curies of I-131 proposed by new TS 3.6.p, anindividual in the containment building and at the point of maximum concentration in theunrestricted 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 extremelyconservative stay time in containment (by a factor of 5) during the release. This analysis isbounded by the current MUJRR TSs, specifically fueled experiments.7. The proposed MURR TS 3.11, Specification d, requires three charcoal filter banks with anefficiency of at least 99 percent to be operable when 1-1 31 is being processed in the PHC.a. It is not clear if the 99 percent requirement pertains to each individual filter bank, or to alloperable (three) filter banks collectively. Explain.The individual CAMFIL and Flanders filters each have an iodine-retention efficiency of greaterthan 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 thosethat should be considered relative to the removal of radioiodine species from off-gas streams usingsolid 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 includepredominately molecular iodine (12), which accounts for greater than 99% of the 1-131; andmethyl iodide (CH13I), 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 areremoved from an off-gas stream by TEDAiKI-impregnated charcoal can be significantlydifferent depending on other determinants.Molecular iodine is removed at high efficiency, retaining a greater-than 99% efficiency over awider range of air flow rates and relative humidity compared to methyl iodide. This iodine-speciation determinant (12 vs CU3I) is why the more challenging methyl iodide is used as theadsorbate in ASTM D3803-9 1 (R20 14), "Standard Test Method for Nuclear-Grade Activated43 of 62 Carbon" to determine the iodine-removal efficiency of solid sorbents (Ref. 10). The firstsentence in ASTM D3 803, under "Scope," states, "This test method is a very stringentprocedure 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 iodidecan represent substantial fractions of the radioiodine activity during fuel reprocessing activitiesand 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 theiodine in the core." However, in contrast, based on measurements of the I-131 collected in theproduct-collection traps and the exhaust stream from the product-collection traps from the I~of irradiated Iin the Processing Hot Cell (PHC), the CH31- 131 component ofthe of an irradiated I target is estimated to be less than 0.2%. Aconservatively-increased methyl iodide concentration of 1% of the total 1-131 activity has beenused 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 airstream must be considered together and in conjunction with the chemical species involved,molecular iodine (12) and methyl iodide (CH3I), in the case of the of irradiatedItargets.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 beyondapproximately 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 humidityfor methyliodide (CH31) at 30 °C and an optimized minimal air-flow rate.C.t--.5",0Ea-I0100 -95-90-85-80-7545 50 55 60 65 70 75 80relative humidity (%)85 90 95 100Figure 1 -Methyl Iodide Retention Efficiency of a TEDA/iKI-Jmpregnated Charcoal Filtervs. Relative HumidityOver the course of 12 months the relative humidity, averaged over 1 to 5 weeks, was recordedat three (3) locations in and around the 1-131 processing area and are representative of the airentering 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 recordingperiods and three (3) locations was 30.3% to 81.7%. The maximum average relative humidityfor a single recording period in any of the locations was 90%. In summary, the relativehumidity of air entering the PHC and entraining the radioiodine from the of theirradiated 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 methyliodide (open squares) as shown in Figure 2. Also shown in Figure 2 is the iodine retentionefficiency 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 for100% molecular iodine and the (99:1) mixture of molecular iodine and methyl iodide are shownon 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 filtersserving the PHC and the Flanders filter serving the entire 1-131 processing facility will retain45 of 62 efficiencies greater than 99% for iodine removal under the relative humidity and aft-flow ratesassociated with a Retention efficiency (%) at 95% relative humidity by solid sorbents at variable air flow (0.5 to 5.5 SCFM)for 12 alone and for a99% 12, 1% CH21 mixture (percent retention scale on left Y axis), andfor CHI alone (percent retention scale on right Y axis).e 100.0 -100X99~98~-99.9 97-r96 ~+ 9S99.8 9> o99.7 91 Ez"99.6 88 -o 87C'-. 8699.5 ...........850.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 5.5 6.0air-flow rate (SCFM)---- 12 efficiency (left Y axis)0..o. 12 & CH2I hybrid efficiency (left Y axis)o] CH31 efficiency (right Y axis)Figure 2 -Iodine Removal Efficiency of a TEDA/KI-Impregnated Charcoal Filtervs. Air Flow Rate3. 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 enteringthe PUC. The average temperature, standard deviation, median, minimum and maximum were20.2 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 inthe PHIC typically increases to a range of 20 to 24 °C (70 to 75 °F). In summary, thetemperature in and around the PHC varies over a narrow range and does not have an inverseimpact on the iodine-retention efficiencies of the filters.4. Iodine Loading Concentration and Cumulative Iodine Loading: Both the concentration ofiodine in the aft stream impacting the solid sorbent filter material and the cumulative mass ofiodine loaded over time influences iodine removal from an air stream. High iodine-loadingconcentrations and the increasing mass of iodine loaded over time can both reduce iodineremoval efficiencies.46 of 62 The total iodine loading in a is hypothetically determined by the stableiodine (I-127) impurity in the target, which has been determined to be 0.47jig/g. Rounding to 0.5 pxg/g, this represents 90 jig iodine per the maximum ltarget. 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 assumingfour (4) processes per week, each with an l target, and operating 52 weeks peryear will a maximum of 18,720 jig (18.72 rag) of iodine per year. The assumptionthat all of the stable iodine in a I target will during a ishighly conservative in that the stable iodine will largely exist in forms. Inaddition, 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/processcorresponding to 936 jig/year. There are three (3) TEDA/KI-impregnated charcoal filtersassociated 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 thisfilter is 0.000246 mg iodine per gram carbon (mg J/g C), which is negligible compared to theloading capacities reported in the "Service History" section of ORNL/TM-6607 in whichcumulative iodine loadings ranging from 0.69 mg JI/g C to 0.96 mg J/g C were present incharcoal filters having an in-service history of 2.5 and 4.7 years and while remaining effectiveas verified by iodine-desorption testing.Considering a uniform release of 4.5 jig (0.0045 mag) of total iodine to the PHC during a singleprocess of a l target (from the preceding paragraph), a flow rate of 5.5 CFM(0.15574 m3/min), and a process time of approximately 120 minutes, will result in an iodineloading concentration of 0.0002408 mg/rn3, which is 0.014% of the concentration of methyliodide used in the ASTM D3803 procedure (1.75 mg CH3I/m3).In summary, neither the iodine-loading concentration nor the cumulative loading attained overmany years of processing under the MUIRR 1-131 processing facility protocols will exceedcommonly employed metrics for these parameters.5. Other Determinants: Various components that can be entrained in the off-gas stream inconcentrations adverse to iodine-removal efficiency by solid sorbents are discussed in theORNL/TM-6607 report. These include gases such as SO2, NO and NO2; hydrocarbon vaporsfrom fuels and lubricants; other organic vapors from paints, sealants and solvents; and steamand condensed aerosols. None of these exist in significant concentrations in the MURR 1-131processing facility.In summary, the three (3) individual dedicated TEDA/KI-impregnated CAMFIL charcoal filters insole-service to the PHC, and the Flanders filter serving the entire 1-131 processing facility, underthe conditions associated with the of irradiated l targets, will each have aniodine-removal efficiency of greater-than 99% for the radioiodine species and their relative47 of 62 distributions as discussed in the preceding sections; therefore, the 99% requirement pertains to eachindividual filter bank.b. It is not clear if the 99 percent requirement pertains to a mechanical efficiency, a chemicaladsorption 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 (CH3I) intoconsideration at the relative humidity (95%) specified in the ASTM D3803 testing protocol, andthis is conservative relative to the lower median relative humidity (70%) in the MUTRR 1-131processing facility, which increases filter efficiency compared to 95% relative humidity. Theiodine removal efficiency (>99%) is cited for the air flow rate through thetriethylenediamine/potassium iodide (TEDA/KI) impregnated charcoal filters serving theProcessing 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 D3803testing protocol.c. It is not clear what form(s) of 1-i 31 (elemental, organic, or particulate) the 99 percentrequirement pertains to, and whether these form(s) are representative of what would beexpected for 1-13 1 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 ofat its melting point In addition methyl iodide (CH3I)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 andmethyl iodide into consideration. Furthermore, we employ silver zeolite filter cartridges on boththe exhaust from the product-collection traps (processing line exhaust) and the exhaust linein the Processing Hot Cell (PHC) to minimize the discharge of CH3I-1 31 into the P11G.d. It is not clear what temperature and humidity the 99 percent requirement pertains to, andwhether this temperature and humidity is representative of what would be expected for 1-131-contaiminated air passing through the carbon filters following a release ofi1-131 to the PHC.Explain.Over the course of 12 months the air temperature and relative humidity, averaged over 1 to 5weeks, were recorded at three (3) locations in and around the 1-131 processing area and arerepresentative 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 operationof the at the temperature in the PHC typically increases to a range of 20 to 24 °C48 of 62 (70 to 75 °F). During this same recording period the average and median relative humidity were61.9% and 70.5%, respectively. The range in monthly relative humidity, averaged over the 1 to 5week recording periods and at the three (3) locations was 30.3% to 81.7%. The maximum averagerelative humidity for a single recording period in any of the 3 locations was 90% and will notexceed 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 inverseimpact on the iodine-removal efficiencies of the filters. Relative humidity in and around theMURR 1-131 processing facility varies over a much wider range compared to temperature; andmust be considered in conjunction with air-flow rate and the two iodine species (molecular iodineand 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 isgreater than 99%.e. MURR 's license amendment request, Attachment 8, specifies that the Flanders/CSC filtersused in Filter Bank No. 4 have a mechanical efficiency of at least 99.9 percent. However, theNRC 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 Flandersspecification that their adsorbers (filters) shall exhibit a minimum mechanical efficiency (thepercentage of air that actually contacts the activated carbon in a system without penetrating voids orcracks) 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/potassiumiodide (TEDAiKI) impregnated. charcoal used in the Flanders filter is determined by a two-stepmechanism in which the adsorbate must first make contact with the sorption material's surface. Inthe second step of the mechanism, a chemical reaction occurs that binds the adsorbate to thecharcoal matrix. For example, CH3I reacts with TEDA to form a thermodynamically-stablequaternary ammonium salt as shown by the following reaction:C6H12N2 + 2CH31 { [C6H12N2(CH3)212+[2I-]}The second step in the mechanism has the mechanical efficiency as its upper limit. The so calledchemical efficiency can be limited by relative humidity, when excessive, and/or air flow rate asdiscussed in the response to Question 7.a.f. MURR 's license amendment request, Attachment 7, provides specifications for the CAMFILfilters used in Filter Bank Nos. 1, 2, and 3. However, the NRC staff is not clear if the vendor49 of 62 provides efficiency ratings (mechanical, chemical, or total) for the CAMFIL filters for theiruse as described in MURR '.s license amendment request. Explain.The vendor certifies that the CAMFIIL filters have a mechanical efficiency of 99.9%. These aretriethylenediamine/potassium iodide (TEDA/KI) impregnated, nuclear-grade charcoal filters andwill have an iodine-removal efficiency determined by the actual operating conditions and iodinespeciation, which, in the case of the MIURR I- 131 processing facility translates to an iodine removalefficiency of >99% as discussed in the responses to Questions 7.a. through 7.e.g. NRC RG 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and AdsorptionUnits of Post-Accident Engineered Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," provides guidance that a 99 percent carbon filterdecontamination credit should be taken, provided that carbon filters comply with certaincriteria. Clarify if these criteria are being met by providing the following additionalin form ation for the carbon filters used in Filter Banks 1 through 4:i. Total bed depth;ii. Rated flow;" and,iii. Residence time associated with the rated flow rate.The below flow diagram (Figure 1) provides the amount of carbon, total bed depth, air flow rateand residence time for each charcoal filter bank. These values are specific to the Processing HotCell (PHC) because of the established air flow rate through this hot cell, but are typical of the othertwo (2) hot cells -Handling Hot Cell (HI-IC) and Dispensing Hot Cell (DHC).50 of 62 iKesioence i mre LatcUlasipn Iot II-ICUeranK .Residence Time = Net Screen Area x Bed DepthlFlow = (2.545 sq ft) (1.375 In) (1 ft/12 in) (60sec/min)/1(47 cu ft/min)-0.37 secI 1.1 liters of CarbonResidence Time 0.42 seBed Depth 1.417 inchesFlow 5.5 cfm j1.1 lIters of Carbon1Residence Time 0.42 secBed Depth 1.417 inchesFlow 5.5 cfmIBask No.2 jResidence Time CalIulatio~n fr Filter Ranks V .2 &J 3.3 liters of Carbon J3.3 liters of Carbon Residence Time = Volume Carbon/ Flow = (3.3 liters)Residence Time 1.27 sec Residence Time 1.27 sec J (0.00100003 cu meters/iiter) 160 sec/min) (1/5.5 cuBed Depth 1.969 inches Bed Depth 1.969 inches ft/min) (35.3147 cu ft/cu meter)Fiow 5.5dcm Fiow 5.5dcm = 0.42 secondsI TBan No.1 jHC-11B HC-11BFigure 1 -Flow Diagram Depicting Total Bed Depth, Rated Flow Rateand Residence Time Associated with Rated Flow Rate8. The amendment request discusses the possible consequences of an accidental release of I-131 to thePHC. However, 1-131 releases" outside of the hot cells do not appear to be discussed in theamendment request.a. Discuss whether any experiment failure could cause an 1-131 release during targetirradiation.The following analyses discuss a loss of target containment during irradiation of atarget using realistic assumptions. Also presented at the end is a worst-case analysis of completerelease of 150 Curies of 1-131 using extremely conservative, bounding assumptions.Initial Conseqiuence (Gaseous 1-131 Release): The maximum temperature attained by atarget having a diameter of 22 mm and length of 86 mm; and irradiated at the maximum51 of 62 thermal flux permitted under the Reactor Utilization Request (RUR) (Ref. 14) governing thisexperiment () for a time adequate to reach thermal equilibrium; and havingcumulative 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 attainthe 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 undervacuum was measured to be 0.000025%. Therefore, if the two encapsulation cans were both todevelop leaks during irradiation at the point when the maximum activity I-1 31) had beenattained, 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-leachedfrom a sample (Can No. 127) from a full-size target irradiated (30 minutes) at peak fluxin graphite reflector irradiation position "HI ." The results were extrapolated to a full-size targetirradiated for at its peak 1-131 activity ( The leaching time was 16.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> atapproximately 25 0C (77 0F). There were four (4) distinct dissimilarities in experimental leachingconditions compared to those that would be experienced in the case of a leak-induced floodedtarget can. These are:1. Temperature: The leaching experiment was carried out at approximately 25 °C (77 "F) and thetemperature of the water in a flooded can both during irradiation and post-irradiation arevariable and unknown.2. Leaching Time: The leaching time from submersion of the test sample to sampling the leachatewas 16.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> and is not determinable in a flooded can.3. The leaching experiment was done with a finely ground sample having an estimatedsurface area of 50 m2/g. The target ingot has a surface of 0.042 m2/g. This difference insurface area would be expected to substantially enhance I-131 leaching from the powdered testsample compared to the target ingot. Nevertheless, no correction was made for thisdifference in surface area.4. The test sample powder was completely submerged in water in the leaching experiment.Because of the small void (=2 cm3) in the secondary encapsulation can, only a fraction of thetarget ingot will be in contact with the water. No correction was made for this differencein contact.Based on the experiment described above, and not correcting for the dissimilarities between theleaching 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 llis not expected to exceed 0.35 mCi and would be expected to be dissolved in the water in theform 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 floodedtarget at its maximum 1-131 activity during irradiation would not result in a significantradiation exposure to MiURR staff or the general public.Additionally, as discussed in the response to Questions 6, the safety analysis for atarget irradiation (current Administrative limit) (Ref. 14), MUIRR assumed a worst-case scenario ofa total release of all of the theoretical activity () from the target material into the reactorpool whether it is single or double encapsulated. Using a very conservative ten (10) minute staytime (typical evacuation time is about 2 minutes), an individual in the containment building wouldreceive a Total Effective Dose Equivalent (TEDE) of 125.79 mrem. An individual at the point ofmaximum concentration in the unrestricted area would receive a TEDE of 0.00 6 mrem. If you ratiothis activity to the maximum activity of 150 Curies of 1-131 proposed by new TechnicalSpecification (TS) 3.6.p, an individual in the containment building and at the point of maximumconcentration 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 ofirradiated targets from the irradiation position to the HHC.A credible scenario where any experiment failure could cause an 1-131 release during movement ofthe irradiated targets from the irradiation position (reactor pool) to the Handling Hot Cell (ITHC) isunable to be identified as all movement occurs in a dedicated, robust and sealed transfer cask whichhas been in use at MUJRR for over 30 years without incident. However, the release of 1-131 wasmeasured in a full-size target by puncturing the sealed primary and secondary irradiation cansin a closed system under vacuum -See the response to Question 8.a. When extrapolated to a targethaving the maximum normal operational 1-131 activity () and a fraction available forrelease 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 therestricted area within the MIURR as the target is being transferred to the EHHC which corresponds topersonnel radiation exposures to well within annual 10 CFR 20 limits in even the most conservativeassumptions.c. The NRC staff noted, in Attachment 25, Section 6.4, of the licensee's letter dated January 28,2015 (ADAMS ML 15034A474), an evaluation for a spill of 1-131 solution outside the hotcells. 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 airlock seals via the floor port of the Dispensing Hot Cell (DHC). Therefore, there is no credibleaccident scenario where a spill of the product solution onto the laboratory floor exists as discussedin Attachment 25, Section 6.4 of the licensee's letter dated January¢ 28, 2015 (ADAMS53 of 62 ML1 5034A474). That analysis was performed as an original scoping study to determine whatquantities of 1-131 could safely be handled outside of the hot cells, if desired. The only productsolution from this experiment handled outside of the hot cell is that used for U.S. Food and DrugAdministration (FDA) quality analysis which is administratively controlled per the MURR ProjectAuthorization process to activity levels inherently safe within the restricted and unrestricted areaswithout the presence of engineered safety features.d. Discuss whether any experiment failure, 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 identifiedthat 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 isotopesof iodine, or activation products of target impurities), or toxic materials, inside or outside the hotcells do not appear to be discussed in the amendment request. Discuss whether other failures existthat 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, whichwill 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 RAIsincluding NRC and MURR staff on December 7, 2015, during which the release of Xe-131im wasdiscussed. In Part 2 of this response, potentially activation products from impurities in the~targets, are discussed.Part 1: Xenon-131m Production from Decay of 1-131Xe-i131 m (half-life =11.84 days) is produced through a minor pathway (shown below) from thedecay of I-131. The maj or pathway for the decay of I-131 produces stable Xe-1 31 directly.B3f .023 da Ct2) 11.X I84 da C1oD%)Published values for the f2 branching ratio for the decay of 1-131 into Xe-131im are in the range of0.39% to 1.3% and are summarized in Table 1 below along with the respective source for each.54 of 62 Table 1 -Branching Ratio Values (%) for the I-131 to Xe-i131 m Minor Decay Pathwayfrom Seven Different SourcesBranching Ratio (f2 %) Source0.39 IAEA/Nuclear Data sheets0.43 Table of Isotopes0.48 INEL/GECAT1.0 Personal communication ITD)1.1 Idaho Isotopes Inc. Datasheet1.2 Applied Radiation & Isotopes, 68 1846-54 (2010)1.3 World Health OrganizationThe Xe-i131 m activity produced when a target is irradiated for themaximum irradiation time at the maximum neutron flux () wascalculated using f2 =1.0% and the results are shown in Figure 1 below. The Xe-131im activities atthe end of the irradiation (EOI), at the anticipated processing time (EOI+24 hours), and atits 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 theparameters 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 aresatisfied and would continue to be satisfied if processing occurred at the peak Xe-i131 m calculatedactivity (0.263 Curies), which occurs at 191 hours0.00221 days <br />0.0531 hours <br />3.158069e-4 weeks <br />7.26755e-5 months <br /> following the end of the irradiation.55 of 62 Xe-I 31 m activity (Ci) from a maximum-activity targetatpeak neutron flux)0.300.255 0.20e0.15E0.050.000 100 200 300 400 500 600total lapsed time (hours) from start of irradiation (0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />)start processing (eoi+24 hours) 0.217 Ci-- peak Xe-I131 m activity (eoi+1 91 hours0.00105 days <br />0.0253 hours <br />1.50463e-4 weeks <br />3.46255e-5 months <br />) 0.263 CiFigure 1 -Xe-135m Activity from a TargetPart 2: Activation Products from an Impurity700Prior to selecting material from which targets would be fabricated, test sampleswere obtained from five (5) suppliers and these were analyzed for 24 trace-element constituents bya combination of Neutron Activation Analysis (NAA) and Inductively-Coupled-Plasma MassSpectroscopy (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 forproducing 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/gin 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 in the maximumtarget mass (I) at the maximum irradiation time and the maximumneutron flux (), the peak 1-128 activity (0.0331 Curies) occurs at EOI andwill have decayed completely (1 .5E-l19 Curies) at the anticipated time of processing (EOI+2456 of 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br />). If all the 1-128 activity were released to the environment at EOI, the release limitsimposed 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. Seleniumforms 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 rangedfrom <0.5 jig/g, in the 99.995% product selected, to 1.4 in a sourcelisted as having a purity of 99+% that was rejected.Assuming the worst-case selenium concentration of the products tested (1.4 jgg/g), airradiation of a target, the maximum thermal neutron flux ( and no neutron attenuation by the target, the maximum Se-75 activity producedwould 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, aqueoustraps or charcoal filters) would not result in a Se-75 release in excess of the limits imposed byTSs 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 ProcessingHot Cell (PHC). Consequently, no release of Se-75 to the environment is anticipated undernormal conditions.10. The NRC staff noted that the proposed MURR TS 3.6, Specification p, limits the 1-131 inventory ofa 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 airborneconcentration of radioactivity averaged over a year will not exceed the limits of Appendix B, TableI of 10 CFR Part 20. Exception: Fueled experiments (See Specification 3. 6a)." Explain how thelimits of TS 3.6, Specification c, and proposed TS 3.6, Specification p, are satisfied for the proposedIodine production.Current MIURR Technical Specification (TS) 3.6.c will be revised to read, "Where the possibilityexists that the failure of an experiment could release radioactive gases or aerosols to the reactor bayor atmosphere, the experiment shall be limited to that amount of material such that the airborneconcentration of radioactivity averaged over a year will not exceed the limits of Appendix B, TableI of 10 CFR Part 20. Exception: Fueled and non-fueled experiments that produce iodine 131through 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 proposediodine 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 Processing Hot Cells Radiation Monitor. The amendment request,Section 5.0O, "Radiation Monitoring Equipment," refers to a 1-131 Processing Laboratory Exhaust57 of 62 Duct Monitor for each hot cell, and also describes the ALMO-6 Hot Cell Dose Rate RadiationMonitor, which is a six detector system that includes one detector location at the operator 's workstation of each of the three hot cells, and one detector located in each of the bays above the threehot cells.a. Clarify whether the 1-131 Processing Laboratoiy Exhaust Duct Monitors for each of the threehot cells are the same as the three detectors "located in each of the bays above the three hotcells. "The "1-131 Processing Laboratory Duct Monitor" (singular) is NOT the "Iodine-131 ProcessingHot Cells Radiation Monitor" as listed in proposed Technical Specification 3.11l.c.2. As describedin 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 designedto measure airborne concentrations of radioactive iodine in the exhaust air that is sampled by ashrouded probe in the ventilation ducting immediately downstream of all of the 1-131 hot cell androom filtration systems. The system is capable of measuring real-time exhaust flow rate as its basisfor release concentrations. A pitot tube measurement device and flow transmitter provides input tothe 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, commonduct downstream of all three (3) hot cells, not each individual cell. The 1-131 ProcessingLaboratory Duct Monitor is similar to the facility Stack Radiation Monitor; however, it only has asingle detector that measures radioactive iodine whereas the facility Stack Radiation Monitor hasthree (3) detectors that measure particulate, iodine and noble gas. The 1-131 Processing LaboratoryDuct Monitor is pointed out in MUIRR Drawing No. 1125, Sheet 5 of 5 (Attachment 12). Noproposed TS requirement is being imposed upon this piece of equipment.b. Clarify whether the Iodine-131 Processing Hot 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 threehot cells, "for the PHC only, to the detectors "located in each of the bays above the three hotcells, "for all three hot cells, or to the entire six-detector Hot Cell Dose RateRadiation Monitor system.The "Iodine-i131 Processing Hot Cells Radiation Monitor" proposed by new TechnicalSpecification (TS) 3.11 .c.2 refers to the entire six-detector ALMO-6 Hot Cell Dose Rate RadiationMonitor 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 eachhot 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 3.0and 5.0 of the original license amendment request, "The ALMO-6 Hot Cell Dose Rate RadiationMonitor, as described in Section 3.0, consists of a six (6) detector radiation monitoring system58 of 62 designed to provide radiation dose level information to the process operators. Three (3) of thedetectors (G-M) are located at the operator's work station where the hot cell manipulators arelocated. These detectors provide real time dose rate information to the operators when they areperforming a process. The remaining three (3) detectors (G-M) are located next to the first in aseries of charcoal filters (Bank No. 2 and No. 3) located in each of the bays above the three (3) hotcells. These are designed to give the process operators real time information related to the captureand loading of I- 131 onto the first charcoal filter in each external bank of the individual cells. Thisallows the process operators to monitor the condition of the charcoal filters and will alert them ofthe need to change to a bank of alternately available filters. The ALMO-6 radiation monitor shallbe 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 radiation monitorsabove each hot cell.As stated in the "Exception" to proposed Technical Specification (TS) 3.11 .c.2, "When the requiredradiation monitoring channel becomes inoperable, then other radiation detection instruments maybe substituted for the normally installed monitor in specification 3.11 .c.2 within one (1) hour ofdiscovery for a period not to exceed one (1) week." Should any one of the detectors fail on theIodine-1 31 Processing Hot Cell Radiation Monitor, then a portable instrument may be substitutedfor the normally installed detector. See the Response to Question 12 below for further informationregarding the functionality of a replacement instrument. As stated above, one of the two purposesof the Iodine-i131 Processing Hot Cell Radiation Monitor is to provide the process operators realtime information related to the capture and loading of 1-131 onto the first charcoal filter in eachexternal bank of the individual cells. MUIIRR feels that this "Exception" provides sufficientredundancy for this purpose.Additionally, the facility Stack Radiation Monitor, as described in proposed TS 3.11 .c.2, alsoprovides information regarding hot cell filtration loading by monitoring all of the air exiting theMURR 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 DuctMonitor also samples the air from a single, common duct downstream of all of the hot cells forradioactive iodine. All three (3) of these radiation monitoring systems ensure that the air effluentsof 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 aportable monitor as a substitute for the monitors listed in the accompanying table. It is not clearlydescribed in the TS or Basis how a portable monitor will be capable of providing all the functionsof 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 potentialsubstitute currently available for MUJRR is electronic alarming dosimeters with installed telemetrymodules 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 ProcessingHot Cells Radiation Monitor" as described in Section 5.0 of the original license amendmentrequest. It is also noted that, under administrative control, processing personnel are required towear electronic alarming dosimeters and ambient room air will be continuously monitored forradioactivity.13. The proposed TS S. 7, Specifications c and d, require that the radiation monitors listed in proposedTS 3.11, Specifi cation c, be calibrated semi-annually and tested monthly. Provide a basis for thesesurveillance requirements.Section 4, Surveillance reciuirements, of American National Standard ANSIIANS-15. 1-2007, "TheDevelopment of Technical Specifications for Research Reactors," establishes surveillance intervalsfor radiation monitoring systems and effluents (Ref. 16). For operability, including, wherepossible, source checks, the frequency is monthly to quarterly. For calibrations, the frequency isannually to biennially. The proposed surveillance intervals for the Iodine 131 Processing Hot Cellsradiation 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 requiredby these specifications, shall be calibrated on semi-annual intervals" and "Radiation monitoringinstrumentation as required by these specifications shall be checked for operability with a radiationsource at monthly intervals," respectively. Any radiation monitoring instrumentation required bythe 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 RadiationMonitor" as required by current TS 3.4.a. As described in Section 5.0, "Radiation MonitoringEquipment," of the original license amendment request, the "Stack Radiation Monitor" monitors allof the air exiting the MURR facility through the ventilation system exhaust stack for airborneradioactivity. This includes the containment and laboratory buildings as well as all of the facilityhot cells, fume hoods and gloveboxes. The intent was to create specifications specific to theIodine-131 Processing Hot Cells to avoid confusion with other TSs; hence, proposed TSs 5.7.c and5.7.d for the "Stack Radiation Monitor" are the same surveillance frequencies as current TS 5.4.aand 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 licenseamendment request. It is a single-channel radiation monitor with six (6) detectors, measuringradiation dose in front of each hot cell as well as the exhaust filtration system on top of each hotcell. 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) itstates that the instrument does not require any particular maintenance. The vendor was alsocontacted 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 RadiationMonitor" will be calibrated on a semiannual basis and checked for operability with a radiationsource at monthly intervals, as stated in proposed TSs 5.7.c and 5.7.d. As stated in the bases ofthese proposed surveillance TSs, "Semiannual channel calibration of the radiation monitoringinstrumentation will assure that long-term drift of the channels will be corrected" and "Experiencehas shown that monthly verification of operability of the radiation monitoring instrumentation isadequate 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. Giventhe changes to the facility as described in the amendment request, discuss whether any changes areneeded 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 tocope with emergency situations connected with operation of MUIIRR and the conduct of experimentsat M7URR. The plan focuses primarily on handling of situations that may cause or threaten to causeradiological hazards affecting the health and safety of University of Missouri staff or the public. Itoutlines the objectives to be met by the emergency procedures and defines the authority andresponsibilities to achieve these objectives." Additionally, on page 9, under Section 3.3 Alert, itstates, "Situations that may lead to this class include: ... .2. Significant releases of radioactivematerials as a result of experiment failures."MURR feels that these statements adequately envelop the experiment described in the originallicense amendment submittal and that no changes to the MURR EP are required. MURR EPimplementing procedure EP-RO-006, "Radiological Emergency," was revised to address anyradiological emergencies associated with the Iodine-i131 Processing Hot Cells (Ref. 18).Furthermore, eighteen (18) response procedures have been developed to safeguard personnel andequipment 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 facilityventilation exhaust stack) and the site boundary. Definition 9.19, Site Boundarv, of the MIURR EPstates, "The site boundary is that boundary listed in the on-site definition, not having restrictivebarriers, surrounding the operations boundary wherein the reactor administrator may directlyinitiate emergency activities. The area within the site boundary may be frequented by peopleunacquainted with the reactor operations." Definition 9.13, Onsite, of the MUJRR EP states, "Thepart 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 RecreationTrail; east of the MKT Nature and Fitness Trail. The University of Missouri owned and controlledgrounds extend beyond these boundaries but are not included in our definition of "on-site"."61 of 62 Additionally, the bases for proposed Technical Specification (TS) 3.11 .c and the wording of proposed TS5.7.b were revised based on the discussion the NRC and MIURR staff had on December 7, 2015.62 of 62 Case Summary of MURR Transfer Cask Pg fPage l of 3ATTACHMENT 1MicroShield 8.02University of Missouri (8.00-0000)D~ate I By ICheckedFilename I Run Date IRun Time IDurationMURR Transfer Cask.msd December 8, 2015 3: 11:54 PM 00:00:00 JProject InfoGeometr 10 -Cylinder Surface -External Dose PointSource DimensionsHeight I1.0 cm (0.4 in)IRadius 5.08 cm (2.0 in)Dose PointsA 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 0.00122Shield 1 12.7 cm Lead 11.32Transition ________ Air 0.00122Air Gap _______ Air 0.00122SouceInpt:Grouping Method -Standard IndicesNumber of Groups: 25Lower Energy Cutoff: 0.015Photons < 0.015: Included__________Library: Grove1-lieI131 a~i/im2 z i cmjiNa-24 8.1100~e-003 3.0007e+008 2.5408e+002 9.4011 e+0062.6500e+001 9.8050e+011I 8.3024e+005 3.0719e+0105.6700e+000 2.0979e+011 1 .7764e+005 6.5727e+0091 .9500e+002 7.21 50e+012 6.1093e+006 2.2604e+011I1.1600e+001 4.2920e+011 3.6342e+005 1.3447e+0102 .5000e-004 i 9.2500~e+006 7.8324e+000 2.8980e+0057.1700e+000 2.6529e+011 2.2463e+005 8.3115e+0092.6100e+-001 9.6570e+01 1 8.1771e+005 3.0255e+010Buildup: The material reference is Shield 1Integration ParametersY Direction (axial) I 20Ifile :///Z:/MicroShield/M 12/8/2015 Case Summary of MURR Transfer CaskPae2o3Page 2 of 3ATTACHMENT 1CircumferentialI 20____________ ~Results -Dose Point # 1 -(17.8,0,0) cm ______Fiuence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec nmR/hr mR/hrNo Buildup With Buildup No Buildup With Buildup0.015 2.336e+11 0.000e+/-00 8.379e-21 0.000e+00 7.187e-220.03 1.560e+12 0.000e+00 1.151le-19 0.000e+00 1.140e-210.04 1.362e+10 0.000e+00 1.376e-21 0.000e+00 6.088e-240.06 1.623e+09 8.159e-283 2.660e-22 1.621 e-285 5.283e-250.08 2.563e+11 1.632e-128 6.276e-20 2.582e-131 9.93 le-230.1 7.933e+ -10 0.000e+00 7.705e-04 0.000e+00 1.179e-060.15 8.911le+l1I 2.713e-114 9.961 e-18 4.467e-117 1.640e-200.2 1.987e+l11 1.593e-53 1.464e-19 2.81 le-56 2.583e-220.3 6.642e+ -11 2.975e- 17 5.526e- 17 5.644e-20 1.048e- 190.4 6.715e+12 5.251e-06 1.221e-05 1.023e-08 2.379e-080.5 7.058e+ 10 1.068e-03 2.925e-03 2.097e-06 5.742e-060.6 7.229e+1 1 1.872e+00 5.528e+00 3.653e-03 1.079e-020.8 1.038e+12 4.923e+02 1.651 e+03 9.363e-01 3.141 e+001.0 3.176e+11 2.169e+03 7.755e+03 3.999e+00 1.430e+011.5 2.103e+10 3.018e+03 1.113e+04 5.077e+00 1.873e+012.0 3.962e+ 10 1.799e+04 6.688e+04 2.782e+01 1.034e+023.0 2.997e+08 3.420e+02 1.236e+03 4.640e-01 1.677e+004.0 1.923e+05 3.036e-01 1.060e+00 3.756e-04 1.31 le-03Totals 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 RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_________ ______________No Buildup With Buildup No Buildup With Buildup0.015 2.336e+11 0.000e+00 1.763e-22 0.000e+00 1.512e-230.03 1 .560e+ 12 0.000e+00 2.421 e-2 1 0.000e+00 2.399e-230.04 1.362e+ 10 0.000e+00 2.896e-23 0.000e+00 1.281 e-250.06 1.623e+09 2.158e-284 5.596e-24 4.286e-287 1.1 12e-260.08 2.563e+11 3.347e-130 1.320e-21 5.297e- 133 2.089e-240.1 7.933e+ 10 0.000e+00 1.621 e-05 0.000e+00 2.480e-080.15 8.91le~l 1 5.546e-116 2.096e-19 9.133e-119 3.451 e-220.2 1.987e+ 11 3.385e-55 3.080e-21 5.974e-58 5.435e-240.3 6.642e+11 6.415e-19 1.190e-18 1.217e-21 2.258e-210.4 6.715e+12 1.118e-07 2.598e-07 2.178e-10 5.063e-100.5 7.058e+ 10 2.260e-05 6.187e-05 4.435e-08 1.215e-070.6 7.229e+11I 3.946e-02 1.165e-01 7.703e-05 2.275e-040.8 1.038e+12 1.034e+01 3.469e+01 1.967e-02 6.598e-021.0 3.176e+ 11 4.548e+01 1.625e+02 8.384e-02 2.996e-011.5 2.103e+10 6.313e+01 2.328e+02 1.062e-01 3.916e-012.0 3.962e+10 3.763e+02 1.398e+03 5.819e-01 2.162e+00file :///Z:/MicroShield/MURR%20Transfer%20Cask.html1280512/8/2015 Case Summary of MURR Transfer CaskPae3o3Page 3 of 3ATTACHMENT 13.0 2.997e+08 7.156e+O0 2.585e+01 9.708e-03 3.507e-024.0 I 1.923e+05 6.357e-03 2.218e-02 7.864e-06 2.744e-05Totals I 1.282e+13 5.024e+02 1.854e+03 8.014e-01 2.955e+00file :///Z:/MicroShield/M URR%20Transfer%20Cask.html1280512/8/2015 Case Summary of ITD Transfer Cask Pg fPage 1 of 3ATTACHMENT 2D~ate By ICheckedJFilename IRun Date I Run Time IDuration]lTD TransferCask.msd December 8, 2015 3:10:44 PM 00:00:00 JProject InfoCase Title ITD Transfer CaskDescriptionGeometr 10 -Cylinder Surface -External Dose PointSource DimensionsHeight I1.0 cm (0.4 in)IRadius 5.08 cm (2.0 in)Dose Points#1/ 20.4 cm (8.0 in) I0.0 cm (0 in) 0.0 cm (0 in)v _,4#2 120.4 cm (3 ft 11.4 in) 0.0 cm (0 in) 0.0 cm (0 in)Shields 7_____ _____Shield N Dimension Material DestCyl. Radius 5.08 cm Air 0.00122Shield 1 15.24 cm Lead 11!.32Transition ________ Air 0.00122Air Gap _______ Air 0.00122Source Input: Grouping Method -Standard IndicesNumber of Groups: 25Lower Energy Cutoff: 0.015Photons < 0.015: Included___________Library: GroveNa-24 8.1100~e-003 3.0007e+008 2.5408e+002 9.4011 e+006Sl 2.6500e+001 9.8050e+011 8.3024e+005 3.0719e+0105.6700e+000 2.0979e+011 1.7764e+005 6.5727e+0091 .9500e+/-002 7.2150e+012 6.1093e+006 2.2604e+011I1 .1600e+001 4.2920e+01 1 3.6342e+005 1 .3447e+0102.5000e-004 9.2500e+006 7.8324e+000 2.8980e+0057.1 700e+000 2.6529e+01 1 2.2463e+005 8.311 5e+0092.6100e+00I 9.6570e+/-01 1 8.1771 e+005 3.0255e+010Buildup: The material reference is Shield 1Integration ParametersY Direction (axial) I 20Ifile:///Z 12/8/2015 Case Summary of lTD Transfer CaskPae2o3Page 2 of 3ATTACHMENT 2CRrcu mf-Doereonti#1-a 2.400lcI 2Results -Dose Point # 1 -(20.4,0,0) cmFluence Rate Fluence Rate [Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_______________________No Buildup With Buildup No Buildup With Buildup0.015 2.336e+/- 1 0 .000e+00 6.249e-21 0.000e+00 5.360e-220.03 1.560e+12 0.000e+00 8.582e-20 0.000e+00 8.505e-220.04 1.362e+10 0.000e+00 1.027e-21 0.000e+00 4.540e-240.06 1 .623e+09 0.000e+00 1 .984e-22 0.000e+00 3.940e-250.08 2.563e+1 1 2.579e-155 4.681e-20 4.081e-158 7.407e-230.1 7.933e+10 0.000e+00 5.746e-04 0.000e+00 8.791e-070.15 8.91 le+l1I 2.017e-138 7.430e-18 3.322e-141 1.223e-200.2 1.987e+/-11I 1.944e-65 1.092e-19 3.430e-68 1.927e-220.3 6.642e+11I 4.253e-22 6.652e-19 8.068e-25 1.262e-210.4 6.715e+12 7.458e-09 1.808e-08 1.453e-11 3.523e-110.5 7.05 8e+1 0 1 .006e-05 2.922e-05 1 .975e-08 5.736e-080.6 7.229e+11I 4.633e-02 1.463e-01 9.042e-05 2.856e-040.8 1.038e+12 3.157e+01 1.155e+02 6.005e-02 2.197e-011.0 3.176e+11 2.224e+02 8.805e+02 4.100e-01 1.623e+001.5 2.103e+10 5.116e+02 2.150e+03 8.607e-01 3.616e+002.0 3.962e+10 3.592e+/-03 1.538e+04 5.555e+00 2.378e+013.0 2.997e+08 7.528e+01 3.185e+02 1.021e-01 4.322e-014.0 1.923e+05 6.730e-02 2.781 e-01 8.325e-05 3.441 e-04Totals 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 RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr__No__Buildup___With Buildup NoBuldupL With Buildup0.015 2.336e+11I 0.000e+00 1.687e-22 0.000e+00 1.447e-230.03 1.560e+12 0.000e+00 2.317e-21 0.000e+00 2.297e-230.04 1.362e+ 10 0.000e+00 2.772e-23 0.000e+00 1.226e-250.06 1 .623e+09 0.000e+00 5.3 57e-24 0.000e+00 1 .064e-260.08 2.563e+ 11 6.692e- 157 1.264e-21 1.059e- 159 2.000e-240.1 7.933e+ 10 0.000e+00 1.552e-05 0.000e+00 2.374e-080.15 8.91 le-fl11 5.213e-140 2.006e-19 8.584e-143 3.304e-220.2 1.987e+1 1 5.211le-67 2.948e-21 9.197e-70 5.203e-240.3 6.642e+ 11 1.168e-23 1.796e-20 2.216e-26 3.407e-230.4 6.715e+12 2.029e-10 4.920e-10 3.954e-13 9.586e-130.5 7.058e+10 2.724e-07 7.913e-07 5.346e-10 1.553e-090.6 7.229e+1 11 1.251 e-03 3.952e-03 2.442e-06 7.7 14e-060.8 1.038e+12 8.500e-01 3.110e+00 1.617e-03 5.915e-031.0 3.176e+11 5.977e+00 2.366e+01 1.102e-02 4.361 e-021.5 2.103e+ 10 1.372e+01 5.763e+01 2.308e-02 9.695e-022.0 3.962e+10 9.631e+01 4.121e+02 1.489e-01 6.373e-01file :/!Z :/M icroShield/ITD%20TransferCask.htm I1//0112/8/2015 Case Summary of ITD Transfer CaskPae3o3Page 3 of 3ATTACHMENT 23.0 2.997e+08 2.019e+f00 8.540e+00 2.739e-03 1.159e-02I 4.0 1 I.923e+05 I1 .806e-03 I7.460e-03 I2.234e-06 I9.229e-06Totals 1.282e+13 1.189e+02 5.051e+02 1.874e-01 7.954e-01fi le:/i/Z :/M icroShield/ITD%20TransferCask.html1280112/8/2015 Case Summary of HHC and PHC Dose Pg fPage 1 of 2ATTACHMENT 3~MicroShield 8.02University of Missouri (8.00-0000)Date I By ICheckedFilename IRun Date I Run Time I DurationPHC lDose.msd December 29, 2015 2:04:29 PM 00:00:00Project InfoCase Title HHC and PHC DoseDescription Nominal Dose to OperatorsGeometr 1 -PointDose PointsAI 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)S______ hields_______ _____Shield N 1 Dimension Material DensityShield 1 J 80.0 cm I Air 0.00 122Shield 2 J 20.0 cm Lead 11.32Air Gap J____ ___ Air 0.00122 _ _________Source Input: Grouping Method -Standard IndicesNumber of Groups: 25Lower Energy Cutoff: 0.015Photons < 0.015: IncludedLibrary: GroveNuclide_____Ci BgNa-24 __8.0000e-003 2.9600e+008____2.6500e+001 9.8050e+01 15.6700e+000 2.0979e+011I____1.9500e+002 7.2150e+0121.1600e+001 4.2920e+011I____2.5000e-004 9.2500e+006l7.1700e+000 2.6529e+01 12.6100~e+$001 9.6570e+011IBuildup: The material reference is Shield 2____________ ~ Results -Dose Point #11 -(100,0,0) cm ______Fluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_______________________No Buildup With Buildup No Buildup With Buildup0.015 2.336e+11I 0.000e+00 2.442e-22 0.000e+00 2.094e-230.03 1.560e+12 0.000e+00 3.353e-21 0.000e+00 3.323e-23file:///Z:/MicroShield/HHC%20&%20PHC%20Dose.html 1/92112/29/2015 Case Summary of H-HC and PHIC DosePae2o2Page 2 of 2ATTACHMENT 30.041 .362e+100 .000e+004.011le-230.000e+001 .774e-250.06 1 .623e+09 0.000e+00 7.752e-24 0.000e+00 1 .540e-260.08 2.563e+1 1 1.921e-205 1.829e-21 3.040e-208 2.894e-240.1 7.933e+10 0.000e+00 2.245e-05 0.000e+00 3.435e-080.15 8.911e+11 1.381e-183 2.903e-19 2.274e-186 4.780e-220.2 1.987e+11I 5.695e-88 4.266e-21 1.005e-90 7.529e-240.3 6.642e+11I 1.282e-31 2.599e-20 2.431le-34 4.930e-230.4 6.715e+12 9.328e-15 2.390e-14 1.818e-17 4.657e-170.5 7.058e+10 3.618e-10 1.142e-09 7.101e-13 2.241e-120.6 7.229e+11I 8.954e-06 3.101e-05 1.748e-08 6.053e-080.8 1.038e+12 3.071e-02 1.263e-01 5.841e-05 2.402e-041.0 3.176e+11 4.684e-01 2.125e+00 8.635e-04 3.917e-031.5 2.102e+10 2.404e+00 1.207e+01 4.044e-03 2.031e-022.0 3.962e+10 2.177e+01 1.131e+02 3.367e-02 1.750e-013.0 2.956e+08 5.229e-01 2.751e+00 7.095e-04 3.733e-034.0 1.897e+05 4.727e-04 2.478e-03 5.848e-07 3.065e-06Totals 1.282e+13 2.520e+01 1.302e+02 3.934e-02 2.032e-01Results -Dose Point # 2 -(150,0,0) cmFluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hrNo___Buildup___With Buildup NoBilu With Buildup0.0 15 2.336e+1 1 0.000e+00 1.085e-22 0.000e+00 9.308e-240.03 1.560e+12 0.000e+00 1.490e-21 0.000e+00 1.477e-230.04 1.362e+10 0.000e+00 1.783e-23 0.000e+00 7.885e-260.06 1.623e+09 0.000e+00 3.445e-24 0.000e+00 6.843e-270.08 2.563e+11 8.454e-206 8.128e-22 1.338e-208 1.286e-240.1 7.933e+10 0.000e+00 9.979e-06 0.000e+00 1.527e-080.15 8.91l1e+ll 6.088e-184 1.290e-19 1.002e-186 2.125e-220.2 1.987e+11I 2.512e-88 1.896e-21 4.434e-91 3.346e-240.3 6.642e+11 5.660e-32 1.155e-20 1.074e-34 2.191e-230.4 6.715e+12 4.122e-15 1.056e-14 8.031e-18 2.058e-170.5 7.058e+10 1.599e-10 5.049e-10 3.140e-13 9.910e-130.6 7.229e+1 1 3.960e-06 1.372e-05 7.730e-09 2.677e-080.8 1.038e+12 1.359e-02 5.590e-02 2.585e-05 1.063e-041.0 3.176e+11 2.074e-01 9.410e-01 3.823e-04 1.735e-031.5 2.102e+10 1.065e+00 5.348e+00 1.792e-03 8.999e-032.0 3.962e+10 9.650e+00 5.016e+01 1.492e-02 7.757e-023.0 2.956e+08 2.319e-01 1.220e+00 3.146e-04 1.656e-034.0 1 .897e+05 2.097e-04 1.100~e-03 2.594e-07 1 .360e-06Totals 1.282e+13 1.1 17e+01 5.773e+01 1.744e-02 9.006e-02file:///Z:/MicroShield/HHC%20&%20PHC%20Dose.html129/0512/29/2015 Case Summary of DHC I- 131 Pg fPage 1 of 2ATTACHMENT 4MicroShield 8.02University of Missouri (8.00-0000)FDate I By ICheckedEFilename IRun Date I Run Time IDurationDIC-IC 1-3 1 Dose.msd December 8, 2015 3:03:57 PM 00:00:00Project InfoCase Title DHC I-13 31Description II- 131 Dose to OperatorsGeometr 1 -PointDose PointsIA 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 Dimension Material DestShield 1 j 80.0 cm I Air 10.00 122Shield2j 10.0 cm j Lead 11.32Air Gap ________ Air [0.00122 ___________Source Input: Grouping Method -Actual Photon EnergiesNuclide /Ci BqBuildup: The material reference is Shield 2[ Integration ParametersResults -Dose Point # 1 -(90,0,0) cmFluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_______ _______No__ BidpWith Buildup NoBuldup With Buildup0.0041 4.477e+1 0 0.000e+00 1 .583e-23 0.000e+00 1.1 80e-230.0295 1.096e+1 1 0.000e+00 2.851 e-22 0.000e+00 2.984e-240.0298 2.034e+11I 0.000e+00 5.353e-22 0.000e+00 5.423e-240.0336 7.231 e+l10 0.000e+00 2.171 e-22 0.000e+00 1.544e-240.0802 2.131le+1 1 7.975e-100 1.884e-21 1.261le-102 2.979e-240.1772 2.1 56e+ 10 1 .790e-58 5 .260e-22 3 .072e-6 1 9.028e-250.2843 4.926e+/-1 1 2.333e-15 4.013e-15 4.393e-18 7.557e-180.3258 2.041e+10 1.346e-11 2.513e-11 2.578e-14 4.813e-140.3294 1 .875e+10 2.729e-1 1 5.1 36e-11I 5.233e-14 9.849e-140.3645 6.607e+12 5.458e-06 1.110e-05 1.057e-08 2.150e-080.503 2.935e+10 6.024e-03 1.513e-02 1.182e-05 2.970e-050.637 5.910e+l 11 1.547e+01 4.214e+01 3.008e-02 8.193e-020.6427 1.787e+10 5.395e-01 1.474e+00 1.048e-03 2.865e-03fi le://iZ:/MicroShield/DHC%201-131I%20Dose.html 1//01! 2/8/2015 Case Summary of DHC 1-13 1Pae2o2Page 2 of 2ATTACHMENT 4I 0.7229 [ 1.467e+11I2.364e+01 I 6.723e+01I 4.546e-02 I 1.293e-01T otals 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 RateEnergy (MeV) iActivity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_________ ______________No Buildup With Buildup No Buildup With Buildup0.0041 4.477e+10 0.000e+/-00 6.542e-24 0.000e+00 4.877e-240.0295 1.096e+11I 0.000e+00 1.178e-22 0.000e+00 1.233e-240.0298 2.034e+1 1 0.000e+00 2.2 12e-22 0.000e+00 2.241e-240.0336 7.231e+10 0.000e+00 8.973e-23 0.000e+00 6.382e-250.0802 2.131e+1I 3.264e-100 7.786e-22 5.160e-103 1.231e-240.1772 2.1 56e+1 0 7.339e-59 2.1 74e-22 1 .260e-61 3.731le-250.2843 4.926e+11I 9.578e-1 6 1 .648e-1 5 1 .804e-I18 3.1 03e-1 80.3258 2.041e+10 5.527e-12 1.032e-11 !.059e-14 1.977e-140.3294 1.875e+10 1.121e-ll 2.109e-1I 2.149e-14 4.045e-140.3645 6.607e+12 2.242e-06 4.562e-06 4.340e-09 8.830e-090.503 2.935e+10 2.476e-03 6.220e-03 4.861e-06 1.221e-050.637 5.910e+11 6.363e+00 1.733e+01 1.237e-02 3.370e-020.6427 1.787e+10 2.219e-0l 6.065e-01 4.312e-04 1.178e-030.7229 1.467e+1 1 9.726e+00 2.767e+01 !.870e-02 5.321e-02Totals 8.588e+12 1.631e+01 4.561e+01 3.151le-02 8.810e-02file://!Z:iM icroShield/DHC%20I- 131 %20Dose.html12805! 2/8/2015 Case Summary of Waste in HHC Pg fPage 1 of 2ATTACHMENT 5MicroShield 8.02University of Missouri (8.00-0000)[ D ate By ICheckedFilename IRun Date I Run Time I Duration]HHC Waste.msd December 1, 2015 4:50:48 PM 00:00:00 JProject InfoCase Title Waste in HHCDescription At Equilibrium Activities offl IsotopesGeometr 1 -PointDose PointsAj 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 Dimension Material DestShield 1 60.0 cm Air 10.00 122Shield 2 j 20.0 cm Lead 11.32Air Gap j _______ Air 0.00122 ___________Source Input: Grouping Method -Standard IndicesNumber of Groups: 25Lower Energy Cutoff: 0.015Photons < 0.015: Included__________________Library: GroveNuclide 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 1215.0200e+001 1.8574e+012Buildup: The material reference is Shield 2Integration Parameters____________ ~ Results -Dose Point # 1 -(80,0,0) cm ______Fluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_________ ______________No Buildup With Buildup No Buildup With Buildup0.015 3.355e+ 12 0.000e+00 5.479e-21 0.000e+00 4.699e-220.03 1.941 e+ 13 0.000e+/-00 6.51 8e-20 0.000e+00 6.459e-220.04 1.637e+11 0.000e+00 7.535e-22 0.000e+00 3.333e-240.06 3.790e+ 10 0.000e+00 2.828e-22 0.000e+00 5.616e-250.08 3.017e+l10 3.547e-206 3.364e-22 5.613e-209 5.324e-250.1 9.844e+09 0.000e+00 4.353e-06 0.000e+00 6.660e-09file:///Z:/MicroShield/H HC%20Waste.html1280512/8/2015 Case Summary of Waste in HHCPae2o2Page 2 of 2ATTACHMENT 50.152.044e+1 34.967e- 1821.041le-178.179e- 1851 .714e-200.5 1.051e-Ill 8.439e-10 2.664e-09 1.656e-12 j5.228e-120.6 j 5.069e+11I 9.830e-06 3.404e-05 1.919e-08 6.645e-080.8 1 .990e+10 9.209e-04 3.788e-03 I1.752e-06 7.205e-06Totals 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 RateEnergy (MeV) Activity (Photons/see) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr__________No Buildup With Buildup No Buildup With Buildup0.015 3.355e+12 0.000e+00 2.075e-21 0.000e+00 1.780e-220.03 1.941e+13 0.000e+00 2.468e-20 0.000e+00 2.446e-220.04 1 .637e+11I 0.000e+00 2.854e-22 0.000e+00 1 .262e-240.06 3.790e+10 0.000e+00 1.071e-22 0.000e+00 2.127e-250.08 3.017e+10 1.330e-206 1.274e-22 2.105e-209 2.016e-250.1 9.844e+09 0.000e+00 1 .649e-06 0.000e+00 2.522e-090.15 2.044e+13 1.866e-182 3.941e-18 3.072e-185 6.490e-210.5 1.051e+ll 3.179e-10 1.003e-09 6.240e-13 1.970e-120.6 5.069e+11 3.704e-06 1.283e-05 7.231e-09 2.504e-080.8 1.990e+10 3.473e-04 1.428e-03 6.605e-07 2.717e-06Totals 4.408e+13 3.510e-04 1.443e-03 6.677e-07 2.745e-06file:///Z:/MicroShield/1H HC%20Waste.html 1//0112/8/20 ! 5 Case Summary of Shipping Cask Dose Pg fPage l of 2ATTACHMENT 6MicroShield 8.02University of Missouri (8.00-0000)[ D ate By IChecked[Filename I RunuDate I Run Time I Duration 2[ HS Cask with .msd December 2, 015 11:43:03 AM 00:00:00JProject InfoCase Title Shipping Cask DoseDescrptionof 1-131 in SS Insert and DU CVGeometr 7 -Cylinder Volume -Side ShieldsSource DimensionsHei~ght I1.0 cm (0.4 in)Radius 1.55 cm (0.6 in)Dose Points8.6 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 DensityZSource 7.548 cm3 Water 1HShieldi1 1.7 cm Water 1.1Shield 2 .44 cm Aluminum 2.7Shield 3 4.756 cm Uranium 19.1Transition ________ Air 0.00122Air Gap _______ Air 0.00122Source Input: Grouping Method -Actual Photon EnergiesNuclide ICi IBq I 3 I Bq/cm3Buildup: The material reference is Shield 3Integration ParametersRadial I 10Circumferential I 10Y Direction (axial) 20Results -Dose Point # I -(8.6,0,0) cmFluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hrNo__Buildup With Buildu NoBilu With Buildup0.0041 4.070e+ 10 0.000e+00 1 .595e-21I 0.000e+00 1.1 89e-21I0.0295 9.966e+10 0.000e+I00 2.816e-20 0.000e+00 2.947e-220.0298 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-22Ifi 12/8/2015 Case Summary of Shipping Cask DosePae2o2Page 2 of 2ATTACHMENT 60.08021.937e+11I1.864e-1 141.736e-192.947e-1 172.745e-220.1772 1.960e+I0 6.698e-60 6.283e-15 1.150e-62 1.078e-170.2843 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-130.3294 1.705e+10 4.031e-10 6.673e-10 7.730e-13 1.280e-120.3645 6.006e+ 12 1.382e-04 2.412e-04 2.674e-07 4.668e-070.503 2.668e+10 4.529e-01 9.227e-01 8.890e-04 1.811le-030.637 5.373e+11 1.810e+03 3.914e+03 3.519e+00 7.611le+000.6427 1.625e+10 6.388e+01 1.385e+02 1.241e-01 2.692e-010.7229 1.334e+11 3.191 e+/-03 7.176e+03 6.137e+00 1.380e+i01Totals 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 RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr______________No Buildup With Buildup No Buildup With Buildup0.0041 4.070e+ 10 0.000e+00 3.407e-23 0.000e+00 2.540e-230.0295 9.966e+ 10 0.000e+00 6.016e-22 0.000e+00 6.296e-240.0298 1.849e+$- 11 0.000e+00 1.129e-21 0.000e+00 1.144e-230.0336 6.573e+10 0.000e+00 4.562e-22 0.000e+00 3.245e-240.0802 1.937e+1 1 6.31 le-1 16 3.709e-21 9.979e-1 119 5.865e-240.1772 1.960e+10 1.897e-61 1.342e-16 3.255e-64 2.304e-190.2843 4.479e+11I 2.968e-16 4.721e-16 5.590e-19 8.890e-190.3258 1.855e+1-0 4.278e-12 7.047e-12 8.195e-15 1.350e-140.3294 1.705e+10 9.250e-12 1.531e-11 1.774e-14 2.935e-140.3645 6.006e+ 12 3.125e-06 5.454e-06 6.049e-09 1.056e-080.503 2.668e+1 0 9.962e-03 2.029e-02 1 .955e-05 3.982e-050.637 5.373e+11I 3.939e+0 1 8.51 6e+0 I 7.659e-02 1 .656e-010.6427 1.625e+ 10 1.390e+00 3.013e+00 2.701 e-03 5.854e-030.7229 1.334e+11 6.919e+01 1.555e+02 1.331e-01 2.991e-01Totals 7.808e+12 1.100e+02 2.437e+02 2.124e-01 4.706e-01fi le :/!/Z:/MicroShieldiH S%20Cask%20with%20200%20Ci .htmi 282112/8/2015 Case Summary of PHC 150 Ci Release Pg fPage 1 of 2ATTACHMENT 7MicroShield 8.02University of Missouri (8.00-0000)/ D ate I By I CheckedFilename I Run Date I Run Time IDuration]PHC 150 Ci Distributed 1- 131 .msd December 8, 2015 10:51:20 AM 00:00:01jProject InfoCase Title PHC 150 Ci ReleaseDescription I -131 Only¢Geometry 13 -Rectangular VolumeSource DimensionsLength 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 ljA X Y ZI#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 Density7Source 2.88e+06 cm3 Air 0.00122ZShield 1 20.0 cm Lead 11.32Air Gap _________ Air 0.00122Source Input: Grouping Method -Actual Photon EnergiesNuclide ICi IBg I ttCi/cm3 BqH/cm3 I1- 131 1.5000e+002 5.5500e+012 5.2083e+001 1.9271 e+006Buildup: The material reference is Shield 1Integration ParametersX Direction 10Y Direction I 20Z Direction 20____________ ~ Results -Dose Point # 1 -(140,75,80) cm ______Fluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr________ _____________No Buildup With Buildup No Buildup With Buildup0.0041 3 .053e+ 10 0.000e+00 1.1 68e-23 0.000e+00 8.705e-240.0295 7.475e+10 0.000e+00 2.103e-22 0.000e+00 2.201e-240.0298 1.387e+1 11 0.O00e-+00 3.948e-22 0.000e+00 4.000e-240.0336 4.930e++/-10 0.000e+00 1.602e-22 0.000e+00 1.139e-240.0802 1.453e+11 1.210e-206 I.390e-21! 1.913e-209 2.197e-240.1772 1.470e++/-10 4.419e- 123 3.880e-22 7.584e- 126 6.659e-2531 .html1280512/8/2015 Case Summary of PHC 150 Ci ReleasePae2o2Page 2 of 2ATTACHMENT 70.28433.359e+1 15.977e-381 .584e-201 .126e-402.983e-230.3258 1.392e+10 5.533e-29 8.598e-22 1.060e-31 1.647e-240.3294 1 .279e+ 10 2.502e-28 8.086e-22 4.798e-3 1 1.551 e-240.3645 4.505e+12 3.111e-20 3.949e-19 6.022e-23 7.645e-220.503 2.001e+10 1.046e-ll 3.343e-ll 2.053e-14 6.561e-140.637 4.030e+11I 3.666e-06 !.334e-05 7.127e-09 2.593e-080.6427 1.218e+10 1.477e-07 5.403e-07 2.869e-10 1.050e-090.7229 1.000e+ll 3.491e-05 1.381e-04 6.714e-08 2.655e-07Totals 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 RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/seci MeVlcm2lsec mR/hr mR/hr_______________No__ BidpWith Buildup NoBuldupL. With Buildup0.0041 3.053e+10 0.O00e+00 4.902e-24 0.000e+00 3.654e-240.0295 7.475e+I10 0.000e+t00 8.830e-23 0.000e+00 9.240e-250.0298 1.387e+1 1 0.000e+00 1.658e-22 0.000e+00 1.679e-240.0336 4.930e+ 10 0.000e+00 6.724e-23 0.000e+00 4.782e-250.0802 1.453e+11 1.149e-206 5.834e-22 1.817e-209 9.225e-250.1772 1.470e+10 4.321e-123 1.629e-22 7.416e-126 2.796e-250.2843 3.359e+11 5.958e-38 6.650e-21 1.122e-40 1.252e-230.3258 1.392e+10 5.509e-29 3.610e-22 1.055e-31 6.914e-250.3294 1.279e+10 2.491e-28 3.395e-22 4.777e-31 6.510e-250.3645 4.505e+t12 3.094e-20 1.884e-19 5.988e-23 3.647e-220.503 2.001e+10 l.032e-11 3.299e-ll 2.026e-14 6.475e-140.637 4.030e+11I 3.575e-06 1.300e-05 6.951le-09 2.527e-080.6427 1.218e+10 1.439e-07 5.263e-07 2.797e-10 1.023e-090.7229 1.000e+llI 3.375e-05 1.333e-04 6.491e-08 2.564e-07Totals 5.856e+I12 3.747e-05 1.469e-04 7.215e-08 2.827e-07file:/i/Z:/MicroShield/PHC%20 150%20Ci%20Distributed%20I- 131 .html1280512/8/2015 Case Summary of PHC 150Ci 1- 131 Only Pg fPage 1 of 2ATTACHMENT 8MicroShield 8.02University of Missouri (8.00-0000)D~ate By ICheckedFilename I Run Date I Run Time IDuration]PHC 150 Ci 1-131 Dose.msd December 9, 2015 11:41:20 AM 00:00:00jProject InfoCase Title PHC 150Ci 1-131 Description I150 Ci Hycpothetical Accident 1-131 Dose to OperatorsGeometr 1 -PointDose PointsAl 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 _XShield N Dimension Material DensityShield 1 80.0 cm Air 10.00 122Shield 2 20.0 cm Lead [ 11.32Air Gap ____ ___ Air [0.00122 __________Source Input: Grouping Method -Actual Photon Energ~iesNuclide ICi Bg1- 131 1 .5000e+002 5.5500e+012Buildup: The material reference is Shield 2I Integration ParametersResults -Dose Point # 1 -(100,0,0) cm ______Fluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/see) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_______________________No Buildup With Buildup No Buildup With Buildup0.0041 3 .053e+1 0 0.000e+/-00 8.742e-24 0.000e+00 6.51 7e-240.0295 7.475e+10 0.000e+00 1.575e-22 0.000e+00 1.648e-240.0298 1.387e+11I 0.000e+00 2.956e-22 0.000e+00 2.995e-240.0336 4.930e+ 10 0.000e+00 1.1 99e-22 0.000e+00 8.529e-250.0802 1.453e+1 1 2.125e-204 1.041e-21 3.361e-207 1.645e-240.1772 1.470e+10 4.773e-121 2.905e-22 8.191e-124 4.986e-250.2843 3.359e+11 2.208e-36 1.186e-20 4.158e-39 2.233e-230.3258 1.392e+10 I.547e-27 6.437e-22 2.963e-30 1.233e-240.3294 1.279e+10 6.845e-27 6.054e-22 1.313e-29 1.161 e-240.3645 4.505e+12 7.023e-19 1.628e-18 1.359e-21 3.151e-210.503 2.001e+10 1.394e-10 4.416e-10 2.736e-13 8.667e-130.637 4.030e+i11 3.601 e-05 1.291e-04 7.002e-08 2.511le-070.6427 1.218e+10 1.436e-06 5.177e-06 2.790e-09 1.006e-08file:///Z:/MicroShield/PHC%20 1 50%20Ci%20%20I- 131 %20Dose.html1290512/9/2015 Case Summary of PHC 150Ci 1-131 OnlyPae2o2Page 2 of 2ATTACHMENT 8I 0.7229 I 1.000e+1lI 2.984e-04 I1.158e-03 I 5.738e-07 I 2.227e-06I Totals J 5.856e+12 1 3.358e-04 I1.292e-03 j 6.466e-07 [ 2.4,,e-06Results -Dose Point # 2 -(150,0,0) cmFluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr______________No Buildup With Buildup No Buildup With Buildup0.0041 3.053e+10 0.000e+00 3.885e-24 0.000e+00 2.897e-240.0295 7.475e+10 0.000e+00 6.999e-23 0.000e+00 7.324e-250.0298 1.387e+11 0.000e+00 1.314e-22 0.000e+00 1.331e-240.0336 4.930e+ 10 0.000e+00 5 .330e-23 0.000e+00 3.791 e-250.0802 1.453e+1 1 9.354e-205 4.625e-22 1.479e-207 7.3 12e-250.1772 1.470e+10 2.105e-121 1.291e-22 3.612e-124 2.216e-250.2843 3.359e+11 9.748e-37 5.271e-21 1.836e-39 9.926e-240.3258 1.392e+10 6.832e-28 2.861e-22 1.309e-30 5.480e-250.3294 1 .279e+ 10 3 .023e-27 2.691 e-22 5 .797e-30 5.1 60e-250.3645 4.505e+12 3.102e-19 7.192e-19 6.005e-22 1.392e-210.503 2.001e+10 6.162e-ll 1.952e-10 1.210e-13 3.832e-130.637 4.030e+11 1.593e-05 5.713e-05 3.097e-08 1.1lie-070.6427 1.21 8e+1 0 6.351 e-07 2.290e-06 1 .234e-09 4.450e-090.7229 1.000e+/-ll 1.320e-04 5.124e-04 2.539e-07 9.853e-07Totals 5.856e+ 12 1 .486e-04 5.7 18e-04 2.86 1e-07 1.101le-06file :///Z:/MicroShield/PHC%20 150%20Ci%20%201- 131 %20Dose.html1290512/9/2015 Case Summary of PHCfl Only Pg fPage i of 2ATTACHMENT 9MicroShield 8.02University of Missouri (8.00-0000)FDate I By ICheckedFFilename IRun Date I Run Time DurationPHC lDose.msd December 8, 2015 10:26:11 AM 00:00:00Project InfoCase Title PH-CE OnlyDescription INominal Te Dose to OperatorsGeometr 1 -PointDose Points1000c ft3. n)(Z~#1 1000 cm ( ft 3. n) 0.0 cm (0 in) I0.0 cm ( n#2 150.0Ocm(4 ft 11.1 in) 0.0Ocm (0in) 0.0 cm (0 in)J______Shields ________Shield N Dimension IMaterial DensitShield 1 80.0 cm Air 0.00 122Shield 2 20.0 cm j Lead j 11.32Air Gap _______[ Air [0.00122Source Input: Grouping Method -Standard IndicesNumber of Groups: 25Lower Energy Cutoff: 0.015Photons < 0.015: Included_________________Library:_GroveNuclide Ci Bq____2.6500e+001 9.8050e+01 15.6700e+000 2.0979e+011I_____I.9500e+002 7.21 50e+/-0 121.1600e+001 4.2920e+01 1____2.5000e-004 9.2500e+006____7.1700e+000 2.6529e+0l112.6100e+001 9.6570e+01 1Buildup: The material reference is Shield 2I Integration ParametersResults -Dose Point # 1 -(100,0,0) cm ______Fluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cmn2/sec MeV/cm2/sec mR/hr mR/hr______________No Buildup With Buildup No Buildup With Buildup0.015 1.888e+/-+ 11 0.000e+00 1.974e-22 0.000e+00 1.693e-230.03 1.175e+ 12 0.000e+00 2.525e-21 0.000e+00 2.503e-230.04 1.362e+10 0.000e+00 4.011le-23 0.000e+00 1.774e-250.06 1 .623e+09 0.000e+00 7.752e-24 0.000e+00 1 .540e-26file://!Z :/M icroShield!PHC%20Te%20Dose.html 1//0112/8/2015 Case Summary of PHC Te OnlyPae2o2Page 2 of 2ATTACHMENT 90.084.320e+1 03.237e-2063 .082e-225.123e-2094.877e-250.1 7.933e+10 0.000e+00 2.245e-05 0.000e+00 3.435e-080.15 8.911le+1 1 1 .381e-1 83 2.903e-19 2.274e-1 86 4.780e-220.2 1.772e+11 5.077e-88 3.803e-21 8.961e-91 6.712e-240.3 1.324e+11 2.554e-32 5.180e-21 4.846e-35 9.826e-240.4 1.078e+11 1.498e-16 3.839e-16 2.919e-19 7.479e-190.5 4.123e+10 2.114e-10 6.671e-10 4.149e-13 1.309e-120.6 1.141e+ll 1.413e-06 4.893e-06 2.758e-09 9.550e-090.8 8.917e+1 1 2.637e-02 1.085e-01 5.015e-05 2.063e-041.0 3.176e+11 4.684e-01 2.125e+/-00 8.635e-04 3.917e-031.5 2.073e+10 2.370e+00 1.190e+01 3.987e-03 2.002e-022.0 3.962e+10 2.177e+01 1.131e+/-02 3.367e-02 1.750e-01Totals 4.235e+12 2.464e+01 1.273e+02 3.857e-02 1.991e-01Results -Dose Point # 2 -(150,0,0) cm ______Fluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeVcm2/seci MeV/cm2/sec mR/hr mR/hr__No___Bui~ldup With Buildup NoBildup With Buildup0.015 1.888e+1 1 0.000e+00 8.773e-23 0.000e+00 7.525e-240.03 1.175e+12 0.000e+00 1.122e-21 0.000e+00 1.112e-230.04 1.362e+10 0.000e+00 1.783e-23 0.000e+00 7.885e-260.06 1.623e+09 0.000e+00 3.445e-24 0.000e+00 6.843e-270.08 4.320e+10 1.425e-206 1.370e-22 2.254e-209 2.168e-250.1 7.933e+10 0.000e+00 9.979e-06 0.000e+00 1.527e-080.15 8.911e+11 6.088e-184 1.290e-19 1.002e-186 2.125e-220.2 1.772e+11 2.240e-88 1.690e-.21 3.953e-91 2.983e-240.3 1.324e+11I 1.128e-32 2.302e-21 2.140e-35 4.367e-240.4 1.078e+11 6.620e-17 1.696e-16 1.290e-19 3.305e-190.5 4.123e+10 9.344e-ll 2.949e-l0 1.834e-13 5.789e-130.6 1.141e+llI 6.248e-07 2.164e-06 1.220e-09 4.224e-090.8 8.917e+1 1 1.167e-02 4.800e-02 2.219e-05 9.131e-051.0 3.176e+11 2.074e-01 9.410e-01 3.823e-04 1.735e-031.5 2.073e+10 1.050e+00 5.273e+00 1.767e-03 8.872e-032.0 3.962e+10 9.650e+00 5.016e+01 1.492e-02 7.757e-02Totals 4.235e+12 1.092e+01 5.642e+01 1.709e-02 8.827e-02file :///Z:/MicroShield/PHC%20Te%20Dose.html1280512/8/2015 Case Summary of Ductwork Plateout Pg fPage 1 of 2ATTACHMENT 10MicroShield 8.02University of Missouri (8.00-0000)[D ate By IChecked][Filename IRun Date I Run Time IDuration]Duct Work Dose.msd December 7, 2015 1:43:23 PM 00:00:00 JProject InfoCase Title Ductwork PlateoutDescription I150 Ci, two filters at 99%, 3rd out of serviceGeometr 2 -Line[ Source Dimensions[ Length I250.0 cm (8 ft 2.4 in)y[ Angle 90.00°Dose PointsAJ 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 zXShel NDimension IMaterial IDensityAir Gap Air 0.00 122Source Input: Grouping Method -Actual Photon EnergiesNuclide ICi IBg I Ci/cm I Bg/cmI-131 1 .5000e-002 5.5500e+008 6.0000e+t001 2.2200e+006Buildup: The material reference is Air Gap__________________ __Inte__ration_ Parameters_______________Len th Se ments [ 20___________Results -Dose Point # 1 -(250,125,0) cmFluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr______________No Buildup With Buildup No Buildup With Buildup0.0041 3 .053e+06 9.1 42e-03 1 .020e-02 6.81 5e-03 7.601 e-030.0295 7.475e+06 2.339e-01 2.627e-01 2.448e-03 2.749e-030.0298 1 .387e+07 4.394e-01I 4.936e-01I 4.452e-03 5.001 e-030.0336 4.930e+06 1.791 e-01 2.012e-01 1.274e-03 1.431 e-030.0802 1 .453e+07 1 .307e+00 1 .436e+00 2.067e-03 2.271 e-030.1772 1.470e+06 2.954e-01 3.124e-01 5.070e-04 5.362e-040.2843 3.359e+07 1.089e+01 1.133e+01 2.052e-02 2.133e-020.3258 1.392e+06 5.181 e-01 5.369e-01 9.923e-04 1.028e-030.3294 1.279e+06 4.814e-01 4.987e-01 9.231e-04 9.563e-040.3645 4.505e+08 l.879e+02 1.941e+02 3.637e-01 3.758e-01file ://Z :!MicroShield/Duct%20Work%20Dose.html1280112/8/2015 Case Summary of Ductwork PlateoutPae2o2Page 2 of 2ATTACHMENT 100.5032.001le+061.156e+001.186e+002.269e-032.328e-030.637 4.030e+07 2.956e+01 3.021e+01 J5.748e-02 5.873e-020.6427 1.218e+06 j9.020e-01 9.216e-01 1.753e-03 1.791e-030.7229 1 .000e+07 8.341 e+00 8.506e+00 1 .604e-02 1 .636e-02Totals 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 RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_______________________No Buildup With Buildup No Buildup With Buildup0.0041 3 .053e+06 1 .673e-01 1 .722e-0 1 1 .247e-0 1 1 .284e-0 10.0295 7.475e+06 3.244e+00 3.346e+00 3.395e-02 3.502e-020.0298 1.387e+07 6.088e+00 6.279e+00 6.168e-02 6.362e-020.0336 4.930e+06 2.452e+00 2.529e+00 1 .744e-02 1 .799e-020.0802 1.453e+07 1.742e+01 1.786e+01 2.754e-02 2.824e-020.1772 1.470e+06 3.905e+00 3.964e+00 6.703e-03 6.804e-030.2843 3.359e+07 1.434e+02 1.449e+02 2.700e-01 2.729e-010.3258 1.392e+06 6.811e+00 6.876e+00 1.305e-02 1.317e-020.3294 1 .279e+06 6.328e+00 6.388e+/-00 1.21 3e-02 1 .225e-020.3645 4.505e+08 2.468e+03 2.489e+03 4.776e+00 4.81 8e+000.503 2.001 e+06 1.51 4e+0 1 1 .525e+01I 2.972e-02 2.992e-020.637 4.030e+07 3.864e+02 3.887e+02 7.513e-01 7.557e-010.6427 1.218e+06 1.179e+01 1.186e+01 2.291e-02 2.304e-020.7229 1.000e+07 1.089e+02 1.095e+02 2.095e-01 2.106e-01Totals 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 RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr________________No__ BidpWith Buildup NoBildupL. With Buildup0.0041 3.053e+06 1.144e+00 1.154e+00 8.526e-01 8.602e-010.0295 7.475e+06 2.070e+01 2.090e+01 2.167e-01 2.188e-010.0298 1.387e+07 3.883e+01 3.921e+01 3.934e-01 3.972e-010.0336 4.930e+06 1.560e+01 1.575e+01 1.109e-01 1.120e-010.0802 1.453e+07 1.100e+02 1.109e+02 1.740e-01 1.754e-010.1772 1.470e+06 2.462e+01 2.474e+01 4.226e-02 4.246e-020.2843 3.359e+07 9.031e+02 9.061e+02 1.701e+00 1.706e+000.3258 1 .392e+/-06 4.288e+0 1 4.301 e+0 1 8.21 4e-02 8.238e-020.3294 1.279e+06 3.984e+01 3.996e+01 7.640e-02 7.662e-020.3645 4.505e+08 1.553e+04 1.557e+04 3.006e+01 3.015e+010.503 2.001e+I06 9.523e+01 9.544e+01 1.869e-01 1.873e-010.637 4.030e+07 2.429e+03 2.434e+03 4.724e+00 4.732e+000.6427 1.21 8e+06 7.41 2e+01I 7.425e+0 1 1 .440e-01 1I.443e-0 10.7229 1 .000e+07 6.846e+02 6.857e+02 1.31 7e+00 1.31 9e+00Totals 5.856e+08 2.001e+04 2.007e+04 4.008e+01 4.020e+01file:!i/Z :/MicroShield/Duct%20Work%20Dose.html1280512/8/2015 Case Summary of Updated Pg fPage 1 of 2ATTACHMENT 11MicroShield 8.02Nathan Hogue (8.00-0000)Date By ICheckedFilename 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 UpdatedDescription I150 Ci Target-Mitigated (4 of 4 filters-DF 1000)-Filter No. 1Geometr 12 -Annular Cylinder -External Dose PointSource DimensionsHeigt .....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)jShieldsShield N' Dimension ,Material DensityClRais4.0 cm Air 0.00122Source 204.204 cm3 Carbon 1.8Transition Air 0.00122Shield 5 10.0 cm Lead 1 I1.35Air Gap ____ ___ Air 0.00122Source Input: Grouping Method -Actual Photon Energies '...Nuclide ...... Ci IBg 3 Bq/cm3I111 .4985e+002 5.5445e+012 7.3383e+005 2.7152e+010 JBuildup: The material reference is Shield 5Integration ParametersRadial 10Circumferential I 20Y Direction (axial) 20_____________ ~~~~Results_____ ___ _______Fluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) lMeV/cm2/sec MeV/cm2/sec mR/hr mRlhrNo Buildup With Buildup NBuldup With Buildup0.0041 .........3.050e+10 O.O00e+O0 3.712e-23 O.O00e+O0 2.767e-230.0295 ... 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-2312/29/2015 Case Summary of UpdatedPae2o2Page 2 of 2ATTACHMENT 110.03364.925e+1 00.000e+005 .092e-220.O00e+O03 .622e-240.0802 1.452e+1 1 1.382e-100 4.418e-21 ... 2.185e-103 ...6.986e-240.1772 ___1.468e+ 10 5.996e-59 1.234e-21 1.029e-61 2.117e-240.2843 .... 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-140.3294 1 .277e+10 2.11 3e-I 1 3.995e-1 1 4.053e-14 7.661 e-140.3645 4.500e+12 4.538e-06 9.287e-06 8.784e-09 1.798e-080.503 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-020.6427 ' 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-01Totals 5.850e+12 4'.416e+O1 1.264e+02 8.530e-02 2.442e-01file 12/29/2015 Case Summary of Updated Pg fPage 1 of 2[ATTACHMENT 11MicroShield 8.02Nathan Hogue (8.00-0000)rDate By Checked]Filename IRun Date I Run Time I Duration]'Filter I1.msd ... December 29, 2015 10:16:27 PM 00:00:00 JProject Infocase Title .. ...UpdatedDescription .150 Ci Target-Mitigated (4 of 4 filters-DF 100)-Filter No. 112 -Annular Cylinder -External Dose PointSource DimensionsHeight 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 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 DensityCyl. Radius 4.0 cm Air 0.00122Source 204.204 cm3 Carbon 1.8Transition ________ Air 0.00122Shield 5 10.0 cm Lead 11.35Air___Gap___ Air 0.00122Source Input: Grouping Method -Actual Photon Energies .............Nuclide ICi IBq ptCi/cm3 Bg/cm3I- 13 1 1.4850e+002 5.4945e+012 7.2722e+005 2.6907e+010Buildup: The material reference is Shield 5..... .Integration ParametersRadial 10Circumferential I 20Y Direction (axial) 20___________ _________________Results.........Fluence Rate Fluence Rate Exposure Rate Expo'sure RateEnergy (MeV) Activity" (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr_______ ___________No Buildup With Buildup NoBuldup.. With Buildup0.0041 3.022e+ 10 0.000e+O0 3.679e-23 0.000e+00 2.742e-230........00295 -" 7.400e+1 0 0.000e+00 6.626e-22 0.000e+00 6.935e-240.0298 1.373e+11I 0.000e+00 1.244e-21 0.000e+00 1.260e-2312/29/2015 Case Summary of UpdatedPae2o2Page 2 of 2ATTACHMENT 110.03364.881le+10O.O00e+O05 .046e-220.000e+003.589e-240.0802 ___1.439e+11I 1.369e-100 4.378e-21 2.165e-103 6.923e-240.1772 1.455e+10O ... 5.942e-59 i'.222e-21 ]'.020e-61 '2.098e-240.2843 3.325e+11 1.579e-15 2.725e-15 2.974e-18 5.132e-180.3258 __...... 1.378e+10 1.024e-11 1.921e-1 1 1.962e-14. 3.679e-140.3294 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 I 1.782e-080.1503 ...1.981e+10 ...5.892e-03 1.501e-02 1.156e-05 2.946e-050.637 .....J989e+ll 1.662e+01 "4.622e+01 3.232e-02 8.987e-020.6427 1.206e+ 10 5.817e-01 1.623e+I00 1.130e-03 3.153e-030.7229 9.904e+10 2.655e+01 7.744e+01 5.106e-02 1.489e-01Totals ... 5.797e+12 4.376e+O1 1.253e+02 8.453e-02 2.420e-O1fie 12/29/2015 Case Summary of Updated Pg fPage 1 of 2ATTACHMENT 11MicroShield 8.02Nathan 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 InfoCase Title .......UpdatedDescription I150 Ci Target-Mitigated (4 of 4 filters-DF 1000O)-Fil!ter No.2Geometr 12 -Annular Cylinder -External Dose PointSource DimensionsHeight 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 c*m (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 0.00122Source 106.311 cm3 -Carbon 1..18 ..Transition Air 0.00122Shield 5 10.0 cm Lead 11.35Air Gap Air 0.00122Source Input: Grouping Method -Actual Photon Energies......Nuclide ICi IBq I aCi/cm3 I Bq/cm3I-131 1.4985e-001 5.5445e+009 1.4095e+003 5.2153e+007Buildup: The material reference is Shield 5...... Integration ParametersRadial 10Circumferential ...20 ........Y Direction (axial) 20Results______________............ Fluence Rate Fluence Rate Exposure Rate Exposure RateiEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm'/sec mR/hr mR/hr_____________No Buildup With Buildup No Buildup With Buildup0.0041 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-270.0298 1 .385e+08 0.000e+00 1 .382e-24 0O.0e+00 1 .400e-2612/29/2015 Case Summary of UpdatedPae2o2Page 2 of 2ATTACHMENT 110.03364.925e+070.000e+005 .605e-250.000e+003.987e-270.0802 1 .452e+08 2.448e-103 _4.864e-24 .......3.870e-106 7.690e-270.1772 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-210.3258 "1.390e+07 1.476e-14 2.764e-14 2.826e-17 5.295e,170.3294 1 .277e+07 3.012e-14 5.688e-14 5.775e-1 7 1 .091e-160.3645 4.500e+09 6.367e-09 1.302e-08 1.232e-1 1 2.519e-llI0.503 i1.999e+07 ... 8.033e-06' 2.041le-05 1.. 1.577e-08 4.006e-080.637 4.026e+08 2.221e-02 6.150e-02 4.318e-05 1.!96e-040.6427 1.217e+07 7.766e-04 2.158e-03 1.509e-06 4.193e-060.7229 9.994e+07 3.514e-02 1.020e-01 ...... 6.757e-05 1,961e,04Totals 5.850e+09 ... 5.813e-02 1.656e-01 1.123e-04 3.199e-04 ....file :///C 12/29/2015 Case Summary of Updated Pg fPage 1 of 2ATTACHMENT 11KMicroShield 8.02Nathan Hogue (8.00-0000)D ate IBy ................ Checked. ..Fienm Run Date I Run Time I DurationFilter 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.4Geometr........ 13 -Rectangular VolumeSource DimensionsLength ...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) ZShieldsShield N Dimension Material DensitSource 900.0 cm3 I Carbon 1.8Shield 1 1 .635 cm 1 Lead I 11.35Air Gap) Air 0.00122Source Input: Grouping Method -Actual Photon Energies1- 131 1 .4985e-007 I 5.5445e+0)3' 1 .6650e-004 610 +0Buildup: The material reference is Shield IInte ration ParametersX Direction 10Y Direction ........ 20Z Direction 20Resultsr, , Fluence Rate Fluence Rate Exposure Rate Exposure RateEnergy (MeV) Activity (Photons/sec) MeV/cm2/sec MeV/cm2/sec mR/hr mR/hrNo Buildup With Buildup No Buildup With Buildup0.0041 3.050e+01 0.000e+00 4.499e-32 0.000e+00 3.354e-320.0295 7.467e+01 1.172e-101 8.104e-31 1.227e-103 8.481e-330.0298 1.385e+02 1.135e-98 1.521e-30 1.149e-100 1.541e-320.0336 4.925e+0 1 ..........1.471 e-73 6.171 e-31 ... I.046e-75 4.389e-330.0802 1.452e+02 1.354e-1 1 1.599e-11I 2.140e-14 2.529e-140.1772 1.468e+01 1.976e-09 2.900e-09 3.391e-12 4.977e-120.2843 3.356e+02 ....4.272e-05 5.43 le-05 8.045e-08 1.023e-07file:///C:/Program%2OFiles%20(x86)/MicroShield%208/Examples/CaseFiles/HITML/Filt... 12/29/2015 Case Summary of UpdatedPae2o2Page 2 of 2ATTACHMENT 110.32581 .390e+014.543e-065.893e-068.701 e-091.129e-080.3294 ___1.277e+01 4.456e-06 5.789e-06 8.545e-09 1.110~e-080.3645 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-070.637 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-070.7229 9.994e+01 4.930e-04 6.961le-04 9.482e-07 1 .339e-06Totals 5.850e+03 4.829e-03 6.526e-03 9.353e-06 1.264e-05file:///C 12/29/2015

ATTACHMENT 14TECHNICAL SPECIFICATIONUNIVERSITY OF MISSOURIRESEARCH REACTOR FACILITYNumber 3.6Page 4 of 5Date _______Amendment No._____SUBJECT: Experiments (continued)o. Fueled experiments containing inventories of Iodine 131 through 135 greater than 1.5 Curies orStrontium 90 greater than 5 millicuries shall be in irradiation containers that satisfy therequirements of specification 3 .6.i or be vented to the exhaust stack system through HEPA andcharcoal 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 greaterthan 150 Curies.q. Non-fueled experiments that are intended to produce Iodine 131 shall be processed in hot cellsthat are vented to the exhaust stack system through charcoal filters which are continuouslymonitored for an increase in radiation levels.Basesa. Specification 3.6.a restricts the generation of hazardous materials to levels that can be handledsafely and easily. Analysis of fueled experiments containing a greater inventory of fissionproducts 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 orwater annulus surrounding the center test hole by restricting materials which could generate oraccumulate gases or vapors.c. The limitation on experiment materials imposed by specification 3.5.c assures that the limits ofAppendix 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 poolcomponents resulting from detonation of explosive materials.e. Specification 3.6.e is intended to limit the experiments that can be moved in the centertest hole while the reactor is operating, to those that will not introduce reactivitytransients more severe than one that can be controlled without initiating safety systemaction (Ref. Add. 5 to HSR).

ATTACHMENT 14TECHNICAL SPECIFICATIONUNIVERSITY OF MISSOURIRESEARCH REACTOR FACILITYNumber 3.6Page 5 of 5Date ________Amendment No._____SUBJECT: Experiments (continued)f. Specifications 3.6.f and 3.6.g provide guidance for experiment safety analysisto assure that anticipated transients will not result in radioactivity releaseand that experiments will not jeopardize the safe operation of the reactor.g. Specification 3.6.h is intended to reduce the likelihood of reactivitytransients due to accidental voiding in the reactor or the failure of anexperiment from internal or extemnal heat generation.h. Specification 3 .6.i is intended to reduce the likelihood of damage to thereactor and/or radioactivity releases from experiment failure.i. Specification 3.6.j provides assurance that no chemical reaction will takeplace to adversely affect the reactor or its components.j. Specification 3.6.k provides assurance that the integrity of the beamportswill be maintained for all loop-type experiments.k. Specification 3.6.1 assures that corrosive materials which are chemicallyincompatible with reactor components, highly flammable materials and toxicmaterials are adequately controlled and that this information is dissem-inated to all reactor users.1. The extremely low temperatures of the cryogenic liquids present structuralproblems 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 ofIodine 131 can be performed safely and that equipment necessary foraccident mitigation has been installed.

ATTACHMENT 14TECHNICAL SPECIFICATIONUNIVERSITY OF MISSOURIRESEARCH REACTOR FACILITYNumber 3.11Page 1 of 2Date _______Amendment No._____SUBJECT: Iodine 131 Processing Hot CellsApplicabilityThis specification shall apply to the limiting conditions of operation on the equipmentneeded to safely process Iodine 131.ObjectiveThe objective of this specification is to reasonably assure that the health and safety ofthe staff and public is not endangered as a result of processing Iodine 131.Specificationa. The facility ventilation exhaust system shall be operable when processing Iodine 131 inthe Iodine 131 processing hot cells.b. The facility ventilation exhaust system shall maintain the Iodine 131 processing hotcells at a negative pressure with respect to the surrounding areas when processingIodine 131.c. Processing of Iodine 131 shall not be performed in the Iodine 131 processing hot cellsunless the following minimum number of radiation monitoring channels are operable.::::Radiation Monitoting Channel,:: -, Number1. Stack Radiation Monitor 12. Iodine-131 Processing Hot Cells Radiation Monitor 1Exception: When the required radiation monitoring channel becomes inoperable, thenportable instruments may be substituted for the normally installed monitor inspecification 3.11 .c.2 within one (1) hour of discovery for a period not to exceed one(1) week.

ATTACHMENT 14TECHNICAL SPECIFICATIONUNIVERSITY OF MISSOURIRESEARCH REACTOR FACILITYNumber 3.11Page 2 of 2Date _______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 shallbe operable when processing Iodine 131 in the Iodine 131 processing hot cells.Basesa. Operation of the facility ventilation exhaust system when processing Iodine 131 in theIodine 131 processing hot cells ensures proper dilution of effluents to preventexceeding the limits of 10 CFR 20 Appendix B.b. Maintaining the Iodine 131 processing hot cells at a negative pressure with respect tothe surrounding areas ensures safety for the facility staff.c. The radiation monitors provide information to operating personnel regarding routinerelease of radioactivity and any impending or existing danger from radiation. Theiroperation will provide sufficient time to take the necessary steps to prevent the spreadof radioactivity to the surroundings. The Stack Radiation Monitor continuouslymonitors 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 areinstalled and the other is located in the bay above the hot cell next to the exhaustcharcoal filters.d. The potential radiation dose to staff and individuals at the Emergency Planning Zoneboundary and beyond have been calculated following an accidental release of Iodine131 activity. These calculations are based on the facility ventilation exhaust systemdirecting all Iodine 131 processing hot cell effluents through charcoal filtration with anefficiency of 99% or greater prior to being released through the facility exhaust stack.

ATTACHMENT 14TECHNICAL SPECIFICATIONUNIVERSITY OF MISSOURIRESEARCH REACTOR FACILITYNumber 5.7Page 1 of 2Date _______Amendment No._____SUBJECT: Iodine 131 Processing Hot CellsApplicabilityThis specification shall apply to the surveillance of the equipment needed to safelyprocess Iodine 131.ObjectiveThe objective of this specification is to reasonably assure proper operation of theequipment needed to safely process Iodine 131.Specificationa. An operability test of the facility ventilation exhaust system shall be performedmonthly.b. The operability of the facility ventilation exhaust system to maintain the Iodine 131processing hot cells at a negative pressure with respect to the surrounding areas shall beverified 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 foroperability with a radiation source at monthly intervals.e. The efficiency of the Iodine 131 processing hot cells charcoal filter banks shall beverified biennially. It shall be verified that the charcoal filter banks have a removalefficiency of 99% or greater for iodine.Basesa. Experience has shown that monthly tests of the facility ventilation exhaust system aresufficient to assure proper operation.

ATTACHMENT 14STECHNICAL SPECIFICATIONUNIVERSITY OF MISSOURIRESEARCH REACTOR FACILITYNumber 5.7Page 2 of 2Date _______Amendment No._____SUBJECT: Iodine 131 Processing Hot Cells (continued)b. Verifying that the Iodine 131 processing hot cells are at negative pressure with respectto the surrounding areas prior to use ensures personnel safety.c. Semiannual channel calibration of the radiation monitoring instrumentation will assurethat long-term drift of the channels will be corrected.d. Experience has shown that monthly verification of operability of the radiationmonitoring instrumentation is adequate assurance of proper operation over a long timeperiod.e. Biennial verification of filter banks ensures that the filters will perform as analyzed.