ML121420212

University of Missouri - Columbia - Anticipated Basis for Exemption from Testing Facility Classification

ML121420212
Person / Time
Site:	University of Missouri-Columbia
Issue date:	05/30/2012
From:	Jessie Quichocho Research and Test Reactors Licensing Branch
To:	Rhonda Butler Univ of Missouri - Columbia
ADAMS A, NRC/NRR/ADRA/DPR/PRTA 415-1127
References
Download: ML121420212 (4)

Text

May 30, 2012 Mr. Ralph Butler, Director Research Reactor Center University of Missouri-Columbia Research Park Columbia, MO 65211

SUBJECT:

UNIVERSITY OF MISSOURI - COLUMBIA - ANTICIPATED BASIS FOR EXEMPTION FROM TESTING FACILITY CLASSIFICATION

Dear Mr. Butler:

This is in response to your letter dated February 17, 2012, discussing an anticipated basis for an exemption from the definitions of testing facility, testing reactor and research reactor related to your potential conversion from high-enriched uranium (HEU) to low-enriched uranium (LEU) fuel. Your letter states that it is not an exemption request but is intended to permit the U.S. Nuclear Regulatory Commission (NRC) to identify areas of regulatory concern, if any, for the University of Missouri to address in its formal request for the University of Missouri-Columbia Research Reactor (MURR).

We understand that conversion feasibility studies have shown that to maintain neutron flux levels in key experimental facilities the reactor power level will need to be increased from 10 MW(t) to 12 MW(t). This reduction in the neutron flux levels with conversion from HEU to LEU fuel is consistent with the conversions performed to date.

While it is your responsibility to develop the application for exemption including the technical justification for the request, the NRC staff has several comments on your discussion in the letter. Any exemption application needs to meet the regulatory requirements in Title 10 of the Code of Federal Regulations (10 CFR) 50.12.

Your letter contains a discussion of why an exemption would not present an undue risk to public health and safety. The application should contain a complete discussion of the difference, if any, in radiological risk from routine operation and accident conditions, and margins of safety between the HEU and LEU fueled reactor. The application should clearly discuss and justify why these differences would not present an undue risk to public health and safety. Because of the detailed technical information needed to support this finding, unless a complete conversion safety analysis report is available sooner, the NRC staff believes that the exemption application should be submitted as part of the application for conversion which would contain the complete technical justification to support conversion.

Your discussion of undue hardships associated with becoming a testing facility refers to increased costs and burdens to MURR. These costs and burdens should be quantified to the extent possible in your application. You refer to increased review fees. The University of Missouri-Columbia is currently exempt from fees in accordance with 10 CFR 170.11(a)(4) and

10 CFR 171.11(a)(1) because it is a non-profit educational institution. Your bases for MURR being assessed fees if it is classified as a testing facility should be clearly explained in your exemption application.

If you have any questions regarding this response, please contact Alexander Adams at (301) 415-1127.

Sincerely,

/RA/

Jessie F. Quichocho, Chief Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-186

Enclosure:

As stated

cc w/encl: See next page University of Missouri-Columbia Docket No. 50-186 cc: John Ernst, Associate Director Regulatory Assurance Group Research Reactor Facility Columbia, MO 65201 Homeland Security Coordinator Missouri Office of Homeland Security P.O. Box 749 Jefferson City, MO 65102 Planner, Dept of Health and Senior Services Section for Environmental Public Health 930 Wildwood Drive, P.O. Box 570 Jefferson City, MO 65102-0570

Deputy Director for Policy Department of Natural Resources 1101 Riverside Drive Fourth Floor East Jefferson City, MO 65101 A-95 Coordinator Division of Planning Office of Administration P.O. Box 809, State Capitol Building Jefferson City, MO 65101 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML121420212 NRR-106 OFFICE PRLB:PM PRLB:LA OGCPRLB:BCPRLB:PM NAME AAdams GLappert BMizunoJQuichochoAAdams DATE 05/22/2012 5/22/2012 5/23/20125/22/20125/30/2012