ML15049A039

University of Missouri-Columbia - Response to Request for Additional Information Regarding the Renewal of Facility Operating License No. R- 103 Dated December.3, 2014

ML15049A039
Person / Time
Site:	University of Missouri-Columbia
Issue date:	02/12/2015
From:	Butler R A, Fruits J L Univ of Missouri - Columbia
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1580
Download: ML15049A039 (18)

Text

UNIVERSITY of MISSOURI RESEARCH REACTOR CENTER February 12, 2015 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Mail Station P1-37 Washington, DC 20555-0001

REFERENCE:

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

SUBJECT:

Written communication as specified by 10 CFR 50.4(b)(1) regarding the response to the "University of Missouri at Columbia -Request for Additional Information Regarding the Renewal of Facility Operating License No. R- 103 for the University of Missouri at Columbia Research Reactor (TAC No. ME 1580)," dated December.3, 2014 On August 31, 2006, the University of Missouri-Columbia Research Reactor (MURR) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to renew Amended Facility Operating License No. R- 103.On December 3, 2014, as part of the NRC staff's review of the renewal request, the NRC requested additional information in the form of two (2) questions.

By letter dated January 28, 2015, -HMURR responded to those two questions.

Attached are the following two items: 1. "10 CFR 2.390 Affidavit of Ralph A. Butler," dated February 12., 2015; and 2. Attachment 13: Modification Record 01-09, Addendum 5; "Emergency Electrical in AfIB Eastward Expansion." The attached affidavit replaces the one submitted on January. 28, 2015 in its entirety.

Additionally,"Attachment 13: Modification Record, 01-09, Addendum 5; Emergency Electrical in MIB Eastward Expansion," replaces the attachment that was submitted on January 28, 2015. It was incorrectly iabeled as Attachment 14.If there are questions regarding this response, please ..contact me at (573) 882-5319 or FruitsJ@missouri.edu.

I declare under penalty of 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.edu Fighting Cancer with Tomorrow's Technology Sincerely, John L. Fruits Reactor Manager Reviewed and Approved, Ralph A. Butler, P.E.Director Enclosed: 1. "10 CFR 2.390 Affidavit of Ralph A. Butler," dated February 12, 2015 2. Attachment 13: Modification Record 01-09, Addendum 5; "Emergency Electrical in MIB Eastward Expansion" xc: Reactor Advisory Committee, w/o attachments Reactor Safety Subcommittee, w/o attachments Dr. Kenneth Dean, Interim Provost, w/o attachments Dr. Robert Hall, Associate Vice Chancellor for Research, w/o attachments Mr. Alexander Adams, U.S. NRC, w/o attachments Mr. Geoffrey A. Wertz, U.S. NRC, w/o attachments Mr. Johnny Eads, U.S. NRC, w/o attachments DONNA RATHKE Notary Public -Notary Seal State of Missouri Commissioned for Boone County My Commission Expires: August 15, 2017 Commission Number: 13515190~ "t,i CWOT,1j 8Er%?E ME Iý 01TAXI ThAKELIC.

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..9'I-DW& TGrkýOT'A" NEL-Ic-P -FE3 -Is'Mý Vommjc-ý)Op UNIVERSITY of MISSOURI RESEARCH REACTOR CENTER 10 CFR 2.390 AFFIDAVIT OF RALPH A. BUTLER AFFIDAVIT I, Ralph A. Butler, herby affirm and state as follows: (1) I am the Executive Director, of University of Missouri Research Reactor (MURR), and I have been authorized to execute this affidavit on behalf of MURR.(2) The information contained in Attachment 22 and Attachment 23 of the enclosed letter dated January 28, 2015 regarding Request for Additional Information is proprietary commercial information related to MURR becoming a domestic supplier of Iodine 131. The proprietary information includes sensitive business information created by or for MURR. This information should be held in confidence by the NRC and withheld from public disclosure.

(3) In making this application for withholding of proprietary information of which it is the owner, MURR believes that the information qualifies for withholding under the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Section 552(b)(4), the Trade Secrets Act, 18 U.S.C. Section 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.390(a)(4) for trade secrets and commercial information because: i. This information is and has been in confidence by MURR.ii. This information is of a type that is customarily held in confidence by MURR, and there is a rational basis for doing so because the information includes sensitive business information pertaining to how MURR will irradiate and process target material to create Iodine 131.iii. The information is being transmitted to the NRC voluntarily and in confidence.

iv. This information is not available in public sources and could not be gathered readily from other publicly available inf6rmation.

v. Public disclosure of this information would create substantial harm to the competitive position of MURR by disclosing certain business decisions MURR has made or is considering and the analysis that went behind those decisions.

Development and evaluation of this commercial information was achieved at, and disclosure could lead to additional, significant cost to MURR.vi. Public disclosure of the information sought to be withheld is likely to cause substantial harm to MURR'S competitive position and foreclose or reduce the availability of profit-making opportunities.

The value of the information goes beyond the disclosure of actual information pertaining to MURR's potential business, and includes substantial time and work towards developing the project, and represents significant efforts by MURR and its associates.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by MURR. The precise value of the information is difficult to quantify, but clearly is substantial.

1513 Research Park Drive Columbia, MO 65211 Phone: 573-882-4211 Fax: 573-882-6360 Web: www.murr.missouri.edu Fighting Cancer with Tomorrow's Technology vii. MURR's competitive advantage will be lost if its competitors are able to use the results of MURR's activities to aid their own commercial activities.

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

Ralph A. Butler Subscribed and sworn before me, a Notary Public, in and for the State of Missouri, this Lcday of 2015.Witness my hand and Notarial Seal.-.NOTAW'y0--

• -UX3. SEAm~MARGEE P. STOUT My Commission Expires March 24, 2016 Montgomery County Commission

1. 12511436 Notary Public My Commission Expires: _ _ _ _ _ _ _ _2PY//i /P Date Ab~qfUff~e3 AP-RO-I115 Revision 8 MODIFICATION RECORD: SHORT FORM FOR: I) Addenda to existing Modification Records (e.g., modifications of same nature as ones previously reviewed and approved).

2) Significant modifications to the facility or facility systems that are not described in the Hazards Summary Report.3) Modifications that require engineering decisions/implementation in a time frame that precludes normal licensed operator review prior to implementation.

4) Modifications to non-safety systems; for documentation and review only.Licensed operators will review these modifications as part of the Operator Requalification Program.The Reactor Safety Subcommittee will review these modifications.

Modification Number: 01-09; Add. 5 WA Modification Title: Emergency Electrical in MIB Eastward Expansion.F Number: 14-8008 By Page No.1 2 3 4 5 6 Page Title Modification Record: Short'Form Modification Description (Why Short Form is appropriate)

Hazards Summary Report Evaluation Reactor Safety Evaluation Procedure, PM, CP, and Print Evaluation Spare Parts Requirements Required Yes No__z_Date Completed 0111114/2061L 091/442NOV By (Initials) 34-5 Tt&50.59 Screen Completed:

AVOW ., 0,gst'.° Reactor Manager -En ineering)Reactor Safety Subcommittee Review: (geacto-rM ger)Modification Approved:

_(P/actor Manager)Modification Completed:

I A Z (Pleactor Manager)Modification Closed: c (Rjactor Manager)Date : .DC41f24VV Date: ) i-d Date: q- r-_t--_Date: k) -Ic (Date: 1_3 ____Attachment

8. I OiRIGINALj 6)ATOMNA 13 AP-RO-l 15 Revision 8 Modification Number: 01-09; Add. 5 REVIEW AND FOLLOW-UP ACTION Item No.1 2 3 4 5 6 Page Title Reactor Safety Subcommittee Review Operating Procedures Updated Preventive Maintenance Procedures Updated Compliance Procedures Updated MURR Prints Updated Spare Parts System Updated Required Yes No-7_ _ ___,,, V,-7 Date Completed w(q ,Z4 /IU 1016/114l 04 (%4/ILA Documented by (Initials)

.7",(,1T.T-¶_$Ia Attachment 8.1 O~RIGINAL AP-RO-l 15 01-0; Ad. 5Revision 8 Modification Number: 01-09; Add. 5 MODIFICATION DESCRIPTION Provide a concise description of the system change. Include any proposed PRE-OPERATIONAL TESTS required for this change. (If additional pages are necessary, insert after this page.)This Modification Record documents the addition of loads to the Emergency Electrical Power System in the MURR Industrial Building (MIB) Eastward Expansion.

The addition will provide one 120 volt circuits to the MIB Eastward Expansion for emergency power to emergency lighting.Modification Record 01-9, and its addenda document various changes to the Emergency Electrical System.The Emergency Electrical Power System is designed to provide emergency electrical power to key essential reactor components in order to monitor systems and assure personnel safety should the facility experience a loss of normal electrical power. The system includes an Emergency Diesel Generator (EDG), an Auto-transfer bus system, the Emergency Distribution Center (EDC), its various loads, panels, and low voltage sub-panels.

The Emergency Electrical Power System currently provides power to facility loads such as Exhaust Fans EF-13 and EF-14, the EDG Distribution Panel, exit and stairway lighting, Intercommunication System, Off-Gas Stack Monitor, specific reactor related loads through an Uninterruptible Power Supply (UPS), and others as described in the Hazards Summary Report and its addenda.This modification consists of adding one 120 V circuit to breaker 15 of the 120/208 panel"Diesel Room Distribution Panel" located in room 231E. The circuit will be used to provide emergency lighting for the various rooms within the MIB Eastward Expansion.

Why a Short Form is appropriate.(At least one of four reasons listed on Page I, with justification)

The short form Modification Record is appropriate because this is an Addendum to an existing Modification Record (Reason 1) and this is a modification to a non-safety system and requires documentation and review only (Reason 4).2 Attachment

8.1 ORIGINAL

ATftf4j 1 AP-RO-I115 Revision 8 Modification Number: 01-09; Add. 5 HAZARDS

SUMMARY

REPORT EVALUATION Does this change involve a modification to the reactor facility as defined in the Hazards Summary Report?Yes: X No: Signature:

Date: Z4,/I If YES, make an analysis below and provide the suggested revision(s) to the HSR. If NO, outline the basis for the decision.This modification does involve a change to the reactor facility as defined in the Hazards Summary Report and its addenda. The Emergency Electrical Power System is discussed in the following Sections and Figures of the Hazards Summary Report and its addenda: Original Hazards Summary Report: Section 7.1.4 Addendum 1: Figure 3.8.1 Addendum 3: Figures 2.3.a and 2.3.d Addendum 5: Section 2.4.1 and Figure 2.1 The following sections and figures of the HSR and its addenda will be revised as described below: Addendum 1: Section 3.8 Change to read-"3) Diesel Room Distribution Panel which provides power for the EG controls, emergency lighting, and selected receptacles." Addendum 3: Figures 2.3.a and 2.3.d-Revise Figure 2.3.d (MURR Print No. 522, Sheet 4 of 5) per the attached draft.All other sections, tables and figures of the HSR and its addenda are considered correct and will remain unchanged.

3 Attachment

8.1 ORIGINAL

ff~Iiff F 13 AP-RO-1 15 Revision 8 01-09; Add. 5 Modification Number: REACTOR SAFETY EVALUATION Does this change involve a revision(s) to the Technical Specifications or a question pursuant to 10 CFR 50.59?NOTE: A licensee may make changes to the facility as described in the HSR without obtaining a license amendment only if: (i) A change to the Technical Specifications incorporated in the license is not required, and (ii) The change does not produce any of the following results: I. More than a minimal increase in the frequency of occurrence of an accident previously evaluated in the HSR;2. More than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the HSR;3. More than a minimal increase in the consequences of an accident previously evaluated in the HSR;4. More than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the HSR;5. Create a possibility for an accident of a different type than previously evaluated in the HSR;6. Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the HSR;7. Altering or exceeding a design basis limit for a fission product barrier as described in the HSR, 8. A departure from a method of evaluation described in the HSR used in establishing the design bases or the safety analyses.Yes: No: Signature:

Date: 04/0q/201.

If YES, the change must be performed using a Long Form Modification Record. If NO, outline the basis for the decision.This modification does not involve a change to the Technical Specifications or a question pursuant to 10 CFR 50.59.The Emergency Electrical Power System is discussed in MURR Technical Specifications 3.10.a, 4.5, 5.6b, and 5.6c. This modification will not change these Technical Specifications.

A 50.59 screen (14-34) is attached and shows that the proposed activity can be implemented without further evaluation or a license amendment 4 O}RIGINAL Attachment

8. I ATTACHMENT 13APR-0 I coPy 50.59 SCREEN AP-RR-003 Revision 8 Page 1 of 2 Number: 14-34 Title: Undiflration Rprn~rrl 1A-0c) Adripnirili

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Description of Activity (what is bein% -' -*:__. 'I, Connect Emergency Electrical power connections for the MIB/BOB eastward expansion to the existing MURR Emergency Electrical Distribution System.Safety Determination:

Does the proposed activity have the potential to adversely affect nuclear safety or safe facility (i.e., MURR) operations?

D1 YES NO If this question is answered yes, do not continue with this procedure.

Identify and report the concern to the Reactor Manager.50.59 Screening Questions:

I. Does the proposed activity involve a change to an SSC that adversely affects a designfinction described in the JISR?2. Does the proposed activity involve a change to a procedure that adversely affects how HSR described SSC design functions are performed, controlled, or tested?3. Does the proposed activity involve revising or replacing an HSR described evaluation methodology that is used in establishing the design bases or used in the safety analyses?4. Does the proposed activity involve a test or experiment not described in the HSR, where an SSC is utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the HSR?5. Does the proposed activity require a change to the MURR Technical Specifications?

LI YES LI YES 11 YES 11 YES 11 YES NO NO NO NO NO If all screening questions are answered NO, then implement the activity per the applicable approved facility procedure(s).

A License Amendment or a 50.59 Evaluation is not required.If Screen Question 5 is answered YES, then request and receive a Licensew rti ,,hiuk pr:or to implementation of the activity.If Screen Question 5 is answered NO and Question 1, 2, 3, or 4 is answered YES, then complete and attach a 50.59 Evaluation form.[ Refer to Attachment 9.2. ]NOTE: If the conclusion of the screening questions is that a 50.59 Evaluation is not required, provide justification for the "No" determination.

In addition, list the documents (HSR, Technical Specifications, and other Licensing Basis documents) reviewed where relevant information was found. Include section / page numbers. Use Page 2 of this form to document your statements.

Print Name I .SignName Date Preparer:

Aric Luebbering

_1y Reviewer: Reactor Manager: John Fruits Submit copy of screen to HSR / SAR file (circle o~e)? Yes// No[I coPY Attachment

9. I ATTACHMENT 13 AP-RR-003 Revision 8 50.59 SCREEN (Cont.) , Number: 14-34 Page 2 of 2 Title: Modification Record 01-09, Addendum 5; Emergency Electrical In MIB Eastward Expansion If the conclusion of the five (5) Screening Questions is that a 50.59 Evaluation is not required, provide justification to support this determination:

[ Use and attach additional pages as necessary.

]I. Does the proposed activity involve a change to an SSC that adversely affects a design function described in the HSR?No. The connection of these new circuits to the electrical system will not involve changes to an SSC that could adversely affect a design function described in the HSR. The addition and utilization of these new circuits in the MIB Eastward Expansion is within the design function of the Emergency Electrical Distribution System and will not result in any electrical panel loading exceeding the 80% loading requirement.

These types of loads are specifically specified in the HSR for this system.2. Does the proposed activity involve a change to a procedure that adversely affects how HSR described SSC design functions are performed, controlled, or tested?No- The connection of these new circuits to the Emergency Electrical System will not involve any procedure changes related to HSR described SSC design functions.

These new circuits do affect any SSC design functions, and are wholly within the design function of that system. Reactor Emergency Procedures (REPs) related to electrical power loss and the Emer ency ElectricalAstem are unaffected by this change.3. Does the proposed activity involve revising or replacing an HSR described evaluation methodology that is used in establishing the design bases or used in the safety analyses?No. The connection of these new circuits to the Emergency Electrical System will not involve any HSR described evaluation methodology used for establishing design bases or used in safety analyses.

The safety analysis assumes a total loss of electrical power: an additional load to the system will not change this methodology.

These new circuits are not related to any design bases or safety analyses, and are within the design function of the Emergency Electrical System.4. Does the proposed activity involve a test or experiment not descrlova in dhe ti.oR where an SSC is used or controlled in a manner that is outside the reference bounds of the design for that SSC, or is inconsistent with analyses or descriptions presented in the HSR?No. The connection of these new circuits to the Emergency Electrical System will not involve any tests or experiments not described in the HSR. The scope of this Modification Record Addendum is only the connection of Emergency Electrical Power to the MIB Eastward Expansion and does not involve any tests or experiments.

List the documents (HSR, Technical Specifications, and other L reviewed where relevant information was found. [ Include section / page numbers.]HSR Section 7.1-4; HSR Addendum 1. Section 3R8 HSR Addendum 3, Section 2-4;HSR Addendum 5, Section 2.4 Technical Specifications 3.10, 4.5, 5.6 REP 9, 10, 11 MURR Print #522 (Sheet 1 of 5 and Sheet 4 of 5)jjf-j...:;

,/ Attachment

9.1 ATTACHMENT

13"-NIB Expansion Emergency Lighting Load fJcop', 8/1/14/2006 WP# 14-8008 MIB Expansion Emergenc" 1 2 Coine.tion to spare DG panel single pole 20A breaker #15 Based on the attached proposed MIB Expansion Emergency lighting load data and historical data for the DG emergency power panel, the activity described in WP#14-8008 is within the design specification of the DG panel and the electrical distribution system.WorkContlate 8a-/-a/Work Control Manager Grade Level -F32T8 Bulbs (3) three bulb fixtures @ .80 amps each totaling (3) four bulb fixtures @ 1.1 amps each totaling (1) two bulb fixtures @ .53 amps each totaling Grade level total lighting load Stairwell-F32T8 Bulbs (3) two bulb fixtures @ .53 amps each totaling Stairwell total lighting load Material Lift Shaft-F32T8 Bulbs (1) two bulb fixtures @ .53 amps each totaling Material Lift total lighting load Basement -F25T5 Bulbs (3) four bulb fixtures @ .83 amps each totaling Basement total lighting load (4) Exit Lights @ .031 amps each totaling Exit lights total loading Total Emergency Lighting Load 2.40 amps 3.3amps.53 amps 6.23 amps 1.59 amps 1.59 amp.53 amps.53 amps 2.49 amps 2.49 amps.U93 amps.093 amps 10.93 amps cc ATTACHMENT 13 0I/i 'f 0O (6919 LI SpoT7 LN4ý 7 f i-c -)v 0 Char, Page I of I Chart A 33-32-31".30 29-28.27?2f 2S, 24 23 22-21-2 1 1s 17 1 15 14 13 12 11 1 8 I Phase A>1 H m Z H 12/9/2003 12:.00:00' AM4 lZ/.0/Z003 12:.00:00 AM 12/3.1/2003

'12:00:00 Am4 1z/12/2003

'12:00:00 m ' Ul2 /ZOO' 1z:o00:00 Am. 12/1ý/2003'12:00:o00 Am 1 5/lso2001'12:00.0 RMS Current -IC 2-.l Start: 12/8/2003 8:57:25 AM End: 12/15/2003 2:56:55 AM Chart. Page 1 of 1 A Chart 6-Phase C m 12/9/2003 12:00:00 Am 12/10/2003 12:00:00 Am 12/.1/2003 12:00:00 Am 12/12/2003 12:00:00 Am 12/13/2003 12:00:00 Am 12/14/2003 12:00:00 AM 12/15/Z3 .3 :0 SrRMS Current .,=WA Ap cd 1. L .Start: 1218/2003 8:57:25 AM End: 12/15/2003 2:56:55 AM X < i~0~~ -

fT 13 AP-RO-1 15 Revision 8 Modification Number: 01-09; Add. 5 OPERATING, PREVENTATIVE MAINTENANCE, COMPLIANCE PROCEDURE AND PRINT EVALUATION Does this change require a revision(s),Io .any Operating, Preventati.ve..Maintenance, or Compliance Procedure, or any Print?Yes: X No: Signature:re:

Date: MLAL2.6tI4 If YES, provide the suggested revision(s).

OPERATING PROCEDURES:

No revisions required for this modification.

PREVENTIVE MAINTENANCE PROCEDURES:

No revisions required for this modification.

COMPLIANCE PROCEDURES:

No revisions required for this modification.

PRINTS: The following print will be revised per the attached draft revisions:

MURR Print No. 522 (4 of 5), "Electrical Distribution Reactor/Laboratory Panels -2" 5 O)RIGINAL Attachment

8.1 _____

_____ _,_.. ...._-_.

AT WOKWO AP-RO- I15I Modification Number: 01-09; Add. 5 SPARE PARTS REQUIREMENTS EVALUATION Does this change require that any new or additional Spare Parts be maintained in inventory?

Yes: No: X Signature:

.Date: #,.]If YES, provide a list of the spare parts There are no spare parts required for this modification.

U 6 Attachment 8.1 O)RIGINAL