ML17292A052

University of Missouri-Columbia Research Reactor - Supplemental Information in Support of May 3, 2017 Request to Amend Technical Specifications

ML17292A052
Person / Time
Site:	University of Missouri-Columbia
Issue date:	10/17/2017
From:	Rhonda Butler, Meffert B Univ of Missouri - Columbia
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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ML17292A049	List: ML17292A052 ML17292A053
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Download: ML17292A052 (5)

Text

UNIVERSITY of MISSOURI RESEARCH REACTOR CENTER October 17, 2017 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station Pl-37 Washington, DC 20555-0001

REFERENCE:

Docket No. 50-186 University of Missouri-Columbia Research Reactor Renewed Facility Operating License No. R-103

SUBJECT:

Supplemental information in support of the request to amend the University ofMissouri-Columbia Research Reactor Technical Specifications, which are appended to Renewed Facility Operating License No. R-103, pursuant to 10 CPR § 50.59(c) and 10 CPR § 50.90, as submitted to the U.S. Nuclear Regulatory Commission by letter dated May 3, 2017 By letter dated May 3, 2017, the University of Missouri Research Reactor (MURR) submitted a license amendment request (LAR) to the U.S.* Nuclear Regulatory Commission (NRC) in order to conduct an experiment that would produce molybdenum-99 (Mo-99) in large quantities as part of its role in supplying critical medical radioisotopes to the domestic and international community. The experiment would utilize General Atomics' (GA) Selective Gas Extraction (SGE) process, which consists of irradiating target rods containing low-enriched uranium (LEU) pellets in the reactor graphite reflector region in order to produce fission product Mo-99. The Mo-99 would then be extracted from the LEU in dedicated hot cells using the SGE technology.

By letter dated June 19, 2017, MURR submitted two (2) attachments of additional technical information to supplement the May 3, 2017, submittal to further assist the NRC in review of the LAR, specifically GA Design Report No. 30441R00038, "Computational Fluid Dynamics Analysis of Target Housing Design Calculation Report," and GA Design Report No. 30441R00041, "Critical Heat Flux Testing at the University of Wisconsin Final Report," Attachments 9 and 10, respectively.

Enclosed are two (2) versions of an attachment (Attachment 11 to the LAR) of additional technical information to supplement the May 3, 2017, submittal to further assist the NRC in review of the LAR, specifically GA Design Report No. 30441R00045, "Target Cooling System Flow Test Report. One version of the attachment contains proprietary information, and we request that you withhold it from public disclosure per 10 CFR § 2.390. This document is clearly labeled "Withhold from Public Disclosure Under 10 CPR 2.390." The other attachment is a redacted version that can be disclosed to the public. Also 1513 Research Park Drive Columbia, MO 65211 Phone: 573-882-4211 Fax: 573-882-6360 Web: http://web.missouri.edu/-murrwww Fighting Cancer with Tomorrow's Technology

attached is the affidavit (executed by Christina A. Back), dated October 13, 2017, which explains the reasoning for the request.

If there are any questions regarding this letter, please contact me at (573) 882-5118 or MeffertB@missouri.edu. I declare under penalty of perjury that the foregoing is true and correct.

ENDORSEMENT:

Sincerely, Reviewed and Approved

~~

Bruce A. Meffert

£22~

Ralph A. Butler, P.E.

Reactor Manager Director xc: Reactor Advisory Committee Reactor Safety Subcommittee Isotope Use Subcommittee Dr. Mark Mcintosh, Vice Chancellor for Research, Graduate Studies and Economic Development Mr. Alexander Adams, U.S. Nuclear Regulatory Commission Mr. Geoffrey Wertz, U.S. Nuclear Regulatory Commission Mr. Johnny Eads, U.S. Nuclear Regulatory Commission

Enclosures:

a. General Atomics Affidavit of Christina A. Back, dated October 13, 2017

b. Attachment 11 -GA Design Report No. 30441R00045, "Target Cooling System Flow Test Report"

- Redacted Version

c. Attachment 11 -GA Design Report No. 30441R00045, "Target Cooling System Flow Test Report"

- Un-redacted Version

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+ t:/SN/SRAL .ll'TOll/lleS ANO IU=J!#l&IA'nlO aJMPIUlllGS GENERAL ATOMICS AFFIDAVIT OF CHRISTINA A. BACK I, Christina A. Back, Vice President of Nuclear Technologies and Materials, General Atomics, do hereby affirm and state:

(1) I have been delegated the function of reviewing information described in paragraph 3 which General Atomics requests be withheld from public disclosure or publication and I am authorized to execute this affidavit on behalf of General Atomics.

(2) The affidavit is submitted under the provisions of 10CFR Part 2.390 to withhold documents containing confidential commercial and proprietary information (as set forth in paragraph 3 following) of General Atomics from public disclosure or publication.

I (3) General Atomics (GA) has part_nered with The University of Missouri Research Reactor (MURR) and Nordlon to develop the Reactor-Based Mo-99 Supply System (RB-MSS)

Project using its Selective Gas Extraction process. The Information sought to be withheld is related to the analysis, design, development and licensing of General Atomics' technology for deployment at MURR.

This Information Is contained in the following documents submitted as supporting information for MURR's "License Amendment Request to Implement Selective Gas Extraction Target Experimental Facility at the University of Missouri Research Reactor."

License Amendment Request TITLE Attachment No.

GA Report 30441 R00045: Target Cooling System Flow Test 11 Report" Nonproprietary redacted versions of these documents are being simultaneously provided where the proprietary information on each page has been appropriately redacted.

(4) In making this application for withholding of proprietary information of which it is the owner, General Atomics relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10CFR Part 9.17(a)(4), a2.390(a)(4), and 10CFR2.390(b) for "trade secrets and commercial or financial Information obtained from a person and privileged or confidential." The material for which exemption from disclosure is hereby sought Is all "confidential commercial information," and/or also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 In, respectively, Critical Mass Energv 3550 OENERALATOMICS COURT.SAN DIEGO, CA 92121-112;! PO BOX 95608, SAN DIEGO, CA 92186-5608 (658) 455-3000

Project v. Nuclear Regulatory Commission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA. 704F2d1280 (DC Cir. 1983).

(5) Pursuant to Paragraph (4) above, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Atomics' competitors without license from General Atomics constitutes a competitive economic advantage over oth_er companies;

b. Information which, If used by ,a competitor, would reduce his or her expenditure of resources or improve his or her competitive position in the design, manufacture, shipment, installation, assurance or quality, or licensing of a similar product.

c. Information which discloses patentable subject matter for which It may be desirable to obtain patent protection.

d. The information sought to be withheld is being submitted to the NRG in confidence.

The Information is of a sort customarily held in confidence by General Atomics,,and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held In confidence by General Atomics. No public disclosure has been made, and it is not available In public sources.

e. The Information classified as proprietary was developed and compiled by General Atomics at a significant cost to General Atomics. This Information is classified as proprietary because It contains detailed data and analytical results not available elsewhere. This information would provide other parties, Including competitors, with information from General Atomics technical database and the results of evaluations performed by General Atomics. Release of this information would improve a competitor's position without the competitor having to expend similar resources for the development of the database. A significant effort has been expended by General Atomics to develop this Information.

f. The research, development, engineering, and analytical costs associated with General Atomics' unique selective gas extraction system and process comprise a substantial investment of time and resources by General Atomics, whose precise value Is difficult to quantify, but clearly is substantial and extends beyond the original development cost. Public disclosure of the information sought to be withheld is likely to cause substantial harm to General Atomics' competitive position.

GENERAL ATOMICS Christina A. Back Vice President, Nuclear Technologies and Materials A notary publlc or other officer completing this certificate verifies only the Identity of the individual who signed the document to which this certificate Is attached, and not the truthfulness, accuracy, or validity of that document.

State of Callfornla County of San Diego On D~ r3., 9211 before me, Brenda B. Dawson, Notary Public, personally appeared Christina A. Back, who proved to me on the basis of satisfactory evidence to be the person whose name Is subscribed to the within Instrument and acknowledged to me that he executed the same in his authorized capacity, and by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph Is true and correct.

WITNESS my hand and official seal.

~~.~s>v-:1 (Signature of Notary)