ML15049A039
| 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 MISSOURIRESEARCH REACTOR CENTERFebruary 12, 2015U.S. Nuclear Regulatory CommissionAttention: Document Control DeskMail Station P1-37Washington, DC 20555-0001REFERENCE: Docket 50-186University of Missouri-Columbia Research ReactorAmended Facility License R-103SUBJECT: Written communication as specified by 10 CFR 50.4(b)(1) regarding the response tothe "University of Missouri at Columbia -Request for Additional InformationRegarding the Renewal of Facility Operating License No. R- 103 for the University ofMissouri at Columbia Research Reactor (TAC No. ME 1580)," dated December.3, 2014On August 31, 2006, the University of Missouri-Columbia Research Reactor (MURR) submitted arequest to the U.S. Nuclear Regulatory Commission (NRC) to renew Amended Facility OperatingLicense No. R- 103.On December 3, 2014, as part of the NRC staff's review of the renewal request, the NRC requestedadditional information in the form of two (2) questions. By letter dated January 28, 2015, -HMURRresponded to those two questions.Attached are the following two items:1. "10 CFR 2.390 Affidavit of Ralph A. Butler," dated February 12., 2015; and2. Attachment 13: Modification Record 01-09, Addendum 5; "Emergency Electrical in AfIBEastward 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 EastwardExpansion," replaces the attachment that was submitted on January 28, 2015. It was incorrectly iabeledas Attachment 14.If there are questions regarding this response, please ..contact me at (573) 882-5319 orFruitsJ@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.eduFighting Cancer with Tomorrow's Technology Sincerely,John L. FruitsReactor ManagerReviewed and Approved,Ralph A. Butler, P.E.DirectorEnclosed:1. "10 CFR 2.390 Affidavit of Ralph A. Butler," dated February 12, 20152. Attachment 13: Modification Record 01-09, Addendum 5; "Emergency Electrical in MIBEastward Expansion"xc: Reactor Advisory Committee, w/o attachmentsReactor Safety Subcommittee, w/o attachmentsDr. Kenneth Dean, Interim Provost, w/o attachmentsDr. Robert Hall, Associate Vice Chancellor for Research, w/o attachmentsMr. Alexander Adams, U.S. NRC, w/o attachmentsMr. Geoffrey A. Wertz, U.S. NRC, w/o attachmentsMr. Johnny Eads, U.S. NRC, w/o attachmentsDONNA RATHKENotary Public -Notary SealState of MissouriCommissioned for Boone CountyMy Commission Expires: August 15, 2017Commission Number: 13515190~ "t,i CWOT,1j 8Er%?E ME Iý 01TAXI ThAKELIC. i',J A13D FOTLTI--r,, vT/-:f_ or , l'-mu 1a.w"t/A1 OýT-egm-umn/q )l'WITl--css Mj J H-Ob ýO'fq-Y-ILSbu ..9'I-DW& TGrkýOT'A" NEL-Ic-P -FE3 -Is'Mý Vommjc-ý)Op UNIVERSITY of MISSOURIRESEARCH REACTOR CENTER10 CFR 2.390 AFFIDAVIT OF RALPH A. BUTLERAFFIDAVITI, 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 beenauthorized to execute this affidavit on behalf of MURR.(2) The information contained in Attachment 22 and Attachment 23 of the enclosed letter datedJanuary 28, 2015 regarding Request for Additional Information is proprietary commercialinformation related to MURR becoming a domestic supplier of Iodine 131. The proprietaryinformation includes sensitive business information created by or for MURR. This informationshould 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 fromdisclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Section 552(b)(4), theTrade 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 thereis a rational basis for doing so because the information includes sensitive businessinformation pertaining to how MURR will irradiate and process target material to createIodine 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 readilyfrom other publicly available inf6rmation.v. Public disclosure of this information would create substantial harm to the competitiveposition of MURR by disclosing certain business decisions MURR has made or isconsidering and the analysis that went behind those decisions. Development andevaluation of this commercial information was achieved at, and disclosure could lead toadditional, significant cost to MURR.vi. Public disclosure of the information sought to be withheld is likely to cause substantialharm 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 actualinformation pertaining to MURR's potential business, and includes substantial time andwork towards developing the project, and represents significant efforts by MURR and itsassociates. The research, development, engineering, and analytical costs comprise asubstantial investment of time and money by MURR. The precise value of theinformation 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.eduFighting Cancer with Tomorrow's Technology vii. MURR's competitive advantage will be lost if its competitors are able to use the resultsof MURR's activities to aid their own commercial activities. The value of this informationto MURR would be lost if the information were disclosed to the public. Making suchinformation available to other entities without their having been required to undertakea similar expenditure of resources would unfairly provide competitors with a windfall,and deprive MURR of the opportunity to exercise its competitive advantage to seek anadequate return on its large investment.Ralph A. ButlerSubscribed and sworn before me, a Notary Public, in and for the State of Missouri, this Lcdayof 2015.Witness my hand and Notarial Seal.-.NOTAW'y0--*-UX3. SEAm~MARGEE P. STOUTMy Commission ExpiresMarch 24, 2016Montgomery CountyCommission #12511436Notary PublicMy Commission Expires: _ _ _ _ _ _ _ _2PY//i /P Date Ab~qfUff~e3AP-RO-I115Revision 8MODIFICATION RECORD: SHORT FORMFOR: I) Addenda to existing Modification Records (e.g., modifications of same nature as onespreviously reviewed and approved).2) Significant modifications to the facility or facility systems that are not described in theHazards Summary Report.3) Modifications that require engineering decisions/implementation in a time frame thatprecludes 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 OperatorRequalification Program.The Reactor Safety Subcommittee will review these modifications.Modification Number: 01-09; Add. 5 WAModification Title: Emergency Electrical in MIB Eastward Expansion.F Number: 14-8008ByPage No.123456Page TitleModification Record: Short'FormModification Description(Why Short Form is appropriate)Hazards Summary Report EvaluationReactor Safety EvaluationProcedure, PM, CP, and Print EvaluationSpare Parts RequirementsRequiredYes No__z_DateCompleted0111114/2061L091/442NOVBy(Initials)34-5Tt&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 : .DC41f24VVDate: ) i-dDate: q- r-_t--_Date: k) -Ic (Date: 1_3 ____Attachment 8. IOiRIGINALj 6)ATOMNA 13AP-RO-l 15Revision 8Modification Number: 01-09; Add. 5REVIEW AND FOLLOW-UP ACTIONItem No.123456Page TitleReactor Safety Subcommittee ReviewOperating Procedures UpdatedPreventive MaintenanceProcedures UpdatedCompliance Procedures UpdatedMURR Prints UpdatedSpare Parts System UpdatedRequiredYes No-7_ _ ___,,,V,-7DateCompletedw(q ,Z4 /IU1016/114l04 (%4/ILADocumented by(Initials).7",(,1T.T-¶_$IaAttachment 8.1O~RIGINAL AP-RO-l 1501-0; Ad. 5Revision 8Modification Number: 01-09; Add. 5MODIFICATION DESCRIPTIONProvide a concise description of the system change. Include any proposed PRE-OPERATIONAL TESTS required for this change. (If additional pages are necessary, insert afterthis page.)This Modification Record documents the addition of loads to the Emergency ElectricalPower System in the MURR Industrial Building (MIB) Eastward Expansion. The addition willprovide one 120 volt circuits to the MIB Eastward Expansion for emergency power toemergency lighting.Modification Record 01-9, and its addenda document various changes to the EmergencyElectrical System.The Emergency Electrical Power System is designed to provide emergency electrical powerto key essential reactor components in order to monitor systems and assure personnelsafety should the facility experience a loss of normal electrical power. The system includesan Emergency Diesel Generator (EDG), an Auto-transfer bus system, the EmergencyDistribution Center (EDC), its various loads, panels, and low voltage sub-panels.The Emergency Electrical Power System currently provides power to facility loads such asExhaust Fans EF-13 and EF-14, the EDG Distribution Panel, exit and stairway lighting,Intercommunication System, Off-Gas Stack Monitor, specific reactor related loads throughan Uninterruptible Power Supply (UPS), and others as described in the Hazards SummaryReport 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 provideemergency 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 anexisting Modification Record (Reason 1) and this is a modification to a non-safety systemand requires documentation and review only (Reason 4).2 Attachment 8.1ORIGINAL ATftf4j 1AP-RO-I115Revision 8Modification Number: 01-09; Add. 5HAZARDS SUMMARY REPORT EVALUATIONDoes this change involve a modification to the reactor facility as defined in the Hazards SummaryReport?Yes: X No:Signature:Date: Z4,/I If YES, make an analysis below and provide the suggested revision(s) to the HSR. If NO, outlinethe basis for the decision.This modification does involve a change to the reactor facility as defined in the HazardsSummary Report and its addenda. The Emergency Electrical Power System is discussed inthe following Sections and Figures of the Hazards Summary Report and its addenda:Original Hazards Summary Report: Section 7.1.4Addendum 1: Figure 3.8.1Addendum 3: Figures 2.3.a and 2.3.dAddendum 5: Section 2.4.1 and Figure 2.1The following sections and figures of the HSR and its addenda will be revised as describedbelow: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 andwill remain unchanged.3Attachment 8.1ORIGINAL ff~Iiff F 13AP-RO-1 15Revision 801-09; Add. 5Modification Number:REACTOR SAFETY EVALUATIONDoes this change involve a revision(s) to the Technical Specifications or a question pursuant to10 CFR 50.59?NOTE: A licensee may make changes to the facility as described in the HSR without obtaining a license amendmentonly 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 inthe HSR;2. More than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important tosafety 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 safetypreviously 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 anypreviously 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 orthe 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 thebasis for the decision.This modification does not involve a change to the Technical Specifications or a questionpursuant to 10 CFR 50.59.The Emergency Electrical Power System is discussed in MURR Technical Specifications3.10.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 implementedwithout further evaluation or a license amendment4O}RIGINALAttachment 8. I ATTACHMENT 13APR-0I coPy50.59 SCREENAP-RR-003Revision 8Page 1 of 2Number: 14-34Title: Undiflration Rprn~rrl 1A-0c) Adripnirili .5 Fmp-rqenrcV Fler~trirsaI In MIR Fn-,twrr F~ronn-nnn-... "d-' -J.:.......Description of Activity (what is bein% -' -*:__. 'I,Connect Emergency Electrical power connections for the MIB/BOB eastward expansion to theexisting 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?D1YESNOIf 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 designfinctiondescribed in the JISR?2. Does the proposed activity involve a change to a procedure that adversely affects how HSRdescribed SSC design functions are performed, controlled, or tested?3. Does the proposed activity involve revising or replacing an HSR described evaluation methodologythat 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 isutilized or controlled in a manner that is outside the reference bounds of the design for that SSC oris inconsistent with analyses or descriptions in the HSR?5. Does the proposed activity require a change to the MURR Technical Specifications?LIYESLIYES11YES11YES11YESNONONONONOIf all screening questions are answered NO, then implement the activity per the applicable approved facility procedure(s). A LicenseAmendment 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 whererelevant information was found. Include section / page numbers. Use Page 2 of this form to document your statements.Print Name I .SignName DatePreparer: Aric Luebbering _1yReviewer:Reactor Manager: John FruitsSubmit copy of screen to HSR / SAR file (circle o~e)? Yes// No[I coPYAttachment 9. I ATTACHMENT 13AP-RR-003Revision 850.59 SCREEN (Cont.) ,Number: 14-34 Page 2 of 2Title: Modification Record 01-09, Addendum 5; Emergency Electrical In MIB Eastward ExpansionIf the conclusion of the five (5) Screening Questions is that a 50.59 Evaluation is not required, providejustification 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 theHSR?No. The connection of these new circuits to the electrical system will not involve changes to an SSC thatcould adversely affect a design function described in the HSR. The addition and utilization of these newcircuits in the MIB Eastward Expansion is within the design function of the Emergency ElectricalDistribution System and will not result in any electrical panel loading exceeding the 80% loadingrequirement. 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 designfunctions are performed, controlled, or tested?No- The connection of these new circuits to the Emergency Electrical System will not involve anyprocedure changes related to HSR described SSC design functions. These new circuits do affect anySSC design functions, and are wholly within the design function of that system. Reactor EmergencyProcedures (REPs) related to electrical power loss and the Emer ency ElectricalAstem are unaffectedby this change.3. Does the proposed activity involve revising or replacing an HSR described evaluation methodology that is used inestablishing 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 HSRdescribed evaluation methodology used for establishing design bases or used in safety analyses. Thesafety analysis assumes a total loss of electrical power: an additional load to the system will not changethis methodology. These new circuits are not related to any design bases or safety analyses, and arewithin 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 controlledin a manner that is outside the reference bounds of the design for that SSC, or is inconsistent with analyses ordescriptions presented in the HSR?No. The connection of these new circuits to the Emergency Electrical System will not involve anytests or experiments not described in the HSR. The scope of this Modification Record Addendum isonly the connection of Emergency Electrical Power to the MIB Eastward Expansion and does notinvolve any tests or experiments.List the documents (HSR, Technical Specifications, and other L reviewed whererelevant 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 2.4Technical Specifications 3.10, 4.5, 5.6REP 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 LoadfJcop',8/1/14/2006WP# 14-8008MIB Expansion Emergenc" 1 2 Coine.tion to spare DG panel single pole 20A breaker #15Based on the attached proposed MIB Expansion Emergency lighting load data and historical datafor the DG emergency power panel, the activity described in WP#14-8008 is within the designspecification of the DG panel and the electrical distribution system.WorkContlate 8a-/-a/Work Control ManagerGrade 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 totalingGrade level total lighting loadStairwell-F32T8 Bulbs(3) two bulb fixtures @ .53 amps each totalingStairwell total lighting loadMaterial Lift Shaft-F32T8 Bulbs(1) two bulb fixtures @ .53 amps each totalingMaterial Lift total lighting loadBasement -F25T5 Bulbs(3) four bulb fixtures @ .83 amps each totalingBasement total lighting load(4) Exit Lights @ .031 amps each totalingExit lights total loadingTotal Emergency Lighting Load2.40 amps3.3amps.53 amps6.23 amps1.59 amps1.59 amp.53 amps.53 amps2.49 amps2.49 amps.U93 amps.093 amps10.93 ampscc ATTACHMENT 130I/i 'f0O(6919LISpoT7LN4ý 7 f i-c -)v0 Char,Page I of IChartA33-32-31".3029-28.27?2f2S,242322-21-211s171151413121118IPhase A>1HmZH12/9/2003 12:.00:00' AM4lZ/.0/Z003 12:.00:00 AM12/3.1/2003 '12:00:00 Am41z/12/2003 '12:00:00 m ' Ul2 /ZOO' 1z:o00:00 Am. 12/1ý/2003'12:00:o00 Am 1 5/lso2001'12:00.0RMS Current -IC2-.lStart: 12/8/2003 8:57:25 AM End: 12/15/2003 2:56:55 AM Chart. Page 1 of 1A Chart6-Phase C m12/9/2003 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 :0SrRMS 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 13AP-RO-1 15Revision 8Modification Number: 01-09; Add. 5OPERATING, PREVENTATIVE MAINTENANCE, COMPLIANCE PROCEDUREAND PRINT EVALUATIONDoes this change require a revision(s),Io .any Operating, Preventati.ve..Maintenance, or ComplianceProcedure, or any Print?Yes: X No:Signature:re:Date: MLAL2.6tI4If 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"5O)RIGINALAttachment 8.1
_____ _____ _,_.. ...._-_.
AT WOKWOAP-RO- I15IModification Number: 01-09; Add. 5SPARE PARTS REQUIREMENTS EVALUATIONDoes 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 partsThere are no spare parts required for this modification.U6Attachment 8.1O)RIGINAL