ML15034A473

University of Missouri-Columbia Research Reactor Response to NRC Request for Additional Information Re License Renewal Application

ML15034A473
Person / Time
Site:	University of Missouri-Columbia
Issue date:	01/28/2015
From:	Butler R A Univ of Missouri - Columbia
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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UNIVERSITY of MISSOURIRESEARCH REACTOR CENTERJanuary 28, 2015U.S. Nuclear Regulatory CommissionAttention: Document Control DeskMail Station P1-37Washington, DC 20555-0001

Reference:

Docket 50-186University of Missouri-Columbia Research ReactorAmended Facility License No. R-103Enclosed you will find the University of Missouri-Columbia Research Reactor's (MURR) responses tothe U.S. Nuclear Regulatory Commission's (NRC) request for additional information, dated December 3,2014, regarding our renewal request for Amended Facility Operating License No. R-103, which wassubmitted to the NRC on August 31, 2006, as supplemented. Additionally, we request that you withholdAttachments 22 and 23, Project RL-76, "Production of 1-131 Radiochemical Sodium Iodide Solution,"and 50.59 Screen No. 12-07, "Iodine-131 Processing Laboratory," respectively, from public disclosureper 10 CFR 2.390. Attached is the affidavit, dated January 27, 2015, which explains the reasoning forthis request. The Attachments are clearly labeled "Withhold from Public Disclosure Under 10 CFR2.390."If you have any questions regarding the responses, please contact John L. Fruits, the facility ReactorManager, at (573) 882-5319 or FruitsJ@missouri.edu.Sincerely,Ralph A. Butler, P.E.DirectorRAB/jlbEnclosures01513 Research Park Drive Columbia, MO 65211 Phone: 573-882-4211 Fax: 573-882-6360 Web: www.murr.missouri.eduFighting Cancer with Tomorrow's Technology UNWVERSITY 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 pertainiii. 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 information.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.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 information01513 Research Park Drive Columbia, MO 65211 Phone: 573-882-4211 Fax: 573-882-6360 Web: www.murr.missouri.eduFighting Cancer with Tomorrow's Technology to 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 7 dayof SA QQAK>I 2015.Witness my hand and Notarial Seal.Notary PublicMy Commission Expires: 21 AU -IDONNA RATHKE 'DateNotary Public -Notary SealState of MissouriCommissioned for Boone CountyMy Commission Expires: August 15, 2017Commission Number: 13515190