ML19209D081

Notifies NRC That Union Carbide Corp May Be Affected by Upgrade Rule & That Facility May Fall Under Category I. Provides Estimated Economic Impact If Present Criteria Are Changed

ML19209D081
Person / Time
Site:	05000054
Issue date:	09/25/1979
From:	George K UNION CARBIDE CORP.
To:	John Miller Office of Nuclear Reactor Regulation
References
NUDOCS 7910190372
Download: ML19209D081 (2)

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@ UNION CARBIDE CORPORATION MEDICAL PRODUCTS DIVISION p.O. BO X 324, TUXEDO. N E W YO R K 10987 TELEPHONE: 914 351 2131 September 25, 1979 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Dr. James R. Miller Acting A/D for Sira and Safeguards Gentlemen:

By letter of August 15, 1979, we advised you that we did not believe we would be af fect3d by the Up3rade Rule, but we did give some estimates of the cost and impact of upgrading if our belief was incorrect. Our conclusion was based on c-iteria presently in effect, specifically the 100 R/hr at 3 ft. exemption. It now appears that the criteria are being examined and may be changed, with the distinct possibility that we may become subject to the Upgrade Ruie in the future as a Category I facility.

This possibility arises not only due to the use of highly-enriched uranium (HEU) in our reactor fuel elements but also due to th necessary use of HEU in the target material for producing medical radioisc opes.

The low-enriched uranium (LEU) program being conducted by"Argonne National Laboratory may eventually enable HEU fuel elements to be phased out and replaced by LEU ( < 20% U2 35) elements. This event is likely to take more than 5 years, however, due to the very high fuel density requirement of our reactor. The LEU test fuel presently being fabricated is suitable only for the lower power reactors. There will still, however, be a need for HEU material for use in isotope production targets, a recuirement based on chemical and biological considerations. ,

Conforming to the proposed Upgrade Rule would have the following estimated impacts:

a. Walls, fences, guard-houses and vaul ts would have to be constructed; alarm systems and protection hardware would have to be purchased. The est imated capi tal cost is approximately $1,000,000.

b. A guard force would have to be acquired and trained; operating man-power added for the 2-man rule; security plans and procedures modified and approved. Estimated cost is $50,000 (one-time) and $600,000 annually.

c. The cost of shutting down and decommissioning the facility is estimated as approximately $1,700,000.

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d. Loss of tFis facility would have a most serious effect on the delivery of health care (diagnostic and therapeutic nuclear medicine) in the United States and some foreign countries. This facility is the only domestic supplier of fission product 99Mo/93"Tc, the most widely-used radioisotope in diagnostic nuclear medicine, and of the 131 1 used in both diagnosis and therapy. While there are some foreign suppliers that may be able to replace some of tne loss, it would surely be dangerous to the health of citizens of the United States to place all reliance on such suppliers. It is a fact that our facility has, on a number of occasions, bailed out foreign suppliers when their facility had production problems.

e. The great cost of implementing the Upgrade Rule would mean, that to remain a viable commercial supplier of medical radioisotopes, we would have to pass the additional cost on to the medical consumer.

In such a competitive business, however, this action would almost guarantee that supply would soon pass to foreign producers.

f. Closing the reactor facility would also adversely impact the com-panion activity, production of radiodiagnostics, at this site and conceivably the entire Medical Products Division. The reactor and radiochemical production staff numbers about 65 and the radio-diagnostics staff comprises an additional 32 people. At this site alone a total of about 200 people could be affected.

With the present criteria, viz. formula quanti ty of HEU = 5 kg and exempt radiation level = 100 R/hr at 3 f t., we are able to operate and be a viable commercial supplier of medical radioisotopes without conforming to ,the Upgrade Rule. Should either of these criteria change adversely, we could not.

Very tru ly yours ,

Georg Senior Development Scientist KDG:cas cc: R. E. Bollinger D. B. Hol:graf J. J. McGovern i175 227