ML19254E891

Comments on Proposed Rules 10CFR70 & 73:high Cost of Complying W/Upgrade Rule Would Interrupt Commercial Supply & Adversely Affect Health Care Industry.Criteria for Application Should Exempt Vendor

ML19254E891
Person / Time
Site:	05000054
Issue date:	09/26/1979
From:	George K UNION CARBIDE CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-43FR35321, RULE-PR-70, RULE-PR-73 NUDOCS 7911050018
Download: ML19254E891 (1)

Text

.

EUBL[g Mcug

'--~ ~

UNION CARBIDE CORPORATION _ 'D ll u f

" MEDICAL PQODUCTS OlV!SION

/. s o 322 sss: ,~snveox m s?

? 6.E bac N E - Die 33i 2131

1. M EC rm Septemb=r 26, 1979 s

~N:a:, ,-

LMED ?ULE -

0 MDN , j  %'g lw,Y ../ n ,;: u\

Secretary of the Cct.vaission  !*4 g U.S. Nuclear Regulatory Commission A . -- ' 'C73 D.q Wasnington, D.C. 20535 P D

O' . ,, y

m .... , :co os Gentlemen: Y4 s/

1. 1. • M Re:

Imoact or Uccrade Rule

'rst i 1 J

If this facility were to ceccme subject to the proposed Upgrade Rule, for example by removing the exemption for "self protocted" irradiated fuel, the impact on the delivery of health care to the citizens of tne United States would be adverse and serious. This impact, at worst, would be an interruption in the commercial supply of the radioisotope most widely-used in diagnostic nuclear medicine, or at best an eventual dependence on foreign sources for its supply. This follows from the high monetary cost of ccmplying with Upgrade.

This research reactor facility, the Union Carbide Nuclear Reactor (License R-81) located near Tuxedo, New York, produces radioi sotopes for use in diagnostic and thertpeutic nuclear medicine. It is the only domestic commercial producer of radioicdine-131 and of the most widely-used diagnostic isotope in nuclear medicine, fission-product molybdenum-99/ technetium-99m. At least 10 million diagnostic precedures, mainly related to detection of cancer, are performed each year in the United States using the latter short-lived radioisotope. Interruption of its supply would have a serious effect on medical care.

Fission product radioisotopes are produced f rom high-enrichee uranium (HEU) targets by irradiating these in the reactor and then processing then in the associated hot cells. The reactor itself also uses HEU in its fuel elements. Under the current criteria, this facility, comprising the reactor and processing cells, is exemot f rem the pro-pesed Rule by virtue of the high radiation level that is maintained in irradiated produc:s and fuel. Unieradia:ed HEU is stric:ly l imi ted to 5 kilograms. An uoward change in the radiatien level recuired for fuel to :;ual i ty as "self-protected" could, however, e.::'ose the f acili ty to the stringent safeguarcs of the Rule.

While it is possible tha :ne reac:or fuel elements may eventually be replaced by low-enriched fuel elements (LEU), this recuices successful -

conclusion of a cevelocment program uncerway a: Argonne Naticnal Laboratory, which is excected to take at least 'ive years. Even if our reactor fuel were successfully enanged :o LEU, it wculd still be necessary for chemical anc biological reasons to use iEU for tne target material. The total target inventory, typically 13 kg, could

~

P00R DUM 2 911 o s oe 1265 MD

September 26, 1979 -

Page Two - -

____r not be usefully reduced wi thout increasing the frequency of offsite shipmen:s of irradiated waste HEU target material, an uncesirable alternative from a public safety viewcoint.

To comply wi th the proposed Ru le a t this f acility .4ould require the expenaiture of over 31,000,000 for construction ano equipment, anc over $600,000 per year for operation. A posi tion comeeti tive wi th potential foreign supoliers coulc not be mainta'nec witn such large added costs.

It is urged that, in the interest of reliable medical care for the public, the criteria for application of the Upgrace Rule be sucn that this facility is exemp;ea from its provisions.

Very truly yours, b.b-:

K. Ot George Senior _ elopment Scientist KDG/smf m

i L t l .) 'u !

~

?00R ORl8EL