ML19276H012

Responds to 790730 Ltr.Safeguards Upgrade Rule Will Not Have Significant Impact on Facility Operation

ML19276H012
Person / Time
Site:	05000054
Issue date:	08/15/1979
From:	George K UNION CARBIDE CORP.
To:	John Miller Office of Nuclear Reactor Regulation
References
NUDOCS 7908310333
Download: ML19276H012 (2)

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UNION CARBIDE CORPORATION MEDICAL PRODUCTS DIVISION P.O. so x 324, TUXEDO, NEW YO RK 10987 TELEPHONE: 91&351 2131 August 15, 1979 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Dr. James R. Miller Acting A/D for Site and Safeguards Gentlemen:

Your letter, dated July 30, 1979, supplied information on the forthcoming Safeguards Upgrade Rule and requested data on the impact of this rule at this facility.

We have reviewed the material supplied and have also consulted with your staff in attempting to determine the applicability of the rule at our facility. We have concluded, to the best of our ability, that the Upgrade Rule will not have a significant impact on our facility operation. The basis of this conclusion is given below.

Our facility utilizes a research-type reactor that is operated at 5-megawatts on a 98% duty cycle. One of the principal uses of the reactor is to irradiate U-235 material in the form of targets for the production of medical radioisotopes. Both the reactor fuel and the U-235 target material are enriched to 93% in the U-235 isotope, and thus are strategic special nuclear material (SSNM).

Through our current licenses, R-81 for the reactor and SNM-639 for the target material, we are required to keep the combined quantity of unirradiated SSNM less than 5000 grams. The balance of the total authorized SSNM is in the form of irradiated fuel elements and target material in the reactor core or stored underwater and having an unshielded radiation level in excess of 100 rem /hr at 3 feet, or as irradiated target material situated in the hot cells. Protection of all SSNM, whether in the reactor or the hot cells, is as described in the approved reactor security plan.

It is our understanding that the Upgrade Rule is not intended to apply to facilities that have less than a formula quantity of un-self-protected SSNM. It is also our understanding that Part 73.50,

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- . Page Two August 15, 1979 which as [ow revised, applies the Upgrade Rule to formula quantities of self-protected SSNM, does not apply to the self-protected SSNM located and used at our nuclear reactor f acility, even though this SSNM is authorized under two distinct licenses.

In the event that our conclusion is incorrect, or if subsequent changes are made to the Upgrade Rule that would require us to institute the protection measures called for in (for example) 73.45 and 73.46, the impact on our operations would be prci.ound and would require an assessment of whether the added expense would justify continued operation. We estimate, for example, that if the Upgrade Rule were applied to our facility, the added expense for equipment and facility modifications would be cre million dollars and the added operation cost would be one-half million dollars per year. The current operating cost of our reactor facility is 800,000 dollars per year. In this connection, it should be pointed out that this facility is the only domestic producer of the fission-product 99Mo and the 131I used by the medical profession in the United States.

Should you require additional information at short notice, please call the undersigned at 914-351-2131.

Very truly yours,

, k  %

. . orge (

Senior Development Scientist KDG/smf

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