ML20148J829

Forwards Ltrs Re Appl of 10CFR73.50 Requirements to Co'S Site Whenever Total U-235 in Unirradiated Fuel Elements & in Irradiated & Unirradiated Target Matl Exceeds 5,000 & Notes Inapplicability to Facil.Proprietary Info W/Held

ML20148J829
Person / Time
Site:	05000054
Issue date:	11/10/1978
From:	Voth M UNION CARBIDE CORP.
To:	Stello V Office of Nuclear Reactor Regulation
References
NUDOCS 7811160147
Download: ML20148J829 (1)

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a ,. .i UNION CARBIDE CORPORATION  !

P.O. BOX 324, TUXEDO, NEW YORK 10987 TELEPHONE 914 351 2131 CO RPO R ATE RESEARCH LABORATORY oveder 10, 1970 4

Mr. Victor Stello', Jr., Director Division of Operating 1 Reactors U. S. Nuclear Regulatory Commission Washington,'D. C. 20555 Subj: . Exemption From 10 CFR 73.50.

Dear Mr. Stello:

We have appreciated your recent interest and concern regarding the hardships imposed on test, research, and training reactors by the promulgation of new security regulations. Because.of the unique nature of the design and operation of each reactor in this group, we believe that certain of the regulations are without sound technical bases in their application to these unique facilities.

For your information two letters are attached. Mr. George W. McCorkle's (USNRC) letter to Union Carbide Corporation dated September 21, 1978 states. that the requirements of 10 CFR 73.50 apply to our, site whenever the total uranium-235 in unirradiated fuel elements and in irradiated and unirradiated target material exceeds 5,000 grams. My response to I Dr. Clifford V. Smith dated November-10,1978 provides numerous reasons why 10 CFR 73.50 is inappropriate for our facility at Sterling Forest. However, the route we have taken, which ,

we hope to be more expedient, is to request an exemption from j 10 CFR 73.50 in that self-protected target material, in l addition to irradiated fuel elements, be exempt from the 5,000 gram limit.

We solic.. your itaunch support of what we trust you will find to be a sound technical resolution to our special situation.

We are most receptive to any questions or comments you may have regarding this matter.

Yours very truly', l CULtur.

Mar us H. V th l 781116 O/97 Manager Nuclear Operations l

MHV:js Attachments C\

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.. _cc: .Dr. Clif ford V... Smith (USNRC) g

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HESEARCH LABORATORY UNION CARBIDE CORPORATION P.O. BOX 324. TUXEDO, NEW YORK 10987 TELEPHONE: 914 351 2131 oved er 10, M78 Mr. Victor Stello, Jr., Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Subj: Exemption From 10 CFR 73.50.

Dear Mr. Stello:

We have appreciated your recent interest and concern regarding the hardships imposed on test, research, and training reactors by the promulgation of new security regulations. Because of the unique nature of the design and operation of each reactor in this group, we believe that certain of the regulations are without sound techni' cal bases in their application to these unique facilities, s For your information two letters are attached. Mr. George W. McCorkle's (USNRC) letter to Union Carbide Corporation dated September 21, 1978 states that the requirements of 10 CFR 73.50 apply to our site whenever the total uranium-235 in unirradiated fuel elements and in irradiated and unirradiated target material exceeds 5,000 grams. My response to Dr. Clifford V. Smith dated November 10, 1978 provides numerous reasons why 10 CFR 73.50 is inappropriate for our facility at Sterling Forest. However, the route we have taken, which we hope to be more expedient, is to request an exemption from 10 CFR 73.50 in that self-protected target material, in addition to irradiated fuel elements, be exempt from the 5,000 gram limit.

We solicit your staunch support of what we trust you will find to be a sound technical resolution to our special situation.

We are most receptive to any questions or comments you may have regarding this matter.

Yours very truly, MD%

%figgf Marcus H. Voth Manager Nuclear Operations MHV:js Attachments C\

cc: Dr. Clifford V. Smith (LJNRC) h g (