ML20196E839

Requests Exemption Under 10CFR50.12(a)(1) & (2) to Begin Const of Temporary non-nuclear Storage Facility,Per 871117 Application for Permit to Construct Stable Isotope Enrichment Facility.Requests Concurrence by 880311

ML20196E839
Person / Time
Site:	05000604
Issue date:	02/22/1988
From:	Bell D ALL CHEMICAL ISOTOPE ENRICHMENT, INC.
To:	Thompson H NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
29073, NUDOCS 8803010324
Download: ML20196E839 (4)

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cu to Nuclear Regulatory Commission Document Control Desk Office Nuclear Material Safety and Safeguards Washington, D.C. 20555 ATTN: Mr. Hugh L. Thompson, Jr.

SS396-MNSS Docket Material Gentlemen:

In our original application dated November 17, 1987, for a permit to construct a stable isotope enrichment facility an exemption was requested to allow AlChemIE to start construction of a temporary non-nuclear storage facility. 'rhis work will entail construction of a temporary facility to house classified gas centrifuge components until they can be utilize in a permanent production facility. Work on the permanent production j facility will not start until a construction permit is granted by the NRC.

AlChemIE's approach to this issue is two-fold, and we request that each issue b3 considered. First, AlChemIE believes that we are entitled to an exemption from the dictates of 10CFR50.10(c) for the following reasons:

1. AlChemIE's business, while utilizing centrifuge technology, )

involves enrichment only of stable, non-radioactive isotopes. AlChemIE will not possess, nor be licensed to j possess, any special nuclear materials.

2. Special situations abound in the A1ChemIE project. An NRC license is necessary only because under the Atomic Energy Act of 1954 centrifuge machines, by their capability to enrich uranium, are defined as production facilities.

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3. AlChemIE operations, by definition, pose no radiological hazards.

4. In order to accommodate Department of Energy requirements for removal of classified materials from the DOE /GCEP facility in Portsmouth, Ohio, AlChemIE must have a secure storage space. This necessary space is of a temporary character, housing classified components until they can be installed on line. The cog aneni:s of the centrifuge machine cannot unless assembled u cascade arrangement, enrich uranium.

5. The intent and purpose of 10CFR50.10(c) do not contemplate a project which is not enriching or possessing special nuclear materials. AlChemIE, therefore, is appropriately situated to be exempted from said requirements.

Secondly, even if AlChemIE is not granted an exemption, we feel that said regulations exclude from their purview the type of preliminary construction activities contemplated by AlChemIE.

A1ChemIE seeks to do preliminary site preparation. This is to be done in conjunction with activities by the Town of Oliver Springs to develop a new industrial park. Proposed A1ChemIE activities will consist of site work, construction of temporary storage facilities and fencing. All activities are redressable, and all activities contribute to the development of the new industrial park.

In further support of this request, it is also pointed out that:

1. AlChemIE is attempting to obtain a construction permit in May 1988. The early construction would occur from i approximately March 15, 1988 until the above CP date.

During this time period AlChemIE will not have possession of any classified centrifuge components. j l

2. The centrifuge machines are shipped disassembled with non-classified components stored a5 a location different from the classified components. Assembly of a machine (s) in the storage facility is virtually impossible in that a overhead crane with approximately a 100 ft lift capability is needed. The storage facility will be 60 ft high. In other words, the construction undertaken cannot, by its nature, function as a production facility.

3. Contractural commitments with DOE require shipments of ,

classified components to start on approximately September 1, l 1988. An early construction of the storage facility is required to meet this commitment.

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a Nuclear Regulatory Commission February 22, 1988 Page 3

4. The site upon which the storage facility is located is in a general industrial park being developed by the Town of Oliver Springs.

In recognition of the above it is requested that under 10CFR50.12(a) (1) and (2) that an exemption be . granted. Your concurrence with this request is required by March 11, 1988.

Should you have any questions or. require additional information, please contact Mr. Stephen Irving or Mr. W. A. Pfeifer at A1ChemIE. Thank you for your continuing ' support of A1ChemIE's efforts.

Very truly yours, ALCHEMIE, INC.

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