ML20196K162
| ML20196K162 | |
| Person / Time | |
|---|---|
| Site: | 05000000, 05000054 |
| Issue date: | 07/09/1987 |
| From: | Mcgovern J CINTICHEM, INC. |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20149C434 | List: |
| References | |
| FOIA-87-825 GL-86-12, NUDOCS 8803150212 | |
| Download: ML20196K162 (18) | |
Text
y, ; Lg A ~N CINTICHEM, INC.
e wholly owned subsdory of fvledi-Physics, Inc.
p.o. sox e,c. Tuxeoo. NEW YoM 10987 19141351 2131 i
l July 9, 1987 1
U.S. Nuclear Regulatory Commission Director of the Of fice of Nuclear Reactor Regulations Washington, D.C.
20555
Dear Sir:
REF. (a) Cintichem Letter, WGR 9/18/86 (b) NRC Letters, 50-54, 12/30/86 and 2/11/87 Title 10 of the Code of Federal Regulations Part 50.64 allows reacter licensees to apply f or a unique purpose exemption from the requirement to convert f rom high enriched uranium (HEU) to low enriched uranium (LEU) for reactor fuel.
Generic letter 86-12 provides speelfic guidance by which licensees may apply for such exemptions and also the criteria by which they may be granted by the Ccrnmission.
Accordingly, Cintichem applied for such a unique purpose exemption by letter referenced above (Ref.a) and NRC requested additional Information by letters referred to in (b) above.
In the Interest of coherence CIntichem hereby restates its original arguments of reference (a) with elaboration in response to NRC's request for additional information in in reference (b).
l.
INTRODUCTION This application reviews the isotope production program at the Tuxedo, N.Y.
reactor facility which is the sole domestic source of vital radiolsotopes for certain medical applications. The reliable and continuous supply of these isotopes cannot be reasonably accomplished without the continued use of HEU fuel.
This application also details the unique status of the Cintiches reactor as a ccrnmercial enterprise >hich functions within and is influenced by a worldwide market and which is capendent upon the econcrnic viability of the program.
Cintichem's 5 MW MTR research reactor and adjoining hot laboratory are used prl,marily for the production of medical radioisotopes.
Target material is irredlated in the reactor core to produce the desired isotopes.
The redloactive targets are then transferred to the adjoining hot laboratory where the desired isotopes are chemically separated and packaged for shipment to hospitals and pharmaceutical firms throughout the world.
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l The Cintichem facility is the only ccanmerci al supplier of reactor-produced I sdtopes in the United States, it also produces a substantial share of the world's needs of these Isotopes. One In every four patients in U.S. hospitals i
benefits from a nuclear diagnostic procedure and seventy percent of all nuclear diagnostic procedures are performed with reactor-produced Isotopes, amounting to more than 125 million M vivo and h vitro diagnostic tests conducted yearly in the U.S.
C!ntichem's production of medical radioi sotopes is in :he national Interest because Cintichem is the only domestic source of several vital isotopes that are essential for the Dractice of nuclear medicine.
Table A below shows the portion of the U.S.
requirement for medical radioisotopes supplied by the Cintichem reactor and Table B shows the number of diagnostic tests that are accomplished with them.
TABLE A Approxleate Amount Medical isotooes From Cintichem Mo99/Tc99m 54%
l-131 50%
Xe-133 13%
l-125 25%
P-32 1005
3 TABLE B Percent Provided Procedure
_No./Yr.
By Cintichem IN YlVO TESTS:
Mo99/Tc99m Diaonostle Scans 1 Brain 115,000 Liver / Spleen 703,000 Bone 2,021,000 Thyroid 186,000 Lung 752,000 Heart 684,000 Kidney 218,000 TOTAL 4,679,000 54%
l-131 Diaonostic Scans 1 Thyrold 104,00'0 Kidney 63,000 TOTAL 167,000 50%
l-131 Therapy Thyroid 156,000 50%
Xe-133 Luno Scans 545,000 135 fr-192 Implants 1,068,000 50%
IN VITRO TESTS:
1-125 Radiolmmunesssay2 120,000,000 33g 1 Market Measures, Inc., 3rd Quarter 1986 - (Quarterly Reports of Products Used for in Vivo Radiodtagnostic Procedures Performsd in U.S. Hospitals - By Organ).
2 Based on 1-125 Customer's Share of in Vitro Market as reported in IMS America, 4th Quarter 1979, Hospital and Private Labora-tories Survey, p.344.
4
4 I I. TECHNICAL ISSUES Medical redlot sotopes, of necessity, are short lived.
They cannot be stored or stocked for future use.
Theref ore, it is necessary that production f acilities operate continuously (day to day) and reliably at a sustained capacity in order for the medical ccanmunity to have these meter!als readily available at any time.
Any interruption in the supply of these isotopes would have a signifIcant negative Impact on the practice of nuclear medicine.
The Cintichem f acility maintains a preeminent role for supplying these vital medical radiolsotopes within the United States.
Statements f rom the Society of Nuclear Medicine and the American College of Nuclear Physiciens attesting to this are being f orwarded under separate cover.
Cintichem's role was achieved not only through the appilcation of Innovative technology but, more importantly, it is maintained by providing a continuous reliabie supply of these short-lived isotopes.
This f acility must also stay v i ab le economically as a ccrnmerci al venture.
Sustained reliability and econcrnic vlability then are essential for maintaining Cintichem's position as the preeminent s,upplier of these I sotopes in the U.S.
as well as a major supplier In the International market.
j i
The NRC Regulatory Analysis of its originally proposed HEU rule expressed concerns about the societal cost f rom any loss of reactor capabilities.
It stated that f or f acilities above 1-2 W power, LEU conversion could have an impact on the source of neutrons necessary f or production processes. Of most concern in thc NRC's analysis was the capability to produce short-lived I sotopes for medical research and diagnosis, which could be affected by ternporary or permanent f aellity shutdowns, or by competitive market f orces.
The Regulatory Analysis stated that the provisions of the rule are Intended to minimize any potential losses in f acility capabilltles and availability, j
Clntichem f ully appreclates and supports the NRC's concern for the societal cost of a reduction of the U.S.-produced radloisotope capacity.
Cintichem also agrees with the NRC's stated desire that the rule's provisions, notably the "unique purpose" exemption provlsion, can be used to minialze the Impact or prevent the loss of domestic reactor capabilities.
The following are our reasons:
(a) Conversion of the Cintichem reactor to low enriched fuel will have an adverse Imoact on the operatino characteristics of the reactor f or producino radiolsotopes and other nuclear services. The result will be a 105 reduction in isotope production ceDacity and inevitable shortaces of supply of medical Iso _ topes to the U.S. market. The known reduction of thermal flux, the change in neutron energy spectrum and the anticipated reduction In core excess reactivity will be detritnental to the isotope production program at Clntichem.
The I AEA LEU Core Conversion Guldebook (I AEA-TECDOC-233 App. F-1 MTR Benchmark Calculations) concludes that a hardened neutton energy spectrum and an approximate 10% reduction in the thermal neutron flux can be expected af ter
5 1.EU conversion.
This was confirmed in the Ford Reactor conversion to LEU.
The Clntichem reactor is basically a thermal neutron source for producing radiolsotopes and performing nuclear Irradiation service.
A 105 reduction in th*e thermal neutron flux will result in a 10% reduction in isotope production capacity.
Simply put, radioisotope production is expressed as a f unction of i target atcrns x cross section x flux x saturation f actor. Target atoms, cross section and flux are scalers in this equation while the saturation f actor is a time and halfilfe dependent variable which is asymptotic.
Therefore, produc-tion capacity varies proportionately with flux and disproportionately with time, especially beyond one hal filfe of the radiolsotope being produced.
The flux hardens with LEU conversion even while the power level of the core is maintained at 5 MW.
Theref ore, to produce the same number of thermal neutrons and correspondingly the same number of radioisotopes by thermal neutron Induced nuclear reactions, the reactor power level would have to be increased by 10%. The Cintichem reactor cannot easily be run at 5.5 MW.
This is due to the existing reactor cooling capabilities and present power level l icense limits.
Similarly, radioisotope production could not be Increased by increasing reactor operati ng time as the reactor now operates at an approximate 95% duty cycle.
The 5% down time is necessary for reactor maintenance and refueling.
Other constraints dictated by product specifications, such as product hal f lives and Induced long lived contaminates also preclude the longer operating time as a solution to this problem.
This anticipated reduction in capacity cannot be overcome by adding more isotope production targets to the core because of the technical specification limits on the core coolant flow that can be diverted to cool targets.
The specification is as follows:
l "The total primary coolant flow utilized by all in-core experiments shalI meet the f of Iowing requirements; fraction of core flow in experiments 5. 1-5/6 (fraction of rated power production In f uel elements)."
The equation states that If all the rated power is produced in the fuel elements, then 1/6th of the core flow can be devoted to in-core experiments.
If the experiments are f ueled and produce a percentage of the total rated core power, then greater than 1/6th flow can be given to the experleent s.
Cintichem fission product isotope targets do produce fission power and theref ore Cintichem allows the total experimental flow to be greater than 1/6th of the total core f low.
Knowing the flow rates through the isotope target stringers and the f uel elements, the percentage of the total core flow through all experiment positions is calculated.
This
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6 actual experiment flow rate Is then compared to the maximum allowed experiment flow rate.
The maximum allowed experiment flow rate is calculated with the above technical specif ication f ormula using the known amount of power produced in the f ueled experiments.
This calculation is done at normal minimum total core flow rate of 2000 gpm.
There is Insuf ficient flow to add more f ueled targets and therefore Clntichem is at the current limit for the number of Mo99 production targets.
No more core space can be dedicated to fission product snolybdenun production, given the limitations of the technical specifications, the present product mix and the current state of target technology.
Increases In isotope capacities can only be achieved through tradeof f s.
An increase in one isotope must be acccrnmodated by reductions or changes in other products, services, or operating parameters.
Ci ntichem has reviewed the available data on control rod worth changes f ollowing a conversion f rom HEU to LEU f uel.
Experimental and theoretical data Indicate that a decrease in rod worths will be experienced.
The whole core LEU demonstration at the Oak Ridge reactor and other sources have predicted that, in general, control rod worths would go down by approximately f Ive percent with LEU f uel due to the harder neutron spectrum and less neutron absorption in the control rods relative to the f uel.
A f Ive percent reduction of control rod worths would decrease current operational maximum excess reactivity which is dictated by the technical speci f ication limit on minimum shutdown margin.
This reduction would decrease the operating time between ref uelings and, because we run with the highest duty cycle practicable, extra shutdowns to ref uel would decrease our productivity.
This of feet can be initially evaluated as follows:
HEU Core LEU Core Gang Rod Worth
+9.35%
+8.88%
Xenon Equil.
-3.505
-3.50%
Power Coeff.
-0.35%
-0.35%
Max. Worth Rod
-2.655
-2.52%
Excess SDM
-0.505
-0.505 Allowable Excess Operating Delta K/K
+2.35%
+2.01%
Change in allowable excess Delta K/K = -14.5%
Therefore the al lowable operating tim., between reactor fuel loadings wil I decrease by approximately 15% as a result of a 5% decrease in rod bank worth.
This would result in a reduction In overall duty cycle and consequent reduction in isotope production capacity.
7 The reduction in thermal neutron flux and the ant ici pated loss in excess reactivity will reduce our current capacity to produce medical isotopes by
> 10%.
There have been numerous occasions in the past (and there will undoubtedly be f uture occasions) when one of the foreign producers of medical I sot' opes will experience an Interruption or a shortf al l in production and Cintichem has had to go to maximum capacity 19 make up this shortage.
If Cintichem loses the current capacity due to conarston to LEU, it will not be able to completely make up f or future shortfalla.
Since a large portion of the current domestic supply is dependent on thi impcrts, there will be a shortage of medical isotopes in the U.S. as well e.s overseas.
Additionally, any reduction of Cintichem's current capacity wl;l limit our ability to maintain a preeminent role in the f uture expansion ci the nuclear medical field.
A brief history of Cintichem's experience in making up produc-tion lapses of foreign producers is presented in Table C.
(b)lt is uncertain that I sotopes produced in
- a. LEU core would be comparable in Quality; product and waste requalifications woLld be necessary J
resultino in disturbance in the continuity of supply of letortant medical isotope 1 The reliable and continuous supply cf medical isotopes (particularly Mo-99) could also be adversely af fected due tc changes in the characteristics of the product due to the anticipated enanges in the neutron energy spectrum within the core.
The isotopes and. services that are currently pr ov ided from Cintichem's HEU fueled core could also be prc4uced in an LEU f ueled core but It is uncertain if they would be ccmparable In quality.
For example, the predominant isotope produced in the Clntichem f acility is Mo-99, it is made through the fission reaction of U-235 anc then it is separated f rom the other f Ission products by a process that has develcped and evolved over more than 15 year s.
The production process is ccrn;atible with the plant design and physical capacity.
The Mo991sotope is used as the active Ingredient of a parente-al drug product and as such has been well quellfled.
It is characterized particularly to be free of transuranic elements.
The anticipated change in tre neutron f lux energy spectrum within the core would increase the production of Pu-239 due to increased resonance capture in the U-238 which is present in the isotope production target.
Cintichem believes that this would necessitate a requalI f Ication of this product.
Requalif ication would Involve Irradleting targets in a low enriched uranium core, processing the targets to remove the molybdenum, and then testing f or conf ormance with speci f ications on radionuclidic purity, i.e.
absence of g ainma, beta, and alpha crnitters.
This testing generally re:;uires the test matqrlal to be decayed and then analyzed on a mass spectrcrneter.
(Mass spectrometers are generally not available for this type of radioactive material analysis.)
Following this testing it would be necessary to make a
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molybdenum-technitium generator, and then test the eluent from this product for radionucildic
- purity, redlochemical
- purity, and pharmacological efficacy.
This requalification would require the core to be in place and operating.
The analysis would have to be done on the finished drug product and it would be a time-consuming process.
Clntichem does not see how this can be accompIlshed without causing some disturbance in the continuity of supply of this isotope.
Requallfication of our product is the paramount concern.
However, it is almost as important to requalify the radioactive waste produced.
10 CFR 61 requires detailed classification and verification of waste isotopes and this classification is highly dependent on the waste plutonium content which changes significantly as the core's neutron energy spectrum changes.
it theref ore would be necessary to requalify the waste produced as thoroughly as the radioisotope products.
This waste reclassification would be a time consuming complex process.
Making the overalI requalIfIctstion process even more compt Icated Is the fact that actual conversion from HEU to LEU fuels is a long process.
The anticipated method of core conversion would be to proceed from HEU to LEU by incrementally introducing LEU f uel elements into an HEU ccre.
As the HEU elements become depleted, more LEU elements would be added, resulting, af ter a year or so, in a f ull LEU core.
This process would result in the overall core neutron energy spectrum slowly changing f rom HEU to LEU.
This could require continuous sampling, analysis, and requalification as the energy spectrum changes and would significantly add to the complexity and scope of the total requalI f Ication ef f ort.
At present Cintichem does not see how this can be accomplished without, at
- worst, a significant Interruption of the normal supply of medical isotopes or, at best, a signifIcant added expense for continuous requal I f Ication during the conversion period.
Cintichem believes that it is unreasonable to have to bear this added contingent econcrnic burden as a consequence of con-verting to LEU.
(c) Other services f or non-medical eestczners will be threatened as a result of conversion to LEU.
Cintichem's major reason for operating its reactor is to produce radioisotopes f or the medical ccrnmunity.
We also have a program in which reactor service irradt attons are performed f or var tous non-medical use customers.
The largest contingent in this category is to produce neutron transmutation-doped silicon.
It is complementary to the redlotsotope program and*does not compete for reactor core space.
The doping of high purity silicon is done by the reaction, SI-30 (n, gamma)
S I-31 --> P-31 +
B.
This reaction uses thermal neutrons to produce the desired phosphorous doping.
Therefore, the higher the thermal flux the faster the crystal doping can be done.
Reducing the thermal flux reduces doping
)
l 11 productivity.
On the other hand, f ast neutron flux causes crystal defects to occur.
With a harder f lux spectrum, more f ast neutron crystal damage will occor.
Most silicon manufacturers are quite concerned with the fast to thermal flux ratio and compare competing reactor f acility cadmium ratios when choosing reactor irradiation f acilltles to dope their sillcon.
Clntichem includes the silicon concern In its unique purpose execption request because LEU conversion will harden the neutron spectrum, cause more sillcon crystal i
def ects, cause lower doping productivity, and theref ore reduce the quality and quantity of the NTD silicon service Irradiation program.
The above arguments pertaining to the disadvantages of converting to LEU (<20%
U235 enrichment) reactor fuel will also apply to interrediate enrichment but i
It is difficult to say, without exper imentation, what enr ichment will be Insignificant in every respect.
Any change could be significant until it is proven not to be.
Cl ntichem has so far reviewed the technical problems associated with the conversion of the Cintichem reactor to LEU f uel and the detriment to the continuous and reliable supply of vital, short lived medical isotopes. Any one of these compilcations has the potential f or causing eventual shortages; all of them combined will surely have a detrimental ef feet in the future.
I l l. ECONOMIC ISSUES Cintichem understands that the NRC has Indicated that econernic benefit is not e basis for a unique purpose exemption, but when economic viability is one's raison d'etre and, without this viability the sole domestic supplier would cease operation, it then becomes a pertinent consideration f or assuring the supply of a material which is vital for the national health and welf are.
In addition to these derrestic concerns, the Clntichem facility is a net exporter of products and services which contribute positively to the U.S.
Balance of Trade Payments.
The loss of this f acility would have the compound I
of feet of the loss of income f rom current exports f rom the f acility as well as i
from the purchase of all product and services that are currently distributed domestlealIy i
As an introductory ccrunent to these ccrnmerci al considerations Cintichem believes it important to note that the final rule on non-power reactor conversion to LEU f uel was expanded to include "ccrnmercial activity" In the definition of unique purpose.
NRC Generic L e.'ter 86-12 includes the "as}urance of a domestic supply of scrne essentiel product" as a valid consideration f or a unique purpose exemption.
Any cyrnercial enterprise is based primarily on the expectation that profit, return on Investment, and growth will occur.
Without these results there Is no motive fcr sustaining a business. Clntichem believes that commercial viability must at least be a valid f actor in determining whether a program can reasonably be continued by private enterprise without the use of HEU fuel.
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12 i
l The fuel f abrication estimato was provided by [nanufacturers who have had l iralted experlence working wit 5 the relative higher density LEU loadings.
Cintichem believes its reactor r!ll require the highes' density f uel loading (greater than 4.5 gm U/cc) In oMer to maintain present design metal / water ratio and f uel element burn up which is currently at > 50% of the fissionable material.
This high density can only be achieved w*th silicide f uel and, since fuel f abricators have had no ongoing productic experience with this process, this estimate could be inaccurate.
The waste disposal figure assumes that the transuranic content of the isotope production waste will increase due to the hardened ne. tron flux in the core.
The current of f active production cross section f or Pu, including the resonance Integral, has been measured to be approximately 2/3 the maximum that is theoretically possible but a f actor of 2 above the t ermal neutron capture cross section for this reaction.
The difference is attributable to the resonance capture of epithermal neutrons.
As the nostron flux spectrum hardens with 1.EU conversion, the Pu production increases.
The amount by which it does has been conservatively estimated by applying the highest theoretical cross section, if the Pu content of the waste caused t:e waste classification to change f rom B to C it could lead to higher cost and reduced availability of disposal space. These details are unclear at this time.
1 Last known price of silicide fuel used in ORR 2 F.R. Vol. 51, No. 32 p.5754, 2/18/86 i
e 13 These are the cost elements of radioisotope production that Clntichem now predicts will increase as a result of converting the reacter fuel to LEU.
The total estimated increase applies to the routine, direct, ongoing expense of production.
Since it is estimated that the conversion to LEU fuel cannot be accomplished until 1989 or 1990, other f actors 'could develop that cannot be anticipated now.
Not included in the above estimate are the costs that Cintichem can forosee that will be involved in the initial reactor conversion.
There will be man-years of work in revising techqlcal specifications, saf ety analyses, licenses, operating procedures, and training documents in addition to the work of the actual conversion.
The cost associated with product and waste reclassification previously described will also amount to a substantial Initial cost.
Also of note here is that NRC's Regulatory Analysis impiled that the costs i nvolved in en LEU conversion would only involve initial changeover costs.
As discussed above, this increase is an ongoing cost carried on Indefinitely after core conversion.
If LEU is mandated at Cintichem, the Federal Government, in meeting lis rule to f und f acilities for all the costs of LEU conversion, should provide funding for the initial core conversion and ongoing annual subsidles to of f set the higher production costs associated with LEU fuels.
Clntichem also notes. that the U.S. Department of Ent gy has nott fled us that Federal f unding f or a Clntichem LEU conversion will not be made avalleble during fiscal year 1987 and that current 0.0.E.
plans only include initial funding and only for university reactor conversions. The 0.0.E.'s February 11, 1987 letter addressing this subject is enclosed.
Other market considerations are that there are only a few major suppllers of reactor-roduced redlochcrnicals In the world. C!ntichem is the only ccrunercial domestic supplier end participates In a world market against competitors who are subsidized by their gover nment s or use government cwned reactor s.
Clntichem's main competitor s are AECL (Canada),
IRE (Belgium), Australian Aternic Energy Agency and East Germany, it must be emphasizad that this business is conducted as a
separate and distinct entity from the radlopharmaceutical Industry which it serves.
The estimated cost increase will have to be fully absorbed within this business and it will be very if recognizable by the pharmaceutical manuf acturers, who are our custcreers.
competing producers are not subject to the same cost pressures, Cintichem would be at a definite disadvantage.
Since Clntichem's ccrnpe ti t or s are not wholly commercial entitles, and since they use higher powered, govern-
14 asent owned test reactor f acilities, Clntichem believes that it would be at a def inite competitive disadvantage.
Specif ically, conversion to LEU In a low power reactor is more signifIcant from the standpoint of production cost than it *ls in a high power reactor.
Production batch sizes vary with core power level. The direct lacremental cost of production I.s inversely proportional to production batch size.
The direct incremental cost of production in a low power reactor, theref ore, is a much higher fraction of the total cost than it Is in higher power reactors.
Assuming the flxed costs remain the same, the incremental cost to the producer with a low power reactor would be much greater than for the producer with the higher powered reactor and any decrease in process yleid would be magnifled in the cost experknee of the lower powered reactor facility. A rationalization of the direct production cost of Mo99 In reactors of dif fering power levels is shown on Table D. In a commodity type business such as radlochemicals, margins are made and price is of ten based upon incremantal direct production cost.
Cintichem has the lowest powered reactor of alI the radictsotope producers and hence it will experlence the highest direct production cost increase and it will be placed at a competitive disadvantage.
It is unlikely that the increase in wst could be compensated for by increasing prices because of the af orementioned ccnpe t ition.
Cintichem, as a private business enterprise, requires prof itabil ity and growth to stay viable.
The I nstant aneous and continuing econcnic consequences of converting to LEU reactor fuel could Joopardize its existence.
IV. CX)NCLUS10N In summary, CI nti chem is applying f or a unique purpose exemption frem the requirements under 10 CFR Ft 50.64 to convert the reactor f uel f rom HEU to LEU f or the f ollowing reasons:
1.
CIntichem has a preem inent position as a commercial supplier of certain medical radloisotopes which are vital in the practice of nuclear medicine and that it is in the national Interest to maintain this sole dcmestic supply capability, j
2.
It is leperative to the practice of nuclear medicine to have l
continuity of a ready and adequate supply of sncet-lived Isotopes.
3.
Conversion of the Cintichem reactor fuel to LEU will cause a reduction in isotope production capacity by at least 10% which will result in shortages of certain Isotopes when other producers cannot i
supply their usual share to the market due to technical dif ficultles, as has happened in the past.
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It will practically be impossible to requalify products and waste made in the Clntichem LEU core and simultaneously continue to supply product during the conversion process.*
Cintichem's failure to sustain its supply to its market segment will result in shortages within the U.S.A.
5.
Cintichem will be at a competitive disadvantage because:
(a) Initial costs of conversion, such as rel icensings, all associated changes in operating and training documentation, and the recharacterization of radioisotope products and waste, will not be subsidized under the current DOE funding plan.
Competitors use reactors owned and operated by government agencies or consortia and they will be relatively unaf fected by conversion costs of this kind.
(b)
The ongoing added cost of production caused by lower yloids and other cost elements prevfously mentioned are directly related to product and, because Cintichem's direct production cost is a higher portion of total production cost compared to suppliers using higher powered reactors, Clntichem wilI experlence a greater cost increase than its competitors.
(c) Conversion to LEU reactor fuel will adversely affect reliability and ef fIclency of Cintichem services.
These ccenpetitive disadvantages will Impact negatively on Cintichem's success in the radlositope market.
Clntichem relles on profitability and growth to justify its continuance.
In my opinion, conversion to LEU reactor fuel could be the cause for l
Cintichem's eventual discontinuance as a dcmestic source of medical radioi sotopes.
Very truly yours, i
p<G
. J.
vern Senior Vice President JJMcGreb enc.
l
0 Department of Energy.
Washington, DC 20585 I
TEB 1 1 1987 Dr. William C. Ruzieks Manager, Nuclear Operations Cintichem, Inc.
P.O. Box 816 Tuxedo. New York 10987 Dea 5 Dr. Ruzieks:
In accordance with Nuclear Regulatory Commission Rule,10 CFR Part 50, Limiting The Use of Highly Enriched Uranium in Domestically licensed Research and Test Reactors, you are hereby notified that Federal funding by the Department of Energy for conversion of your reactst will not be available during Fiscal Year 1987.
Current Department of Energy plans include funding for conversion of university owned reactors only. You will be notified if these circumstances change.
Sincerely, l
Richard E. Stephens Division of University & Irdustry Programs of fice of Field Operations Manage =ent of fice of Energy Research j
l I