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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20155H9301998-11-0404 November 1998 Forwards Listed Canceled Financial Assurance Documents Re Decommissioning of Cintichem Facility in Tuxedo,Ny.Without Encls ML20154H6341998-10-0505 October 1998 Responds to Requesting That Order on Consent for Case D200059005 Be Terminated.Released from All Requirements Set in Order,Effective 981005 ML20237C4981998-08-19019 August 1998 Informs That Commission Has Issued Encl Order Terminating FOL R-81 for Cintichem 5 Megawatt Open Pool Nuclear Research Reactor IAW 901019 Application.Copies of Amend 16 to Idemnity Agreement B-14 Encl for Signature.Se & EA Encl ML20237C5491998-08-19019 August 1998 Informs That NRC Completed Review of Info Submitted by Cintichem,Inc to Support Decommissioning of Tuxedo,Ny Facility.No Further Remediation or Actions W/Respect to NRC Regulated Matl Required,Based on Conclusions ML20197C7691998-07-28028 July 1998 Responds to Requesting Amend to Order on Consent Case D200059005.Amend 10 Which Requires That Sampling of 001 Outfall & Retention Pond Continue Encl ML20236L7321998-06-0808 June 1998 Informs of Completed Review of Final Status Survey Rept for Decommissioning of Bldg 4.Facility May Be Released from Radiological Control.License Termination,Encl ML20236S0211998-06-0202 June 1998 Forwards Confirmatory Surveys of Bldgs & Areas of Cintichem Facility Located in Tuxedo,Ny.Radionuclide Concentration in Bedrock Soil Samples & Orise Resrad Calculation,Encl ML20248D6681998-05-27027 May 1998 Requests That Process for Terminating Licenses R-81 & SNM-639 Be Resumed Due to All Radioactive Matl Having Been Removed as Final Condition for Termination Subject Licenses ML20216C5311998-04-15015 April 1998 Forwards Results of NRC TLD Direct Radiation Monitoring Around Cintichem Facility for Fourth Quarter of 1997.Final Rept Due to Termination of Program ML20217Q6411998-02-10010 February 1998 Responds to Requesting Mod to Ref Order on Consent.Amend 9 to Order,Authorizing Most Changes Requested Enclosed ML20202A8051998-02-0202 February 1998 Forwards Amend 10 to License SNM-639,in Resonse to 971204 Request to Amend Decommissioning Plan for Tuxedo,Ny Facility to Reduce off-site Environ Monitoring Program ML20202E1841998-01-28028 January 1998 Forwards Revised Tables Including Sr-90 Analytical Results. Five Individual Samples from Adjacent Locations Consolidated Into One Sample for Sr-90 Analysis ML20202E1941998-01-28028 January 1998 Forwards Amended Table Which Includes Sr-90 Data Re Final Survey of Soils at 001 Outfall.Conclusion That Survey Results Meet Soils Acceptance Criteria Has Not Changed ML20202E4781998-01-19019 January 1998 Forwards Cintichem Final Status Survey Plan & Rept,Per Section 7 of Licensee Radiopharmaceutical Facilities Decommissioning Plan.W/O Encl ML20199C2511998-01-0202 January 1998 Responds to Concerning Status of mixed-waste at Cintichem Site.Attached Table Presents Overview of Radioactively Contaminated Waste That Remains to Be Disposed of from Decommissioning Project ML20198C8521997-12-23023 December 1997 Forwards Result of NRC TLD Direct Radiation Monitoring Around Cintichem Facility, for Third Quarter of 1997 ML20199B6091997-10-22022 October 1997 Forwards Characterization Rept for Union Carbide Spoils Area Tuxedo,Ny.Area Meets Criteria for Unrestricted Use ML20217G2501997-10-0808 October 1997 Forwards Response to 970819 RAI Re Survey Repts of Hot Laboratory Support Bldgs & Outdoor Areas Inside & Outside of RCA ML20199B6151997-10-0303 October 1997 Responds to 971002 Request for Mod to Order on Consent Case D200059005.Amend to Order on Consent Authorizing Changes Encl ML20199B6601997-10-0202 October 1997 Requests That Order on Consent D200059005 Be Amended to Allow for Delay in Analysis of Water Samples from S-12 for Gamma Emitting Radionuclides,As Currently Done W/Analysis for Sr-90 ML20211C5501997-09-22022 September 1997 Forwards Bedrock Dose Assessment Rept, Which Completes Final Survey Process.W/One Oversize Drawing ML20210R8271997-08-22022 August 1997 Forwards Results of NRC TLD Direct Radiation Monitoring for Second Quarter of 1997 ML20210Q6631997-08-19019 August 1997 Requests That Listed Info Be Submitted in Order to Complete Preliminary Review of Sections 11-18 of Cintichem Final Plant & Rept Submitted by 970606,27,0703,25 & 30 Ltrs ML20210L8541997-08-0505 August 1997 Informs That Responsibility for Non-Power Reactor Insp Program Has Been Transferred from Regional Ofc to Nrr.All Activities Re Non-Power Reactors Including Licensing,Insp & Operator Licensing Will Be Responsibility of NRR ML20149G7981997-07-0303 July 1997 Forwards Chapters 15 & 16 of Final Survey Repts for Cintichem Outdoor Areas Outside Former RCA, Which Describes Cintichem'S Approach to Conducting Final Survey for Areas of Property ML20149G9111997-06-27027 June 1997 Forwards Chapters 13 & 14 Final Survey Repts for Cintichem Outdoor Areas Inside of Former Rca. Chapter 14 Presents Results of Survey ML20140H0591997-04-24024 April 1997 Informs of Completion of All Remediation Work & Final Surveys Per Cintichem Decommissioning Plan.Will Submit Last Sections of Final Survey Rept for Review & Approval in May ML20137W1391997-04-0303 April 1997 Discusses Radiological Characterization Plan for Union Carbide Spoils Area ML20135D1601997-02-21021 February 1997 Forwards Results of TLD Direct Radiation Environ Monitoring Around Facility for Fourth Quarter of 1996 ML20133A4641996-12-20020 December 1996 Forwards Results of NRC TLD Direct Radiation Monitoring Around Cintichem Facility ML20133N0281996-12-19019 December 1996 Informs of Agreement to Extension of Deadlines for Weekly & Monthly Repts in Response to 961206 Request Re Reporting Requirements in Order of Consent Case D200059005 ML20132B6591996-12-0606 December 1996 Informs That License SNM-639 Will Remain in Effect Until Completion of Decommissioning Operations ML20134K7041996-11-14014 November 1996 Advises That SNM-639 License Expires on 961215,per Amend 7 Issued 950118.Request License Remain Effective Through June 1997,allowing Sufficient Time for Completing Work Outlined ML20134F7571996-10-29029 October 1996 Submits Response to Re Radiological Status of Bedrock at Tuxedo,Ny Facility ML20134F7611996-09-25025 September 1996 Provides Comments Re Ground Water Issues Raised at Cintichem Inc Decommissioning Project ML20078N4221995-02-0202 February 1995 Submits Comments Re Cintichem,Inc Decommissioning Proposed Bedrock Criteria ML20078K4791995-02-0101 February 1995 Confirms Discussions Had Yesterday & Morning Re Strontium-90 Analyses of Water Discharged Through 001 Outfall at Cintichem Site ML20059K1891994-01-14014 January 1994 Forwards Insp Repts 50-054/93-03 & 70-0687/93-03 on 931116- 18.No Violations Noted ML20058C9821993-11-22022 November 1993 Provides Results of NRC TLD Direct Radiation Monitoring Around Cintichem Facility for Third Quarter of 1993 ML20057C7521993-09-24024 September 1993 Expresses Appreciation for J Mcgovern Addressing Town Board & Public Re Decommissioning of Cintichem ML20057B7701993-09-14014 September 1993 Forwards FRN Discussing 930726 Final Rule on Decommissioning Recordkeeping & Documentation.W/O Encl ML20056H4001993-09-0101 September 1993 Responds to Re Towns Request for Status Rept on Licensees Decommissioning Project.Advises That Town Board Meeting Will Commence on 930922 & Outline of Planned Presentation Will Be Issued ML20057A5751993-08-31031 August 1993 Forwards Results of TLD Direct Radiation Monitoring at Facility for Second Quarter 1993 ML20056H1131993-08-27027 August 1993 Provides Clarification Re 930715 Exemption Request from Requirements of Revised 10CFR20 ML20056H4061993-05-25025 May 1993 Suggests That Meeting Date Be Set Up for Sept to Hold Discussions on Closing of Cintichem Reactor Facilities ML20128L3931993-02-11011 February 1993 Forwards Potential Effects of Cintichem-Proposed Residual Soil Criteria on Water Quality of Indian Kill Reservoir ML20128F2901993-02-0303 February 1993 Provides Clarification Re Use of Proposed Subsurface Soil Criteria ML20128B8781993-01-28028 January 1993 Confirms Meeting Arrangement W/Cintichem on 930201 in Tuxedo,Ny to Discuss Unrestricted Release Criteria for Soil at Ny Facility ML20127C1521993-01-0707 January 1993 Requests Assistance in Obtaining Info Re Residual Radiation Exposure Criteria for Decontamination & Decommissioning of Licensed Sites.Author Employed by DOE to Provide Assistance ML20127J5791993-01-0404 January 1993 Forwards Listed Proprietary Procedures for Soil from Teledyne,Per .Procedures Withheld 1998-08-19
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20236S0211998-06-0202 June 1998 Forwards Confirmatory Surveys of Bldgs & Areas of Cintichem Facility Located in Tuxedo,Ny.Radionuclide Concentration in Bedrock Soil Samples & Orise Resrad Calculation,Encl ML20248D6681998-05-27027 May 1998 Requests That Process for Terminating Licenses R-81 & SNM-639 Be Resumed Due to All Radioactive Matl Having Been Removed as Final Condition for Termination Subject Licenses ML20202E1841998-01-28028 January 1998 Forwards Revised Tables Including Sr-90 Analytical Results. Five Individual Samples from Adjacent Locations Consolidated Into One Sample for Sr-90 Analysis ML20199B6091997-10-22022 October 1997 Forwards Characterization Rept for Union Carbide Spoils Area Tuxedo,Ny.Area Meets Criteria for Unrestricted Use ML20217G2501997-10-0808 October 1997 Forwards Response to 970819 RAI Re Survey Repts of Hot Laboratory Support Bldgs & Outdoor Areas Inside & Outside of RCA ML20211C5501997-09-22022 September 1997 Forwards Bedrock Dose Assessment Rept, Which Completes Final Survey Process.W/One Oversize Drawing ML20149G7981997-07-0303 July 1997 Forwards Chapters 15 & 16 of Final Survey Repts for Cintichem Outdoor Areas Outside Former RCA, Which Describes Cintichem'S Approach to Conducting Final Survey for Areas of Property ML20149G9111997-06-27027 June 1997 Forwards Chapters 13 & 14 Final Survey Repts for Cintichem Outdoor Areas Inside of Former Rca. Chapter 14 Presents Results of Survey ML20134K7041996-11-14014 November 1996 Advises That SNM-639 License Expires on 961215,per Amend 7 Issued 950118.Request License Remain Effective Through June 1997,allowing Sufficient Time for Completing Work Outlined ML20134F7611996-09-25025 September 1996 Provides Comments Re Ground Water Issues Raised at Cintichem Inc Decommissioning Project ML20078N4221995-02-0202 February 1995 Submits Comments Re Cintichem,Inc Decommissioning Proposed Bedrock Criteria ML20056H1131993-08-27027 August 1993 Provides Clarification Re 930715 Exemption Request from Requirements of Revised 10CFR20 ML20128L3931993-02-11011 February 1993 Forwards Potential Effects of Cintichem-Proposed Residual Soil Criteria on Water Quality of Indian Kill Reservoir ML20127C1521993-01-0707 January 1993 Requests Assistance in Obtaining Info Re Residual Radiation Exposure Criteria for Decontamination & Decommissioning of Licensed Sites.Author Employed by DOE to Provide Assistance ML20127J5791993-01-0404 January 1993 Forwards Listed Proprietary Procedures for Soil from Teledyne,Per .Procedures Withheld ML20126A6191992-12-15015 December 1992 Forwards Addl Info Requested in in Support of Proposed Residual Soil Contamination Acceptance Criteria Included in Initial Submittal & Recently Modified in Submission ML20115C6591992-10-13013 October 1992 Informs That T Mach License (SOP-10461-1) Should Be Terminated Since Individual No Longer Employed by Vendor ML20092H4071992-02-10010 February 1992 Advises That Licensee Will Carry Out Full Decommissioning Project as Directed in NRC Order to Decommission ML20076N0701991-03-13013 March 1991 Withdraws 910214 Request for Hearing & Petition to Intervene in Proceeding Re Proposed Issuance of NRC Orders Authorizing Cintichem,Inc to Dismantle Reactor Facility & Dispose of Termination of License R-81.W/Certificate of Svc ML20029A5271991-02-19019 February 1991 Submits Addl &/Or Clarifying Info Re Decommissioning Plan, Per 910213 Ltr ML20029B5621991-02-19019 February 1991 Confirms 910214 Telcon Informing of Inability to Utilize Telegram Notification as Specified in 910114 Fr Notice (56FR1422) Because Datagram Identification 3737 Inactive. Telegram Notice Requirement Waived ML20029B6331991-02-14014 February 1991 Forwards Ny State Dept of Environ Conservation Request for Hearing & Petition to Intervene ML20028H8231991-01-21021 January 1991 Forwards Proposed Task Lists for Discussion on 910211 at NRC Headquarters ML20065S0991990-12-10010 December 1990 Identifies Two Tech Spec Required Items Difficult or Impossible to Perform Due to Transitional Period Between Normal Operations & Decommissioning ML20059N5771990-10-0303 October 1990 Advises That Repairs to Canal & Gamma Pit Sections of Reactor Primary Water Sys Completed,Per Order Modifying License.Licensee Decided to Operate at Level of 10 Ft of Water.Radiation Measurements Will Be Conducted ML20055J1721990-07-19019 July 1990 Requests Notification as Soon as Notice of Decommissioning Appears in Fr.Notice Will Enable Town to Go Forward W/ Petition for Public Hearing ML20042G5631990-05-0303 May 1990 Requests That NRC Requested Changes to Licensee Physical Security Plan Ref in NRC 900205 Ltr Be Rescinded Due to Vendor Decision to Decommission Facility ML20042F1031990-03-29029 March 1990 Forwards 900321 Ltr from C Monaco,Cortland County Low Level Radwaste Coordinator Requesting Licenses of All New York State Power Plants & Any Amends Extending Operating Lives of Plants ML20246B9721989-06-0707 June 1989 Provides Status Rept of Listed Open NRC Insp Items,Per EC Wenzinger 890518 Request,Including Inadequate Training or Procedures to Assure Uniform Plant Operations ML20246M9541989-05-0808 May 1989 Responds to NRC Ltr Re Violations Noted in Insps 50-054/89-02 & 70-0687/89-02 on 890328-31.Corrective Actions:Refresher Training Performed Re Contamination Control Aspects of Operation & Handbook Prepared ML20245L3891989-04-28028 April 1989 Responds to NRC Re Violations Noted in Insp Rept 50-054/88-03.Corrective Actions:Policy Manual on Contamination Control Prepared & Will Be Distributed to Employees Routinely Working in Controlled Areas ML20245D3421989-03-20020 March 1989 Forwards Listed Endorsements,Including Endorsements 14,163, 144,94,75,39 & 31 to Nelia Policies NF-295,NF-100,MAELU Policy MF-29,NELIA Policy NF-182,MAELU Policy MF-61,NELIA Policy NF-281 & Maelu Policy MF-112,respectively ML20236D0211989-02-20020 February 1989 Requests Meeting Re Issue W/Potential Impact on All Test,Research & Training Reactor Members.Integrity of Rulemaking Comment Process Questioned ML20235F8421989-02-15015 February 1989 Forwards to NRR Re Proposal to Meet Requirements of 10CFR50.64b for Conversion of Research Reactors from High to Low Enriched U ML20151W1171988-08-12012 August 1988 Responds to NRC Ltr Re Violations Noted in Insp Repts 50-054/88-01 & 70-0687/88-04 on 880713.Corrective Actions: Hot Cell Emergency Ventilation Sys Use Terminated Until Proper Effluent Monitoring Equipment Installed ML20148K1111988-03-22022 March 1988 Forwards Listed Endorsements to Listed Policies,Including Endorsement 102 to Maelu Policy MF-26,Endorsement 123 to Nelia Policy NF-76,Endorsement 71 to Maelu Policy MF-56 & Endorsement 89 to Nelia Policy NF-189 ML20151R3851988-03-14014 March 1988 Elicits NRC Comments on Proposed Procedure by Which Licensee Would Apply for Exemption from Current NRC Requirement to Convert Research Reactors Using High Enriched U Fuel to Low Enriched U Fuel ML20196K1621987-07-0909 July 1987 Partially Deleted Ltr Submitting Addl Info in Response to NRC 861230 & 870211 Requests Re 860918 Application for Exemption from Requirement to Convert from High Enriched U to Low Enriched U for Reactor Fuel,Per Generic Ltr 86-12 ML20238B1301987-07-0909 July 1987 Advises of Recent Organizational Changes & Updates Re Action Taken to Strengthen Radiation Safety Program.Dj Gallaher Replaced Ww Rudley as President on 870415.T Vaughn Replaced C Konnerth as Operations Manager on 870511 ML20235J7041987-07-0909 July 1987 Submits Addl Info in Response to NRC 861230 & 870211 Requests Re 860918 Application for Exemption from Requirement to Convert from High Enriched U to Low Enriched U for Reactor Fuel.Proprietary Response Encl ML20209E3411987-04-27027 April 1987 Supports Exemption from 10CFR50 Requirements Re Conversion from High Enriched to Low Enriched U Fuel for Cintichem,Inc. Cintichem Produces Over 50% of Mo-99 in Us & Is Only Domestic Supplier of Several Vital Radioactive Drugs ML20213G2881987-04-0202 April 1987 Forwards Comments on Reactor Operator & Senior Reactor Operator Exams Administered on 870327 ML20205Q2081987-03-25025 March 1987 Advises That Listed Officers & Directors Mentioned in 841228 Application for Amend to License R-81 Should Be Deleted,Per Director & Shareholder 870120 Resolutions ML20204H2751987-02-0404 February 1987 Responds to Insp Repts 50-054/86-04 & 70-0687/86-05. Procedure Revised So That Each Unlabeled Drum Will Be Labeled at Time Waste First Placed in Container ML20207N0871986-12-31031 December 1986 Forwards Endorsement 6 to Nelia Policy NF-295 ML20214Q4751986-09-18018 September 1986 Requests Exemption from Conversion from Use of Highly Enriched U,Per 10CFR50.64 & Listed Generic Ltr 86-12 Purposes.Justification Provided ML20206T0191986-05-29029 May 1986 Responds to Violation Noted in Insp Rept 70-0687/86-02. Corrective Actions:Technician Counseled Re Posting of Correct Amount of U-235 Stored in Feed Cabinet 4 ML20198D0651986-05-13013 May 1986 Responds to NRC Re Violation Noted in Insp Repts 50-054/86-01 & 70-0687/86-02.Corrective Actions:Procedure Changed to Require That Waste Drums Be tamper-safed Prior to Analysis ML20210L2431986-03-20020 March 1986 Forwards Endorsement 5 to Nelia Policy NF-295 ML20137N7141985-11-22022 November 1985 Responds to Violations Noted in Insp Repts 50-054/85-04 & 70-0687/85-07 on 850819-23.Corrective Actions:Waste Drums Placed in Waste Storage Bldg & Sign Posted by I-125 Loop Glovebox 1998-06-02
[Table view] Category:VENDOR/MANUFACTURER TO NRC
MONTHYEARML20059N5771990-10-0303 October 1990 Advises That Repairs to Canal & Gamma Pit Sections of Reactor Primary Water Sys Completed,Per Order Modifying License.Licensee Decided to Operate at Level of 10 Ft of Water.Radiation Measurements Will Be Conducted ML20042G5631990-05-0303 May 1990 Requests That NRC Requested Changes to Licensee Physical Security Plan Ref in NRC 900205 Ltr Be Rescinded Due to Vendor Decision to Decommission Facility ML20246B9721989-06-0707 June 1989 Provides Status Rept of Listed Open NRC Insp Items,Per EC Wenzinger 890518 Request,Including Inadequate Training or Procedures to Assure Uniform Plant Operations ML20246M9541989-05-0808 May 1989 Responds to NRC Ltr Re Violations Noted in Insps 50-054/89-02 & 70-0687/89-02 on 890328-31.Corrective Actions:Refresher Training Performed Re Contamination Control Aspects of Operation & Handbook Prepared ML20245L3891989-04-28028 April 1989 Responds to NRC Re Violations Noted in Insp Rept 50-054/88-03.Corrective Actions:Policy Manual on Contamination Control Prepared & Will Be Distributed to Employees Routinely Working in Controlled Areas ML20235F8421989-02-15015 February 1989 Forwards to NRR Re Proposal to Meet Requirements of 10CFR50.64b for Conversion of Research Reactors from High to Low Enriched U ML20151W1171988-08-12012 August 1988 Responds to NRC Ltr Re Violations Noted in Insp Repts 50-054/88-01 & 70-0687/88-04 on 880713.Corrective Actions: Hot Cell Emergency Ventilation Sys Use Terminated Until Proper Effluent Monitoring Equipment Installed ML20151R3851988-03-14014 March 1988 Elicits NRC Comments on Proposed Procedure by Which Licensee Would Apply for Exemption from Current NRC Requirement to Convert Research Reactors Using High Enriched U Fuel to Low Enriched U Fuel ML20235J7041987-07-0909 July 1987 Submits Addl Info in Response to NRC 861230 & 870211 Requests Re 860918 Application for Exemption from Requirement to Convert from High Enriched U to Low Enriched U for Reactor Fuel.Proprietary Response Encl ML20196K1621987-07-0909 July 1987 Partially Deleted Ltr Submitting Addl Info in Response to NRC 861230 & 870211 Requests Re 860918 Application for Exemption from Requirement to Convert from High Enriched U to Low Enriched U for Reactor Fuel,Per Generic Ltr 86-12 ML20213G2881987-04-0202 April 1987 Forwards Comments on Reactor Operator & Senior Reactor Operator Exams Administered on 870327 ML20205Q2081987-03-25025 March 1987 Advises That Listed Officers & Directors Mentioned in 841228 Application for Amend to License R-81 Should Be Deleted,Per Director & Shareholder 870120 Resolutions ML20204H2751987-02-0404 February 1987 Responds to Insp Repts 50-054/86-04 & 70-0687/86-05. Procedure Revised So That Each Unlabeled Drum Will Be Labeled at Time Waste First Placed in Container ML20214Q4751986-09-18018 September 1986 Requests Exemption from Conversion from Use of Highly Enriched U,Per 10CFR50.64 & Listed Generic Ltr 86-12 Purposes.Justification Provided ML20206T0191986-05-29029 May 1986 Responds to Violation Noted in Insp Rept 70-0687/86-02. Corrective Actions:Technician Counseled Re Posting of Correct Amount of U-235 Stored in Feed Cabinet 4 ML20198D0651986-05-13013 May 1986 Responds to NRC Re Violation Noted in Insp Repts 50-054/86-01 & 70-0687/86-02.Corrective Actions:Procedure Changed to Require That Waste Drums Be tamper-safed Prior to Analysis ML20137N7141985-11-22022 November 1985 Responds to Violations Noted in Insp Repts 50-054/85-04 & 70-0687/85-07 on 850819-23.Corrective Actions:Waste Drums Placed in Waste Storage Bldg & Sign Posted by I-125 Loop Glovebox ML20205F1661985-10-10010 October 1985 Responds to 850927 Order to Show Cause.Facility Operates on 95% Duty Cycle at 5 MW Power Level W/Fuel Usage of 28 Std Elements Per Yr.Future Inventory of Seven or Less Unirradiated Std Fuel Element Assemblies Will Be Maintained ML20134D7141985-08-12012 August 1985 Notifies That Name Change Authorized by Amend 23 to License R-81 Effective on 850801.Union Carbide Subsidiary B,Inc W/All Rights,Titles & Interest to All Capital Assets of Sterling Forest Facility ML20133B9551985-04-0909 April 1985 FOIA Request for All Background Matl on Proposed Sale of Reactor by Union Carbide to Hoffman-LaRoche & Hearing Date ML20132D0251985-03-26026 March 1985 Discusses Commission Review of Union Carbide Corp Application to Transfer Sterling Forest License R-81 to Medi-Physics.Author Intends to File Petition for Leave to Intervene in Proceeding within Next 10 Days ML20107N0951984-11-0606 November 1984 Forwards Corrections & Clarifications to Tech Specs in Renewed License R-81 Re Terminology Concerning Safety Limits Operational Setpoints.Addl Fee Should Not Be Required Due to Listed Reasons ML20096B3031984-08-28028 August 1984 Advises That Emergency Plan Implementing Procedures Will Be Revised Following Receipt of NRC Appraisal Team Written Comments ML20087H9841984-03-15015 March 1984 Submits Financial Info Re Operation of Facility,Per 840302 Request.Cost Estimate for Decommissioning Encl.Annual Financial Rept,1982 Forwarded ML20072A1011983-06-0202 June 1983 Advises That Fuel Element Cladding Alloy Changed to Comply W/Tech Specs,Requiring High Purity Aluminum Cladding.B&W Contracted to Fabricate New Fuel Element ML20024A8761983-05-19019 May 1983 Forwards Rev 4 to Physical Security Plan.Rev Withheld ML20023C6401983-04-13013 April 1983 Supplemental Response to NRC 830210 Ltr Re Violations Noted in IE Insp Rept 50-054/83-01.Corrective Actions:Tech Specs Define Three Channel Surveillance Insps ML20023C6451983-02-25025 February 1983 Responds to NRC Ltr Re Violations Noted in IE Insp Rept 50-054/83-01.Corrective Actions:Surveillance Requirements for Monthly Channel Test of Coolant Flow Met During Period 820805-0930 ML20063P3351982-09-29029 September 1982 Forwards Figures Inadvertently Omitted from 800523 Application for Renewal of License R-81 & Addl Minor Changes to Tech Specs ML20069F0901982-09-0303 September 1982 Forwards Public Version of Emergency Plan.Plan Includes Agreement Ltrs W/Augmenting Agencies,Facility Description & Postulated Accidents ML20071M8701982-08-0505 August 1982 Responds to NRC Re Violation Noted in IE Insp Rept 50-054/82-03.Disputes Contention That Contribution of I-133 to Total Body Dose in Unrestricted Areas Was Not Considered ML20042C1001982-03-23023 March 1982 Forwards Annual Operating Rept,1981. ML20038B9131981-11-18018 November 1981 Responds to NRC 811103 Ltr Re Change of Ownership of Facilities.Entire Tuxedo Property,Including Reactor,Conveyed to Newly Formed wholly-owned Subsidiary.Other Assests Sold to Cintichem,Inc.Cintichem Sold to Medi-Physics,Inc ML20003E6411981-03-31031 March 1981 Forwards Previously Omitted Page 5 of Annual Operating Summary,1980. ML19350C7251981-03-31031 March 1981 Forwards Annual Operating Rept 1980. ML19338G0691980-10-20020 October 1980 Forwards Corrected Tech Specs,Originally Submitted W/ Application for Renewal of License R-81 ML19323F6961980-05-19019 May 1980 Forwards Annual Financial Rept 1979 in Support of Application for Renewal of License R-81 ML19309C3941980-03-31031 March 1980 Forwards Annual Operating Rept for 1979. ML19270H7701979-12-28028 December 1979 Reports Intention to Request Renewal of License R-81 Expiring 800630.Safety Analysis & Tech Specs up-to-date ML19256E8551979-11-0707 November 1979 Forwards Executed Amend 12 to Indemnity Agreement B-14 Modifying Prefatory Language Re Course of Transportation. ML19254E8911979-09-26026 September 1979 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 ML19209D0811979-09-25025 September 1979 Notifies NRC That Union Carbide Corp May Be Affected by Upgrade Rule & That Facility May Fall Under Category I. Provides Estimated Economic Impact If Present Criteria Are Changed ML19208B7571979-09-17017 September 1979 Forwards Organization Chart Reflecting Personnel Changes ML19256E1211979-09-11011 September 1979 Responds to NRC 790815 Ltr Re Violations Noted in IE Insp Rept 50-054/79-02.Corrective Actions:No Gaps in Exposure Record Will Be Permitted for Any Unusual Length of Time. Estimate of Exposure Based on Daily Dosimeter Readings ML19276H0121979-08-15015 August 1979 Responds to 790730 Ltr.Safeguards Upgrade Rule Will Not Have Significant Impact on Facility Operation ML19259C0551979-06-0505 June 1979 Ack Receipt of Amend 14 to License R-81.Request Clarification of Environ Considerations in Section C of Safety Evaluation ML19340C0081979-05-0404 May 1979 Responds to NRC 790410 Ltr Re Violations Noted in IE Insp Rept 50-054/79-01.Corrective Actions:Clarification Made Re Interpretation of Term,At Controls.Also Discusses IE Bulletins 78-07 & 78-08 & Circular 77-14 ML19282C7431979-04-10010 April 1979 Provides Responses to Proposed Tech Spec Items Re Potential Reactivity,Organization Chart & Definition of Unplanned Transients. ML19261B6271979-02-21021 February 1979 Requests Immediate Tech Spec Change to License R-81 to Increase Production of U-235,due to Recent Slowdown in Canadian Production Which Threatened Shortage to Us Medical Suppliers ML19263B2381979-01-0808 January 1979 Forwards Annual Operating Summary of 1978 Covering Facility Mods & Major Maint,Procedures Manual,Organizational Changes & Summary of Unscheduled Shutdowns 1990-05-03
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r p.- 4 CINTICHEM, INC.
a wholly owned subsidier y of Medi-Physics, Inc. P.O. BOX 818. TUXEDO, NEW YORK 10987 [914] 351-2131 Sept ember 18, 1986 Mr. Harold R. Denton Director of the Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Denton:
The Nuclear Regulatory Commission's 10 CFR 50.64 Rule iImits the use of Highly Enriched Uranium in domestically licensed research reactors. This rule, though, provides for a " unique purpose" exemption from the requirement to convert from the use of HEU fuels if a licensee can justify an exemption to the NRC. This letter is Cintichem's request pursuant to 10 CFR 50.64 (c)(1) for this exemption and our reasoning why this exemption should be granted to us.
10 CFR 50.2 gives broad definitions for acceptable LEU unique purpose exemptions. The NRC's generic letter 86-12 dated July 3, 1986 gives more specific guidance when a licensee may qualify for an exemption. Two of the generic letter's qualifying purposes fit Cintichem's program welI. These
. purposes are:
1.) "A specific program or commercial activity (typically long term) that significantly serves the U.S. national interest and cannot be accomplished without the use of HEU fuel. This purpose is intended to rel9e to technical activities closely coupled to the national Interest, which might include preeminence in a specific field or assurance of a domestic supp,1y of some essential product o .eactor operation."
- 2) "A reseurch project based on neutron flux levels or spectra available only with HEU fuel. This purpose is intended to provide the opportunity to continue using HEU fuel if converting to available LEU fuel would ci ange neutron flux densities and spectra so that the fundamental reason for conducting the reactor based program would be compromised."
Listed below are six categories. Each category lists a separate topic relating to LEU at Cintichem and gives our reasoning why Cintichem should fit into the NRC's " unique purpose" exemption classification.
40 1 l 8609240371 860918 l
PDR ADOCK 05000054 PDR I(O l
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Page 2 September 18, 1986 A. PURPOSE AND BENEFITS OF THE CINTICHEM FACILITY Cintichem's 5 W MTR research reactor and adjoining hot laboratory are used primarily for the production of medical radioisotopes. Target material is irradiated in the reactor core to produce the desired Isotopes. The radioactive targets are then transferred to the adjoining hot laberatory where the desired isotopes are chemically separated and packaged for shipment to hospitals and pharmaceutical firms throughout the world.
The Cintichem facility is the only commercial supplier ~of reactor-produced isotopes 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 benefits from a nuclear diagnostic procedure. Seventy percent of all nuclear diagnostic procedures are performed with reactor produced Isotopes, amounting to more than 60 milIlon diagnostic tests conducted yearly in the U.S.
Page one of this letter listed two purposes which would qualify a licensee to acquire an exemption. Purpose 1 relates to a program that a) serves the U.S. national Interest; b) involves preeminence in a specific field; and c) provides assurance of a domestic supply of an essential reactor product. Clearly, Cintichem's program f its into all three of these categories.
B. LOSS OF PRODUCT The NRC's Regulatory Analysis of its then proposed HEU rule expressed concerns about the societal cost from any loss of reactor capabilities.
It stated that for f acilitles above 1-2 W power, LEU conversion could have an impact un the source of neutrons necessary for production processes. Of most concern in the NRC's analysis was the capability to produce short-lived isotopes for medical research and diagnosis, which could be affected by temporary or permanent facility shutdowns or competitive market forces. The Regulatory Analysis stated, however, that the provisions of the rule are Intended to provide opportunity for minimizing any potential losses in f acility capabilities and availability.
We fully support.the NRC's concern for the societal cost of a reduction of the U.S.-produced radioisotope capacity. We also agree with the NRC's hope that the rule's provisions, notably the " unique purpose" exemption provision, can be used to minimize or eliminate this loss of domest!c reactor capabliItles.
SpactfIcally, Cintichem belleves that conversion of our reactor to Iow enriched fuel will have an adverse impact on the operating characteristics of the reactor for producing radioisotopes and other nuclear services.
The known reduction of thermal flux with LEU conversion is a major Concern.
The IAEA LEU Core Conversion Guidebook (IAEA-TECDOC-233 App. F-1 MTR Benchmark Calculations) concludes that a hardened neutron energy spectrum and an approximate 10% reduction in the thermal neutron flux can be expected af ter LEU conversion. This was confirmed in the Ford Reactor
Page 3~ September 18, 1986 B. LOSS OF PRODUCT (continued) conversion to LEU. Our reactor is basically a thermal neutron source for producing radioisotopes and performing nuclear Irradiation services. A 10% reduction in thermal neutron flux will result in a 10% reduction in product and productivity. The " harder" flux will also reduce the quality of our major service Irradiation work, neutron transmutation doping of electronics grade silicon.
The flux hardens with LEU conversion even while the power level of the core is maintained at 5 MW. Therefore, to produce the same number of thermal neutrons and correspondingly the same number of radioisotopes by thermal neutron !aduced nuclear reactions, the reactor power level would have to be increased by 10% _ The Cintichem reactor cannot easily be run
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at 5.5 MW. This is .due to the existing reactor plant's cooling capabilities and present power level licensing linits. . S imil arl y, radioisotope production could not be increased by increasing reactor operating time as we now operate at a greater than 95% duty cycle. The 5%
. down time is necessary for reacter maintenance and refueling. Other constraints dictated by product specifications, such as product half lives and induced long i Ived contaminates, also preclude the longer operating time as a solution to this problem. The neutron flux energy spectrum in
. LEU cores may also alter control rod worths, the ef fective delayed neutron
! fraction, and other important characteristics, all of which could change 1 operating margins. A reduction in rod worths could detrimentally ef fect l our duty cycle, requiring more refueling and reactor down time.
Page one of this letter Iisted purpose 2 as an accepted reason to achieve
, an exemption. It was intended to provide a lIcensee the opportunity to continue using HEU fuel if LEU conversion would change neutron flux
, density and spectrum so that the fundamental reason for a lIcensee's operation was compromised. As explained above, the 10% loss of product clearly compromises our program and this fact alone should justify granting Cintichem an exemption.
C. WASTE CLASSIFICATION Cintichem Irradiates uranium targets to produce fission product Isotopes.
Only a smalI portion of the fission product isotopes produced are marketable. The remaining isotopes are radioactive waste. This waste is presently classified via 10 CFR 61.55 as low level Class B radioactive waste. If LEU' fuel conversion at Cintichen is mandated, the hardened flux spectrum will change the waste characteristics and it could result in changing the ' waste category. This occurs because the hardened flux, t manifested by the reduction of thermal flux and the increase in epithermal
. flux, will increase Pu-239 production via the U-238 neutron-gamma reaction. This will, at a minimum, add a substantial cost to waste disposal, but at worst, could preclude our use of commercial Class B low level waste disposal areas.
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Page 4 September 18, 1986 D. REACTOR SAFETY The I AEA's LEU Core Conversion Guidebook (I AEA-TECDOC-233 Section 1.4.1) states that "the agreed criteria for LEU conversion is that safety margins and fuel reliability should not be lower than for current HEU designs".
Cintichem questions if this technical criteria for LEU conversion has been or can be achieved with the proposed LEU fuels. The presently used low density, high enriched fuels have been proven to be reliable over-approximately 30 years of normal operation in numerous reactors and also under accident conditions as demonstrated in the SPERT and BORAX tests.
Normal performance of the lower density LEU fuels has been modeled in computer codes and verified in operation, but performance under accident conditions has not been verified with experimental data. In the areas of safety and reliability the presently used aluminide and oxide HEU fuels are excellent. The new HEU fuel types, with dif ferent fuel densities and thermal conductivities, could alter the retention of the fission product source term and they should be fully understood under accident conditions before wholesale conversion to LEU is mandated.
We also anticipate numerous changes in core parameters with a changeover to an LEU core. Some of these parameters, notably the ef fective delayed neutron fraction and the control rod worths, could effect our safety margins and therefore require changes to our operating parameters, which could have a detrimental ef fect on our radioisotope program.
E. REQUALIFICATION OF PRODUCTS All the products and services provided by the Cintichem reactor were developed in an HEU core. If Cintichem's reactor were to convert to LEU, all these products and the product waste would have to be requalified.
Our major product is radlochemical grade Technetium-99m, a daughter of Molybdenum-99. This product would have to be requallfled for purity following LEU conversion. Our fission product waste is currently classified as Class B low level waste. LEU conversion would necessitate a reevaluation of the classification as transuranic isotopes in the waste would increase. Our predominant service irradiation is the neutron transmutation of electronics industry silicon. An LEU core, with its harder flux spectrum, would cause greater f ast neutron silicon crystal damage and would lower the quality of our Irradiation product. These are only three specific examples of product requalification concerns. Each of our products would have to be Individually analyzed and requallfled.
F. FINANCIAL & MARKET CONSIDERATIONS This section discusses the financial and radioisotope market consequences of Cintichem converting to LEU reactor f uel.
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Page 5 September 18, 1986 F. FINANCI AL & MARKET CONSIDERATIONS (continued)
A Cintichem LEU core resulting in a reduction of 10% in the flux / power ratio in the reactor core would result in a 10% overall reduction in the yield of a product for the same amount of work performed. This would increase the overall product cost proportionally by 10%. Our current assessment of the effect that converting to LEU reactor fuel will have on radioisotope costs includes other cost elements beside the reduction in thermal neutron flux. These changes are summarized in the following table.
Cost Factor Cost Factor / Total Cost Factor Estimated increase Total Cost increase Fuel Fabrication + 15% 4% < 1%
Flux / Power + 10% 100% 10%
Fuel Reprocessing + 20% 4% < 1%
Waste Disposal + 50% 12% 6%
Total 18%
The cost factors listed above are those which we can Identify at this time. Others will probably become evident as more experience is gained in f uel development and in reactor operation with LEU f uel.
The fuel fabrication estimate was provided by one manufacturer who has had minimum experience working with the relative higher density LEU loadings.
We believe our reactor will require the highest density fuel loading (greater than 4.5 gm U/cc) in order to maintain our 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 with silIcide fuel and, since fuel fabricators have had no ongoing production experience with this process, this estimate could be inaccurate.
The fuel reprocessing cost was developed by assuming that the DOE would continue this service and that the charges will continue to be based on the gross weight of the fuel processed. It is estimated that the LEU fuel will weigh about 20% more than the HEU fuel. If commercial fuel reprocessing is ever resumed, this number may change radically because it is assumed that DOE would defer to commerce in this function.
The waste disposal figure assumes that the transuranic content of our Isotope production waste will increase due to the hardened neutron flux in the core. The current effective production cross section for 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 thermal neutron capture cross section for this reaction. The difference is attributable to the resonance capture of epithermal neutrons. As the neutron flux spectrum hardens with LEU 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 were deemed to exceed Part 61 limits, there is no practical method of estimating the added cost at this time because there is no t
current disposal method for such waste. This issue has the potential for terminating the business.
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Page 6 September 18, 1986 F. FINANCIAL & MARKET CONSIDERATIONS (continued)
These are the cost elements of radioisotope production that we now can predict will increase as a result of converting the reactor fuel to LEU.
The total estimated 18% increase applles 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 factors could develop that cannot be anticipated now. Not included in the above estimate are the costs that we can foresee that will be involved in the initial reactor conversion. There will be man-years of work in revising technical specifications, safety analyses, licenses, operating procedures, and training documents in addition to the work of the actual conversion.
Also of note here is that NRC's Regulation Analysis implied that the costs involved in an LEU conversion would only involve initial changeover costs.
As discussed above, this 18% Increase is an ongoing cost carried on Indefinitely after core conversion.
The above financial assessment just addresses the incremental ongoing radioisotope cost increase. Also a factor here is that an LEU conversion with. Its 10% less thermal flux could prevent us from meeting our customers' curie capacity requirements. We occasionally run at 100%
capacity and a 10% reduction in capacity could result in an isotope short fall, possibly resulting in our customers seeking alternate suppliers.
This loss of 10% capacity could not be casily accommodated by a 10%
increase in power level as cooling systems would have to be suppleinented.
Also, our present duty cycle of > 95% cannot be increased. This loss of capacity would damage us in the marketplace.
Other market considerations are that there are only a few major suppllers of reactor-produced radiochemicals in the world. We are the only commercial domestic supplier and we participate in a world market against competitors who are subsidized by their governments and who use HEU. We must emphasize that this business is conducted as a separate and distinct entity from the radiopharmaceutical Industry which it serves. The estimated cost increase wilI have to be fully absorbed wIthin this business and it will be very recognizable by the pharmaceutical manufacturers, who are our customers. If competing producers are not subject to the same cost pressures, we would be at a definite disadvantage. Since our competitors are not wholly commercial entities and they are not subject to the same regulations, we believe that we will be at a definite competitive disadvantage.
If Cintichem was forced out of the radioisotope business, it would be possible for other DOE operated reactors to fill the gap, but this could not be done immediately. A substantial lead-time would be required to Install irradiation and radiochemical processing f acilities to meet the production volume requirements. This became very evident when the General Electric Test Reactor (GETR) ceased operation in 1977. Fortunately, the Cintichem reactor had suf fIclent excess capacity at that time to fili a major part of the gap lef t by the GETR. The demand that we were not able to satisfy went to foreign suppliers. Our guess is that a DOE facility
Page 7 September 18, 1986 F. FINANCIAL & MARKET CONSIDERATIONS (continued) could not respond quickly enough to fill a future precipitous gap and therefore most of the demand would go to foreign sources. If current foreign suppliers could not fill the shortf all completely, there would be a shortage of supply for some indefinite period.
The exact gross sales that are generated from the sales of radioisotopes is considered by us to be business-confidential .information. We can say though that the sale of bulk radioisotopes is in the order-of-magnitude of 10's of millions of dollars. There are approximately 100 people directly involved in the production and distribution of bulk radioisotopes. It should be mentioned that the extension of the bulk radioisotope business into the manufacture of pharmaceuticals and research chemicals is an industry that employs thousands of people and ' generates a revenue of hundreds of millions of dollars.
Page one of this letter iIsted purpose 1 as being an acceptable reason for obtaining an LEU exemption. Cintichem feels that these financial and market considerations substantiate our bellef that we meet the objectives of purpose 1. Curtallment of our ability to produce and effectively market our products would not be in the national interest and would jeopardize a domestic supply of an essential reactor product.
CONCLUSION Cintichem submits that the use of our reactor fits into the 10 CFR 50.2 rule category of " unique purpose" for the above stated reasons and accordingly requests the exemption per 10 CFR 50.64. Cintichem has addressed this LEU issue in numerous earlier letters to the NRC and to the U.S. House of Representatives Committee on Science and Technology. If the Commission, in its review of this letter, requests more information or copies of our earlier letters, we will be happy to supply them.
Sincerely, W W ha y sL46~
Wlll1am G. Ruzicka Manager, Nuclear Operations WGR: mag Enclosures cc.: Mr. Herbert Berkow, NRC Mr. Hal Bernard, NRC
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