ML20234B997
| ML20234B997 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 09/23/1987 |
| From: | Mcgovern J CINTICHEM, INC. |
| To: | Emeigh C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 28903, NUDOCS 8801060070 | |
| Download: ML20234B997 (2) | |
Text
7H87 mq Pot tTR.osty CINT! CHEM, INC.
a wholly owned subsidier y of
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Medi-Physics, Inc.
p.a. sax e,s. TUXEDO. NEW YORK 10987 (914) 3 51-2131
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September 23 1987 e
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U.S. Nuclear Regulatory Commission RECENED Division of Safeguards & Transportation, NMSS DEC 29198L }
Licensing Branch 9
Washington, D.C.
20555 I
,pVCLEAR REGULATORT T Attention:
Mr. C.W. Emeigh cogsjcl Reference (a) FR 10033, 3/30/87
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MallSoction (b) NRC, NMSS Letter 5/1 2'
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Dear Mr. Eateigh:
The Federal Register Notice concerning the-final rule on
" Material-Control and Accounting Requirements for Facilities Licensed to Possess and Use Formula Quantities of Strategic Special Nuclear Material" (Ref. (a) ) states in the supplementary information that the new rulemaking specifically applies to four enriched uranium processing facilities.
Cintichem is not mentioned among these facilities.
It also states-that licensees processing special nuclear material of Moderate Strategic Significance and potential licensees processing strategic special nuclear material in irradiated fuel reprocessing plants will continue to be subject to the Material Control and ' Accounting requirements (MC&A) of 10 CFR Pt70.
Cintichem is authorized by its R-81 and SNM 639 licenses to possess strategic special nuclear material in excess of-the formula quantity limit; however, most of the material is in the form of irradiated reactor fuel, irradiated isotope production targets and isotope production waste which includes fissilon products.
This material is not readily separable from mixed fission products and it meets the criteria for exemption.as'self-protected SNM per 10 CFR 73.6 (b).
Therefore, as a "plactical matter, the total inventory of SNM under both Part 50 and Part 70 licenses is limited to a quantity of no greater than thetahf3 moderate strategic significance.
Chapter 7 of the Cintichem FNMC plan describes how SNM (under SNM 639) is handled throughout the isotope production part of the operation.
Reactor Operations procedure RM-10 describes how tor fuel (under R-81)is handled through the reactor facility.
d of these documents are enclosed-for convenient reference.
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'Y Occxho* O trol on the quantity and location of unself-protected c
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I U.S. Nuclear Regulatory Commission P.2 Div. Safeguards & Transportation, NMSS 9/23/87 special nuclear material is dictated by the Security Plan as currently revised for the site and also by-the Technical Requirements of the SNM 639 License (Sec. 4.2).
' Inclusion'of the Security Plan is by reference only because it is considered
" Safeguards Information."
A copy of the SNM 639 Technical License Condition 4.2 is enclosed for. convenient reference.
It can be seen from these license requirements that unself-protected SNM in any single location is limited to a quantity ' that-is of low strategic significance.
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I The Cintichem MC&A program is conducted in accordance with the current FNMC plan which is pursuant to 10 CFR Pt 70.
he submit that Cintichem:
s; (a) never possesses more than a formula quantity of unselfv protected special nuclear material on site; (b) keeps the quantity of unself-protected SNM in any single location within the plant to that of low strategic sig-nificance; (c) is a hybrid facility operating under 10 CFR Parts 50 and 70 and does not specifically fit the type of facility addressed in 10 CFR Part.74 Subpart E.
It is not likely that either a formula quantity or a quantity of SNM of moderate strategic significance can be diverted f rom the
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Cintichem operation because of the above stated license limitations on the quantity, the form and the location of special nuclear material within the plant.
We therefore request an exemption as provided for under 10 CFR Part 74.7 and as dascribed
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in Ref.(b) above, c
We respectfully submit that the granting of this exemption will jeopardize neither the general health and welfare nor the 4
national security.
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