ML20235J704
| ML20235J704 | |
| Person / Time | |
|---|---|
| Site: | 05000054 |
| Issue date: | 07/09/1987 |
| From: | Mcgovern J CINTICHEM, INC. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GL-86-12, NUDOCS 8707150697 | |
| Download: ML20235J704 (20) | |
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- CINTICHEM, INC.
a whoUy owned subsidary of .
fvledi-Physics, Inc. P.O. BOX 818. TUXEDO, NEW YORK 10987 1914) 351-8131 1 \
July 9, 1987 I
U.S. Nuclear. Regulatory Commission.
Director of the Office of Nuclear Reactor Regulations Washington, D.C. 20535
Dear Sir:
REF. (a) Cintichem Letter, WGR 9/18/86 (b) NRC Letters, 50-54. 30/86 and 2/11/87 1
Title 10 of the Code of Federal Regulations Part 50.64 allows reactor licensees to apply for a unique purpose exemption from the requirement to convert from high enriched uranium (HEU) to low enriched uranium (LEU) for reactor f uel . Generic letter 86-12 provides specific guidances by which licensees may apply for such exemptions and also the criteria by which' they , ;
may be granted by the Commission. 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) ebove. 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 radioisotopes 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 Cintichem reactor as a commercial enterprise which functions within and is influenced by a worldwide market and which is dependent upon the economic viability of the program.
Cintichem's 5 MW 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 laboratory where
'the. desired isotopes are chemically separated and packaged for shipment to
. hospitals and pharmaceutical firms throughout the world.
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2 The ' Cint'ichem ~ f acilIty !s 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 and seventy percent of. all nuclear diagnostic procedures are performed with reactor-produced isotopes, amounting .to more then 125 million i n, v ivo and .l_nn v itro diagnostic tests' conducted-: yearly in the U.S.
Cintichem's production of medical radioisotopes is in the national l'nterest because , Cintichem is the only domestic source of several ' vital isotopes that are ' essenti a l 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 4 Approximate Amount Medical isotooes From Cintichem Mo99/Tc99m 54%
l-131 50%
Xe-133 13%
1-125 25%
P-32 100%
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. 3 TABLE B Percent Provided Procedure No./Yr. By Cintichem IN VIVO TESTS:
Mo99/Tc99m Dinanostic Scans 1 Brcin 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 Dlaanostic Scansl Thyroid 104,000 Kidney 63,000 TOTAL 167,000 50%
l-131 Therapy Thyroid 156,000 -50%
Xe-133 Luna Scans 545,000 13%
fr-192 Implants 1,068,000 50%
IN VITRO TESTS:
1-125 Radioimmunoassays 2 120,000,000 33%
1 Market Measures, Inc., 3rd Quarter 1986 - (Quarterly Reports of Products Used for in Vivo Radiodtagnostic Procedures Performed 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.
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i I . TECHNICAL ISSUES Medical radioisotopes, of necessity, are short lived. They cannot be stored or stocked for future use. Therefore, it is necessary that production facilities operate continuously (day to day) and reliably at a sustained capacity in order for the medical community to have these materials 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 radioisotopes within the United States. Statements from the Society of Nuclear Medicine and the American College of Nuclear Physicians attesting to this are being forwarded under separate cover.
Cintichem's role was achieved not only through the application of Innovative technology but, more importantly, it is maintained by providing a continuous reliable supply of these short-lived isotopes. This facility must also stay viable economically as a commercial venture. Sustained reliability and economic viability then are essential for maintaining Cintichem's position as the preeminent supplier of these isotopes in the U.S. as well as a major suppller in the International market.
The NRC Regulatory Analysis of its originally proposed lieu rule expressed concerns about the societal cost from any loss of reactor capabilities. It l stated that for f acilities above 1-2 MW power, LEU conversion could have an '
impact on the source of neutrons necessary for production processes. Of most conce. , 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 by competitive market forces.
The Regulatory Analysis stated that the provisions of the rule are intended to minimize any potential losses in facility capabilities and availability.
Cintichem f ully appreciates and supports the NRC's concern for the societal cost of a reduction of the U.S.-produced radioisotope capacity. C!ntichem also agrees with the NRC's stated desire that the rule's provisions, notably the " unique purpose" exemption provision, can be used to minimize 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 ajverso impact on the operatino characteristics of the reactor f or producino radioisotopes and other nuclear services. The result will be a 10% reduction in Isotope production capacity and inevitable shortaces of suppf v of medical isotopes to the U.S. market. The known reduction of thermal flux, the change in neutron energy spectrum and the anticipated reduction in core excess reactiv!ty will be detrimental to the isotope production program at Cintichem.
The IAEA LEU Core Conversion Guidebook (IAEA-TECDOC-233 App. F-1 MTR Benchmark l Calculations) concludes that a hardened neutron energy spectrum and an approximate 10% reduction in the thermal neutron flux can be expected after l
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The Cintichem reactor is basically a thermal neutron source for producing radioisotopes and performing nuclear Irradiation service. A 10% reduction in the thermal neutron flux will result in a 10% reduction in isotope production capacity. Simply put, radioisotope production is expressed as a function of
- target atoms x cross section x flux x saturation f actor. Target atoms, cross section and flux are scalers in this equation while the saturation factor 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 halfilfe of the radioisotope being produced.
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 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 license limits. Similarly, radioisotope production could not be increased by increasing reactor operating time as the reactor now operates at en apf oximate 95% duty cycle. The 5% down time is necessary for reactor maintenance and refueling. Other constraints dictated by product specifications, such as product half 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:
"The total primary coolant flow utilized by all in-core experiments shall meet the following requirements; fraction of core flow in experiments .5 1-5/6 (fraction of rated power production in fuel 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 1/61h flow can be given to the experiments.
Cintichem fission product isotope targets do produce fission power and theref ore Cintichem al lows the total experimental flow to be greater than 1/6th of the total core flow.
Knowing the flow rates through the isotope target stringers and the fuel elements, the percentage of the total core flow through all experiment positions is calculated. This
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1 actual experiment flow rate is then compared to the maximum-allowed experiment f low rate. The maximum allowed experiment flow rate is calculated with the te above technical specification formula using the known. amount of power produced in'the fueled experiments. ThIs calculation is done at normal minimum total core fIow rate of 2000 gpm. There is .insuf ficient flow to add more f aeled targets and therefore Cintichem is at the current limit.for the. number of Mo99 production targets. No more core space can be dedicated to fission product molybdenum r oduction, given the limitations of the-technical specifications, the present ,. ; duct mix and the current state of target technology, increases in isotope capacities can only be achieved through tradeoffs. An increase in one isotope most be accommodated by reductions or changes in other products, services, or wrating parameters.
Cintichem has reviewed the available data on control rod worth changes
' following a conver. n from HEU to LEU f uel. Experimental and theoretical data indicate that e decrease in rod worths -will be experienced. The whole i core LEU demonstra. ion at the Oak Ridge reactor and other sources have
. predicted that, in general, control ' rod worths would go down by approximately five percent with LEU fuel due to the harder neutron spectrum and less neutron absorption in the control rods relative to the f uel. A-five percent reduction of control rod worths would decrease current operational maximum excess reactivity ' which is dictated by the technical' spect fIcation i imit. on ' minimum shutdown margin. This reduction would decrease the operating time between refuelings and, because we run with the highest duty cycle practicable, extra-shutdowns - to ref uel would decrease . our productivity. This' ef feet can be initially evaluated as follows:
HEU Core LEU Core Gang Rod Worth +9.35% +8.88%
Xenon EquiI. -3.50% -3.50%
Power Coeff. -0.35% -0.35% !
Max. Worth Rod -2.65% -2.52%
Excess SDM -0.505 -0.50%
AlIowabte Excess Operating Delta K/K +2.35% +2.0f%
i Change in allowable excess Delta K/K = -14.5%
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-Therefore the allowable operating time between reactor fuel loadings will decrease by approximately 15% as a result of a 5% decrease in rod bank worth.
This: would result in a reducricn in overall duty cycle and consequent reduction in Isotope production capacity.
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^ The reduction in thermal neutron flux and the anticipated 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 future occasions) when one of the foreign producers of medical isotopes will experience an interruption or a shortf all in production and Cintichem has had to go to maximum capacity to make up this shortage. if Cintichem loses the current capacity due to conversion to LEU, it will not be ,
able to completely make up for future shortfalls. Since a large portion of the current domestic supply is dependent on the imports, there will be a shortage of medical isotopes in the U.S. as well as overseas. Additionally, any reduction of Cintichem's current capacity will limit our ability to maintain a preeminent role in the f uture expansion of 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 isotopes produced in an LEU core would be comparable in quality: product and waste requalif ications would be necessary resultino in disturbance in the continuity of supply of important medical isotopes. The rellable and continuous supply of medical isotopes (particularly Mo-99) could also be adversely af fected due to changes in the characteristics of the product due to the anticipated changes in the neutron energy spectrum within the core. The isotopes end. services that are currently provided f rom Cintichem's HEU f ueled core could also be produced In an LEU f ueled core but it is uncertain if they would be comparable in quality.
For example, the predominant isotope produced in the Cintichem facility is Mo-
- 99. It is made through the fission reaction of U-235 and then it is separated from the other f Ission products by a process that has developed and evolved over more than 15 years. The production process is compatible with the plant design and physical capacity.
The Mo99 isotope is used as the active ingredient of a parenteral drug product and as such has been well quellfied. it is characterized particularly to be f ree of transuranic elements. The anticipated change in the 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 requalifIcation of this product.
Requalification would involve Irradiating targets in a low enriched uranium core, processing the targets to remove the molybdenum, and then testing for conformance with specifications on radionucl idic purity, i.e. absence of gemma, beta, and alpha emitters. This testing generally requires the test material to be decayed and then analyzed on a mass spectrometer. (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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10 finished drug product from this material, i.e. molybdenum-technitium generator, and then test the elvent from this product for radionuclidic purity, radiochemical purity, and pharmacological efficacy. This requalification would require the core to be in place and operating. The I analysis would have to be done on the finished drug product and it would be a time-consuming process. Cintichem does not see how this can be accomplished without causing some disturbance in the continuity of supply of this isotope.
Requalification 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 I:; highly dependent on the waste plutonium content which t changes significantly as the core's neutron energy spectrum changes, it 4 therefore would be necessary to requalify the weste produced as thoroughly as the radioisotope products. This waste reclassification would be a time consuming complex process.
Making the overalI requalifIcation process even more complicated is the f act that actual conversion from HEU to LEU fuels is a long process. The anticipated method of core conversion would be to proceed f rom HEU to LEU by incrementally introducing LEU f uel elements into an HEU core. As the HEU elements become depleted, more LEU elements would be added, resulting, after a year or so, in a full LEU core. This process would result in the overall core neutron energy spectrum slowly changing from 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 requalification effort.
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 requalification during the conversion period. Cintichem believes that it is unreasonable to have to bear this added contingent economic burden as a consequence of con-verting to LEU.
(c) Other services for non-medical efstomers 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 community. We also have a program in which reactor service Irradiations are performed for various non-medical use customers. The largest contingent in this category is to produce neutron transmutation-doped silicon. It is complementary to the radioisotope program and does not compete for reactor core space.
The doping of high purity silicon is done by the reaction, SI-30 (n, gamma)
SI-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
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p1-11 productivity. On the other hand, f ast neutron flux causes crystal defects' to occur. With a harder flux spectrum, more f ast neutron crystal ' damage will
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occur. 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 acilities to dope their silicon. Cintichem~
Includes the silicon concern in its unique purpose exemption request because LEU conversion will harden the neutron spectrum, cause more silicon crystal defects, cause lower doping productivity, and therefore 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 er.richment) reactor f uel will also apply to intermediate enrichment but it Is diffIcuit to say, wIthout experimentation, what enrichment wIll be insignificant,in every respect. Any change could be significant until it is proven not to be.
Cintichem 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 complications has the potential for causing eventual shortages; all of them combined will surely have a detrimental effect in the future.
Ill. ECONOMIC ISSUES Cintichem understands that'the NRC has indicated that econom!c benefit is not a basis for a unique purpose exemption, but when economic viability is one's raison d'etre and, without this viability the sol'e domestic supplier would cease operation, it then becomes a pertinent. con',lderation for assuring the supply of a material which is vital for the natloaal health and welfare.
In addition to these domestic concerns, t: a Cintichem facility is a net exporter of products and services which contribute positively to the U.S.
Balance of Trade Payments. . The loss of this facility would have the compound effect of the loss of income from current exports from the facility as well as from the purchase of all product and services that are currently distributed domestically As an introductory comment to these ccenmercial considerations Cintichem belleves it important to note that the final rule on non-power reactor conversion to LEU f uel was expanded to include " commercial activity" in the u definition of ' unique purpose. NRC Generic Letter 86-12 includes the
" assurance of a domestic supply of some essential product" as a valid consideration f or a unique purpose exemption. Any commercial enterprise is based primarily on the expectation that profit, return on investment, and growth.wilI occur. Without these results there is no motive for sustaining a business. Cintichem believes that commercial viability must at.least be a valid. factor in determining whether a program can reasonably be continued by private enterprise without the use of HEU fuel.
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The fuel fabrication estimate wes provided by manufacturers who have had limited experience working with the relative higher density LEU, loadings.
Cintichem believes its reactor will require the highest density fuel loading (greater than 4.5 gm U/cc) In order to maintain present design metal / water ratio and fuel element burn up which is currently at > 50% of the fissionable material, This high density can only be achieved with silicide f uel and, since f uel f abricators have hed no ongoing production experience with this process, this estimate could be inaccurate.
The weste disposal figure assumes that the transuranic content of the isotope production waste will increase due to the hardened neutron flux in the core.
The current offective 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 factor of 2 above the thermal neutron capture j
cross section for this reaction. The difference is attributable to the i resonance capk . 9f epithermal neutrons. As the neutron flux spectrum hardens with LEU conversion, the Pu production increases. The amount by which 1 It does has been conservatively estimated by applying the highest theoretical )
cross section. If the Pu content of the weste caused the weste classification to change from B to C it could lead to higher cost and reduced availability of disposal space. These details are unclear at this time.
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l Last known price of silicide fuel used in ORR 2 F.R. Vol . 51, IJo. 32 p.57.24, 2/18/86 I
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These are the cost elements of radioisotope production that Cintichem now predicts will increase es a result of converting the reactor f uel to LEU. The total estimated increase applies to the routine, direct, ongoing expense of production. Since it is estimated that the conversion to LEU f uel 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 Cintichem can foresee that will be involved in ihe initial reactor conversion.
There will be man-years of work in revising tdchnical specifications, safety analyses, licenses, operating procedures, end 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 inittel cost. Also of note here is that NRC's Regulatory Analysis implied that the costs involved 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 i Clntichem, the Federal Government, in mooting its rule to fund facilities for all the costs of LEU conversion, should provide f unding for the Initial core conversion and ongoing annual subsidies to of f set the higher production costs associated with LEU fuels. Cintichem also notes that the U.S. Department of Energy has nott f led us that Federal f unding for a Cintichem LEU conversion will not be made avalleblo during fiscal year 1987 and that current D.O.E.
plans only include initial funding and only for university reactor conversions. The D.O.E.'s February 11, 1987 letter eddressing th!s subject is enclosed.
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Other market considerations are that there are only a f ew major suppllors of reactor-produced radiochemicels in the world. Cintichem is the only commerclei domestic supplier and participates in a world market against competitors who are subsidized by their governments or use government owned reactors .
Cintichem's main competitors are AECL (Canada), lRE(Belgium), Australlan !
Atomic Energy Agency and East Germany, it must be emphasized that this l business is conducted as a separate and distinct entity from the I radiopharmaceutical Industry which it serves. The estimated cost increase will have to be fully absorbed within this business and it will be very recognizable by the pharmaceutical manuf acturers, who are our customers, if j competing producers are not subject to the same cost pressures, Cintichem )
would be at a definito disadvantage. Since Cintichem's competitors are l not wholly commercial entitles, and since they use higher powered, govern- i l
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. 4 14 ment owned test reactor f acilities, Clntichem believes that it would be at a def inite competitive disadvantage. SpectfIcalIy, conversion to LEU in a iow power reactor is more significant from the standpoint of production cost than it is in a high power reactor. Production batch sizes vary with core power level. The direct incremental cost of production is inversely proportional to production batch size. The direct incremental cost of production in a low power reactor, therefore, is a much higher fraction of the total cost than it is in higher power reactors. Assuming the fixed 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 wou!d be magnified in the cost experience 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 radiochemical, margins are made and price is often based upon incremental direct production cost.
l C!ntichem has the lowest powered reactor of all the radioisotope producers and j hence it will experience the highest direct production cost increase and it will be placed at a competitive disadvantage.
It is unlikely that the increase in w st could be compensated for by increasing prices because of the aforementioned competition. Cintichem, as a private business enterprise, requires profitability and growth to stey viable. The instantaneous and continuing econcmic consequences of converting to LEU reactor fuel could jeopardize its existence, iV. CONCLUS10N in summary, Cintichem is applying for a unique purpose exemption from the requirements under 10 CFR Pt 50.64 to convert the reactor f uel f rom HEU to LEU for the following reasons:
- 1. Cintichan has a preem inent position as a commercial suppller of certain r,w ical radioisotopes which are vital in the practice of nuclear medicine and that it is in the national interest to maintain this sole domestic supply capability.
- 2. It is imperative to the practice of nuclear medicine to have contPnuity of a ready and adequate supply of short-lived isotopes.
- 3. Conversion of the Cintichem reector fuel to LEU will cause a reduction in isotope production capacity by at least 10% which will resul t in shortages of certain isotopes when other producers cannot supply their usuai share to the market due to technical difficulties, ,
as has happened in the past.
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- 4. It will practically be Impossible to requalify products and waste made in the Cintichem 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 assocleied changes in operating and training documentation, and the recharacterization of radioisotope products and waste, will not be subsidized under the current DOE f unding plan. Competitors use reactors owned and operated by government agencies or consortia and they will be relatively unaffected by conversion costs of this kind.
(b) The ongoing added cost of production caused by lower yields and other cost elements previously mentioned are directly related to product and, because Cintichem's direct production cost is a higher portion of total production cost compared to suppllers using higher powered reactors, Cintichem will experience a greater cost increase than its competitors.
(c) Conversion to LEU reactor fuel will adversely affect reliability and ef ficiency of Cintichem services. These competitive disadvantages wil I impact negatively on Cintichem's success In the radiositope market. Cintichem relles on profitability and growth to justify its continuance.
In my opinion, conversion to LEU reactor fuel could be the cause for Cintichem's eventual discontinuance as a domestic source of medical radioisotopes.
Very truly yours, f poA
. J. M overn Senior Vice President JJMcG:eb enc.
L____--_______-_____-________-_ _ _ _ _ _ _ _ ___-________-____ _ _-____________________ _ - _ _____- - -_ _ _ _ __ _ _ _- - _ ___ __ _ ___
CINTICHEM,' INC.
a wholly owned subsidiary of.
Medi-Physics, Inc. . p.a. eax sie. Tuxsoa. NEW YORK 10987 [914] 351-2131 CINTICHEM-APPLICATION Cintichem, Inc. hereby makes application to withhold a portion of its letter of July 9, 1987 to the Nuclear' Regulatory Commission l from public disclosure on the grounds.that it contains confidential, commercial, and financial Information, as.more specifically set forth in the affidavit of James J.
McGovern,-attached hereto. '
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U.S. NRC i J
In The Matter Oft Docket 50-54 Cintichem, Inc. Reactor License Application For Exemption R-81 Under 10 CFR 50.64 (c) 1 Affidavit of James J. McGovern I, James J. McGovern, affirm under penalty of perjury that the following Is true and accurate to the best of my knowledge, Information, and belief and is based on my personal knowledge or l on Information contained in the record of Med!-Physics and Cintichem:
- 1. I am Senior Vice President and Plant Manager of Cintichem I which is applying for exemption from the requirement to cen-vert the reactor fuel from high enriched uranium to low en-riched uranium, for the purpose of maintaining continuity of supply of vital medical radioisotopes.
- 2. This affidavit is in support of the request to withhold from i public disclosure certain information that is contained in l our application supplement dated July 9, 1987 on the basis ;
that it is confidential, commercial, and financial infvrma-
-tion, including information about market share, production capacity, production cost, and pricing. The specific infor- l mation we wish withheld is as follows:
(a) Page 5, last paragraph, the sentence beginning with "The reactor" and ending with "the core".
(b) Pages 8 and 9, Table C.
(c) Page 11, Section lil, second paragraph beginning with l
"(approximately" and ending with " currently)". 1 (d) Page 12, first paragraph beginning with the words "A Cintichem LEU " and ending with the words " LEU fuel".
1 (e) Page 13, first paragraph, line 3, the number "19.5%"
and line 14, the number "19.5%".
(f) Page 13, second paragraph in its entirety.
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l -(g)-Page 14, second paragraph, line 3, sentences beginning k with "The latest annual" and ending with " unprofitable year".- .1 (t) Page 15, Table.D.
(I) Page 16, Table E.
.3. Cintichem, Inc. and its parent companies are privately held corporations whose financial information is withheld from the public.
- 4. Similar information had'been transmitted'to the commission in confidence on prior occasions, and most recently in the i matter of the transfer of this license from Union Carbide, l Subsidiary B to Cintichem, Inc.
- 5. The Information contained in the document referenced in 2 L above, except'that noted to be from publications, is not L available to the~public.
- 6. This. Information could be useful to our competitors and thereby cause substaniel harm to Cintichem's market' post-tion.
7] N usa
/J AME S J . McGOVERN.
Senior Vice President and Plant Manager, Cintichem, Inc.
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