ML20247L562
| ML20247L562 | |
| Person / Time | |
|---|---|
| Issue date: | 05/26/1989 |
| From: | Peterson M NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Flowers F GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8906020204 | |
| Download: ML20247L562 (3) | |
Text
- _ _ _ - . __
t MAY 2 61989 s
Mr. Fred D. Flowers Manager, Traffic & Regulatory Control M/C 512 General Electric Company 175 Curtner Avenue San Jose, CA 95125
Dear Mr. Flowers:
Attached for your review is a copy of Gereral Electric's export license applica-tion XCOM0460 for the export of reactor components to India to be used as replacement parts for the Tarapur nuclear power reactor.
Please review this application and advise whether or not General Electric is
, still actively pursuing the order and still needs the license, or whether the pending application can be withdrawn.
Your prompt attention to this request would be greatly appreciated.
Sincerely, J/ggy /f bUWCb& "
- y /Y Marvin R. Peterson, Assistant Director for International Security Office of Governmental and Public Affairs
Enclosure:
Application XCOM0460 (India) bec: C. Thorne, DOS R. DeLaBarre, DOS N. Martin, DOE Distributed IP r/f " DCS/DF02 JBecker,0GC.w/Enci ,
PTana, NMSS w/Enci / ,
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GENER AL $ ELECTRIC
. NUCLEAR ENERGY BUSINESS OPERATIONS GENERAL ELECTRIC COMPANY e 175 CURINER AVENUE e SAN JOSE, CAUFORNIA 95195 BDW-065-83
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June 3, 1983 Mr. Carlten R. Stoiber, Director
- p. .
Office of Export and Import Control
- i OES/NEC - Room'4327 A '
De artment of State Wa 'ngton, D.C.. 20520
Subject:
Tarapur Replacement Components
Dear Mr. Stoiber:
This will confirm the information provided today by telephone to Mr. DeLaBarre in response to his questions on this subject.
We are pleased to assist your office in any way
, towards efforts to enable exports of replacement parts >
to Tarapur.
a Very truly yours, !
! Jm
. D. Wilson, Manager Government Relatiens and j Export Licensing '
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BDW:s Attachment i
cc: -J. R. Shea USNRC 4
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TAPS REPLACEMENT COMPONENTS Q. Was-GE able to: ship all of the TAPS components then ordered' by TAPS under.the. Executive Order (12218) of June -19, 1980?
Answer:Except for.a number of items which were specified to t be. covered under XSNM 020 and valued:at about $8,500,:
7' '
. all components that were on order and specified for
- export under XCOM 0240 and XCOM 0250, have been completed.
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Q. As currently. amended, would issuance of XCOM 460 (and extension of the XCOM 20 validity date) provide for all components needed a by TAPS?.
Answer: - The last amendment of the application'for XCOM.460 wes, p
submited in March'1982.- Since that time. a number of L inquiries have been received from TAPS-for-additional-9:
< parts. An' application amendment is being readied for
, submission to the NRC-today.
It will cover 29 incore detectors valued at $539,000,
' control rod drive replacement parts valued at
$400,000 and additional miscellaneous parts valued
'at not more than $50 000 , . <
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-Q., If TAPS exports were authorized in the near future, to what extent would components on order be available for shipment?
Answer: Given renewal of expired commercial agreements relative to the supply of components to TAPS, '
14 of 15 incore monitors on order are available.
A few miscellaneous parts such as underwater lights, spare parts for scram valves,' electrical connectors for:incore monitor cables, etc.~would be available
-also.
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RECEIVED GENER AL $ ELECTWIC %*
- D NUCLEAR ENERGY BUSINE$pPQ$G6 Pl2 :39 D*
GENERAL ELECTRIC COMPANY
- 175 CURTNER AVENUE
- SAN JOSE, CAUFORNIA 95195 BDW-066-83 0FFICE OF INTEP. NATIONAL I PROGRAMS June 3, 1983 )
Ms. Elaine O. Hemby Licensing Reviewer U.S. Nuclear Regulatory Commission 1717 H Street Washington, D.C. 20555 l
Subject:
Application Amendment XCOM 460
Dear Ms. Hemby:
By application dated November 14, 1980, as amended May 18, 1981 and March 11, 1982, General Electric has requested authorization to export certain replacement component parts for the Tarapur Atomic Power Station in India.
The purpose of this letter is to amend the applica-tion for this license to reflect known changes in the components likely to be exported under the license when and if it is issued. The revised list of components is attached hereto.
Very truly yours, bM f.D. Wilson, Manager IGovernment Relations and '
Export Licens1ng BDW:s Attachments cc: Mr. C. R. Stoiber Ms. J. F. Raymond 9
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ATTACHMEN.T List. of Replacement' Components
-for-Tarapur Atomic Power Station
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- 1. Incore Detectors (29) $ 539,000-2.- Control Rod Drive Parts $ 400,000.
' 3. Miscellaneous Unspecified Parts $ .50,000-For Replacement of Existing Items
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isted List Revised: June 3, 1983
Reference:
Application for XCOM 460 l ..
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GENER AL h ELECTRIC NUCLEAR POWER 1
SYSTEMS DIVISION GENERAL ELECTRIC COMPANY,175 CURTNER AVE., SAN JOSE, CALIFORNIA 95125 BDW-029-82 gg g T1 D 4 March 11, 1982 !
i Ms. Elaine O. Hemby Licensing Reviewer Office of International Programs
, U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
APPLICATION AMENDMENT - XCOM 460
Dear Ms. Hemby:
By application dated November 14, 1980 as amended May 18, 1981, General Electric has requested authoriza-tion to export certain replacement component parts for the Tarapur Atomic Power Station (Tarapur) .
' Recently we have been informally notified that Tarapur no longer plans.to install an improved feedwater sparger of General Electric design. Accordingly, this item with an export value of $1,300,000 is hereby deleted from the list of replacement components for which this application is filed. The list as revised is attached.
Ve truly yours,
' flV h%
. D. Wilson, Manager
[GovernmentRelationsand Export Licensing BDW:sc Attachment cc: Mr. C. R. Stoiber i Mr. J. A. Griffin c ' b O\ f DkD\1"L-ccepy t a y,02 cnt LCC SNW g2 C%+GC2 2 2PP'
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' G E N E RIL $ 'E LE CTRIC ATTACHMENT List of Replacement Components ,
for-Tarapur Atomic Power Station 1.- Shroud' Head-Bolts (10) .$ 153,740 2.- Incore D'etectors (29) $.539,000
- 3. Control. Rod Drive Parts S 250,000 n
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f List' Revised: March 11, 1982 Re ference : Application for'XCOM 460 l<
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- - i RECE IVED 1
. GEN ER AL h ELECTRIC uuctuan POwen j
'81 NOV 27 n J :12 SYSTEMS DIVISION 1
?E OF ,
GENERAL ELECTRIC COMPANY,175 CURTNER AVE., SAN JOSE, CALIFORNIA ' 951gFFI ]
B DW-132-81 PF.0 .
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November 20, 1981 l j
Mr. James R. Shea Office of International Programs MNBB 8215 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
XCOM 0460 Safety-Related Parts for Tarapur
Dear Mr. Shea:
Please enter into the record of the subject export license application, the enclosed letter dated October 22, 1981 from the Tarapur Purchase Officer, Mr. B. L. Thakur, to General Electric. That letter summarizes the status of available source range and intermediate range monitoring instrument components and presents technical justification for replenishing the stock of those monitors to ensure safety. These components are included in our November 14, 1980 application for XCOM 0460, as amended.
As you know, we are troubled by the specter of a malfunction at Tarapur which could be attributable to India's inability to obtain needed com-ponents from GE and the several other U.S. export license applicants.
Since our application is now past a year old, we urge at least a fresh review by the Commission and the consulted agencies to determine whether there is some undiscovered avenue, under the constraints of the legislation, for treating reactor component applications on a different basis than for export of fuel for Tarapur.
Very ruly yours,
/
. D. Wilson, Manager Government Relations and Export Licensing Attachment cc: E. B. Steinberg, Department of State G. Porthasarathy, Embassy of India l
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if tf k 8tttTC Idmes l DIRECTORATE OF PURCHASE AND STORES Bef.No.DPS/ TAPS /SPE October 22, 1981 M/s. General Electric Company,
- 175 Curtser Avenue,
. San Jose, California 95125, U. S .A . 4
. i
Dear Sirs,
Attention: Mr. G . V. ani z ar, i
Sub SIQi anA DQl Deteetors.
l We had placed the following Purekase Orders for the supply
' of SBM and IM Detectors, the shipment of which we anderstand is held up for want of Export Licence from USA N.B.C.
We give ;below the details of Detectors in service, number
' held in stock, dues based on the Punhase Orders pending with GE, USA and justification for the quantity as ordered and the need for their immediate shipment.
A) 1. SIQi Detector.
On==tity ordered med shi-nt vet ta he effected, a)P.O.'do.DPS/
Beguisition No.544-7 TAPS /SPh77/ /21182/FE and E - 3 Nos.
-408.
b) P.O.No.DPS/ TAPS /S 1333. /19109/FE and E Requisition No. . - 6 Nos.
- 2. No. required to be operable per Unit i.e.
total 6 Nos. required for both Units. - 3 Aos.
- 3. Present Stack on h==d. - 6 Nos.
- 4. Betectore in Services.
Age of Detectors M,1.1 to 4 years pV 2.1 to 7 years
- 5. Techn4 cal instifieation.
From our experience, 3 Nos. of SBWs (which are more than 2 years in oore) may need change any time. Thus the balance from stock will be O Nos. only.
......... 2/- .
Also the rate of replacement of SWs is about one SW Detector per year for each Unit. Hence the quantity of 9 SW
. Detector for whbh the order has already been placed with GBC and ff ;j.
for which shipment yet to be effected is absolutely essential. '*
..!SW Detector and monitors are part of Beacter Safety System. At 3. ya;3-
' me time the core een be left without monitoring. he SW Deteeters j~
)
and monitors should be en line all the time even enring Unit estage and when the remeters are in cold shutdown eendition to ensare aafety.
It may be noted the the rate of uplacemede of SBM Detectors has been mainly due to:
Yhile working en equipments in CRD housing area like moving, slighting CRD tool while nylacing the control Bed Drive
- assemblies, :iR'A Detectors have high potential to yt mechanically damaged. Also because of the inherent uncertainty of the pulse monitoring system of ler neutron flux, one or two detectors had to be replaced for achieving better reliability.
B) IW Deteetors
- 1. Quantity ordered and shi rnment vetA he ef fe ctsd.
Purchase Order No.DPS/ TAPS /SP /21305/FE -4Nes.
- 2. No. required to be operable per unit -4Nos.
i.e. total 8 Nos. requind for both Units
- 3. Present stock on hand -4Nos.
- 4. Detectors in Service:
Age of I M Detector Unit M 1. 2 to 5 years Unit # 2. 2 te (years
- 5. Techniaal Justification.
Considering the above details 4 of the detectors already in use may need replacement any time. Bus only one detector enn really be eensidered as spare.
IBMs in Neutron monitoring sytten from a part of Beneter Safety System. hese channels are aquind to be operable for safe starting med shutting dern the Beseter. heee an required to maintain the Reactor in sold shutdown !
sendition and form part of Technical syseification regain-ment. has adequate spares anst be saintained. .; %
Considering the rate of replacement, present spare s% i present sendition of detectors in son it is felt that h
.......3/-
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6 Nos. of detectors en order as mentioned above are ..
absolute miniana necessary guantity. ,
1 h are sure the above information will enable E te ;;n ^ j esce again US Conseree Department witha request to release the Expert i licence at the earliest. If any other information/ data is required please write to us for Limmediate compliance.
Thaaking you, Years fai ly 1
J'.. .kar)
I
, oh Officer Copy to: W/s. Elpro International Ltd.,
'Nirmal' Nariman Point, Post Box No.10008, Bombav-400 021.
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, GENER AL h ELECTRIC NUCLEAR ENERGY B U S I N E S S' GROUP GENERAL ELECTRIC COMPANY,175 CURTNER. AVE., SAN JOSE, CALIFORNIA 95125
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August 14, 1981 ,
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w w . 4 (, O Mr. James R. Shea 11 (T"O 11 Office of International Programs MNBB 8215
. U.S. Nuclear Regulatory Commission
- Washington, D.C. 20555
SUBJECT:
XCOM 460 - Replacement Source Range. Monitors
Dear Mr. Shea,
Six (6) source range monitoring detectors for the Tarapur Atomic Power Station are now ready.to exportibut are being held for issuance of NRC License No. XCOM 460. The appli-cation for XCOM 460 was filed November 14, 1980 and amended May 18, 1981 to cover forseeable TAPS replacement parts needs.-
We have received a number of TAPS requests for expedited delivery of these SRM detectors. We believe the timely replacement of in-core-monitoring instruments is important to safe. reactor operation.
Very truly yours,
/
[ Bend. Wilson, Manager Gov't. Relations & Exp. Lic.
MC 873 - (408)9251380 mw S.,;;j *.o ?IR and ACC_ T"6M *'
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GENERALo ""
ELECTRIC NUCLEAR POWER
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- '81 MAY 1 4 IL159 I SYSTEMS DIVISION l GENERAL ELECTRIC COMPANY,175 CURTNER AVE., SAN JOSE, CALIFORNIA 95125FIP.! Of ;
INTERJU l0NA' '
NUCLEAR POWER SYSTEMS MARKETING DEPARTMENT PROGR LMS
- SAN JOSE, CALIFORNIA I May 18, 1981 k
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'4 Mr. James R. Shea, Director Y Office of International Programs U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
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SUBJECT:
Application Amendment - XCOM 460
Dear Mr. Shea,
By letter dated November 14, 1980, a Form NRC-7 application was transmitted requesting authorization for export of certain replacement coaponents for the Tarapur Atomic Power Station reactors in India.
, Action on the application is pending. In the interim, Tarapur has identified additional components which must be replaced. Additionally, the values and quantities of some of the previously listed components have changed.
General Electric hereby amends its application for XCOM 460 by submission of the attached revised list of components for which coverage under the license is requested.
Very truly yours,
. D. Wilson, Manager Government Relations and Export Licensing MC 873 - (408) 925-1380 ke Enc. I TOR 10ILE and Acc_ E. M - Trl ,.
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, G E N E R A L$.E LE CTRIC
' ATTACHMENT LIST OF REPLACEMENT COMPONENTS FOR TARAPUR ATOMIC POWER STATION:
h 1.. Shroud.HeadBolts(10)I $143,740 2.
., ; Incore Dectors (29) 539,000 5- 3. Control Ro'd. Drive Parts 250,000
- 4. ~FeedwaterSparger'(2) 1,300,000.
m
- . List revised May-11, 1981 .
Referencei' Application for XCOM 460 w
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GENERAth ELECTRIC NUCLEAR POWER SYSTEMS DIVISION GENERAL ELECTRIC COMPANY,175 CURTNER AVE., SAN JOSE, CAUFORNIA 95125 4
BDW 80125 November 14, 1980 Y) 8 7 .- =
Mr. James R. Shea, Director ~j ; Q a.
Office of International. Programs E . T U.S. Nuclear Regulatory Commission "
EiM Washington, D.C. 20555 [,g 3
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Dear Mr. Shea:
S Ci =
EnclosedisGeneralElectric'sapplicationfor.anwlicebseto export specified replacement parts for use in components of the Tarapur Atomic Power Station. All of the parts covered by this application are necessary for the maintenance of station safety. They are all specially designed or prepared for place-ment in nuclear reactors and, accordingly, are subject to NRC export licensing authority as specified in 10 CFR Part 110, Appendix A, paragraph (a) (10) .
. The parts covered by the enclosed export license application do not begin to approach in significance the facilities or materials which are subject to the export criteria set forth in Section 127 of the Atomic Energy Act. (Cf., for example, the
" major components" listed in 10 CFR Part 110.2(ss) as con- ,
stituting a utilization facility for export licensing purposes.)
Rather, these parts are but a few out of a large number of identical items that make up components or subcomponents of the existing power reactors at Tarapur. They are of essentially the same relative proliferation significance (which is to say, none) as those components previously licensed by NRC under XCOM-20 and XCOM-84 and those applied for under XCOM-240 and XCOM-250 -- all exported to the Tarapur facility.
As a preliminary matter, it is worthy of note that the components for which an export license is now sought are expected to be installed in the Tarapur reactors, expend their useful lives, and themselves require replacement. In fact, before the fuel most recently released for Tarapur's use becomes spent, further replacements would be required for these or identical items. Thus, the export of these components would do no more than permit the Tarapur reactors to operate safely using U.S.-origin fuel already provided. Clearly, U.S. non-prolifera-tion policy does not require that exports central to the safe On s n s I
-Q ber .
on f0-6' 00
, , G E N E R A L () E LE CT RIC Mr. James R. Shea November 14, 1980 operation of a power reactor be denied after export of the l nuc1 car fuel for the operation of that reactor during the very l same period has already been approved.
In light of the safety importance of these parts, and their l unquestionable insignificance from a proliferation standpoint, it would be most unfortunate, as well as unreasonable, if this l export license application were considered by NRC or the l Executive Branch in conjunction with the pending application for the export of fuel for the Tarapur reactors recently sub-mitted by another applicant (i.e., XSNM-1740). Such j oint consideration unduly risks submerging the component license application in the foreseeable controversy and delay involved 1 in a determination of whether a further fuel shipment to India j meets the criteria set forth in Section 127 and 128 of the Atomic Energy Act. What needs to be done (and what we believe the Commission failed to do in connection with XCOM-240 or XCOM-250) is to focus its attention solely on whether the three criteria set forth in Section 109b. of the Atomic Energy Act are met by the proposed component export.
As you are aware, the generic asurances provided to the U.S.
Department of State by the Embassy of India, by letter dated !
March 23, 1979, meet the Section 109b. criteria. Specifically, that letter confirms that the following conditions apply to the l
, export of U.S.-origin reactor components to India: (1) IAEA safeguards will be applied to the special nuclear material pro-duced through the use of supplied equipment or material for the Tarapur Atomic Power Station (TAPS); (2) the special nuclear material or equipment supplied for use in TAPS or produced through the use of such material or equipment will be devoted exclusively to the needs of TAPS (and therefore not utilized for the production or research and development of any nuclear explosive device); and (3) no equipment, material or device supplied by the U.S. for use at the TAPS will be transferred to unauthorized persons or beyond the jurisdiction of the Government of India.
It is useful to consider the application NNPA criteria one-by-one.
As noted above, Sections 127 and 128 of the AEA are inapplicable to component exports. Section 109b., which is applicable, establishes three exclusive criteria, in sum (i) application of IAEA safeguards in accordance with Article III(a) of the NPT, (ii) no use of the export in or for research on or development of a nuclear explosive device; and (iii) no retransfer of the i
export outside the jurisdiction of the recipient country. At present, of course, all three criteria are met by existing under-takings of the Indian government. The question which seems to l
l l
[_ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
, , GENERAL $ ELECTRIC Mr. Iames R. Shea November 14, 1980 have bothered the Commission in the past is "what happens in the future, if the U.S. should cut off fuel shipments?" Taking the criteria in reverse order, it has never been suggested by the Commission in its decisions that India had threatened, or was a threat, to violate its non-retransfer obligations. To our knowl- !
edge, there is no evidence to support the view that India might retransfer the components subject to the enclosed export license application absent U.S. consent.
Turning to the second criterion, it is clearly met, even without regard to the undertakings of the Indian Government, because the i subject components plainly have no use in a nuclear explosive !
device, nor would they be useful for research or development of
,~ such a device. In short, the second criterion is met by virtue of the nature of the components involved, and their specific design for use in nuclear power reactors.
The final applicable criterion, that concerning safeguards, is also met -- again, by virtue of the nature of the components even with-out regard to the assurances of the Indian Government. Article III (2) of the NPT requires the U.S. and other signatory nations to a refrain from providing to non-nuclear-weapons states either source or special fissionable material or " equipment or material especially designed or prepared for the processing, use, or production of i
~
special fissionable material" unless such material shall be subject to IAEA safeguards. The subject components are obviously not themselves source or special fissionable materials. Neither are they "especially designed or prepared for the processing, use, or production of special fissionable material." They are designed solely to maintain plant safety.
We trust that when the Commission has measured these exports ,
against the applicable licensing criteria, it will determine that i there exists no reason to defer export licensing approval. However, !
in view of the safety importance of the exports covered by this application and General Electric's commitment to maintain the enviable record of BWR safety worldwide, please advise us, to the extent and at the earliest date feasible, whether further informa-tion (from General Electric or others) will be required for the Commission's needs, and if so, the nature of that information, how it relates to the Section 109b. criteria, and a statement of what actions are currently in progress (and by whom) to acquire that information. General Electric is, of course, prepared to provide whatever information we can to facilitate the processing of the attached application.
Verjy truly yours, Spum- ,
f
<B: D. Wilson, Manager j
/ Government Relations 6 i
/hp Export Licensing I Attach.
cc: J. A. Griffin, DOE; L. V. Nosenzo, Dept. of State .
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$Fn ito APPLICATION FOR LICENSE TO EXPORT NUCLEAR
, , MATERIAL AND EQUIPMENT (seeInstructions on anerse)
A;PLICANT'S f. DATE OF APPLICATION b. APPLIC ANT'S REFET.ENCE 2.NRC 4 4.DCSteS NE . '. p. '
N !
- it,em 66C b. DOCaf,ET NO. M uSE 11-14-80 BDW 80125 uSE -
t%nLL APPLICANT'S NAME AND ADDRESS l RIS 4. SUPPLIER'S NAME AND ADDRESS lRIS (Complete if spaticent is not supplier of material) m r7! W b
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General Electric Co. , A ttn: B.D. Wilson STREET ADDRESS M/U dD3 s.NAME I 175 Curtner Ave. !
CITY STATE 2IPCODE D. $7REET ADDRESS . ,' 3 i San Jose CA 95125 c,'i S W T E L E P H ON E N U M B E R (Area Coor - Number - Estension/ c. CITY STATE ZIP CODE I (408) 925-1380 l FIRST SHIPMENT 6. FIN AL SHIPMENT 7. APPLICANT *S CONTRACTUAL 8. PRDPOSED LICENSE D. U.S. DEPARTMENT OF ENERGY SCHEDULED SCHEDULED DELIVERY DATE EXPlRATION DATE CONTR ACT NO. f/f Known)
August 1,1981 December 1982 Same December 1984 N/A l RS k ULTIMATE CONSIGNEE - -
- 11. ULTIMATE END USE l uau, (inciude piant or faciisty nome)
Government of India
- s. STriEET ADDRESS Tarapur - Replacement Parts Dent. of Atomic Enerov 2 CITY - STATE - COUNTR Y l Bombay 400 001 India 11a. EST.DATE OF FIRST USE 10-1-81 I INTERMEDIATE CONSIGNEE l RW 1 13. INTERMEDIATE END USE l c NAME h !
L ST AEET ADDRESS '
o CITY - ST ATE - COUNTRY 13a EST, D ATE OF FIRST USE L INTERMEDI ATE CONSIGNEE l RIS 4
- 15. INTERMEDIATE END USE l NAME u STREET ADDRESS 1
> CITY - ST ATE - COUNTR Y 15a. EST. DATE OF FIRST USE
- 3. 17. DESCRIPTION 1 18. MAX. ELEMENT 19. M AX. 20. MAX 21.
CRC (include chemicat and physico! form or nuclear material. give dotter value of MSE nuclear enurement and components) pyg g g, yz, y ggn3npg y3, ung3
- 1. ShroudHeadBolts(10) $12Jd00
$l 4 3>
- 2. S"fi Detn ices-(6) -
-51,000
- - 3._ 6 % tann solation Vilve 16,v00 D0C A f Parts I
- 4. Power Supply fo ea 15,000 W od Radiation Mo oring System gqg g%
j
(?\ J L COUNTRY OF ORI' GIN.- l : 23. COUNTRY OF ORIGINrSNM I I 24. COUNTRIES WHICH ATTACH l l SOURCE MATE RIAL WHERE ENRICHED OR PRODUCED SAFEGUARDS (if Known) e ADDITIONAL INFORMATION (Use sepersre sheetif necessary) (j
Copy to C3 and A 0 tt-t t- 3D __ e n
f 8 The applicent certifies that this application is propered in conformity with Title 10, Code of Federal Regulations. and that e>l information in this application is correct to the best of his/her knc=ledoc. ,
AUTHORIZED OFFICIAL a. SIGNATURE b. TIT E ,
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D Cl V & VV "' * "_ _U_.___-
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