ML23156A629
| ML23156A629 | |
| Person / Time | |
|---|---|
| Issue date: | 06/29/1971 |
| From: | Mccool W NRC/SECY |
| To: | |
| References | |
| PRM-036-001, 36FR12247 | |
| Download: ML23156A629 (1) | |
Text
DOCUMENT DATE:
TITLE:
CASE
REFERENCE:
KEYWORD:
ADAMS Template: SECY-067 06/29/1971 PRM-036-001 - 36FR12247 - NEW ENGLAND NUCLEAR CORP. (LABELING REQUIREMENTS FOR THE EXPORT OF HYDROGEN)
PRM-036-001 36FR12247 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete
0 11' :
.. J USIAEJ UN 2 31971 Office of the Secretary Public Proceedings Branch ATOMIC ENERGY COMMISSION
[DOCKET NO. PRM-36-17 NEW ENGLAND NUCLEAR CORPORATION Filing of Petition Notice is hereby given that the New England Nuclear Corporation, 575 Albany Street, Boston, Massachusetts, by letter dated May 26, 1971, has filed with the Atomic Energy Commission a petition for rule making to amend the general license in §36.24(b) of 10 CFR Part 36 for export of tritium with a specific activity of not more than 10 curies per gram of hydrogen in labeled organic compounds.
The petition requests that the specific activity restriction of 11 10 curies per gram of hydrogen" be deleted.
The petition states further that if the Comnission considers that additional controls would be required with deletion of the specific acti vity restri ct ion, the single shipment restriction of §36.24(b) could simultaneously be reduced from ten curies to one curie.
A copy of the petition for rule making is available for public inspection in the Commission's Public Document Room at 1717 H Street NW., Washington, D. C.
Dated at Washington D, c.
this 23rd day of __
J=u.n=e _ _____ 1971.
For the Atomic Energy Commissi on W. B. McCool Secretary of the Commission
Docket o.
ltyz Distribution:
Docket File c
tariat w/cy for bltc Document Rooca Stan binaon Asai*tance Branch, REP JRMaaon, SLR Johns
, SLR (Por coneurrenc*** see attached)
REP:PAB GLHutton:eac SL :DD JRMaaon D CIE PETITlO l (Signed) L. Johnson OGC SLR:DIR Ljohnaon 6/21/71 6/ /71 6/18/71 6/ /71 i:.
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- Telephone (617) 426-7311 Telex: 094-6582 Cable Address: Atomlight DOC:(ET. 'U, bER PETITIO RULE PRM-~,-/
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Secretary United States Atomic Energy Commission Washington, D. C. 20545 Att: Chief Pub I ic Proceedings Branch Gentlemen:
May 26, 1971 PM-71-134 In accordance with paragraph 2,802 of the A. E. C. rules of practice, we hereby submit to you a petition for a change in the regulation listed In Part 36, "Export and Import of By-product Material", paragraph 36,24(b).
PETITION: We request that the specific activity restriction of 11 10 curies per gram of hydrogen in labeled organic compounds" be deleted.
RATIONALE: Most of the biochemically useful tritium labeled organic materials which are commercially sold today have specific activities in excess of 1,000 curies of tritium per gram of hydrogen. The very high specific activities of the tritium labeled compounds makes them useful because of the great sensitivity which researchers can then obtain in radioactive tracer studies and in autoradiography. These labeled biochemicals are relatively expensive, ($5-50 per millicurie) and are usually sold in millicurie amounts containing only nanogram quantities of tritium. Thus, it would seem unlikely that the quantities exported from the United States could attain strategic significance. If, however, the A. E. C. felt that additional controls were required, then the single shipment restrictio-n of paragraph 36.24(b) could simultaneously be reduced from ten curies to one curie. Please note that the export of tritium gas and tritium water under 36.24(b) would be specifically excluded since, by definition, they are not II labeled organic compounds".
With regard to strategic significance, it is our understanding that tritium labeled compounds of similar specific activities are produced and sold in large quantities within the Eastern bloc, and that most other western nations, specifically Great Britain and France, apply no export controls on similar products shipped from their countries to East bloc nations.
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tom,c nergy omm1ss1on Page 2
,, Petition May 26, 1971 Also, since paragraph 36.24(c) requires the exporter to provide the U.S. A.E.C.
witli u copy of tlio Shipµnr) l.xport Declaration for uach export, this prnvidus the A._ E. C.
with a method of monitoring, on a day-to-day basis, the actual amounts of materials being shipped from the country under these regulations.
Such action would also be consistent with the United States Government's stated policy of reducing the export controls on East/West trade with respect to such non-strategic items. In addition, the removal of these commodities from specific I icensing regulations will reduce the administrative task of business concerns such as NEN, and that of the U.S. Government. It will also enable American manufacturers to compete with West European competitors on equal terms for export sales dol lars.
We wil I look forward to receiving your reply on this petition.
Yours truly, NEW ENGLAND NUCLEAR CORPORATION
@.~[fcJt Vice President, Marketing PAM;bm cc:
J. Maddox, U.S.A.E.C.
Gerald Hutton, U.S. A. E. C. Radiological and Environmental Protection Section J. Saltzman, Division of State and Licensing Relations