ML19276G152
| ML19276G152 | |
| Person / Time | |
|---|---|
| Site: | 07001821 |
| Issue date: | 01/15/1975 |
| From: | Price W ALLIED GENERAL NUCLEAR SERVICES |
| To: | Anders W, Gilinsky V, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML112700323 | List: |
| References | |
| NUDOCS 7905150683 | |
| Download: ML19276G152 (4) | |
Text
/mied-Genero Nuctec Sen>:ces l'at olce b= t o
[Lunweil, South Corch 29312
\\' ' J. P,b (503) 259-1711
..*. e v,:- i,n:d e nt January 15, 1975 Chairman William A. Anders Commissioner Edward A.
Mason Washington,'D.
C.
20545 Nuclear Regulatory Commission Nuclear negulatory Commission Washington, D.
C.
20545 Commissioner Victor Gilinsky Commissioner Marcus Rowden Huclear Regulatory Commission Nuclear Regulatory Co:iniission Washington, D.
C.
20545 Washington, D.
C.
20545 Commissioner Richard T.
Kennedy Nuclear Regulatory Commission Washington,.D.
C.
20545 Gentlemen:
C.
A_llied-General Nuclear Services has instructed its architect /
k.- e n g i n e t: r, Eechtel Corpor tion, to suspe:.d dculgc. ;_ r.< for the Plutonium Product Facility, which was scheduled for prompt instal-lation and for start-up Movember, 1977, at.the Barnwell Nuclear Fuel Plant.
In view of the nation's urgent need for energy resources, this action has been taken with considerab]e regret and reluctance, and only after extensive discussica and most careful consideration with-in Allied-General and with the partners in Allied-General.
Factors relating to the broad national import of the timely operation of the Barnwell Nuclear Fuel Plant are set forth, among other matters, in Allied-General's letter (attached) of August 27, 1974, to Miss Kathl Black of the Fuels and Materials Division of the Arc.
The reasons for this action re]ating to the Plutonium Product Facility are set forth below, action which has been made necessary by regulatory developments wholly beyond the control of Allied-General.
On August 21, 1974, the U.
S. Atomic Energy Commission announced the availability of its draft of a report entitled " Generic Environment 2 S t'a t eme n t, Mixed Oxide Fuel (GESMO)".
On November 4, 1974, Allied-Gene wrote :.r.
S.
H.
Smiley, Deputy Director for Fuels and Materials, Licensi AEC, setting forth the importance to the industry of timely and appropr'
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L regulatory action on the Barnwell Plant.
This letter (copy _ attached) included the statement, "As noted above, ve trust in this connection that per incion to begin construction of the Plutonium Product Facility would he granted by January, 1975, so that requisite tiine schedules can be met."
On December 10, 1974, the Atomic Energy Commission ann'ounced its intention of holding hearings related to GESMO at a time and place yet to be announced.
On this name date, December 10, 1974, Allied-General was advised by letter from the AEC (copy attached) that the licensing of the Plutonium Product Facility would proceed under 10 CFR Part 70.
Under this Part of the Regulations, construction cannot con =ence until the Commission has issued its Final Environmental State-ment, in the absence of an exemption granted by the Commission (which, thus f ar, there has been no indication that the Cccaission vould grant)
Then, on December 23, 1974, in a letter (copy attached) from Mr. Edson G.
Case of the AEC Regulatory Staf f to Mr. Anthony Z.
Roisman the statenent was made,
...a delay in issuance of final environmental decision thereon would be appropriate and in the public interest."
Accordingly, we can only conclude that the present intention of the Regulatory Staf f is that the conunencement of cons,truction of the
_ Enr:xell plutoniun incility be Sch.,cd at least until the time a,t uhich the lins) GESMO has ocen issued and a Coraission decisj on has bc<m re:n c_ e. - h e r.a o n.
The industry has no way of knowing the period of time that will be required for the Nuclear Regulatory Cornission to finalize GESMO.
Judg from the time required for resolution of such matters.as ECCS, Appendix to 10 CFR Part 50 and the generic siatenant on transportation of fuel to and from reactors, considerable time may pass before such final reso lution on GESMO.
Behind the basic GESMO question are several secondary uncertaintie that could have a significant impact on the design and operation of an; facility for conversion of plutonium nitrate to plutonium oxide.
Then include:
1)
The question of the frequency of inventory shutdown and cleanout requirements.
Such frequency has a direct impact on the productive capacity of a facility, and, as the capacity for the Barnuell Plant is well defined, it must be known, witl in reasonable limits, what percentage of the tine t)e plant can be operated so that its components can be sized appropria4 2)
The possibility, which is discussed in GESMO, that the radioactivity level of the product plutonium oxide should be i
e
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raised over the level in the pb.;er reactor grade pluto-nium by the deliberate addition of more radioactive material.-
Such a requirement could well involve process changes, and it certainly will af fect the Plutonium Product Facility de-
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sign as related to shielding and remotability.
3)
Other matters related to safeguards that might be added to the already existing regulatory requirements with po-tential effects that could add to structural and detection requirements.
Until these are resolved, further design work of the Plutonium Pro-duct Facility night well be non-productive.
Under all the circum-stances, it appears undesirable for Allied-General to proceed with further design of the Plutonium Product Facility at this time.
With the design capability of storage of. plutonium. nitrate in the Separations Facility of the Barnwell Plant (9000 kg of plutonium), the lack of operation of the Plutonium Product Facility has an obvious po-tential impact on the period of time within which the Separations Fa.cility could be operated until this storage would be full.
Alternat acti ns that night L11cv_are this problem ars being c:c _rred.
Ec.-le cer obvious.ly, just as the storage now being installed has a limit in stor capaa lity and in en - re m um ne perid.ta_: w._ 1. per:.._
con ti:..; ad
,_ operation of the Separations Facility, so similarly will eny alternat' action.
One further, local, factor must be considered.
The Sarnwell Cou, area sas. listed as a " depressed area" prior to start cf crnstruction of the Barnwell Plant.
Since such start, many people (mestly constru related--as many as 2,000'have been employed) have moved into the are<
to expand and I boosting the economy and prompting existin; businesses businesses to come in.
It was anticipatea that, as the 1ecel of con-struction vorker employment on the Separations Facility decreased, thc level of activity on the Plutonium Product Facility would build up, ti maintaining a stable economy in the area.
It now appears that, at a I inappropriate time, there will be a drop in local employment and the local economy.
.In view of the above facts and the national needs related to one we urge the Commission to expedite its actions to the greatest extent possible.
The specific actions that we consider to be of most import related to GESMO and to the Barnwell Nuclear Fuel Plant. and in turn, indeed, the whole nuclear industry are:
1) earliest and full resolu tion of GESMO in a manner which will assure safety but not result in needless economic burden which would be a drain on nationa_ resources and would ultimately be borne by the consumer of electric energy,
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i 2) continued active ef forts 15y the Cornission, in reviewing the regulatcry aspects of the Barnwell Plutonium Product Facility, to detaraine at the earliest possible time whether construction
,.. can be initiated on the Plutonium Product Facility and can be under-taken uith assurance.
In view of the potential national impact of these matters, ve, of course, vould be most pleased to meet with you at any time to. discuss this and related matters.
Sincercly yours, h'. J.
Price
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