ML19332A573

Comments on Rulemaking 50-5:GESMO Proceedings Should Be Reopened to Provide Early Procedural Framework for Subsequent Licensing

ML19332A573
Person / Time
Site:	West Valley Demonstration Project, 05000564, 07001327, 07001821, Barnwell, 07001432
Issue date:	09/08/1980
From:	Richards R GENERAL ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-45FR53933, RULE-RM-50-5-45FR53933 45FR53933-4, NUDOCS 8009160420
Download: ML19332A573 (2)

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%w p.c Septaber 8, 80 M et 50-332-Secretary S'o -I(,f U.S. Nuclear Fegulatory Ca:r.'ission 70 - / M 7 Wasbingten, D.C. 20555 7 3 - / ay3 2, Attention: Chief, Dccketing and Service Branch b '/

Subject:

GESBD Precdnes, Dccket Nos. FM 50-5

-201, -332, -364,

-1327, -1432, -1821 J

Dear Mr. Secretarf:

I am pleased to have the opportunity to ccurnent en the questien of whether or not GESSD ard other recycle-related licensing procdngs should be recpened.

'Ihe Afvanced Paactor Systers Departnent of the General Electric Camany is a participant in Departnent of Energy develegrent programs for advanced reacters and has a vital interest in the future of fuel recycle.

There are a nu:ia.r of reascns why it is important that GESD proceedings be recpened, and I strcngly urge that de NPC do so in the near future. Fuel re-cycle is necessary to achieve the energy su ply advantages of breeder reacters.

Khile fuel reprocessing and mixed exide fabrication have both been perfor:ned in the past, technical questions still reain with recard to the chemistry and equi: rent designs to be used for multiple recycling en a ccrraercial scale.

Answers to dese questicns cannet be fully obtained in the laboratorf, but must be de::cnstrated in prototypes of ccurercial facilities. As with the develc; rent of the reacters themselves, this will necessitate a series cf prototypical re-processing and BDx fabrication facilities.

It is a mistake to assure that recycle facilities can be easily obtained after the decisien is made to ccurercialize de breeder.

Father, they must be develcped together with the reactor in a parallel and intecrated program. To do less would be similar to building a seace station withcut de vehicle needed to put it in crbit.

Licensing of recycle facilities is likely to be as difficult and tire const:&.g as that of breeder plants. Scre of the issues will be of a similar nature but others unique to these facilities. Fecpering of the GESD prcceedings will pre-vide an early procedural framewcrk that can aid the licensing of later facilities

uch in the way that IXR licensing will prcvide the initial step in licensing of breeders. Withcut such an initial step, fuel facilities are likely to centinue to lag benind the develc rent of breeder reactors.

In 1977 de A ninistration was highly ccncerned with de danger of weapcns prc-liferaticn resulting frcm widespread use of plutenium and ccnstruction of recycle DSOE S

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Secretary Septemger 8, 1980 facilities. The International Nuclear Fuel Cycle Evaluation (DI.:G) has been instrumental in allaying such cancerns.

In addition to making the participating nations more aware of the dancers of weapcns proliferation, EEC shced that 4

a) Breeders and plutonium recycle are not likely to be m.cnical cutside of industrialized nations for :rany years, b)

Adequate prctecticn against using recycle facilities for pro-liferaticn can be achieved by interraticnal agreements, inter-national inspecticns and physical safeguards, c)

Pecycle and the use of plutonium are vital. to the ecenanic wlfare of sane industrialized nations.

hhile the Administratien centinues to feel the need for a moratcrium en recro-cessing as a part of the U.S. ncn-proliferation policy, such a moratorium 'is actually counterproductive to the establishment cf the ncn-proliferation measures identified in DEC, since it urAmines U.S. influence in these proceedines.

'Ihus, the stance against fuel recycle is vieaed by other nations as rcre o5 a posture acainst the breeder than a ncn-proliferaticn statement. Any non-proliferaticn advantace to be gained fran continued suspensien of GESMO is heavily cutweiched by

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the censiderable advantage of dealing with the licensing issues at this time.

Yours very truly,

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/ & SW R. 3. Ricbards da

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