ML20057B863

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Comments on Encl Ltr from H Arnold,La Energy Svcs Re Energy Policy Act of 1992 (Energy Act),Section 1016,requiring That U Inventory Study Be Performed by 931024
ML20057B863
Person / Time
Site: Claiborne
Issue date: 09/15/1993
From: Grafton R
LOUISIANA ENERGY SERVICES
To: Duffy L
ENERGY, DEPT. OF
References
NUDOCS 9309240084
Download: ML20057B863 (4)


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September 15, 1993 Mr. Leo Duffy, Assistant ~ Secretary for Environmental Restoration and Waste Management United. States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585

SUBJECT:

Letter to you dated November 6, 1992, from Howard Arnold, President, Louisiana Energy Services and Referenced:

Louisiana Energy Services Claiborne' Enrichment Center

't Energy Policy Act of_1992 Uranium Inventory Study LES File #: 8.4.6 (Copy enclosed)

Dear Mr. Duffy:

In Mr. Arnold's SUBJECT letter he states that by the year 2000 "it is expected that at least three domestic entities (sic) the Department of Energy (" DOE"), the United States Enrichment Corporation ("USEC"), and Louisiana Energy Services ("LES")

will possess signiticant~ quantities of depleted uranium hexafloride ("DUF-6").

DOE, a non-domestic entity, now possesses on the order of-500,000 tonnes of DUF-6 or about one billion pounds in storage, mainly.

in 48G cylinders._ This amounts to about 40,000 cylinders which is already a significant amount.

In view of the fact that DOE has always considered DUF-6 to be a resource material, and since no useful disposition of this material has ever been found, and since LES appears to be

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decidedly interested in participating with DOE in some future program dealing with the DUF-6 problem, and since Mr. Arnold's SUBJECT letter has becolae o part of the LES license application; I am by this means requesting that I be provided with a copy (s) of (all) correspondence generated by DOE, past, present and-future, resulting from Mr. Arnold's SUBJECT letter.

Sincerely:

\\

Rudy Grafton i

Rt 4, Box 287-S Il o m e r, LA 71040

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'f cc: Mr. Charles Haughney e-U.S.

NRC I

Washington, DC 20555 Docket # 70-3070 e

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November 6' 1992

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Mr. Leo Duffy, Assistant Secretary for Environmental Restoradon and Waste Management United States Department of Energy t

1000 Independence Avenue, SW Washington, DC 20585 L

Re:

Louisiana Energy Services Claibome Enrichment Center Energy Policy Act of 1992 Uranium Inventory Study LES File #: 8.4.6 i

Dear Mr. Duffy:

The Energy Policy Act of 1992 (" Energy Act"), Sec.10: 5 requires that a uranium inventory study be performed by October 24, 1993. Among other things, this study shall include "recommendadons for the future use and disposiden of such (uranium) inventories." " Pac referenced inventories include depleted tailings (i.e., depleted uranium hexafluoride). By the year 2000, it is expected that at least three domesde entities - the Department of Energy

(" DOE"), the United States Endchment Corporation ("USEC"), and Louisiana Energy Services

("LES") will possess significan: quantities of depleted uranium hexafluoride ("DUF, ").

'r four separate entities deal with this issue in different ways and on Rather than have 1

different time sca* ;, i t ould suggest that DOE take the lead and estab1Ish a national program for the handling of this potentially valuable material. Such a program would be most economical for all parties because of economics of scale, and a sing!.c point of control would allow the environmental consequences of shipment, conversion, handling and storage to be minimized.

Absent such a coordinated program, one or mo're of these entities could take actions which might prejudien the opdmum roludon of this situation. LES wotid be p! cased to participate in such a program, and we would be prepved to provide assistance in the study phass and share in expenses for conversion, storage and disposiden on an equitable basis.

LES applied for a license to construct and operate the Claibome Enrichmen't Center (" CEC")

l in January 1991. The appheadon is currently under resiew by the United States Nuclear M

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Mr. Leo Duffy November 6,1992 Page 2 v.

Regulatory Commission ("NRC"). We expect a license to construct and operate the be issued in the third quarter of 1994. One of the outstanding licensing issues is dispos the depleted uranium hexaDuodde produced at the CEC. Aldough not a waste, the NRC ha indicated they believe it will be treated as such.

Depleted uranium ir a potenti[A energy source, and should be preserved in retrievable form.

One potential is as input to a fu 're endchment plent, which would become economical were the price of separative work to drop signincantly or the price of natur21 uranium ore to rise dramatically. Another potential is as breeding matedal in liquid metal reactors. Such reactors have been demonstrated to be technically feasible, and may become economical if the pric natural uranium ore becomes high enough. However, such uses are undoubtedly decade and extended stor:ge of the material will be required before it can be decided that the matedal is indeed useful or should be dispositioned.

9 The LES license applicatica postulated that UF. would be suf5ciently stable for extended pedods, but the NRC, by letter to LES dated September 22,1992 (copy enclosed), has stated its preference for disposition to be as U 0, in a facility not as yet dc5ned other than that it is 3

net licensed under 10 CFR 50 part 61. Such an approach, our studies show, could be quite conly and result in a disposal plan which reaches well beyond the low level of dsk presented by depleted tails.

However, we do agree that U 0, is stable, non-corrosive, and insolub!c in 3

water so that it would be an execilent form for either extended storage or disposal. In a draft study prepared for DOE by Martir. Marietta dated September 1991, it is stated that a preferable option (as opposed to disposing of the DU 0,) may be to crea.e a strategic reserve and store the 3

conve. qed matedal in retdevable form in a facility designed for indermite, low maintenance operation. This is currently being done in France with a pordon of the DUF, being generated in the Eurodif gaseous diffusion facility.

i DOE currently possesses essentially all the DUF, inventory in the United States. However, the USEC will begin to generate this material as soon as the DOE facilities come under its operational control via the Icase speciSed in the Energy Act. Since the Energy Act also specifies that the USEC must be certifed by the NRC within two years, we anticipate that the NRC requirements indicated to us in the letter of September 22 will apply to the USEC as wcil.

The LES licensing and the USEC certification regulations are now being examined by the NRC, prompting an early resoludon of this issue. This schedule is compatible with the time frame of your uranium inventory study, so we urge that you define its scope breadly enough to include these issues. As our date of commencement of operations is no earlier than the middle of 1997, and the deadline for removal of the first DUF. from the CEC site is well beyond 2010, we expect that there will be sufficient time for us to coordinate the speciEc arrangements for the actual handling of our material once the plan is in place. Indeed, in this time period other carr'es could also generate depleted uranium in the United States. For example, the Energy Act t

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Mr. Leo Duffy November 6,1092 Page 3 contemplates licensing the Atomic Vapor Laser Isotope Separation ("AVLIS") technology currently owned by DOE to a private entity who would build an enrichment plant.

As stated above, LES would be pleased to participate with ycu and the USEC in discussing this matter at your earliest convenience. We are prepared to provide input to your study, and would look forward to working with you in the implementation phase when our inventory of DUE is to be dealt with.

i Sir.cerely, h-WHAlpp Enclosure e

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