EDO Principal Correspondence Control

FROM: DUE: EDO CONTROL: G20110345

DOC DT: 04/27/11

FINAL REPLY:

Jacques Besnainou

AREVA

TO:

Chairman Jaczko

FOR SIGNATURE OF : ** GRN ** CRC NO: 11-0276

DESC: ROUTING:

Future Recycling Facilities

(EDATS: SECY-2011-0283)

DATE: 05/11/11

Borchardt

Weber

Virgilio

Ash

Muessle

OGC/GC

Johnson, NRO

Moore, FSME

Burns, OGC

Frazier, OEDO

ASSIGNED TO:

NMSS

CONTACT:

Haney

SPECIAL INSTRUCTIONS OR REMARKS:

For Appropriate Action. If a response is made,

please provide copies to OEDO and SECY.

'-Fzqý ok-. S V -01- CV-0
EDATS Number: SECY-2011-0283 Source: SECY

Geerl norato

Assigned To: NMSS

Other Assignees:

Subject: Future Recycling Facilities

Description:

OEDO Due Date: NONE

SECY Due Date: NONE

CC Routing: NRO; FSME; OGC

ADAMS Accession Numbers- Incoming: NONE Response/Package: NONE

Othe Inorato I

Cross Reference Number: G201 10345, LTR- 11-0276

Related Task:

File Routing: EDATS

Staff Initiated: NO

Recurring Item: NO

Agency Lesson Learned: NO

OEDO Monthly Report Item: NO

ArctoTyess Apporoprateiionroiy:Mdu Action Type: Appropriate Action Priority: Medium

Sensitivity: None

Signature Level: No Signature Required Urgen

Approval Level: No Approval Required

OEDO Concurrence: NO

OCM Concurrence: NO

OCA Concurrence: NO

Special Instructions: For Appropriate Action. If a responsý is made, please provide copies to OEDO and SECY.

cy: NO

Doumn Inorato

Originator Name: Jacques Besnainou

Originating Organization: AREVA

Addressee: Chairman Jaczko

Incoming Task Received: Letter

Date of Incoming: 4/27/2011

Document Received by SECY Date: 5/11/2011

Date Response Requested by Originator: NONE

Page 1 of l
OFFICE OF THE SECRETARY

CORRESPONDENCE CONTROL TICKET

Date Printed. May 09, 2011 16:30

PAPER NUMBER:

ACTION OFFICE:

LTR-1 1-0276

EDO

LOGGING DATE: 05/09/2011

AUTHOR:

AFFILIATION:

ADDRESSEE:

SUBJECT:

ACTION:

DISTRIBUTION:

LETTER DATE:

ACKNOWLEDGED

SPECIAL HANDLING:

Mr. Jacques Besnainou (AREVA)

CHRM Gregory Jaczko

Concerns fuel cycle services globally

Appropriate

RF

04/27/2011

No

NOTES:

FILE LOCATION: ADAMS

DATE DUE: DATE SIGNED:

EDO -- G20110345
A

AREVA

Jacques Besnainou

Chief Executive Officer

April 27, 2011

Hon. Gregory Jaczko

Chairman

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Dear Chairman Jaczko:

As you are aware, AREVA provides fuel cycle services globally. With the experience

gained from 40 years operating the world's largest and most successful fuel recycling

complex - with commercial separation and waste conditioning at our La Hague facilities,

MOX fuel fabrication at our MELOX facility, and recent licensing experience supporting

the Mixed Oxide Fuel Fabrication Facility in Aiken, SC - AREVA is uniquely positioned

to support initiatives to implement fuel recycling.

AREVA has been evaluating the establishment of a commercial used fuel recycling

center in the U.S. for the last five years. In 2010, Senator Voinovich proposed new

legislation that would support recycling as an'option to the integrated used fuel strategy

in the U.S. Several states and commumtifls hav e'asked AREVA to site a recycling center

ii•.heir jurisdiction. We are therefore seriously considering a commercial US. facility

and have been working with the U.S. Recycling Advisory Panel (USRAP), a,,

subcommittee of the Nuclear Infrast uctuiie Council (NIC) that involves both,

representatives from utilities and siphli&r, "to upport this activi-ty. Assuming a final rule

in 20,l5 (as'i'dentifift by NRCin pubi i'riytin• •on' September 7,andOctober 19, 2010),

cu~e~itproj ectibns suggest thit constr66et6in o6idIdtegin as earlyasi 2020, with- receipt of

used fuel in 2025, and initial fuel treatment in 2030. Licensing by the NRC is on the

critical path.

AREVA applauds the NRC's work identifying gaps in the existing licensing basis for

recycling facilitihs, the ong6ing work- on the rgthlatory basis, and-&trpngly~encqurages the

N;RC to continue this 'activity to meef the ainouih!&d d;chedule objective of final rulemaking in 2015 to address appropriate ha"I j'to the licensing process. Our view is

still consistent with fiundamental 'reCrti•i-ndations made previouslyand mentioned

,during NRC publimeetfihgs., Virst, recycling fhciltties should be addremsed under a new

Part (referred to as Part 7x/5x). Second, a'one-step licensing process is needed for the

same reasons that underpin the reactor COL'process. As the requisite investment for

such a fuel cycle facility is larger 6 than 'or powerpant, no prdent company (er

AREVA INC.

One Bethesda Center - 4800 Hampden Lane, Suite 1100, Bethesda, MD 20814

Tel.: 301 841 1642 -Fax: 301 841 161.1 - www~areva.com
companies) will enter into a process which could authorize construction but leave

uncertainty about future approval for operation.

In summary, AREVA strongly urges the NRC to continue its activities into Fiscal Years

2011 through 2015 to prepare a modem licensing basis for future recycling facilities.

With its extensive experience in recycling, AREVA pledges to assist the NRC staff by

providing non-proprietary information where it can be useful to the staff in its

development activites.

Please feel free to contact me at AREVA if you wish to discuss the recommendations

contained in this letter.

Sincerely,

Jacques Besni, ou