The preceding chart serves also to illustrate the one-time nature of some of the scrap. We can expect more of this if our reactor development program is successful.

We have emphasized this matter because it seems important for us to remember the development nature of any facility which is proposed for this interim period of reactor development. We note also the low total volume of the commercial load.

In a general way, we are familiar with Commission facilities for the recovery of irradiated materials and with the status of the recovery as developed in those facilities. For the sake of argument, we are obliged to accept the fact that early recovery of spent fuels is desirable even though the quantity is small as in this case. We accept this premise, not for financial reason but in the belief that reactor design improvement is in a major way dependent on recovery data.

In view of the small volume, we also accept as axiomatic that recovered U and Pu when decontaminated to present Commission practice can be returned to their respective inventory pools and thereby diluted sufficiently so that other isotopes are of "deminimis” concern for the next 10 to 15 years.

In our brief review of the Nuclear Fuel Services' proposal, we are impressed with the effort made to provide a facility which can deal with a number of different fuels. This has been done by a proposed system of mechanical breakdown of the various irradiated scrap materials followed by a leaching extraction of the fissionable materials. The inert scrap is buried. Several extraction processes are proposed depending upon the chemical components of the solutions. Waste solutions are handled conventionally with the assumption that the State of New York will assume perpetual care.

We

We note a state of change currently as to the detailed plant facilities and, hence, we cannot comment in great detail here. As an illustration of this, we note major differences in scope between June and August of this year. interpret this as a Spartan move aimed at a preconceived capital figure. We also note marginal areas of design which when corrected can only increase the capital cost. As illustrations of this, we mention the following:

(a) Instrumentation. Although normal radiation monitoring appears adequate, the apparent absences of a separate nuclear instrument monitoring (NIM) system, neutron or other concentration measuring devices to indicate deviation from normal fissionable material concentrations and facilities to check the condition of fixed poisons in normally inaccessible areas is an area of concern. (b) The approach to contamination control by differential pressure control appears to be in accord with common practice. With respect to maintaining an operable facility, however, the zero flow ventilation concept, particularly in areas such as the MPC and CPC, must be questioned. These areas depend upon remotely operated cranes for maintenance. The cranes, in turn, must be maintained, and in the absence of positive ventilation control there is a strong possibility that they will become contaminated to the extent that their own maintenance will be impossible with available personnel.

(c) Assuming any Darex processing, the presence of any chlorides in subsequent processing in stainless steel equipment must be questioned. SRP experience indicates that <1 p.p.m. chlorine where concentrating mechanisms are present may cause stress-corrosion failure of stainless steel equipment. (d) Could use either more economical iodine system or none.

(e) The problem of solids in feed to extraction system.

(f) Waste problems-thorium, molybdenum, chloride.

(g) Lack of laboratory space.

We are certain that new money will be required to make the facility fully meet expectations. We are equally certain that before the plant is built there will be increases in scope which cannot be foreseen now and which can only increase the cost.

The separation of uranium from fission products has been carried out in Commission facilities for something approaching 15 years. Indeed, the concept of solvent extraction for uranium goes back to the early days of the chemical industry. For these reasons, we are confident that the minimum amount of research will be involved in the fuels as we know them or expect them. Chemical processing, however, in the presence of radiation and fissionable materials introduces plant problems which only semiworks and plant experience can point up and solve.

This experience exists for the regular production reactor fuels such that their recovery processes may be properly considered hard. This is far from true for the miscellaneous irradiated fuel elements from power reactors both commercial and military. For purposes of illustration, we list a few of the extra problems which these fuels as a group present:

(a) Presence of sodium and, hence, hydrogen, storage of Na fuel under water with very limited ventilation.

(b) Zirconium, both as cladding and alloy.

(c) Stainless steel, both as cladding and alloy.

(d) Presence of thorium in major amounts.

The problem of solution criticality is always present but each process has its peculiarities in this respect, and only experience can completely point to the necessary control. This has been painfully brought home to all Commission facilities by events since 1950. We have not concerned ourselves here with the so-called "hazards analysis” which we assume has been carefully covered. We are more concerned here with abnormal operating situations which cannot be anticipated in the abstract. For this reason and considering the present state of experience, we consider the site undesirable at this time.

We feel that it is a bit presumptuous to comment on proposed operating costs as related to operating force. However, by analogy we are convinced that the proposals for manning are Spartan and will be possible only after some years of operating experience. We show comparative estimates as to staffing, but we show them only to indicate that we believe the staff proposals are conservative.

An explanation of the manning variance follows: Plant manager's office.—The plant manager's staff is increased by five to handle customer relations including shipping and processing scheduling, arbitrate variances in uranium and plutonium measurements, follow changes in customer fuel so that the effect on processing can be assessed by technical assistance prior to processing. This staff would serve as liaison with the various Government agencies which would regulate, advise, or require technical operating information from NFS.

Production. It is proposed that operating supervision be increased to a minimum of two per shift plus added day supervision in sensitive areas such as product handling, fuel unloading, and waste disposal. A production engineering staff to write detailed operating procedures, review process data and determine trouble areas, recommend corrections or refer problems to technical assistance, and translate nuclear and radiation safeguards into operator language is essential. There is a high probability that changes in reactor fuel will be frequent and thus operating instructions must be changed quite often. Operating personnel training must be carried out continuously. Safe operation is dependent upon a staff large enough and trained well enough to handle with dispatch those emergencies which are incident to a complex operation such as the NFS plant. Experience at ICPP has shown that there is no substitute for adequate knowledgeable supervision and staff.

Maintenance.—Several necessary crafts are missing in the NFS maintenance staff, such as welders, pipefitters, electricians, machinists, heavy equipment

operators, riggers, carpenters, and painters. The New York area is not noted for leniency in union affairs, and it appears these services would not be available. The plant cannot be operated without them. Even the enlarged 53-man maintenance staff could not handle work resulting from a major radioactive spill.

Health physics.-More prudent health physics coverage would include two health physicists per shift, extra day shift monitors, and specialists in decontamination and instrumentation. A plant safety engineer appears to have been overlooked by NFS.

The

Technical assistance. The fuels to be processed by the NFS plant are extremely diverse. There may be significant variations in cores from a given reactor. processes proposed are unknown. All these problems dictate the necessity for a strong technical assistance group. If production is the prime objective, cold pilot plant facilities and personnel must be available. A strong and knowledgeable processing engineering group must be available to provide process and equipment flowsheet changes both during startups and after since the fuels will be ever changing. A strong basic chemistry and laboratory development staff is needed to properly assess fuel changes, particularly those subtle changes which can occur with added burnup or the addition of trace additives. Corrosion evaluation must be carried out aggressively to prevent escape of radioactive wastes and minimize plant downtime. The ever-changing fuel types will be a challenge that can only be overcome by competent personnel attained in this area. A criticality expert and a safeguard committee of three or more members to scrutinize the equipment, the processes, and the operating instructions should be manned by the technical assistance group. An engineering group of 16, a chemical group of 16, and a technical director and staff of 6 are suggested for routine operation.

Control laboratory (analytical).—The routine analyses to insure process and criticality control will require more staff than proposed by NFS. A significant amount of analytical development work will be required since many of the "hot" analyses are as untried as the processes.

Industrial relations.-The NFS staff does not include the following services: labor relations, employment recruiting and interviewing, and personnel records. Accounting-Buyers, storekeepers, warehousemen, property inventory clerks, internal control personnel, auditors, and budget personnel are not included in the NFS manning.

On an overall basis, we believe the plant could be operated after some years' shakedown at about $500,000 per month including plant depreciation but exclusive of waste tank depreciation.

The startup period, if emergency staffed, would probably be about 1 year. After that we see no reason to quarrel with the assumed operating "in-time" of about 80 to 85 percent.

The facility can be made to operate, but because of the immaturity of the processes the risks are great; and from a practical point of view, since this is the case, the Commission must in effect guarantee operability and assume all risks, process, and operating. This may be the same as saying the proposition is premature by as much as 10 years. In that period of time, we have reason to hope that reactor designs might be firmer and the volume better known so that the matter might be a more proper subject for production contracting. It is reasonable to hope for such a result. In the meantime if the Commission recovers its own fuels in existing facilities, the process knowledge will probably carry over to commercial processing with no more than ordinary commercial risks. There are perhaps those who believe that process development in this area should be a private industry function. With this concept in mind, the proposed small plant might be looked upon as a semiworks for process development with the developments becoming the property of the contractor. We might then postulate a proprietary position which could later produce profits for the company involved. We cannot visualize this position since patent protection would seem improbable and, long range, undesirable, when and if the load becomes large enough to merit a competitive operating situation.

We are obliged to call your attention to another matter which is closely tied to the technical risks inherent in this kind of a business. The proposed contractor has no other business from which to draw funds to support extraordinary startup costs or any other major penalties which are frequent in the chemical industry. Any catastrophic operating cost situation would have to be covered by the U.S. Government one way or another. This is in contrast to a