2011/03/08-Comment (45) of W. C. Hale on FR Doc # 2010-32242

I am writing in support of the American Physical Society's petition (Docket ID NRC-2010-0372) to change the Nuclear Regulatory Commission’s rules to require Nuclear Proliferation Assessments as part of the NRC licensing process.

I support an amendment to regulations at subpart D of 10 CFR part 70, “Domestic Licensing of Special Nuclear Material,” Sec. 70.22, to include the following language to be made part of an applicant’s license application: Nuclear Proliferation Assessment. Each applicant for the license of an enrichment or reprocessing facility shall include an assessment of the proliferation risks that construction and operation of the proposed facility might pose. Such an assessment must be prepared in draft form and be required to be reviewed by NRC staff, recognized external experts and members of the public and that public comments be solicited and incorporated into a final version of the assessment.

New nuclear technologies, such as the proposed GE-Hitachi laser enrichment facility in North Carolina or new spent fuel reprocessing technologies for which licensing regulations are being developed could pose unique and substantial proliferation risks. It is thus essential that a proliferation assessment be prepared before a such technologies are licensed, rather than waiting to deal with a situation where the technology may be proliferating due to commercial demands or because of clandestine use.

I urge the NRC to accept the APS petition and apply NRC regulations so as to require a thorough analysis of the proliferation implications in the licensing review of new nuclear technologies related to uranium enrichment, reprocessing and other new nuclear technologies.

Thank you very much for your consideration of the views expressed in this comment and for posting my comment in both the docket and in ADAMS.