ML19295A633

Comments on Rulemaking 50-5:GESMO Proceeding Should Be Rescheduled

ML19295A633
Person / Time
Site:	West Valley Demonstration Project, 05000564, Marble Hill, 07001327, 07001821, Barnwell, 07001432
Issue date:	09/29/1980
From:	Burt D, Field M, Todorovich M AFFILIATION NOT ASSIGNED, CAPITAL LEGAL FOUNDATION, SCIENTISTS & ENGINEERS FOR SECURE ENERGY
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-45FR53933, RULE-RM-50-5-45FR53933 45FR53933-45, NUDOCS 8010020663
Download: ML19295A633 (2)

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SUITE 810 Dan M. Burt WA5Hf NGTON. D.C. 20036 202,'29H900 September 29, 1980 Chanern.tn n the %ard t..u. w.

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Via e President nuor co,pm.i.on Mr. Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission g,,,,,,

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Dear Mr. Chilk:

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In response to the invitation of the Nuclear the s.a co,p*'" "

Regulatory Commission of 7 August, 1980 to comment on t= <e o th der..

the question of the continuation of the GESMO and other U3.M"c,,,,,

recycle-related proceedings, Scientists and Engineers for Secure Energy, Capital Legal Foundation and Mid-Atlantic

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Legal Foundation urge the Commission to:

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orn Century Fan 1)

Reschedule GESMO and other recycle-related 44,.i w.r-c. uon proceedings which were suspended by the t swee' red Commission in 1977 and 1978.

A proper regulatory u o,,,u,,3,,,,,,

framework is required prior to the issuance of Panne'

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operating licenses, and by refusing to complete c ne o. w.6..'

the GESMO proceedings, the Commission has vetoed

$'e"o".e, i c3.e.,i.,

the issuance of am reprocessing licenses in violation of its statutory obligations.

Frankhn w. Peters Peps.oent Peterdue' 2)

The licensing applications related to commercial reprocessing of nuclear materials should be expedi-o.. w. s a tiously processed in accordance with the commission's i,,,,...s.,,,,,

P'esident own mandatory procedures and within the existing "C"

regulatory framework.

Even if the United States isn't embarking upon a breeder program at this time, other countries are, and by ignoring international, commercial reprocessing of nuclear materials, the United States may suffer significant economic damage.

Breeder reactors make nuclear fuel a renewable resource.

Spent reactor rods contain significant amounts of reusable material and car national commitment to resource conservation implies recycling recoverable fuels.

Fecycling also reduces the need for mining and processing of uranium ore with 80100200 0

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Mr. Samuel J. Chilk September 29, 1980 Page 2 concomitant favorable health and safety consequences.

Nuclear waste management and ultimate disposal of nuclear waste are simplified by appropriate reprocessing, thus reducing health hazards related to waste storage.

Reprocessing also extends the world supply of uranium ores.

For these reasons, we favor e:;peditious licensing of any facilities for the commercial reprocessing of nuclear material.

3)

The Commission should review other practical nuclear fuel cycles considered in the International Nuclear Fuel Cycle Evaluation study and should institute, independent of GESMO, additional proceedings which may be necessary to prepare the United States for the time when other contem-plated nuclear fuel cycles may become commercially viable both domestically and internationally.

We appreciate the NRC's detemnination of the above with respect to its statutory obligations and in the spirit of an independent regulatory agency of the United States.

Sincerely,

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Dan M.

Burt President Capital Legal Foundation

,NJ Myrnp P.

Field President Mid-Atlantic Legal Foundation

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oc Miro M.

Todorovich Executive Secretary Scientists and Engineers for Secure Energy, Inc.