ML19347C149
| ML19347C149 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project, 05000564, 07001327, 07001821, Barnwell, 07001432 |
| Issue date: | 10/08/1980 |
| From: | Moody J YANKEE ATOMIC ELECTRIC CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| RULE-RM-50-5-45FR53933 WYC-80-32, NUDOCS 8010160695 | |
| Download: ML19347C149 (2) | |
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Cetober 8, 1980 bD T4XETED USNPC I
Secretary of the Cc= mission z
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U.S. Nuclear Regulatory C0= mission k
Office cf the Secretaly Washington, DC 20555
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Attention:
Docketing anc Service Eranch a
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Subject:
Comments on GESMO - International Nuclear Fuel Cycle Evaluation (45FR53933-8/13/80)
Cear Sir:
Yankee Atomic Electric Ccapany appreciates the opportunity to coc=ent on whether the Ccesission should reopen GESMO. Yankee Atomic cwns and operates a nuclear power generating plant in Rowe, Massachusetts. The Nuclear Services Division also provices engineering services for other nuclear power plants in the Northeast inclucing Vermont Yankee, Maine Yankee and Seabrook i and 2.
Yankee Atomic is a member of the GESMO Utility Group which participated in the original proceeding. We believe the GESMO proceeding snould be reopened for the following reasons:
Completion of GESMO is essential to nuclear fuel cycle closure and the future of nuclear energy. Fuel reprocessing, the breeder program, anc ultimate waste storage are i=portant programs of national interest requiring many years to implement.
!=plementation of these programs are significantly impared until completion of GESMO.
The GESMO proceedings were originally discontinued due largely to proliferation concerns. Alternate fuel cycles were examined and the International Nuclear Fuel Cycle Evaluation (INFCE) study has concluded that there is no realistic proliferation-proof fuel cycle and that institutional controls are i=portant to limiting proliferation risks.
The* NFCE study confir:ed the ecenceic advantages of reprocessing anc recycling fissionacle caterial both frem the standpoint of conservation of rescurces as well as waste =anagement.
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U.S. Nuclear Regulatory Commission October 8, 1980 Attn: Secretary of the Commission Page 2 l
Many countries are continuing to develop their nuclear capabilities, including reprocessing, independent of the United States and as a 1
consequence we may lose any ability to influence international cont rols. This could adversely effect the proliferation problem.
1 In summary, we believe it is in the National interest to complete GESMO hearings as a prelude to closure of the nuclear fuel cycle.
If you should have any questions regarding our ccaments, please contact us.
j 7ery truly yours, YANKEE ATCMIC ELECTRIC COMPANY
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i H. Moody
~ nior Licensing Engineer
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g Attention:
Chief, Docketing and Service Section
& fg GESMO Docket No. RM-50-5
Dear Sir:
Arizona Public Service Company,* Carolina Power
& Light Company, Commonwealth Edison Company and Wisconsin Electric Power Company, full participants in the now dor-mant GESMO rulemaking, submit these comments pursuant to your request of August 7, 1980 (45 Fed. Reg. 53933).
The NRC is seeking the views of the public with respect to the resumption of the GESMO rulemaking as well as specific licensing proceedings.
Since the above-named utilities (hereinafter referred to as the " Group"), as licensees for the construction and operation of light water nuclear power reactors, are primarily concerned with the generic availa-bility of the reprocessing / recycle option, the Group's comments will be limited the question of reopening the GESMO rulemaking.
The Group supports the resumption of che GESMO rulemaking.
We believe it is necessary to complete this rulemaking in order to establish sound decisionmaking bases for determining the efficacy of spent fuel reprocessing and recycle.
Cruc'ai decisions regarding the form of high level Arizona Public Service Company submits these comments on behalf of itself and the participants in the Palo Verde Nuclear Generating Station.
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1 nuclear waste for permanent disposal are inherent in the reprocessing question.
Moreover, it is imperative that l
these questions be answered with finality in order (i) to i
provide needed certainty with respect to the nuclear li-l consing process and the energy resource mix available to the nation, and (ii) to maintain this country's capability as an international nuclear supplier.
Since the.GESMO proceeding i
primarily involves an environmental assessment, under the i
National Environmental Policy Act of 1969, this process I
permits a full exploration of all policy views, including j
those of the Administration.
Indeed, we can conceive of no better mechanism for testing the soundness of the Admin-istration's policy of proscribing domestic reprocessing /
j recycle programs as a part of its nuclear weapons nonprc-i liferation policy.
1 I
i The Administration's recommendation in 1977 to terminate the GEGMO proceeding was prompted by two principal 4
concerns.
Completion of the INFCE study was deemed necessary i
as a precursor to the GESMO rulemaking.
And it was perceived that any action other than termination would be construed by the international community as undermining both the INFCE j
effort and this country's declared policy of limiting and i
deterring the proliferation of nuclear weacons.
The INFCE j
study is now complete, and the Adminiocration's nonprolifera-i tion policy is well-established.
"nerefore consistent with j
the teachings of the Westinchouse
=se,*
it would appear l
improper to restrain any longer the process for determining i
.he future of reprocessing and recycle -- the GESMO rulemaking.
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The two year INFCE study, initially sponsored by the Administration, concluded, among other things, that re-t processing for light water reactor plutonium recycle may have net economic benefit, that breeder reactors cannot be ruled out as energy sources for at least some countries, that reprocessing is essential for the breeder fuel cycle, and j
that, based on a review of a large number of alternate fuel cycles, no fuel cycle stands out on technical grounds as sig-nificantly more proliferation resistant than any other fuel cycle.
Nevertheless, the Administration has reiterated its intention to postpone consideration of reprocessing and l
. recycle indefinitely.
The continuation of this moratorium i
is now tantamount to a decision to commit to the once-through, or throw ~away, nuclear fuel cycle, a decision at variance with j
the conclusions of INFCE and unsupported by any programatic i
1 1
1 Westinchouse Electric Corporation v. NRC, 598 F.2d 759 (3d Cir. 1979).
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.i environmental impact statement as required by law.
Recog-nizing this de f acto decision, the Nuclear Waste Confidence Rulamaking (PE-50, 51) is premised on the assumption that spent fuel will be disposed of directly without reprocessing.
Resuming the GESMO proceeding would serve to provide the necessary environmental statement, and more significantly it would provide a proper factual basis on which the NRC could render its own independent judgment on issues that since 1977 are more urgently in need of solution.
Sincerely, O
Joseph Gallo Counsel for Arizona Public Service Company, Carolina Power & Light Company, Commonwealth Edison Company a
and Wisconsin Electric Power Company e