ML20040C793

Package of Six Comments Opposing Exemption of Facility from Std Licensing Procedures

ML20040C793
Person / Time
Site:	Clinch River
Issue date:	01/21/1982
From:	Marlone Davis, Friedman J, Frieman J, Mccurry A, Miller S, Sanfilippo M, Warnermills S AFFILIATION NOT ASSIGNED, External Citizen/Individual/Media (Affiliation Not Assigned), PEOPLES ACTION FOR CLEAN ENERGY, INC., SORGHUM ALLIANCE, LEXINGTON, KY
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
ISSUANCE-E, ISSUANCES-E, NUDOCS 8201290244
Download: ML20040C793 (7)

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3-RECEP1ED J AM 2T N* t9 Forest Street

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Office of the Secretary N Nuclear Regulatory Commission Washington, D.C. 20555 UC T.': n RE: Clinch River Breeder Reactor Exemption Requests by DOE F.C.C.P.[,Q,p-[$][g)

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Dear Sir or Madam:

I as writing this letter in reaction to the request made by the Department of Energy to exempt the Clinch River Breeder Reactor project from certain NRC regulations, specifically from the requirement of a construction permit in order to proceed with on-site preparation.

I would like to voice my strong opposition to any such exemptions.

First, to grant such exemptions contradicts the " regulatory" role of the Consaission, which is intended to provide protection not to the industry but to the public. I understand that the utility claims that these exemptions should be granted on the grounds that the site preparation it proposes involves no safety risk whatsoever.

My reasons for opposing the exemptionr, however, go beyond safety-related considerations. The utility is planning an investment of $88 million for site preparation. Both the preparation of the land itself for this specific purpose and the investment of such a large sum will make it much harder for the utility to decide against proceeding with i the reactor at any future time (e.g., for reasons of drastically declined public energy requirements) or for the utility to accept a negative ruling by the Commission on the licenses it will eventually require without resorting to legal appeals. For these reasons, exempting the utility from requirements now will result in much greater pressure on the Consnission in the future to allow the project to proceed, even in the event of potential safety and environmental violations, particularly because it has set a precedent of disregarding its own regulations.

Regardless of the Commission's eventual findings about the safety of the Clinch River Breeder Reactor project, therefore, exempting any project from the Conunission's own requirements not only contradicts but is sure to counteract that Commission's future role as an effective regulatory agency.

I understand that today is the final day for submitting public comment

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on this issue. For that reason, I telephoned your office in Maryland earlier today to do so. The woman I spoke with reconumended that I put my cotanents in I (7 writing and assurred me that if my letter were postmarked with today's date (January 18, 1982), my coumments would be considered- and recorded in the Federal Register. Thank you for your consideration of. my conuments.

Sincerely, 1

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Susan Warner-Mills

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Nuclear Pegulatory Commission Washington, D.C. 20555 RE: Docket 450-537 s Exemption request under 10-CFR- 6 s T To the Secretary of Cornissioning: c ,

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It has come to my attention that there has been a request to exempt he JQfg prototype Clinch River breeder reactor in the Tennessee Valley from stan Ed W g h licensing procedures. T 'W pp {<;

The concept of increasing the available supply of world fuel and promotin'g s j the independence of this country from fuel producing nations is laudable, but\N, ,

to attempt to do so through methods which breed more plutonium is perilously short-sighted, given the attractiveness of this substance to persons of minimal impulse control (terrorists and/or the insane), the smai.etown availability of technology for assembling instruments of destruction, and the fact that safeguarding this material from misuse is not absolutely possible, with the direst consequences for civilization.

I am proud of our country and of its place as.the forerunner of technological development in the world. Some of my ancestors founded this countrf, and it is astounding that so much of the grand dream they and the other brave people who came and joined in the creation and development of this nation brought with them has been brought to fruition. A major disadvantage of being a young country is the lack of a sense of history, of the continuity frem the past into the future; an adolescent striving to be the greatest that breeds i=pulsivity, reckless competitiveness, and a disregard for ongoing human needs and for the ecnsequences of such careless thought, planning, and action. A leading nation must balance its brilliant accomplishments and fertile potential with attention to the experience of its people. I will soon start a family, and while I expect that teur; country will have available resources for me to purchase to keep my family varm;and-provided for, the agony of ongoing fear that surrounds knowledge of the proliferation of plutonium causes tremendous concern and anger about the ability of someone to bring an end to all our lives in the guise of providing fuel for civilization.  % 3 J

I completely oppose the current effort to reverse government policy and -

exempt the Clinch River breeder reactor from standard licensing procedures Such /

an irresponsible action reflects the arrogant and erroneous notion that,the plutonium produced could be kept absolutely safe and used only-~for the purpose _

for which it would be made. I subnit that such naivete can lead to the destruction

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2s Secretary of Consissioning of families, technologies, civilization itself, the ultimate embarrassment to ~

a people trying so' to be the greatest there ever was, while carelessly ignoring the more mature. consideration of consequences.

I urge you to oppose this request for examption, in the interest of us all.

Mank you.

Very truly yours, * ,

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___ January 16, 1982 M llalnut Place Newton Hignlan'ds, MA 02161 Secretary of the Commission

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Deer Mr. Secretary I understand you clan to cernit the building of the Clinch River. Tennessee, breeder reactor without the no:-aal regulatory orocedures. I consider this an extreately dangerous "teve. Nuclear reactors are hazardous enough even when nor tal regulations are followed.

I strongly urge you NOT to exeatot the Clinch River breeder reactor fron nor-tal regulatory orocedures.

Sincerely yours, c/b /N Susan Miller

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Secretary-of . . [ .b.? h+-I37 (f ) IZe- ---- - -

Nuclear Regulatory Commission Washington, DC 20555 Re: Docket No. 50-537--exemption request under lo CFR 50.11

Dear Secretary of the Commission:

You are urged not to exempt the Clinch River 3reeder Reactor from rule 10 CPR 50.1 .

'The Clinch River project was supposedly designed to demon-strate that breeder reactors are licensable. Sidestepping nor=al licensing procedures would =ake the project worthless as an example.

Furthermore, the full procedure for licensing needs to be followed to ensure the feasibility and the safety of construction ~

on the proposed location before millions of dollars are spent on site preparations. Many nuclear power plants are experiencing problems because they were poorly sited. These problems include complex evacuation planning due to the proximity of large popula-tions and the necessity for involved construction techniques due to soft ground or earthquake faults. The Bailly plant in Indiana is a prime example, as construction at this plant was abandoned (after it was well underway), largely because the plant had been poorly sited. A breeder reactor which uses liquid sodium rather than water as a coolant is potentially far more dangerous than a

'btandard" nuclear power plant. From both a safety and an economic point of view, the public cannot afford shortcuts that might make possible a mistake at Clinch River.

l Ihere is, moreover, no emer6ency situation which would suggest l a setting aside of normal procedures. Uranium mines are closing l in the West for lack of purchasers of uranium, and the rate of increase of America's consumption of electricity is declining.

Sincerely, tc 8 .h M. 3. Davis I

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