ML20040H333

Opposes Applicant Request for Exemption from Licensing Procedures Under 10CFR50.12

ML20040H333
Person / Time
Site:	Clinch River
Issue date:	02/04/1982
From:	Peter Meier NUCLEAR INFORMATION & RESOURCE SERVICE
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
ISSUANCES-E, NUDOCS 8202180105
Download: ML20040H333 (2)

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, / '82 FEB 10 P1:33 Nuclear Information and Resource Service 1536 Sixteenth Street NW, Washington, D.C. 20036 (202)483-0045

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eitt,hCH February 4,1982 gy\[ h To: Secretary o5 the Commission -

[1 U.S. Nuclear Regulatory Commission /'. ,,. D ,

Washington, D.C. 20555 -: N jA y ,..40  ;

Re: Docket #50-537 Exemption request -\, i' 'p) vp% /s k /, .}

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under 10 CFR 50.12 J p Q , M 1- d ]

The Nuclear Information and Resource Service, an organizat' ion '

representing citizens across the country concerned about nuclear power issues, urges the U.S. Nuclear Regulatory Commission not to exempt the Clinch River Breeder Reactor from licensing procedures under 10 CFR 50.12.

The Nuclear Information and Resource Service (NIRS) opposes the exemp t ion - f o r ' t he r f o llo wingm r ea son s :

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1). Licensing the Clinch River Breeder Reactor' is not an emergency situation -:and therefore does not warrant any kind of special exemptions from the normal prodedures. To exempt CRER from certain prodedures would undermine the licensing process.

2). W~easeda no " Congressional mandate" to encourage the Nuclear Regulatory Commission to expedite the licensing process of CRER.

It is a mistake to call the extremely close voting record a " Congressional mandate."

3). The Clinch River Breeder Reactor is the second commercial demonstration reactor. The first 200 MWT breeder reactor, Fermi Breeder Reactor, was built by a consortium of utilities at Laguna Beach, Michigan.

Fermi suffered a serious partial core meltdown accident and was shut . .

down in 1966 and later permanently closed in 1972. The safety of the breeder reactor has never been proven. Why should any exemptions be granted from the licensing procedure on a questionable commodity?

l 4). According to Burns and Roe; the architect-engineering firm for the Clinch River Breeder Reactor, stated in a secret corporate memo that, "The CRBR site selected for the Liquid Metal Fast Breeder Reactor demonstration plant is one of the worst sites ever selected for a nuclear power plant based on its topography and rock conditions."

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The Department of Energy's Energy Research Advisory 5).

Board recommended that " funding for the CRBR be terminated and that the 3 savings be channeled into higher priority areas such as conservation and

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environmental R 5 D." (Science, Jan. 1982) .

-l 6). The CRBR was originally planned to accommodate the increase '

.1 in electrical demand, based on the 1960's growth curves for energy. Yet, d

since 1973, the energy growth has declined sharply in response to the

higher prices of electricity. In JanuaYy[$mitted a~propos41][to'selIMD nuclear power reactors to Mexico as a result of lower electrical demand and increased costs of financing nuclear power 'reae,tiors.

7). It is inconsistent with this Administration's overall economic policies to underwrite energy programs so heavily. Whereas '"_

in 1973 a group of 753 private utilities agreed to provide more than'  ;

a third of the capital for CRBR, it now appears that, because of cost ; 'J increases, the private sector will only provide 8% or less of the invest-ment. How viable'would the CRBR be in a free market economy? A thorough

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analysis has been prepared by David Stockman that concludes, "the breeder .i is totally incompatible with our free market approach to energy policy." .

For all of the reasons stated hbove, NIRS urges the Commission not to allow licensing exemptions for t.his controversial demonstration ' reactor, s ,

. Respectfully submitted, S.Lk L$ h% '

Paulette, Meier, NIRS Information Coordinator aaa P

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