ML20049H247
| ML20049H247 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 01/27/1982 |
| From: | Muller D Office of Nuclear Reactor Regulation |
| To: | Check P Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20049H240 | List: |
| References | |
| FOIA-82-272 NUDOCS 8202100497 | |
| Download: ML20049H247 (3) | |
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RBaliard CGears RSamworth PE"0RANDUM FOR:
Paul S. Check, Director CRBR Program Office l,a FRO'4:
Daniel R. Muller, Assistant Director for Environmental Technology
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Division of Engineering e
SUBJECT:
DOE DRAFT SUPPLEMENT TO LPFBR EIS s
We have reviewed DOE's U4FBR EIS Supolement as recuested by your memoranjum of January 6,1982 and provide the attached comments.
Original signed by Daniel R. Muller c
Daniel R. Muller, Assistant Director for Environmental Technology Divhion of Engineering Ettachment:
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r JAN J ! 102 COMMENTS ON LMFBR PROGRAMMATIC STATEMENT SUPPLEMENT General:
There is poor balance in the discussion of alternatives.
For example, the discussion of wind power indicates noise as an issue.
However, there is no mention of cooling tower noise for the LMFBR alternative.
Specific:
pp. 3-4 Re-Cost-Benefit Analysis -- NRC recogni::es that many of the key parameters in a cost benefit analysis are highly uncertain.
However, DOE's cost benefit considerations are an important input into NRC's NEPA review and we urge that DOE prepare-an updated cost benefit analysis for the LMFBR program.
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resulting analysis could rely on a reasonable range of valges for key parameters and results could be clearly identified as highly uncertain.
At a minimum, 00E could provide a summary of all costs and benefits with a qualitative / quantitative (when possible) discussion of each item.
- p. 36 First sentence -- Report incorrectly states that the lifetime uranium requirements for a* LWR varies between 140 and 200 ST U 0g.
This is the annual uranium requirements for a LWR.
3The calculations that follow in the Supplement all reflect this latter relationship.
pp. 43-44 One-Sided Risk of Delay -- The Supplement uses economic arguments-to justify the timing of the LMFBR program.
The cost of not having the LMFBR when needed is cuantified and indirect benefits foregone are also id$f tified.
Alternatively, the cost of bringing it on too early are simply identified as -being a function of the i
direct cost, the cost of money, and time.
We believe this side of the equation should also be quantified and that indirect costs such l
as increased gov't deficits and inflationary pressures should be I
identified.
Finally, we believe tnat for the "too early" vs. "too late" scenarios to be comparative, they must be brought to the same point in time via an appropriate discount rate, t
- c. SS The discussion on alternative site excludes the possibility of l~
sites outside the TVA region because of the contractual arrange-ments DOE has made with TVA.
This appears to be inconsistent with the alternative sites review we are following with CRBR.
Are we doing unnecessary work?
- o. 214 The relative environmental imoacts of alternative technologies are not supported in the text.
For example, there is no basis for the different acreages reported for transmission lines.
Water use for OTEC is reportedly very large and yet there is probably little or no actual consumotion, as comoared to, say, LMFBR cooling towers.
The table is misleading.
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JAN 2 71932
- p. F-6 Second paragrapn, third sentence - Apoarent typo - Sentence
("In 1980, coal.... using oil.") does not make sense in its current form,
- p. F-7 Type -- bottom of page "3.35" should be 3.3"..
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