ML20055G981
| ML20055G981 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/27/1990 |
| From: | Rossin A ENVIRONMENTAL & RESOURCES CONSERVATION ORGANIZATION |
| To: | Carr K NRC COMMISSION (OCM) |
| Shared Package | |
| ML20055G980 | List: |
| References | |
| NUDOCS 9007250002 | |
| Download: ML20055G981 (2) | |
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ENVIRONMENTAL CONSERVATION ORGANIZATION Suite 320 1
101 First Street
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14s Altos, CA,94022 June 27,1990 Hon. Kenneth Carr, Chairman United States Nuclear Regulatory Commission Washington, DC 20555 DOCKET NO. 50 312 Rancho Seco Generating Station Ref: SMUD AGM/NUC 90-114 PROPOSED AMENDMENT NO.184, APRIL 26,1990, and NRC LETTER TO S. D. FREEMAN, June 13,1990
Dear Chairman Carr,
The Environmcntal Conservation Organization (ECO)No.184 was retumed to the Licens has reviewed the above-referenced corresponde' ice. Although the Proposed Amendment because it was incomplete and did not include a alan for ultimate disposition of the Rancho Seco facility, its submittal serves notice that SMUD wishes to convert its license to a
" possession only" license.
The granting by NRC of such a license would permit SMUD to take actions which could make it impossible for the plant to be returned to operation as a nuclear power plant. ECO believes that in the coming years California will need the power that the Rancho Seco Nuclear Station can produce. The alternatives to the electricity this unit has been licensed to generate will, we firmly believe, be found to cause negative impacts on the environment, waste non renewable resources, and result in significant economic penalties to the people of California and possibly in neighboring states as well.
Other alternatives suggested on occasion by the SMUD Board, such as conversion of the station to gas firing or solar energy, appear likely to be impractical, uneconomic, and perhaps even technically infeasible. We believe that the price of natural gas will rise, and since a ~
significant part of California's electricity will come from burning gas, this will drive prices u 3. ECO believes that the Rancho Seco Nuclear Generating Station could produce nuclear e; ectric power at competitive prices without the emissions of oxides of nitrogen and carbon to the atmosphere that will come from burning that gas.
In any case, until such alternatives are propose I and defended in a complete Environmental Impact Statement, and considered in open licensing hearings, it would not be prudent, nor consistant with NEPA, to allow any actions by SMUD which might compromise in any way the potential future operability of Rancho Seco as a nuclear power plant again.
ECO does not want restart tainted by any actions omitted during this entire process. The principal members of ECO are exper,enced nuclear engineers. We know that the actions which would be taken related to defuelling, transportation and decommissioning can be conducted safely, without undue or even any significant risk to the health and safety of the public. This is not the principal basis of our concern, and would not likely be the basis when we request to intervene in relation to a request for a Possession Only license.
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i ECO considers the request for a license amendment as in SMUD's submittal of April 26, e
1990, if it had been accepted, to be a request for NRC to make a decision which would T
unquestionably represent a major Federal action, with the potenthl for significant impact on the quality of the environment. A fulllicensing proceeding would be required to reach a decision, and therefore a full Environmental Impact Statement would be essential.
An electricity source which can hardly be replaced for less than $2 billion is at stake. The alternatives are undefined, including hypothetical savings from conservation which are undefined and maj not be achievable, and even if achieved would at best represent the delay of an undetermined number of years, grhaps a very few, until that capacity would be needed.
Alternative sources of solar, wind and hydroelectric power would seem no more than speculative at this time.
ECO has examined the electric supply situation in California and the Western Region Coordinating Coucil states. It is obvious that almost all of the lost Rancho Seco capacity is being and will be made up by burning natural gas, and then oil when the pilce of gas goes up and shortages of delivered gas begin to take effect.
The history of NRC's actions in the past, many of them forced by court decisions, confirm that license proceedings which had much smaller potential environmental impacts than the decommissioning of Rancho Seco were found to constitute major Federal actions requiring a complete Environmental Impact Statement. We see no way in which a finding of "no sigmficant harm" could be possible in this matter.
In light of these considerations, ECO intends to intervene when the time is appropriate.
Because NRC does not routinely mail copies of correspondence from the licensee to the organizations on the service list, and because our grou? s small at the present time, there is a i
possibility that notice in the weekly report of NRC act.ons might come to our attention late.
We do not want to risk the possibility of being rejected for late filing, so we ask that you have the NRC Rancho Seco Project Manager notify ECO's Coordinator, A. David Rossin, by telephone at 415-948-7939 if and when a new application for a Possession Only license is
' received.
Environmental Conservation Organization appreciates the continued dissemination of com-munications to us, and we thank you for your consideration.
Sincerely, A
Environmental Conservation Organization ec: Chairman, Board of Directors, SMUD Ramon Ashley - Resident of Folsomp, CA, in the SMUD Milton Levenson -(Forn er President, American Nuclear Society)
A. David Rossin - Coc;dinator, ECO (Former Asst. Secretary of Energy)
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