ML20058G905

Comment on Fr Notice Page 41280 to 41282 Re Smud Possession Only License Amend.Believes Termination of Plant OL Prior to End of Authorized Operating Term Will Have Significant Impact on Environ Sources Needed to Generate Power

ML20058G905
Person / Time
Site:	Rancho Seco
Issue date:	10/23/1990
From:	Prussman S AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-55FR41280 55FR41280-00001, 55FR41280-1, NUDOCS 9011140099
Download: ML20058G905 (2)

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October 23, 1990 Gl0 QI $$O Regulatory-Publications Branch Division of Freedom of Information l'QIlp/q()

and Publications Service i

Office of Administration

'U.S.

Nuclear Regulatory Commission Washington, D.'C.

20555-

SUBJECT:

COMMENT ON F.R.. NOTICE PAGE 41280 TO 41282, OCTOBER 10, 1990 SMUD POSSESSION ONLY LIICENSE AMENDMENT To Whom.It May Concern:

The change from an operating license to a possession only license is an understandable procedural step towards reduction of costs when a d4 cision to cease operations has been made.

However, termination of a plant operating license prior to the end of the authorized operating term will arguably have a significant impact on the environmont (e.g.,

V alternative sources will be needed to generate power, the costs of decommissioning will not be spread over the useful plant life).

Since the granting of a possession only license could result in irretrievable commitment of resources (e.g., ESF systems allowed to degrade), an environmental 1 assessment should be required for the amendment or a demonstration should be made that there will be no unacceptable loss of resources, Taking action consistent with'the above comment is required by NRC l'

l regulations on license amendments.- These require consideration of the p

issues applicable to the initial license (10CFR50.92(a)) and either an environmental impact statement or assessment (10CFR51. 20 (b) (14 ) and-51.21).

To allow piecemeal decommissisoning prior to an environmental review of.the decision would also defeat the purpose of 10CFR51.53(b) which requires an environmental report update for decommissioning.

Further, it is important that the commission address this issue on the SMUD docket since thure are several utilities currently looking to L

decommission power plants prior to the end of license and this license amendment will set a precedent.

I'want to make it clear that the intent of this comment is not addressed L,

to the impacts of decommissioning (these were addressed in the GEIS t /

NUREG-0856) but rather to assure review of the cost-benefits associated Lwith the decision'to decommission.

Cost-benefit analyses could look at operating history, cost to restart a shutdown unit, sources and costs of F

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. replacement power, and need for power.

These type assessments are typical of the utility industry in ordering new planto and retirine refurbishing old plants, opening the shutdown decision making proc.sa to public comment is necessary to fairness and need not subject a utility to needless costs (case by case license amendments can be made with a showing of no irreversible impact) during public assessment of the decision.

Very truly yours, M

S G Prussman 122 Ketchams Road Syosset, N.Y.

11791 i

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