ML20062C825

Opines That Rationale Expressed in Applicant post-hearing Ltr Unpersuasive to Grant Exemption Request.Applicants Confuse Total Informational Benefits to Ldp W/Marginal Benefits of 6-month Shift in Schedule

ML20062C825
Person / Time
Site:	Clinch River
Issue date:	08/04/1982
From:	Faden M UNION OF CONCERNED SCIENTISTS
To:	Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM)
References
NUDOCS 8208050369
Download: ML20062C825 (2)

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TT . e  ? DOCKETED (jlll0ll (y .USNRC Comcenmen ., s _4 em SCleNTISTS August 4, 1982 rnF!C[ifMG 00cKn & 5ENCt3!

BRANCH The Ilonorable Nunzio J. Palladino The Ilonorable James K. Asselstine Chairman Commissioner Nuclear Regulatory Commission Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 The llonorable Victor Gilinsky The IIonorable John F. Ahearne Commissioner Commissioner Nuclear Regulatory Commission Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 The Ilonorable Thomas F. Roberts Commissioner Nuclear Regulatory Commission Washington, DC 20555 RE: Clinch River Breeder Reactor Plant Docket No. 50-537 (Section 50.12 Request)

Gentlemen:

Applicants' most recent filing argues that there are considerable "in-formational flow" benefits, primarily to the LDP Program, that can be gained from commencement of CRBR site work 6 months earlier than would occur otherwise, that is without a licensing exemption pursuant to 10 CFR 50.12.

The flaw in this argument is that applicants continue to confuse the total informational benefits to the LDP from CRBR activities with the marginal benefits of a 6 months shift in their relative schedules. Ap-plicants have stated in a June 1982 response to Staff (Amendment XV to the Applicants Environmental Report, P.Q 320.6R-6) that:

Should construction of the LDP begin in the mid-1980's, it would overlap CRBRP construction by 3-4 years. In NUREG 0139, LDP and the CRBRP construction were scheduled to over-lap by about one year. The potential increased overlap now contemplated, does not significantly increase the technical risk associated with the LDP. To the contrary, it is DOE's belief that an overlap of 3-4 years is considered to be con-sistent with most efficient use of LMFBR program resources.

As far as the applicants are concerned, the most favorable conclusion that the above-quoted paragraph supports is that early construction of the CRBR would not unduly increase the risk associated with the LDP.

8208050369 820804 PDR ADOCK 05000 tassachusetts Avenue

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( N The Honorable Nunzio J. Palladino The Honorable Victor Gilinsky '

The Honorable Thomas F. Roberts The Honorable James K. Asselstine The Honorable John F. Ahearne August 4, 1982 Page Two It is also clear that the 6 (or even 12) months schedule change in the CRBR is lost within the uncertainty in the Applicants' own esti-mate of the most efficient overlap in the CRBR and LDP construction schedules. In any event, given the uncertainty in the projected date of LMFBR commercialization and the flexibility inherent in the LDP

- schedule, DOE can adjust the LDP schedule to insure that there will be no significant loss of the marginal informational benefits to the LDP. Thus, the points made in the Applicants' post-hearing letter are not persuasive reasons to grant the exemption request under 10 CPR 50.12.

Respectfully submitted, Michael E. Faden Legislative Counsel l

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