ML20063E408

Comments on Draft Suppl to Fes Re Const & Operation of Facility.Nrc Should Recommend Project Be Canceled Due to Need & Cost Considerations

ML20063E408
Person / Time
Site:	Clinch River
Issue date:	08/17/1982
From:	Frey D SASSAFRAS AUDUBON SOCIETY
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8208300243
Download: ML20063E408 (2)

Text

1 p

& J'? 70 The INDIANA SASSAFRAS AUDUBON SOCIETY

-ee

~

[,p g

of Lawrence - Greene - Monroe -

f

~/

Brown - Morgan & Owen Counties b[ NA

.n.

August 17, 1982 5 -53 7 n

h fg@;%p L g

TO: OFFICE OF NUCLEAR REACTOR REGUIATION, y

g X"~,

U.S. NUCLEAR REGUIATORY CQMISSION i

.r a

Y

~

RE: DRAFT SUPPLEMENI TO FINAL ENVIRONMENTAL SIATEMENT, CLINCH RIVER BREEDER REACTOR The Sassafras Audubon Society has reviewed the Draft Supplement to the Final En-vironmental Statement related to construction and operation of the Clinch River Breeder Reactor Plant (CRBRP), Docket NO. 50-537 and finds it unacceptable on grounds literally too numerous to antion. This statement will be limited to the issues of NEED and COST.

First and fozemost, need for the CRBRP is not established in Chapter 8, NEED FOR THE PROPOSED FACILITY. In fact, only conjectures of its "possible" need decades hence are given as the raison d'etze, mason enough for our reauest that the NRC staff recommend in the Final Supplement that the CRBRP Project be canceled.

The NRC staff notes on page 8-2 that 'Because of the long lead-times involved, ei,en with vigorous pursuit of this plan (construction and operation of the intermediate size CRBRP), a commercially viable IMFBR and significant IMFBR market penetration are decades away." The staff also notes that them have been changes in the emphasis of the program, the most important of which is that the decision on deploynent and commercialization of the IMFBR will be made by the utility industry.

Therefore, there is not only a question of need, but whether a nuchar power utility industry will even be around to contemplate such a decision decades hence. Not a single nuclear power plant has been ordered since 1978, while numerous projects have been canceled and more are under consideration for cancellation. Tha z.uchar power market has evaporated home and abroad. Where is the need for the CRBRP?

What are the reasons for the decline of the nuclear power industry? It is univer-sally admitted that the staggering costs of nuclear construction are not alone to l

blame, but that the continuing nation-wide decline in electrical demand is also responsible. The nation has an over-capacity beyond what is; needed for peak de-i mands. Conservation of energy and more efficient use of energy has been zesponsible in part for the decline in electrical demand with the clear potential of energy l

conservation and increasing use of soft-energy strategies lowering demand notably in the immediate future.

TVA, an applicant in the Clinch River Breeder Reactor Project, has " shelved" many i

nuclear power plant projects and is promoting energy 4onservation-onergy efficiency in its service area. Its participation in the CRBRP Project is obviously political-l ly directed.

C.0 01 With all this in mind, the NRC staff's statements to the effect that the conseauences of the early development of the CRBRP, even at the risk of developing the ontion before it is economically competitive with LWR's, are minor compared to the risk l

8200300243 820817 l

PDR ADOCK 05000537 D

PDR

,.o 2-y of possible electricity shortages and economic penalties associated with late development is irmsponsible. On whar, evidence is the fomcast of "possible electricity shortages" based?

The economic penalties will come. with the construction of the CRBR and be borne by the American people, who will bear over % of the costs at best, and conceivably all of it. The projected cost of. the CRBRP of $3 525 billion is hopelessly over-optimistic in view of what it costs to build an LWR and in view of the enormous coct overruns being experienced in the Fmnch Bmeder Program and those of Japan and other European nations. The final cost of the CRBRP is mom likely.to surpass: $7 billion.-

The futility of further argument is obvious. The Nuclear Regulatory Commissbn has given DON nruission to start construction befom the plant has been licensed I

for " safety". The Nuclear Pagulatory Commission and staff am _ willing to give the administration what it wants whatever the law and whatever the evidence.

Yours sincem E

Mrs.

'd G. Fa y 2625 S. Smith Rogd Bloomington, Indiana 47401 for Energy Policy Committee, SAS