ML20148Q331
| ML20148Q331 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/22/1978 |
| From: | Freeman G, Irwin D, Sisk K BALTIMORE GAS & ELECTRIC CO. |
| To: | |
| References | |
| RULE-RM-50-3 NUDOCS 7811300014 | |
| Download: ML20148Q331 (19) | |
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1 UNITED STATES OF AMERICA e4 k
NUCLEAR REGULATORY COMMISSION 5
b Before the Commission m
In the Matter of
)
)
URANIUM FUEL CYCLE IMPACTS
)
Docket No. RM-50-3p FROM SPENT FUEL AND REPROCESSING
)
AND RADI0 ACTIVE WASTE
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FINAL WRITTEN STATEMENT OF BALTIMORE GAS AND ELECTRIC COMPANY, --ET AL.
TO THE COMMISSION Baltimore Gas and Electric Company, et al.,1/ submit this final written statement in response to the Commission's 1
order of October 19, 1978 requesting " concise,'well-focused written statements" that " focus on the rulemaking record and on the Hearing Board's summary and recommendations."
Order at 2.
This Group's Concluding Statement of Position sub-mitted to the Hearing Board on June 26, 1978 concisely sum-marizes and highlights, from both technical and legal perspec-tives, those portions of the record that this Group " believes should receive the Commission's special attention."
See Order at 2.
We do not believe that the positions summarized therein can be further distilled or amplified to be of maximum use to 1/
- Baltimore Gas and Electric Co.,
Boston Edison Co.,
Carolina i
Power & Light Co., Consumers Power Co., Long Island Lighting Co., Northeast Nuclear Energy Co., Pacific Gas and Electric Co.,
Pennsylvania Power & Light Co., Philadelphia Electric Co.,
Public Service Electric and Gas Co.,
Southern California Edison Co., The Connecticut Light and Power Co., The Hartford Electric Light Co., Virginia Electric and Power Co., Western Massachusetts Electric Co., and Yankee Atomic Electric Co.
7/8113000d
r t
. the Commission in formulating its decision in this proceeding.2/
The Hearing-Board's Summary and Recommendations The Hearing Board's summary (Report of the Hearing Board to the Nuclear Regulatory Commission Regarding Environmentcl Effects of Uranium Fuel Cycle, Docket No. RM-50-3, Aug. 31, 1978) and recommendations (Conclusions and Recommendations of the Hearing Board Regarding the Environmental Effects of the Uranium Fuel Cycle, Docket No. RM-50-3, Oct. 26, 1978), taken as a whole, comprise a careful, fair and accurate summary of the factual record and a set of reasonable conclusions based thereon.
This Group thoroughly agrees with the Board's basic recommendation that " Table S-3 as modified and recommended by the staff should be adopted as the final rule in this proceeding."
Hearing Board Recommendations at 61; see Concluding Statement of Position on Behalf of Baltimore Gas and Electric Company, et al., Docket No. RM-50-3 (June 26,1978) at IV-1.
This Group also supports most of the more specific conclusions reached by the Hearing Board.
Though not all of the Hearing Board's con-clusions are identical with this Group's positions, we believe 2/ articipant Natural Resources Defense Council, P
Inc. has recently l
conceded that the issues in this proceeding "have been amply" addressed in the evidentiary record already developed.
Comments of the Natural Resources Defense Council on the Nuclear Regulatory Commission's Advance Notice of Inrent to Update WASH-1248 (Oct. 20, 1978) at 4 (submitted in response to Notice at 43 Fed. Reg. 39801, Sept.
7, 1978).
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, they are sound and reasonable, except as noted below.3/
The Hearing Board's apparent suggestion that a narrative to Table S-3 be adopted in this croceeding is not well taken.
As this Group noted in its Concluding Statement of Position, there is no legal requirement that a narrative be adopted as part of the S-3 rule.
Concluding Statement of Position cn Behalf of Baltimore Gas and Electric Company, et al. at III-22 1
to III-24.
Nor would it be prudent policy for the Commission i
to engraft a narrative on the S-3 rule at the last minute in this proceeding.
Such a step might needlessly entangle the q
final promulgation of an adequate S-3 rule.
We recommend that the Commission adopt the Regulatory Staff's approach.
Staff Response to Conmission Order of October 19, 1978 (Nov. 16, 1978),
Appendix A at 9-12.
As we understand the Staff's proposal, a narrative shoulc not be adopted in this proceeding as part of the S-3 rule.
Rather, the Staff should complete the promulga-tion of its final Environmental Standard Review Plan 5.7, which will accomplish the obj ectives of the narrative recommended by the Hearing Board without unnecessarily complicating this pro-ceeding.4/
If the Commission desires to adopt a narrative as i
3/
- This endorsement of the Board's conclusions is directed to the Board's summary and recommendations for this proceeding, and does not necessarily apply to each of the Board's suggestions for the j
Staff's impending generic update of the Environmental Survey, Hearing Board Recommendations at 65-70.
See 43 Fed. Re2. 39801 (Sept.
7, 1978).
b/ nvironmental Standard Review Plan 5.7 basically standardizes E
and expands the Staff's current practice of including an explana-tory narrative in each reactor EIS in conjunction with Table S-3.
See Staff's Response to Commission Order of October 19, 1978 (Nov.
TE7 1978), Appendix A at 10; Concluding Statement of Position on Behalf of Baltimore Gas and Electric Company, et al. at III-23 to III-24.
3
1
. a part of the S-3 rule, this should be accomplished in the generic update of the rule that the Staff is currently under-taking EI Board Recommendations for Generic Update of the Environmental Survev The Board's recommendations include a series of suggestions for the Staff's upcoming overall update of the Environmental Survey announced at 43 Fed. Reg. 39801 (Sept.
7, 1978).
See Hearing Board Recommendations at 65-70.
Public comments on the proposed update were submitted by this Group and certain other participants in this docket.
While we believe that the Commission and its Regulatory Staff should consider the Board's suggestions as they proceed with the updating process, we see no value in mixing issues to be covered in the update with the issues that need to be resolved in this proceeding.
Cer-tainly it would be highly imprudent to hold oral argument in this proceeding to address substantively the manner in which models, analyses, technetium, health effects, socioeconomics, economics, and cumulative impacts ought to be treated in the 1
I update.
Such a step would needlessly entangle the completion of this proceeding.
Thus, except insofar as the Board's sug-gestions for the update serve to define the scope of this 5/
- See Comments of Baltimore Gas and Electric Company, TE3 Fed.
et al. on the Commission's Notice of Intent to Update WASH-1248 geg. 39801) (Oct. 20, 1978) at 3-4, attached hereto as Appendix 1.
Ir this question is addressed as part of the overall update of the Environmental Survey, the Staff could propose a narrative, along with the revised Environmental Survey, at the outset of the eventual rulemaking proceeding.
The contours and contents of the narrative could then be hammered out through the process of deliberate rulemaking, rather than being tacked on, almost as an afterthought, in the present proceeding.
See also Staff's Response to Commission Order of October 19, 177E (Nov. 16, 1978),
Appendix A at 9.
. proceeding, we urge the Commission to consider them only within the parameters of the updating process.5/
Oral Presentations Because of the numerous procedural opportunities already afforded participants in this proceeding (see Concluding State-ment of Position on Behalf of Baltimore Gas and Electric Company, et al. at III-11 to III-15), including two opportunities to sum-marize salient features of the record by way of concluding statements to the Hearing Board and these written statements to the Commission, we see no need for oral argument before the Commission.
In the event, however, that the Commission decides to hear oral presentations, we request the opportunity to partici-pate on the same basis, and to be allotted the same amount of time, as any other full participant in this proceeding.
Our presentation would address any issues covered by our previous 6/
- This Group supports the suggestions of the Hearing Board for the updating process except as noted below and in our comments on the update filed with the Commission Staff on October 20, 1978, at'tached as Appendix 1.
First, we wholeheartedly agree with the Board's suggestion that models and analyses in the up-date should be realistic, rather than unrealistically conserva-tive.
Second, it is not possible for us presently to determine whether the assumption of total release of technetium-99 is appropriate; we hope to be in a position to contribute to the resolution of this issue as the updating process unfolds.
- Third, concrete and definable socioeconomic impacts should be discussed in the background document (the updated Environmental Survey) but should not be included as part of any tabulation in the S-3 rule itself.
See Concluding Statement of Position on Behalf of Balti-more Gas and Electric Company, et al., Docket No. RM-5 0- 3 (Jun e 26, 1978) at III-7 to III-9.
Finally, consideration of cumulative impacts of the entire nuclear industry is both unnecessary and inappropriate except as an academic exercise, since the rule is concerned with individual reactor licensings.
See Comments of Baltimore Gas and Electric Company, et al. on the Commission's Notice of Intent to Update WASH-1248 T43 Fed. Reg. 39801) (Oct.
20, 1978) at 7-8; Concluding Statement of Position on Behalf of Baltimore Gas and Electric Company, et al. at III-9 to III-10.
_ _ _ _ _ - _ submissions in this proceeding that the Commission feels need further illumination.
Donald P.
Irwin would address any policy or legal issues, while technical issues would be elucidated by Dr. Joseph A. Lieberman or Dr. Walton A. Rodger, or both, depending on the issues to be covered.
Respectfully submitted, A
Wk W
George C.
Freeman, Jr.
Donald P.
Irwin K.
Dennis Sisk Counsel to Baltimore Gas and Electric Company, et al.
DATED:
November 22, 1978
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I Appendix 1 l
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re.-8 3 5 7 Mr. John K. Lerohl Chief, Technology Assessment Branch Division of Fuel Cycle and Material Safety United States Nuclear Regulatory Commission Washington, D.C.
20555 Comments of Baltimore Gas and Electric Co.,
et al.,
on the Commission's Notice of Intent to Uo3a5 WASH-1248 (43 Fed. Rez. 39801)
Dear Mr. Lerchl:
By notice in the Federal Register of September 7, 1978 (43 Fed. Rez. 38901) the Commission announced its intent to undertake an overall periodic updating of its Environmental Survey of the Uranium Fuel Cycle, outlined certain areas of proposed revision, and invited cccment on its ptoposals.
The Survey underlies the Commission's Uranium Fuel Cycle rule (UFC rule), which is intended to provide a standardiced depic-tion of the environmental effects throughout the uranium fuel cycle attributable to the operation of a typical light water reactor in the United States.
The UFC rule is summariced in tabular form at Table S-3 accompanying 10 CFR S 51.20 and, as the notice observes, is based on the aggregation of documents comprising the Environmental Survey. /
- /
- The Environmental Survey, as the Commission indicates in its September 7 notice, encompasses all the supporting dccuments for Table S-3, 10 CFR S 51.20, including WASH-1248, " Environ-of the Uranium Fuel Cycle," with its supplement 1 mental Survey" Environmental Survey of the Reprocessing and Waste (NUREG-Oll6, i
' Management Portions of the LWR Fuel Cycle") and supplement 2 (NUREG-0216, which presents Staff resoonses to coccents on NUREG-0116)-and the current Hearing Board r'ecord in Docket No. P.M-50-3,.
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Mr. John K. Lec.nl October 20, 1978
]
Page 2 u
HuxTox & WILLIAxs The following comments are being submitted on behalf of Baltimore Gas and Electric Company, et al.,*/ a voluntarily i
consolidated group of 16 electric utility companies which have participated actively in all generic proceedings relating to the UFC rule since its initial proposal in 1972.
Because of the preliminary stage of review evidenced in the September 7 notice, it would be premature to offer detailed proposals for revision to the Environmental Survey or the UFC rule.
At this early point, however, the following general observations can be offered.
First, the UFC rule is an important element in the environ-mental phase of the nuclear power plant licensing process.
It embodies not only the results of the original rulemaking based on WASH-1248, but also subsequent revisions relating to both the front and back ends of the fuel cycle making use of more i
recent information.
The proposed updating involves no necessary implication that the rule as presently formulated is legally inadequate in any respect; indeed, the UFC rule's history of periodic revision when warranted by circumstances seggests j ust the opposite.
Thus the updating should be understood a: a spontaneous effort at refinement of an already adequate rule, and not as a legal requirement.
Second, the Commission's proposals for updating seem (footnote cont'd)
In the Matter of Uranium Fuel Cycle Impacts from Spent Fuel Reprocessing and Radioactive Waste.
43 Fed. Reg. at 39801.
- /
- Baltimore Gas and Electric Co., Soston Edison Co., Carolina Power & Light Co., Consumers Power Co., Long. Island Lighting Co., Northeast Nuclear Energy Co., Pacific Gas and Electric Co.,
Pennsylvania Power & Light Co., Philadelphia Electric Co.,_
Public Service Electric and Gas Co.,
Southern California Edison Co., The Connecticut-Light and Power Co., The Hartford Electric Light Co., Virginia Electric and Power Co.,. Western Massachusetts Electric Co., and Yankee Atomic Electric Co.
Additional com-
- ments may also be submitted by individual members of the Group.
i l
t
j Mr. John K. Lerchl October 20, 197?
Page 3 HuxTox & WILLI AMS divisible into three rough categories:
format,$/ scope 33/
and substance. ***/
For clarity, the distinction among these categories should be recognited and observed since each will
)
have different types of consequences for the rule.
Within broad limits of intelligibility, choices as to format are disex:tionary with the Cocsission.
Decisions as to scope are likewise discretionary, the only caveat being that any matters whose treatment may be legally required and which are not encompassed within the rule will have to be treated in case-by-case fashion.
The following remarks will address each of these areas in turn.
I.
Format of Table S-3 The present format of Table S-3, 51 CFR 5 51.20 (1978),
depicts, in numerical for=, the incremental environmental impacts resulting from the fuel cycle facilities supporting a typical light water reactor (LWR) per reference reactor year (RRY).
This type of format is well suited to the Taale's intended purpose.
The values in the Table can be incorporated into the calculations in each reactor EIS without excessive difficulty and without the need to relitigate generic issues.
In previous proceedings, various parties have ~uggested that a narrative accompany Table S-3 as it is ince' rated in each reactor EIS.
The purposes of auch a proposed arrative would apparently be to explain, and set forth "unce tainties" in, the assumptions and methodology underlying the Table.
These parties assert that such a narrative is necessary :o satisfy NEPA and to make the Table intelligible to the lay public.
As this Group has indicated elsewhere,****! such a narra-tive is not legally required.
Conceptually, the relationship
- /
E.2., should the relationship of the present tabular presenta-tien to the text be modified in any respect?
- / E.g.,
should econocic matters, radiological health effects, or raden releases be included?
- / E.e., are levels of effects attributed to mining and milling, or the method of calculating them, appropriate?
- / n the Matter of RM-50-3, Concluding Statement of Position on I
Behalf of 3altimore Gas and Electric Company, et al. (June 26, 1978),
3-22 to 3-24.
q'
- Mr. John L Ler *J '
l October 20, 19?v
- Page 4 HusTou & WILLI Axs.
between. Table S-3 and its supporting documents is sufficiently clear and informative that we see no need to lengthen individual 4 -
statements with repetition of generically available caterial.
Each reacco: EIS already contains narrative discussion that refers the reader to Table S-3'ssupporting documents.
Any assumptions and uncertainties in specific calculations can be explained in the Environmental Survey, with cross-references,
where appropriate, to Table S-3.
1 l-A brief narrative might be useful, though certainly not required, for two other purposes.
First, a narrative might explain which impacts that are excluded from the Table are
- assumed to be negligible and which brpacts are left for con-j.
sideration in individual proceedings.
See 43 [ed. Rez. 15613 (April 11, 1978).
Second, a narrative could briefly explain the overall relation between the S-3 values and the underlying Environmental Survey.
This " bridging" function could both I
standardize and clarify that portion of each reactor EIS that deals with Table S-3.
Any such narrative should be concise, clear and straightforward.
II.
Scoce of Table S-3 and the Environmental Survey A.
Nonradiological Regulations The Com=ission's outline (43 Fed. Re2. at 39802) proposes to cover nonradiological regulations in the updated Environmental Survey ($ 4.2).
It could be useful and informative for the Survey l
to include a brief suc=ary and comparison of the regulatory
)
philosophies and technical bases underlying radiological and acn-radiological regulations.
The comparison should assess the con-sistency of the. bases upon which health and environmental impacts from radiological and nonradiological releases are evaluated.
B.
Radon Releases frem Uranium Mining and Milling The estimated environcental and health impacts resulting from radon releases from mining and milling should be assessed in the Survey, and numerical values reflecting these i= paces i
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Mr. John K. Le-51 October 20, 19ev Page 5 HUNTox & WILLI AMS should be contained in Table S-3.
This topic is much better suited to treat =ent by a generic rule than by constant relitiga-tion in licensing proceedings.
In calculating releases, we suggest that the Survey reflect the requirements imposed by the Commission in licensing uranium mills, as well as the factual deter =inations being reached in the Perkins3I and related cases.
We believe that a cutoff in the term over which effects are measured is also reasonable in light of the uncertainties in-herent in mechanistic extrapolations ever millennia.
We are confident that the analysis will reveal that the impacts from radon releases do not appreciably alter the environ-mental comparison of nuclear with alternative fuel cycles.
C.
Health Effects The notice proposes revision of the current Environmental Survey to make a specific attempt to account for health effects from radiation releases.
Proper accounting for these effects is a complex, multistep process which may be susceptible to only limited treatment on a generic basis.
Assumptions can be made relatively easily about the level of releases to the general environment from model facilities throughout the fuel cycle.
Translation of these releases into population doses requires estimates about population location and density, meteorology, and other factors which may or may not be capable of meaningful generic determinations, either for specific values or within ranges, for various types of facilities.
Finally, translation of population doses into calculated health effects involves i
alternative layers of assumptions.
'For this step we believe that the most generally accepted approach, though still an i
arbitrary one, based on present knowledge, is to use a linear non-thresheld dose-effect-relationship model.
We believe that this model is conservative at the extremely low dose levels 2"/ n the Matter of Duke Power Comoany (Perkins Nuclear Station, I
Units 1, 2.and 3), Partial Initial Decision (Environmental Consequences of the Uranium Fuel Cycle), July 14, 1973, and subsequent decisions.
. &n John K. Le7 *11 e
October /20,-19'im Page 6 i
HunTox & WILLI Axs experienced by the general population.
He expect to have further material to contribute on this matter as the Staff's proposals develop.
D.
Comparison of Coal and Nuclear Fuel Cycles This Group agrees with the Commission's initial conclusion that "to keep the scope of the uranium fuel cycle update studies within manageable bounds, the studies should exclude considera-tion of" the coal alternative.
43 Fed. Rez. at 39802.
We also believe that the separate generic study of the environmental effects of the coal cycle now being undertaken by the Staff, id.
(perhaps eventually resulting in a comparison of coal and nuclear alternatives), would expedite the processing of applications for nuclear licenses.
Nuclear applicants presently must assimilate extensive data on coal in connection with each nuclear applica-tion' 2"/
The resulting costs and delays could be largely avoided by a generic rule setting forth the typical environmental impacts from a model. coal-fired plant and its supporting fuel cycle.
E.
Fuel Cycle Economic Costs On the basis of present information, we believe that the Staff's proposal-to treat fuel cycle economic costs on a case-4
)
by-case basis, rather than generically, appears reasonable.
III.
Overall Methodolozv and Substance A.
Long-Term. Impacts Few radionuclides resulting from the nuclear fuel cycle will either be. released or remain active for long periods of time.
It is not meaningful to calculate very lcng-term impacts of these : radionuclides by multiplying thousands of years times maximum potencial releases.
This Group believes that (1) any calculation of very long-term impacts becomes the producr of increasingly questionable assumptions as the time period for calculation increases, and (2) maximum releases probably will 9
hl-See In the Matter of Tennessee Vallev Authoriev (Hartsville
-Nuclear Plant Units LA, 1A, 13, and 23), ALA3-367, 5 NRC 92 at
- 102-03 (1977).
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Mr. John K. Le hl October 20, 19'/8 Page 7 HuxTox & WILLI AMS not occur over long periods.
Steps are already being taken to reduce the risk of long-ters releases.
Even without the benefit of these measures, long-term releases from the fuel cycle represent a relatively insignificant percentage increase over natural background radiation.
Comparison to natural back-ground is, in our view, the best method to place the question of impacts from very long-term releases in proper perspective.
Informatien which can be developed over the course of the proposed update of the Environmental Survey, and to which we would propose to contribute, should aid in developing these propositions.
We therefore endorse the calculation of long-ter= impacts for a 500-1000 year range and a comparison of proj ected longer-term releases with natural background, as proposed by the Com-mission.
See 43 Fed. Reg. at 39802.
For the reasons outlined above, we doubt the value of the open-ended suggestion that "public recognition be given to the fact that radon releases of some magnitude will probably continue for much longer periods with indeterminate consequences Id.
3.
Cumulative Impacts Although not discussed in the texr of the notice, " ( c ] umulc-tive impacts of the (encire] nuclear industry" ar'e apparently among the items slated for discussion in the revised Environmental Survey.
See 43 Fed. Reg, at 39802 -- Appendix s 6.
Ne believe that such an aggregate discussion is not consistent with the scope and focus of a document intended for use in the licensing of in-dividual reactors.
The Survey is not a generic environmental impact statement on the entire nuclear industry.
Nor does a decision to license any particular nuclear reactor, incorporating Table S-3, produce an incremental decision that commits the Commission to licensing more nuclear plants in the future.
Thus calculation of the cumulative impacts of the.uclear industry, on a fcanat similar to a program =atic EIS, has no place either
4 Mr. John K. Le il October 20, 1978 Page 8 HuxTox & WILLI Axs in the Survey or in connection with the licensing of a particular plant. /
C.
Use of Model Facilities The Commission notes its intention to base the updated Survey primarily on "the application of available or nearly available commercial technology at the present time or con-ceived for the near-term future."
43 Fed. Rec. at 39802.
We assume that this affirms, and thus does not portend the abandonment of, the use of the model-facility approach for calculating environmental impacts.
The model-facility approach provides the most accurate and useful means for generically calculating fuel cycle impacts resulting from the operation of a LWR.
Some persons and organizations have criticized the model-facility approach.
They point to "past failures" and suggest that current-and future-generation facilities will inevitably continue the mistakes of the past.
Their argument ignores the positive contribution of past experience to the resolution or avoidance of present and future errors.
The model-facility approach used in the Survey does not assume perfect technology, but it does assume that scientists and engineers working on the design and operation of present and future fuel cycle facilities have built, and will build, on both the positive and negttive experiences of the past.
Fredicating the survey on the rea-sonably proven or anticipated performance of currently " avail-able or nearly available commercial technology" eliminates any
- / Should some indication of cumulative fuel cycle imoacts ever be desired, we see no sound reason why these 'i= pacts cannot be
~
reasonably approximated by multiplying the impacts per RRY in Table S-3 times the assumed number of operating reactors,
normalized to a standard reactor, times the number of years each reactor is assumed to operate.
In this connection, the Staff's remark in NUREG-0116 at page 2-20, that a multiple of the RRY does not produce a reasonable approximation of cumulative impacts, is puzzling.
The Survey assumes model facilities, typical s;te parameters,.and median or conservarive release levels.
No rationale is presented why a multiple of the RRY would not produce essentially the same estimate as any other reasonable predictive approach.
Mr. John K. Le-51 October 20, 19,v Page 9 HUNTON & WILLI AM S credible obj ection to the use of the model-facility approach in the updated Survey.
D.
Reprocessing The Staff's intention in updating the Survey is less than clear as to reprocessing.
The notice recognizes the analysis already done on the matter in Docket RM-50-3 and promises "some consideration of (the reprocessing] alternative" in the planned study.
43 Fed. Ret. at 39802.
At the same time, the Staff apps.rently intends to " assume that the U.S. will not reprocess spent fuel" and to focus the updated Survey on "the assumption of interim storage and disposal of spent fuel."
Id.
If the latter direction is the Staff's true one, it both overreaches in its interpretation of " current national policy", id., and makes unwarranted assumptions about its permanence.
The assurp-tion'that reprocessing has been abandoned as a technical cotion is not an accurate reflection of even current national policy:
decisions on reprocessing have merely been deferred pending the completion of international studies which are currently scheduled to be completed within about two years.
Under these circumstances, there is a substantial risk that an updated Survey which does not give equal treatment to reprocessing will be almost obsolete be-fore it is ever put to use in licensing proceedings.
- Moreover, a decision now to focus study on the "no reprocessing" option
=ay inadvertently prejudice near-furure policy determinations about reprocessing.
1 For these reasons, this Grouc. firmi.v believes that any co. -
date of the Environmental Survey should creat the reprocessing and no-reprocessing options equally -- the accroach taken in the formulations of the UFC rule to date.2, This approach will
+
- /- The revisions to the back end of the UFC rule following the decision of the Court of Acceals for the District of Columbia Circuit in 1976, NRDC v. NRC, 367 F.2d 633, rev'd sub nom.
t Vermont Yankee Nuclear Power Coro.
v.
NRDC, 635 U.S.
519 (1973),
did parallel computations for fuel cycle effects with and without reprocessing.
The same type of parallel computation, performed for the front end of the fuel cycle rule as well, would produce internally consistent sets of parallel results for alternative configurations of the fuel cycle.
The formulation of the UFC rule used in reactor licensings should be capable of depicting (cont'd)
Mr. John K. Le hl October 20, 19,o Page 10 H uxTox & WILLI A3IS allow the nation and the nuclear industry to maintain needed flexibility in the face of uncertain future events.
CONCLUSION We appreciate this opportunity to provide early comments.
As the Staff's work progresses, both in terms of definition of issues and compilation of factual information, this Group and i
individual members of it will expect to provide further. = ore specific comments.$/
1 Sir erely y ure, 1
1sJ /"
George C.
Freeman, Jr.
Donald P.
Irwin K. Dennis Sisk l
Counsel to Baltimore Gas and Electric Company, et al.
l (footnota cont'd) both " reprocessing" and "no reprocessing" configurations of the fuel cycle, regardless of what additional evaluations are per-formed as part of the updating of the Survey.
2"/ n carticular, this Group will be looking for greater defini-I tion of the intent and scope of the proposed Chapter 6 concerning the "Overall analysis of fuel cycle environmental impacts."
L3 Fed. Rez. at 39802.
The notice gives little indication as ec the intended approach and content of this section.
We hope to be of assistance to the Staff in developing the detailed ton-ceptual framework for this potentially important portion of the updated Environ = ental Survey.
4 i
UNITED STATES OF AMERICA NUCLEAR REGULATOp.Y C0bDtISSION In the Matter of
)
)
AMENDMENT OF 10 CFR PART 51 --
)
LICENSING OF PRODUCTION AND
)
Docket No. RM-50-3 UTILIZATION FACILITIES
)
)
(Environmental Effects of the
)
Uranium Fuel Cycle)
)
CERTIFICATE OF SERVICE I hereby certify that the Final Written Statement of Baltimore Gas and Electric Company, et al. to the Commission was served on the following this date by deposit ~in the U/S. mail, first class, postage prepaid, and by hand on the Commission:
Michael L. Glaser, Esq., Chairman Honorable Louis J. Lefkowitz Atomic Safety and Licensing Board Attorney General 1150 17th Street, N.W.
c/o John J.
Shea, III, Esq.
Washington, D.C.
20036 Assistant Attorney General Deoartment of Law Dr. John H.
Buck Two World Trade Center Atomic Safety and Licensing Appeal New York, New York 10047 Board U.S. Nuclear Regulatory Commission Roger Beers, Esq.
Washington, D.C.
20555 Helene Linker, Esq.
Natural Resources Defense Council, Mr.
R. Beecher Briggs Inc.
110 Evans Lane 2345 Yale Street Oak Ridge, Tennessee 37830 Palo Alto, California 94360 Dr. Chauncey Kepford Judith Johnsrud, Ph.D.
433 Orlando Avenue 433 Orlando Avenue State College, Pennsylvania 16801 State College, Pennsylvania 16801 Mr. Ellis T. Cox, Chairman Joseph D.
Block, Esq.
Committee on Nuclear Fuel Cycle Edward J. Sack, Esq.
Services Consolidated Edison Company of Atomic Industrial Forum, Inc.
New York, Inc.
7101 Wisconsin Avenue 4 Irving Place Washington, D.C.
20014 New York, New York 10003 Mr. Marvin L. Lewis Herbert H. Brown, Esq.
530 Foster Street Lawrence Coe Lanpher, Esq.
Philadelphia, Pennsylvania 19116 Hill, Christopher & Phillips, P.C.
1900 M Street, N.W.
Washington, D.C.
20036
4 Mr. Austin P. Olney Vincent V.
MacKe n::ie, Esq.
Secretary of the Department Kathryn Burkett Dickson, Esq.
of Natural Resources and Energy Resources Conservation and Environmental Control Development Commission iP.O.
Box 1401 1111 Howe Avenue Edward Tatnall Building Sacramento, California 95825 Dover, Delaware 19901 Ms. Dida McMurray, President Mr. Stanley M..Ehrenpreis Environmentalists, Inc.
PWR Systems Division 1339 Sinkler Road Westinghouse Electric Corporation Columbia, South Carolina 29206 P.O.
Box 355 Pittsburgh, Pennsylvania 15203 Dr. Monica E.
Bainter Department of Physics Bennett Boskey, Esq.
University of Wisconsin Volpe, Boskey and Lyons Stevens Point, Wisconsin 54481 913 16th Street, N.W.
Washington, D.C.
20006 Mr. Gregory A. Thomas Sierra Club Honorable Colt.nen Kaye Nissi 330 Pennsylvania Avenue, S.E.
Assitant Attorney General Washint; ton,
D.C.
20003 Environmental Law Section 4
30 East Broad Street, 17th Floor Mr. Edward F.
Marwick Columbus, Ohio 43215 5149 Morse Avenue Skokie, Illinois 60076 Mr. J.
E. Gilleland j
Assis tant Manager of Power U.
D.
Rowe, Ph.D.'
Tennessee Valley Authority Deputy Assistant Administrator j
Chattanooga, Tennessee 37405 for Radiation Program.s (AU-458)
U.S. Environmental Protection Patrick Walsh, Esq Agency Assitant Attorney General Washington, D.C.
20460
-l Department of Justice 114 East, Stat:e Capitol Barton Z.
Cowan, Esq.
Madison, Wisconsin 53702 Eckert, Seamans, Cherin & Mellott 600 Grant Street, 42nd Flc Lawrence P. Jones, Esq.
Pittsburgh, Pennsylvania 13219 Albert Ferri, Jr.,
Esq.
Pacific Legal Foundation James P.
McGranery, Jr.,
Esq.
Suite 550 LeBoeuf, Lamb, Leiby & MacRae 1990 M Street, ti. W.
1757 N Street,#U.W.
Washington, D.C.
20036 Washington, D.C.
20036 Dr. Marvin Resnikoff Donald R. Marcucci, Esq.
84 DeWitt Street Uestinghouse Electric Corporation Buffalo, New York 14213 Monroeville Nuclear Center (Bay 564-C):
P.O.
Box 355 George C. Deptula, Esq.
Pittsburgh, Pennsylvania 15230 1751 M Street, N.W.
Washington, D.C.
20036 e
.- Herbert E.
Sanger, Jr., Esq.
Docketing and Service Section Alvin Gutterman, Esq.
Office of the Secretary Division of Law U.S. Nuclear Regulatory Commission Tennessee Valley Auth3rity Washington, D.C.
20555 400 Commerce Avenue Knoxville, Tennessee 37902 Dr. Joseph M.
Hendrie, Chairman Mr. Richard T.
Kennedy Dr. Robert Pohl Dr. Victor Gilinsky Department of Physics Peter A.
Bradford, Esq.
Cornell University Mr. John F. Ahearne Ithaca, New York 14850 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ellyn R. Weiss, Esq.
Sheldon, Harmon & Roisman 1025 15ch Street, N. W.
Suite 500 Washington, D.C.
20005 Mr. David Jhirad Executive Director Union of Concerned Scientists 1208 Massachusetts Avenue-Cambridge, Massachusetts 02138 f
Mr. George D.
DeBuchananne I[Av /*
U.S.
Department of the Interior
/
Geological Survey W
Reston, Virginia 22092 tg,' DENNIS 5ISik James P. Murray, Jr.,
Esq.
James Libermatt, Esq.
One of Counsel for u e a ing and forcement Division Baltimore Gas and Electric U.S. Nuclear Regulatory Commission Company, et al.
Washington, D.C.
20555 DATED:
November 22, 1978
^
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