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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063C9281982-08-23023 August 1982 Motion for Clarification,Or in Alternative,Petition for Reconsideration of Aslab 820811 Memorandum & Order ALAB-686 Re Application of Immediate Effectiveness Regulation. Certificate of Svc Encl ML20062F7751982-08-11011 August 1982 Memorandum & Order ALAB-686 Subsequent to ASLB 820630 decision,LBP-82-49.Immediate Effectiveness Review of Mfg Licenses Not Warranted ML20054L9671982-07-0707 July 1982 Errata Order Furnishing Omissions from ASLB 820630 Initial Decision ML20054L8351982-07-0101 July 1982 Notice of Aslab Reconstituion.Cn Kohl,Chairman & WR Johnson & Ha Wilber,Members ML20039E8941982-01-0505 January 1982 Response to NRC 811230 Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20062M3171981-12-11011 December 1981 Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision.Certificate of Svc Encl ML20010C0801981-08-12012 August 1981 Motion for ASLB to Establish Schedule Leading to Completion of Mfg License Proceeding.Hearing Process Should Be Resumed to Address New Matters Contained in Upcoming Ser,Suppl 4. Certificate of Svc Encl.Related Correspondence ML19347B8151980-10-10010 October 1980 Notice of Appearance in Proceeding.Certificate of Svc Encl ML19254D1371979-09-27027 September 1979 Notice of Appearance on Behalf of Nrdc.Certificate of Svc Encl ML19254E4381979-09-14014 September 1979 Response in Opposition to NRC-proposed Mods to 790824 Proposed Partial Findings of Fact in Form of Proposed Initial Decision,Set Forth in Paragraphs 20.D & 20.E.(2), Pages 18-19 of Proposed Findings.Certificate of Svc Encl ML19209C5241979-08-31031 August 1979 Motion for Extension Until 790914 to File Response to NRC 790824 Proposed Partial Findings of Fact.Findings Were Not Received Until 790829.Certificate of Svc Encl ML19225B5541979-06-0101 June 1979 Proposed Partial Findings of Fact in Form of Proposed Initial Decision Submitted by Offshore Power Sys to Aslb. Discusses Each Contention Admitted as Issue in Controversy & ASLB Questions.Certificate of Svc Encl ML19289F2091979-04-0404 April 1979 Motion to Establish Schedule for Filing of Partial Proposed Findings of Fact & Conclusions of Law.Proposed Schedule & Certificate of Svc Encl ML19281B5151979-03-0808 March 1979 Statement of Matl Facts Which Are Not in Dispute.Applicant Not Able to Build Eight Plants by 1985.Statement Filed in Opposition to NRDC Statement of Matl Facts ML19274E6281979-03-0808 March 1979 Applicant'S Motion 10 to Establish Schedule for Hearing on Contentions 3a & 3c by Atlantic County Citizens Council on the Environ.Requests Parties File an Identification of Evidence.Certificate of Svc Encl ML19261C3331979-02-20020 February 1979 Intervenor Withdraws from Active Participation in Licensing Hearings,Due to Util'S Withdrawal of Order for Floating Nuclear Plants Off Nj Coast.Certificate of Svc Encl ML19263D1641979-02-16016 February 1979 NRDC Statement of Matl Facts Which Are Not in Dispute Re Offshore Power Sys'S Intent to Build More than Eight Floating Nuclear Plants.Certificate of Svc Encl ML19263D1621979-02-16016 February 1979 Nrdc'S Memorandum in Support of Summary Disposition Motion. Urges That Programmatic Review of Floating Nuclear Plants Be Conducted.Certificate of Svc Encl ML19263D1601979-02-16016 February 1979 Motion for Summary Disposition Re Failure of Fes to Consider Environ Impact & Alternatives ML19282A6351979-02-12012 February 1979 Informs That Natural Resource Defense Council Missed Filing Deadline,But Plans to File a Brief on Its Contention & Remain in the Proceeding.Certificate of Svc Encl ML19274D6971979-02-0606 February 1979 Applicant'S Rept to ASLB Re Status of Hearings & Motion to Establish Schedule.Proposed Schedule Encl ML19289D1311979-02-0606 February 1979 Motion for Order Dismissing NRDC Programmatic Impact Statement Contention as an Issue Due to Nrdc'S Failure to Comply w/780801 ASLB Order Filing a Motion by 790129.Related Papers & Certificate of Svc Encl ML19259B2891979-01-31031 January 1979 Presentation on ALAB-489(8 NRC 194),NRC Class 9 Accident Reviews,Given at 790114-17 Conference on Legal & Legislative Affairs in Las Vegas,Nv ML19289C9451979-01-22022 January 1979 Brief by NRDC in Response to Opening Briefs.Case Comes Down to 1 of 3 Conclusions.Deciding Which of These Conclusions Is Correct Is the Heart of Applicant'S Case.Certificate of Svc Encl ML19270F2171979-01-22022 January 1979 Reply Amicus Curiae Brief of Union of Concerned Scientists. Believes Applicant'S Facility Should Receive Special Treatment Since It Is Fundamentally Different.Hopes NRC Will Decide Issues in Public.W/Certificate of Svc ML20099A3241979-01-22022 January 1979 Applicant'S Reply Brief Re Mfg License for Floating Nuclear Plant.Decision ALAB-489 Withholding Applicability of Annex to Floating Plant Cannot Stand ML19259B2971979-01-16016 January 1979 Brief by Intervenor State of Nj Urging Commission to Answer in the Affirmative Certified Question Whether Class 9 Accidents Are Proper Subj for Consideration in NRC Environ Statement.Certificate of Svc Encl ML19269C0891979-01-12012 January 1979 NRDC Brief Re Certification of Class 9 Accident Issue. Asserts Commission'S Only Proper Action Is to Order Evidentiary Hearing.Certificate of Svc Encl ML19274D2961979-01-12012 January 1979 Brief of Applicant in Support of Aslab 781221 Order Holding That NRC May Consider Environ Impacts of Consequences of Accidents Beyond Design Basis in Fes.Certificate of Svc Encl ML20083K2881979-01-12012 January 1979 Ucs' Brief Amicus Curiae Re Consideration of Class 9 Accidents.Environ for OPS Proceeding Should Include Evaluation of Probability & Consequence of Class 9 Accidents.Supporting Documentation Encl ML19289C8181979-01-12012 January 1979 Request of the CA Energy Resources Conservation & Development Commission on Issue of Class 9 Accidents. Provides Results of Commission Study of Undergrounding Nuclear Reactors & Class 9 Accidents ML19261A3161978-12-26026 December 1978 Requests Opportunity to Reply to NRC Applicant'S Allegations Re Interpretation of Ltr from Administrator of EPA to Ops. Brief Statement to That Purpose Attached.W/O Encl ML19259B0511978-12-19019 December 1978 Response by Applicant OPS in Opposition to NRDC Request for Directed Certification.Asserts NRDC Has Not Satisfied Criteria for Directed Certification.Epa 781103 Ltr & Certificate of Svc Encl ML20197D9361978-12-0707 December 1978 Pub Meeting in Washington DC on 781207:discussion & Vote on ALAB-500 Offshore Pwr Sys.Pp.1-18 ML20148Q8011978-12-0101 December 1978 Unofficial Transcript of 781201 Affirmation Session 78-30 in Washington,Dc Re OPS Order.Pp 1-3 ML20150E0171978-11-30030 November 1978 NRDC Request for Directed Certification.Expresses Concern Re Inshore Siting of Fnp'S.Finds No Reason to Believe Lic Bd Erred in Rejecting NRDC Contention.W/Encl Related Correspondence ML20204C9851978-11-22022 November 1978 Grants as a Motion, Informal Ltr Request That Bd Extend Deferral of Ruling Until After 781201 on Applicant'S Motion to Plead a Matter in Controversy & Establish a Discovery & Hearing Sched for Such Matter ML20150D0731978-11-21021 November 1978 Time in Which Comm May Determine to Review ALAB-489 & ALAB-500 Is Extended to 781208 ML20148L6161978-11-0909 November 1978 Denies NRDC Motions for Reconsideration of ASLB Order of 780911 & for Certification of 4 Questions to Aslab.Points Out That 10CFR2.758 Prohibits Challenges to NRC Rules & Regs ML19256A2881978-11-0707 November 1978 Intervenor Atlantic County,Nj Response to Memos of 781027 of Hendrie & Gilinsky Re Their Involvement W/Appl Prior to Their Appointments to Nrc.Has No Factual Basis on Which to Object to Commissioners' Participation.Cert of Svc Encl ML20148J2721978-11-0303 November 1978 NRDC Response to Memoranda to Counsel from Hendrie & Gilinsky Re Their Prior Involvement in Issues Re Subj Facil. NRDC Asserts That Disqual of the Commissioners Is Dependent Upon Certain Facts.Cert of Svc Encl ML20148J5021978-11-0303 November 1978 NRC Staff'S Response to Memo to Counsel Filed by Hendrie & Gilinsky Re Possible Prior Knowledge.Staff Has No Objection to Either Commissioner Participating in Review of ALAB-500. W/Cert of Svc ML20148J3381978-11-0202 November 1978 Response of Applicant OPS to Memoranda of Hendrie & Gilinsky to Counsel Re Commissioners' Impartiality in Proceedings Re Subj Facil.Applicant Has No Objection to Either Commissioner Participating in Review of Issues.Cert of Svc Encl ML20150D2381978-10-27027 October 1978 Rev Draft Order in the Matter of Offshore Pwr Sys(Floating Nuc Pwr Plants).Order Was Rev to Clarify That Proposed Review Will Deal W/Class 9 Accidents Only in Context of Floating Nuc Plants & Not as Overall NRC Opinion on Subj ML20197B3941978-10-27027 October 1978 Memo Disclosing Previous Involvement W/Applicant Re Facility During Sept 1974.Author Head of Physical Sciences Dept of Rand Corp.Draft Research Proposal Re Facility Prepared by Physical Sciences Dept in Sept 1974 Encl ML20148E5221978-10-26026 October 1978 Order Extending Time for Commission to Review ALAB-489 & ALAB-500 to 781117 ML20197B0711978-10-23023 October 1978 Grants Applicant 781010 Motion to Defer Ruling Until 781010 Based on Granting Applicant 780905 Motion to Plead Matter in Controversy & Establish Discovery & Hearing Schedule ML20147E0671978-10-0202 October 1978 Opposes Intervenor NRDC 780915 Request for Reconsideration & Certification of ASLB 780911 Order Denying NRDC 780809 Motion to Amend Contentions.Nrdc Has Not Established Grounds for Reconsideration ML20147D6251978-09-29029 September 1978 Applicant'S Motion to Certify to the NRC Question Decided by Aslab in ALAB-489 Is Granted.Held in ALAB-489 That Class & Accidents Are Proper Subj for Consideration in Staff'S Environ Statement Re Floating Nuc Pwr Plant Appl 1982-08-23
[Table view] Category:PLEADINGS
MONTHYEARML20063C9281982-08-23023 August 1982 Motion for Clarification,Or in Alternative,Petition for Reconsideration of Aslab 820811 Memorandum & Order ALAB-686 Re Application of Immediate Effectiveness Regulation. Certificate of Svc Encl ML20010C0801981-08-12012 August 1981 Motion for ASLB to Establish Schedule Leading to Completion of Mfg License Proceeding.Hearing Process Should Be Resumed to Address New Matters Contained in Upcoming Ser,Suppl 4. Certificate of Svc Encl.Related Correspondence ML19254E4381979-09-14014 September 1979 Response in Opposition to NRC-proposed Mods to 790824 Proposed Partial Findings of Fact in Form of Proposed Initial Decision,Set Forth in Paragraphs 20.D & 20.E.(2), Pages 18-19 of Proposed Findings.Certificate of Svc Encl ML19209C5241979-08-31031 August 1979 Motion for Extension Until 790914 to File Response to NRC 790824 Proposed Partial Findings of Fact.Findings Were Not Received Until 790829.Certificate of Svc Encl ML19225B5541979-06-0101 June 1979 Proposed Partial Findings of Fact in Form of Proposed Initial Decision Submitted by Offshore Power Sys to Aslb. Discusses Each Contention Admitted as Issue in Controversy & ASLB Questions.Certificate of Svc Encl ML19289F2091979-04-0404 April 1979 Motion to Establish Schedule for Filing of Partial Proposed Findings of Fact & Conclusions of Law.Proposed Schedule & Certificate of Svc Encl ML19281B5151979-03-0808 March 1979 Statement of Matl Facts Which Are Not in Dispute.Applicant Not Able to Build Eight Plants by 1985.Statement Filed in Opposition to NRDC Statement of Matl Facts ML19274E6281979-03-0808 March 1979 Applicant'S Motion 10 to Establish Schedule for Hearing on Contentions 3a & 3c by Atlantic County Citizens Council on the Environ.Requests Parties File an Identification of Evidence.Certificate of Svc Encl ML19261C3331979-02-20020 February 1979 Intervenor Withdraws from Active Participation in Licensing Hearings,Due to Util'S Withdrawal of Order for Floating Nuclear Plants Off Nj Coast.Certificate of Svc Encl ML19263D1601979-02-16016 February 1979 Motion for Summary Disposition Re Failure of Fes to Consider Environ Impact & Alternatives ML19263D1621979-02-16016 February 1979 Nrdc'S Memorandum in Support of Summary Disposition Motion. Urges That Programmatic Review of Floating Nuclear Plants Be Conducted.Certificate of Svc Encl ML19263D1641979-02-16016 February 1979 NRDC Statement of Matl Facts Which Are Not in Dispute Re Offshore Power Sys'S Intent to Build More than Eight Floating Nuclear Plants.Certificate of Svc Encl ML19282A6351979-02-12012 February 1979 Informs That Natural Resource Defense Council Missed Filing Deadline,But Plans to File a Brief on Its Contention & Remain in the Proceeding.Certificate of Svc Encl ML19274D6971979-02-0606 February 1979 Applicant'S Rept to ASLB Re Status of Hearings & Motion to Establish Schedule.Proposed Schedule Encl ML19289D1311979-02-0606 February 1979 Motion for Order Dismissing NRDC Programmatic Impact Statement Contention as an Issue Due to Nrdc'S Failure to Comply w/780801 ASLB Order Filing a Motion by 790129.Related Papers & Certificate of Svc Encl ML19269C0891979-01-12012 January 1979 NRDC Brief Re Certification of Class 9 Accident Issue. Asserts Commission'S Only Proper Action Is to Order Evidentiary Hearing.Certificate of Svc Encl ML19289C8181979-01-12012 January 1979 Request of the CA Energy Resources Conservation & Development Commission on Issue of Class 9 Accidents. Provides Results of Commission Study of Undergrounding Nuclear Reactors & Class 9 Accidents ML19261A3161978-12-26026 December 1978 Requests Opportunity to Reply to NRC Applicant'S Allegations Re Interpretation of Ltr from Administrator of EPA to Ops. Brief Statement to That Purpose Attached.W/O Encl ML19259B0511978-12-19019 December 1978 Response by Applicant OPS in Opposition to NRDC Request for Directed Certification.Asserts NRDC Has Not Satisfied Criteria for Directed Certification.Epa 781103 Ltr & Certificate of Svc Encl ML20150E0171978-11-30030 November 1978 NRDC Request for Directed Certification.Expresses Concern Re Inshore Siting of Fnp'S.Finds No Reason to Believe Lic Bd Erred in Rejecting NRDC Contention.W/Encl Related Correspondence ML19256A2881978-11-0707 November 1978 Intervenor Atlantic County,Nj Response to Memos of 781027 of Hendrie & Gilinsky Re Their Involvement W/Appl Prior to Their Appointments to Nrc.Has No Factual Basis on Which to Object to Commissioners' Participation.Cert of Svc Encl ML20148J5021978-11-0303 November 1978 NRC Staff'S Response to Memo to Counsel Filed by Hendrie & Gilinsky Re Possible Prior Knowledge.Staff Has No Objection to Either Commissioner Participating in Review of ALAB-500. W/Cert of Svc ML20148J2721978-11-0303 November 1978 NRDC Response to Memoranda to Counsel from Hendrie & Gilinsky Re Their Prior Involvement in Issues Re Subj Facil. NRDC Asserts That Disqual of the Commissioners Is Dependent Upon Certain Facts.Cert of Svc Encl ML20148J3381978-11-0202 November 1978 Response of Applicant OPS to Memoranda of Hendrie & Gilinsky to Counsel Re Commissioners' Impartiality in Proceedings Re Subj Facil.Applicant Has No Objection to Either Commissioner Participating in Review of Issues.Cert of Svc Encl ML20197B0711978-10-23023 October 1978 Grants Applicant 781010 Motion to Defer Ruling Until 781010 Based on Granting Applicant 780905 Motion to Plead Matter in Controversy & Establish Discovery & Hearing Schedule ML20147E0671978-10-0202 October 1978 Opposes Intervenor NRDC 780915 Request for Reconsideration & Certification of ASLB 780911 Order Denying NRDC 780809 Motion to Amend Contentions.Nrdc Has Not Established Grounds for Reconsideration 1982-08-23
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2 Ihk were proposed (Natural Rescurces Defense Council v. Nuclear Regulatory Commissica, 539 F.2d 824 (2nd Cir. 1976), judgment vacated and remanded for consideration of mootness sub ncm.
Allied-General Nuclear Services v. Natural Resources Defense Council, 46 U.S.L.W. 3447 (Jan. 17, 1978)).
This motion for summary disposition really focusses en three arguments. First, that there is a reasonable basis to believe that there is a program for development and deployment of a substantial number of FNPs. Second, that the FES pr9 pared by the PRC Staff is not a programmatic impact statement. Third, that the FNP is a unique concept for which a programmatic approval is required. These arguments essentially depend upcn acceptance of the validity of the Statement of Material Facts Which Are Not in Dispute and the interpretation of those facts for the legal questions presented here. We address in this memorandum the question of the interpretation of those facts.
II. Secpe of Proposed Action It is hardly necessary to elaborate on the cbvious fact that the OPS plan for FNPs is to build substantially more than eight. Clearly CPS has in mind a substantial number of these facilities in the coastal area. For instance, in a New York Times article of June 4, 1972, Ralph Lapp saw the AGS facilities as the forerunners of hundreds of FNPs. Cited in an article by J.A. Ashworth, Assistant to the Project Manager, Public Service Electric and Gas Co., entitled Design Challenges of Cffshcre Standard Plants, a copy of which was provided to NROC by letter 790322 0 0(o 7
3 .
dated Auguso 3, 1974, frc= T.M. Daugherty of CPS. In a speech to the Institutional Conference of Investment Bankers en Cctober 23, 1973, A.P. Cechella, President of CPS stated (p . 6):
Our forecasts shcw that Cffshcre Pcwer Systems at a production rate of four floating nuclear plants per year expects to build 42 plants for installation during the next two decades.
On January 17, 1974, Mr. Zechella told the Cc==ittee on Power Generation of the Association of Edison Illuminating Cc=panies:
Cur plans call for an orderly expansion of our facility manufacturing capability.
Following the shipment of these first two units in 1979 and 1980. [ sic] Cur manufac-turing schedules call for additional plants to ship at a rate of one in 1981, two in 1982, three in 1933 and four in 1934 and subsequent years.
I am pleased to announce, for the first time that shortly, we will arend our manu-facturing license application to increase the number of FNP's frc= eight plants to a total of sixteen. With cur facility producing four plants per year as we reach maturity, the last of these additional eight would be ready for shipment in 1985.
The OPS scheme for FNPs is substantially broader than the eight proposed, and the manufacturing facility for which license approval is sought must be judged en the basis of its potential and OPS's plans for it and not the S FNPs identified in the application.
The Staff apparently believes that because cnly S FNP approvals were requested, cnly the impact of these 3 must be analy:ed. This presents a situation analegcus to Elecce v. Sierra Club, 427 U.S. 390 (1976). Like Klecce, we have a case in *thich
4 an effort is made to artificially define the scope of a proposed action. Like Kleppe, we have here a far broader program of which the specific actions are only a part. Like Kleppe, the consideration of the proposed actions can only occur after a programmatic statement has been prepared which enccmpasses these limited proposals. The OPS characterization of the proposal, as related only to 8 FNPs, is of course not binding, or all applicants could avoid programmatic statements by seg-menting the programs.1 The key is what is really happening, not how an applicant or agency characterizes it. What is clearly happening here is that OPS is launching a major program to build and site hundreds of FNPs.
III. The FES Is Not A Programmatic Impact Statement There is no magic formula for what are the elements of a programmatic impact statement. The key is to identify what is the program and then to develop an FES which fairly addresses that program. This is essentially identical to the process for preparing any FES, except here the program requires consideration of far larger considerations than the standard FES. The scope of the proposed action here was discussed in section II, supra.
A comparison of that program with the FES here conclusively demonstrates that this is not an adequate programmatic FES.
k 1/ Numerous cases have held that artificial segmentation of proposed actions is impermissible. Indian Lookout Alliance v.
Volpe, 434 F.2d 11 (Sth Cir. 1973); Named Individual Members of tne San Antonio Conservation Scciety et al. v. Texas H1:nwav Department, 446 F.2d 1913 (5rn Cir. 1971).
At no time dces the Staff analyze the environmental impacts of hundreds of FNPs in the coastal waters of the United States.
The potential damage which such a fleet of FNPs could generate is set forth in our original petition for leave to intervene.
The elements are included individually in the FES for this case but what is missing is the Staff analyzing the accumulated effect of hundreds of FNPs. If it had done this, we would know the extent of the programmatic effects of the actions analyzed in Sections 5 and 6 of UUREG-0056 and the programmatic effects of the actions analyzed in Subsections 2.4 and 2.5 of NUREG-0056, Supplement 1. These programmatic analyses would have provided a basis for determining whether ocean and near-shore environ-ments could withstand the magnitude of the environmental insult .
which the FNP program would impose. Without those analyses, it is not possible to determine whether an FNP program should be allowed to begin and, if so, how large it should be. The reason for requiring a programmatic review is to be able to make these determinations before allowing a program to begin.
In both SIPI, supra, and NRDC v. NRC, supra, the courts stressed the principle that the purpose of the programmatic review is to make a reascnable forecast of the environmental consequences of an action before it is allcwed to commence. In addition, when the FNPs are viewed as a program whose implement-ation will occur over many years, large scale programmatic alternatives will emerge and have to be considered. The Staff analysis of the alternatives of energy conservation and solar
E energy is completely disterted by the artificially established deadline of the early 1990s. If the FNP is properly viewed, as OPS itself has viewed it, as a program for hundreds of plants over the next several decades, then it is not cnly reasonable but essential to address the many alternatives which exist in that time frame, including conservaticn, which, if properly implemented, can, without any deprivations of life-style changes, maintain a real GNP grcwth rate of 2-3% through the year 2000 with the addition of no more than 10-1f% (7-12 quads) cf new energy and with no additional nuclear plants beyond those already in existence and cader construction. Energy: The Easy Path, Vince Taylor (Jan. 1, 1979); Soft Ena 7y Paths, Amory B.
Lcvins (1977). Similarly, by the year 2000, ne-fourth of our total energy needs could be met with solar energy. Council on Environmental Quality, Solar Eneray: Progress and Prctise (April 1978); Blueprint for a Solar America, Solar Lcbby (January 1979) .
These are factors essentially ignored by the Staff because its entire focus was on eight FNPs by the early 1990s. The program-matic' review required would expand the investigatien of alterna-tives to FNPs and highlight the advantages of these alternatives.
IV. The Floatina Nuclear Plant Is Unicue It is reasonable to anticipate that the applicant will argue that the FNP is not a new program but merely the continu-ation of an old and already established technology -- i.e.,
light water reactors. Mcwever, this entire proceeding and v.uch
7 .
of what is already contained in the FES belie this assertion.
The ACRS and the Staff have treated the FNP as a unique tech-nology requiring a special analysis. Even OPS in seeking to sell the FNP concept has considered it a new concept, albeit alleging that it relies on existing technology.
Of particular relevance are the findings contained in NUREG-0502 with respect to the FNP design. Because of the rni ue risks associated with FNPs, the FNP will be the first reactor to be required to include a core-catcher and other materials to mitigate the consequences of a core-melt accident.
These features make the FNP a markedly different device than existing plants. The risk factor is sufficiently altered by the water siting to transform an otherwise " incredible" accident into a credible accident for which design protections must be provided. Making a Class 9 accident a design basis risk involves a major technological variation from the existing reactor technology.
A similarly important technological difference in FNPs and land-based plants which also focusses on the fact that the plant is sited in water and not adjacent to water is the special site considerations rel'ated to the shoreline siting of FNPs.
The Environmental Protection Agency and the Staff are on record as believing that it is highly unlikely that any shoreline sites for FNPs will be found which are acceptable. NUREG-0502,
- p. XIV. The floating of a nuclear plant with the attendant dredging, sedimentation and other potential adverse consequences
8 identified in NUREG-0056, Supp. 1, Sections 2.4 and 2.5, creates unique problems for all FNPs which are not applicable to all land-based plants.
Undeniably, what is different about FNPs is that they float on water. That difference is demonstrably significant as reflected by all the special conditions being imposed on the FMPs. Thus, the concept of an FNP represents a new technology for which a sufficiently broad implementation is planned that a programmatic review is required.
CONCLUSION Eight floating nuclear plants doesn't mean a hell of a lot; Eight floating nuclear plants dcesn't mean a thing.
But give them to us four a year, Every year for forty years, That's enough for us to see the programmatic scheme.
Respectfully submitted,
/? )
4 3fi N I c%_ %
Anthony Z./ Roisman Natural Rdsourges Defense Council 917 15th Street, N.W.
Washington, D.C. 20005 (2G2J737-5000 Dated: Feb. 16, 1979 2/ With apologies to the composers of " Pajama Game."