ML19256A790

Requests Clarification of Statement in Fes Addendum Part 3 Re Preconditon for Permit to Site Floating Nuclear Plant in Riverine,Estuarine,Or Barrier Island Site.Applicant Can & Will Meet All Conditons in Fes

ML19256A790
Person / Time
Site:	Atlantic Nuclear Power Plant
Issue date:	01/10/1979
From:	Roisman A National Resources Defense Council
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 7901160158
Download: ML19256A790 (2)

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i Natural Resources Defense Council,Inc.

917 15TII STREET, N.W.

WASIIINGToN, D.C. 20005 202 737-5000 DYestern Ofice New York Ofice s345 YALE STREET 122 EAST 42ND STREET PALO ALTO, CAUF. 943o6 January 10, 1979 xEw yoRn, s.v. ooi7 435 387-1080 818 949-0049 Harold Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washin gton , D.C . 20555 Re: Offshore Power Systems, Docket No. STN 50-437

Dear Mr. Denton:

We recently received a copy of the final environmental statement Addendum Part III in the above-titled proceeding.

We wish to commend the Staff for making a substantially improved effort to come to grips with the problem of estu-arine and riverine siting and particularly the inclusion in this ES of certain irrevocable conditions that must be met by anj prospective licensee in the future with respect to the siting of floating nuclear power plants in the estuaries of this country.

There is one point in the conditions that have been laid down which we wish to have clarified on the record.

In the statement of conditions, the prospective applicant is required to " demonstrate techniques" that the conditions can be met. It is not clear, but we assume that it was intended to be clear, that the applicant in fact is required to utilize the techniques which it demonstrates and to in fact be able to meet all of the conditions laid down before the site can be approved for a floating nuclear plant. We therefore would appreciate from you a clarifying letter, to be included as part of the record of the OPS proceeding, that indicates that the Staff intends to establish as a precondi-tion to the granting of a permit to site a FNP in an estuarine, riverine or barrier island site a demonstration by the appli-cant that it can and will meet the conditions laid down in the FES Addendum Part III.

One additional aspect of those conditions that we think is particularly crucial is that the applicant's demonstration of its ability to meet the conditions laid down must be made completely prior to the approval of a construction permit, and that no loophole is built into the conditions that would v

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6 Harold Denton January 10, 1979 Page Two allow an applicant to begin sinking money into the site based upon a promise to demonstrate at a future time that the techniques that it hopes to use to mitigate the conse-quences of the siting will in fact work. In short, the applicants may not use the floating nuclear plant as a guinea pig on which they hope to prove that they can meet the conditions, but rather the appicants must in fact demonstrate that they have in hand the techniques for meeting the conditions and that there is reasonable assur-ance that the techniques they incend to use will in fact meet the conditions. It would therefore be appreciated if the letter which you send me with regard to the item addressed in the previous paragraph also makes clear this aspect of the Staff's position.

I trust that I am correct in assuming that these points which I have raised are in fact matters of clarifi-cation and are not in any way suggestions of policy modifi-cations in the Staff's original position. If it turns out that I am mistaken in this regard, would you please have someone from your staff call me directly prior to the preparation of any answer to this letter so that I might have a direct meeting with them before a formal position is taken by the Staff.

Sincerely,

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7 i ! ,' %w t Anthony /[Z . Roisman cc: service list s