ML19329E530

Responds to AEC 681107 Request for Comments on CP & OL Application.Discusses Radiological & Nonradiological Effects & Requests Util Cooperation in Conduct of pre- & post- Operational Surveys

ML19329E530
Person / Time
Site:	Midland
Issue date:	03/27/1969
From:	Crouthers C INTERIOR, DEPT. OF
To:	Price H US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19329E528	List: ML19329E530
References
NUDOCS 8006160325
Download: ML19329E530 (3)

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United States Department of the Interior OFFICE OF THE SECRE'TARY r WASHINGTON, D.C. 20240 i

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Dear Mr. Price:

This will transmit the comments of the Fish and Wildlife Service on the application by Consumers Power Company for a construction permit and facility license for the proposed Midland Generating Plant, Units 1 and 2, Tittabawassee River, Midland County, Michigan, AEC Dockets Nos. 50-329 and 50-330. These comments are provided in response to '

Mr. Boyd's letter of November 7,1968.

The project would be Located adjacent to the southern boundary of Midland, Michigan, on the south bank of the Tittabawassee River and would use two pressurized water reactors, each designed for an initial output of 2,452 megawatts thermal and a gross electrical output of 650 megawatts.

The condensers would be cooled by water recirculated from a 14,000 c.cre-foot storage pond constructed on the flood plain at the p h t site. The applicant proposes to fill the pond during the flood season since pumping at this time requires a smaller pumping head and there is less chance of reducing the residual river flow to undesirable low levels. After initial filling of the pond, makeup water would be required at a rate of approximately 70 c.f.s. to maintain a full storage pool. The storage pond would have the capac-ity to supply the plant for about 100 days without the addition of makeup water. Therefore, no pumping would be undertaken during periods of insufficient river flow.

I The water quality in the project area is significantly lowered by the addition of industrial pollutants from nearby plants. However, the river supports a moderate sport fishery for largemouth bass, yellow perch, bluegill, carp, catfishes, and suckers.

-The application indicates that the release of radioactive wastes would not exceed limits prescribed in title 10, part 20, of the Code of Federal Regulations. If the concentration in the receiving water were the only consideration, maximum permissible limits would be ade-quate criteria for detemining the safe rate of discharge for fish and wildlife. However, radioisotopes of many elements are. concentrated and stored by organisms that require these elements for their normal metabolic activities. Some organisms concentrate and store radioiso-topes of elements not normally required but which are chemically 8006 ISO 3 2 6 1073 0 I

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3 similar to elements essential for metabolism. In both cases, the radionuclides are transferred from one organism to another through various levels of the food chain just as are the nonradioactive '

i elements. These transfers may result in further concentration of radionuclides and a wide dispersion from the project area, partic-ularly by migratory fish, mammal s, and birds. .

It is imperative that every possible effort be made to protect the fish and wildlife resources of the area frca radioactive contamination.

An environmental radiological monitoring program is needed to deter-mine if the radienuclides released to the environment aref affecting fish and wildlife resources adversely. This program should be planned in cooperation with the Fish and Wildlife Service and the Michigan

.. Department of Natural Resources.

l In order to provide for the conservation, development, and protection l of the fish and wildlife resources, it is recommended that; Consumers Power Company be rpquired to: {

1. CooperatewiththeFishandWildlifeService,thdMichigan Department of Natural Resources, and other interested State and Federal agencies in developing plans for radiological surveys.

2. Conduct pre-operational radiological surveys inc],uding but not limited to the following: I

a. G radioactivity analysis of water and f sedimentipamples collected within 500 feet of f the reactor effluent outfall.

b. Beta and gamma radioactivity analysis of selected fish and wildlife species and organisms important in their food chain collected as near the reactor effluent outfall as possible.

3 Prepare a report of the pre-operational radiological surveys and provide 5 copies to the Secretary of the Interior for evaluation prior to project operation.

4. Conduct post-operational radiological surveys similar to those specified in recommendation 2 above, analyze the data, prepare reports every 6 months during reactor operation until it has been conclusively demonstrated that no significant adverse conditions exist, and submit 5 copies of these reports to the Secretary of the Interior for distribution to appropriate State and Federal agencies for evaluation.

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4 5 Make such reasonable modifications of project structures )

and operations as may be ordered by the Atomic Energy Commission i upon its own motion or upon the recommendation of the Secretary i of the Interior or the Michigan Department of Natural Resources, after notice and opportunity for hearing and upon findings that such modifications are necessary and desirable.

.. We understan'd that the regulatory authority of the Atomic Energy Commission is confined to considerations of common defense, security, radiological health, and safety. However, we recommend and urge that before the permit is issued, the dangers of other potential hazards to fish and wildlife resources which may result frce plant construction and operation be called to the attention of the applicant. Sufficient numbers of fish may be drawn into the intake to reduce the fishable population in the Tittabawassee Riyer below desirable levels. The release of plant wastes, coupled with the anticipated redsetion of the flowoftherivernmaycrea'tefurtherhazardstoaquaticlife. The applicant should meet with representatives of the Fish and Wildlife Service, the Federgl Water Pollution Control Administratibn, and the Michigan Department of Natural Resources to discuss these and any other hazards and should jointly design neans to monitor project effects and to mitigate conditions found adverse to fish and wildlife resources.

In view of the Administration's policy to maintain, protect, and improve the quality of our, environment, we request that the Commi,ssion urge Consumers Power Company to:

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1. Cooperate ~.'with the Fisn and Wildlife Service, the 2

Federal Water Pollution Control Administration, and the Michigan Department of Natural Resources in designing measures to monitor the effects of the project on the natural resources of the area.

2. Takesuchstepsasmaybedeterminednecessarybythe above named sigencies to mitigate any adverse effects of the project.

The opportunity fer presenting our views is appreciated.

Sincerely yours, Deputy Assistara Secretary of the Interior Mr. Harold L. Price Director of Regulations U.S. Atomic Energy Commission Washington, D.C. 20545 3

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