ML19330A068

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Forwards Util Responses to Comments Received from Dept of Commerce,Hew & Doi Re AEC Des.Results of Archeological Value Discussion W/State Liaison for Historic Preservation Will Be Forwarded
ML19330A068
Person / Time
Site: Midland
Issue date: 05/20/1971
From: Restrick J
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Morris P
US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8007140873
Download: ML19330A068 (27)


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...,. ee Genere! Attorney C. J. Breve General Officesi 212 West Michigan Avenue, Jackson. Michigan 40201. Area Code S17 708 0650 H. E. Clark C. 3. Merritt O. M. Peterson

c. H. neda-THIS DOCUMENT CONTAINS May so, 1971
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POOR QUAllTY PAGES J. L. Bacon A. S. Sees G

c. o. o."**a DOCKET NOS. 50-329 AND 50-330 D

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W. A. Kirkby W EC A. O. McCallum MAY 241971

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w. m. milie Dr. Peter A. Morris, Director 9"

J. M. Restrick Division of Reactor Licensing g,c, g e, s2cnwr

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U. S. Atcnic Energy Cecaission renegcymn 7

J. m. smith Washington, D. C.

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A. T. Udrys

Dear Dr. Morris:

w Please find attached hereto copies of Consumers Power Ccxnpeny's responses to ccxanents received from the Departments of Ccx:nnerce, Health, Education and Welfare, and Interior, on the Atcmic Energy Ccenission's Draft Detailed Environmental Statement for the Midland Plant, Units 1 and 2, Docket Nos. 50-329 and 50-330. We have recently received the comments of the Environmental Protection Agency and plan to file responses thereto shortly.

It was reccxmnended by the Interior Department that we discuss archaeological values with the State Liaison for Historic Preservation for the purposes of the environmental statement. We have initiated contact with the State Liaison and expect to forward results of that discussion shortly.

Sincerely, M

JKR/pb John K. Restrick CC: AWMurphy, Esq.

Dr. Clark Goodman Dr. David B. Hall m

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William J. Ginster, Esq.

James A. Kendall, Esq.

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..ED Anthony Z. Roisman, Esq.

Thomas F. Engelhardt, Esq.

g Milton R. Wessel, Esq.

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MAY 241971 >

-12 James N. O'Connor, Esq.

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,,,,,3, Myron M. Cherry, Esq.

res Prx:emp Algie A. Wells, Esq.

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Stanley T. Robinscn, Jr.

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MAY 241971

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ASSISTArt SECRETARY OF C0!OERCE A

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Ccanment:

"We believe this environmental impact statement would be strength-ened materially if a greater socioeconomic data input vere provided by the applicant. For example,Section IV, ' Alternatives to the Proposed Action' (p. 33ff), superficially mentions four alternative considerations and then eliminates each without a single hard economic statistic supporting the decision by comparative analysis. Effective and persuasive analysis of the type envisioned in the Council on Environmental Quality Guidelines vill require a much more solid economic data input than evident in this statement."

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Response

In addition to the alternatives of no power, the following alter-natives are discussed in the Draft Detailed Environmental Statement:

Imported Power Alternate Sites Alternate Plant Comments from the Federal Power Commission in the Draft Statement present facts that show that importing power from other areas is not a feasible alternative. Reserve margins in nearby power supply areas are just at or below the necessary margins for reliable service. Other systems also face the possibility of delays in obtainin6 new generation. Additionally, importation of power would merely export any environmental effects of power generation and increase the amount of transmission facilities necessary.

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2 As stated in the Draft Statement, there is no feasible alter-native for using another site to produce process steem for Dov. The applicant has studied the costs of moving the plant farther from its present location while still delivering steam via piping. The estimated additional capital costs for moving the nuclear plant the following number of miles from its present location are listed below:

One Five Ten

$80 million

$170 million

$300 million In addition to these increased capital costs, such a moving of the plant would result in a decrease in both the quantity and quality of the steam supplied to Dow. Delivery of steam from such a distance would require the use of extremely large pipes, which could be considered unesthetic.

The consideration of type of plant is significantly affected by 4

overall energy cost. In 1967, when a decision was made to construct a nuclear plant at Midland, nuclear energy costs were projected to be lower than fossil fuel costs. While fossil. fuel costs have escalated dramati-cally over the past four years, nuclear fuel costs have risen more gradu-ally. The following table represents the present projection of alternate fuel costs adjusted for the Midland area in cents per Btu:

1976 1980 coal (3% Sulphur) 54 5 62.6 Coal (Less than 1% Sulphur) 60.6 69 7 l

Oil (Crude less than 1% Sulphur) 68.3 73 9 Nuclear (Midland) 22.4 18.6 Natural Gas Gas Supply Not Available l

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The costs are given above for both 1976 and 1980 so as to demonstrate the cost of nuclear fuel at startup when 2/3 of the core is used for less than the equilibrium span of three years and the cost of nuclear fuel in 1980

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when the plant will be operating at equilibrium.

As stated in the Draft Statement, coal is the only feasible

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1 alternate fuel for a base load unit. Taking into account the fact that nuclear plants have higher capital cost and lover themal efficiency than coal units, the energy cost of coal vould have to be reduced to 33 7 cents per million Btu for it to be competitive with nuclear fuel for a base loaded pisnt at the Midland site. Economic factors thus clearly indicate the choice of a nuclear plant for base load generation in the mid-1970's. In addition, as indicated in applicant's response to coments received from the Department of Interior, environmental factors also clearly favor construction of a nuclear plant at this site.

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ASSISTANT SECIEPARY OF COMMERCE Ccznment:

"Further, it is our belief that the basic environmental studies vhich will be conducted by the Applicant (see Section VII, ' Additional Inf formation,' p. 37) should be conducted insofar as possible before, rather than after, the construction pemit is granted. This requirement would em-brace the plans for various preoperative surveys. It may be that certain variables vill surface which could cast doubt on the environmental feasibility of launching a potentially hazardous project."

Response

The basic envircamental studies are conducted to establish pre-operational base lines with which to courpare the results of post-operational studies. Two years of environmental studies are considered adequate to es-tablish these base lines. The most relevant pre-operational data vould be that collected just before operation. Therefore the applicant feels that scheduling the environmental studies prior to receipt of the construction permit is premature. An additional discussion of this topic is contained in applicant's response to consnents from the Department of Interior.

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ASSISTANT SECRETARY OF CCMMERCE Comment:

"Still further, the environmental impact statement contains little relevant technical information on the meteorolo6 cal aspects of 1

the site. As a consequence, our evaluation is based on other, more detailed, technical data previously made available to us.

At the request of the Division of Reactor Licensing of the AEC, a review of the Preliminary Safety Analysis Report of the Midland Nuclear Power Station was prepared by the Air Resources Environmental Laboratory and transmitted to the AEC in separate comments on February 3,1969; July 28,1969; January 5,1970; and February 4,1970.

A copy of the letter is enclosed.

Our conclusion at this point is that sufficiently detailed and appropriate meteorological data have not been developed by the applicant that would enable us to compute relative atmospheric diffusion rates. Our review of the meteorological aspects of the radiological effluent from the facility will not be completed until additional data are submitted."

licsponse:

The applicant submitted detailed meteorological information as part of the PSAR. That information was suitable for site selection, safety analysis and initial design purposes.

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The applicant will gather additional detailed meteorological information at the site after receipt of the construction permit.

This supplementary meteorological information vill be used to determine operating parameters for the proposed plant. These operating parameters will be part of the technical specifications which are prepared at the operating permit stage.

This supplementary meteorological infomation is not needed at this time.

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'T EPARTMENT OF HEALTH, EDUCATION & WELFARE Coment:

"When Midland's vaste management system was finalized, it in-corporated the best vaste treatment systems available at the time. Recent technological advances have been made, however, in the design of vaste treatment systems and in the manner in which they are operated.b)

As a reasonable alternative to installing a 'near zero release system,' ve have concluded that the applicant should:

1) operate the present liquid vaste system 100 percent of the time and 2) operate the Baseous vaste treatment system with a min 4== holdup time of 60 days. The applicant should also clearly state, as official company policy, its ccamitment to use these vaste management systems to their full capacity at all times to maintain all discharge levels et as lov a level as practicable. In this respect, it is noted that the ' clean' liquid vaste system has no evapora-tor, but does have the capability to divert the vaste to the ' dirty' waste system which does. Such a design places a high reliance on plant procedures to achieve a lowest practicable level. Such a comitment would be con-sistent with the changes proposed by the Atomic Energy Comission in 10CW20 and 10CFR50, } end would publicly acknowledge the Company's realization of the necessity for maintaining and improving the quality of the environ-ment."

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Response

Liquid R dioactive Waste i

The design of the Midland Plant liquid radioactive vaste treat-ment system has been modified since the issuance of the Environmental l

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l Report (July 1970) so that it is equal to the current technological ad-vances and will release essentially no radioactivity during normal operat-ing conditions. The system is nov designed to collect, process and reuse all the liquid waste, except laundry vaste, generated during nomal opera-tion of the plant.

The clean liquid vastes - vastes containing relatively low chemical impurities and suspended solids such as the reactor coolant and fuel pool coolant - can be processed through a vacuum degasifier, filters, decineralizers and an evaporator. The end products, concentrated boric acid and demineralized water, are normally stored for later reuse in the reactor coolant cycle.

The dirty liquid vastes - vastes which potentially contain high concentrations of chemical impurities and suspended solids such as the vastes frca radioactive laboratory drains, building sumps and decontamina-tion drains - can be processed through filters, demineralizers and en evapora-tor. The condensate from the evaporator can then be stored in the lov tritiated makeup storage tank for reuse. The evaporator bottoms can either be sent to the boric acid storage tanks for reuse or sent to the solid vaste handling facility for dr-4ng and shipnent to AEC authorized dis-posal facilities in accordance with Department of Transportation regulations.

No liquid waste, except for laundry vaste, will be released to the environment when the radioactivity exceeds the natural radioactivity in the makeup water.

i The new liquid vaste processing system is discussed in more de-tail in Amendment No. 20 to the application for reactor construction per-I

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mit, Docket No. 50-329 and 50-330, for the Midland Plant.

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3 Oaseous Waste Operating experience of present reactors shows that the annual doses from vaste gases to personnel in the vicinity of the proposed plant will be insignificant. However, two hypothetical vorst case assumptions can be made to show what the effect of 30-days versus 60-days holdup of gaseous vastes vould be. These hypothetical assumptions include:

(1) Operation for a full year with the maximum limit of failed fuel (1%).

(2)

Individual being exposed spends the entire year i

at the site boundary.

I With these assumptions it can be shown that 30-days holdup would result in an annual dose of 32 mrem. With the same assumptions and 60-days holdup the dose would be 22 mrem. However, actual experience of PWR indicates that neither of these vorst case assumptions are to be expected and that under normal operating conditions releases of vaste gases will be well below those calculated for the worst case. Because of this small actual release the reduction resulting from a 60-day holdup instead of a 30-day holdup would be less than one mrem. This does not appear to be of sufficient significance to,)ustify an additional 30-day holdup.

Applicant believes that increasing vaste gas holdup time is not the best method of reducing the vaste gas effects of nuclear plants.

Because of the relatively long half-life (10 3 years) of Kr-85, extended holdup (greater than 30 days) before release cannot make a significant change in the doses from vaste gases. Several more advanced gaseous radvaste systems When a are under developnent by reactor vendors and other manufacturers.

cystem is developed which is economically feasible and will significantly

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reduce the doses from the proposed plants the Applicant vill' install such a system. The present design of the gaseous radvaste system pemits addi-tion of the advanced systems under developnent.

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o DEPARTMENT OF HEALTH, EDUCATION & WELFARE Ccxument:

"Most of the steam delivered to the adjacent Dov Chemical Plant will be condensed and returned as heated feedvater after use in the various chemical processes. The steam not condensed vill be replaced by Dow with treated makeup water. A tertiary water cycle with a heat exchanger between the secondary and tertiary systems is discussed in Amendments 15-19 of the PSAR. This sytem is designed to prevent any radionuclides found in the secondary system due to primary to secondary leakage from being transported to the Dov Plant. The applicant plans to use an on-line continuous gamma monitor that will alarm in the centrol room if the level of radioactivity exceeds 3 x 10-6 aci/ce,ontheprocess steam line to the Dov Plant. There vill also be a continuous monitor on the secondary steam system. These monitors are to help insure that radioactivity is not released to Dow at concentrations in the steam sig-nificantly greater than the background beta-gamma levels of Lake Huron water.

"There is no indication as to whether or not the above course of action is initiated autcznatically, nor how long it vill take to switch frcza one heat exchanger to the other, nor how much radioactivity could possibly enter the tertiary system during this time period. More informa-tion relating to this monitoring system is needed to permit a full evalua-tion of this operation.

"The process steam vill be used by Dov in the manufacture of consumer products. The Food and Dru6 Administration should be provided with a listing of the ccznpounds which vill come into contact with the process steam."

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Response

The function of the Tertiary Heat Exchanger (THX) system is to provide complete physical separation in the form of closed heat ex-i changers between the secondary system steam frca the turbine plant cycle and the tertiary system steam delivered to Dov. Thus the presence of radioactivity in the process steem above natural radioactivity levels could only occur if simultaneous leaks existed in the steam generators and tertiary heat exchangers.

Two monitoring methods will be employed on the tertiary side of the heat exchangers. The on-line continuous gamma monitor will pro-vide an audible alarm if the gross gama activity in the process steam reaches a level of 3 x 10-6. sci /cc. In the event of an alam, the process steam flow frca the leaking tertiary heat exchangers will be immediately teminated. In addition to the on-line monitor, periodic grab samples of the process steam will be collected, prepared and analy'ed on highly sensitive detectors capable of detecting tritium and gross beta concen-trations equivalent to the concentration of nacural radioactivity (about 5 x 10"I,ci/cc and 8 x 10-9 tci/cc for tritium and gross beta, respectively) in the makeup feedvater to the teritary heat exchanger. Because of the minute amounts of radioactivity that are involved in detection of leakage

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  • ci/cc gross gama), detemination of leakage may require up to eight hours preparation and analysis of samples.

Following any detemination that the radioactivity in 'the process steam exceeds the radioactivity in the makeup water, the steam from' the leaking I

heat exchanger vill be immediately teminated. All Dov Chemical Company

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products which come in contact with contaminated process steam vill be monitored and in the event the radioactivity in the product exceeds the inherent natural back rouci radioactivity, the product vill be decontami-6 nated or disposed of as necessary.

Representatives of Dow Chemical Company have discussed with, representatives of the Food and Drug Administration the use of process steam from the Midland Nuclear Plant in the manufacture of products.

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e DEPARTMENT OF HEALTH, EDUCATION & WELFARE Comment:

"The applicant's environmental surveillance program is generally of sufficient scope to allow an adequate evaluation of the plant's en-vironmental impact. One additional documentation, however, that we be-lieve should be included is a detailed plan for the sampling of nonaquatic foodstuffs. We believe that the applicant should document the ext;ent to which he, or some other Federal or State agency, will sample such items as milk and the various crops grown in the area. An invescigation should also be made as to whether dairy cattle may obtain drinking water downstream of the plant in such a way that I-131 may reach and expose the population.

In addition, we suggest that the applicant indicate the degree to which he plans to coordinate his proposed environmental surveillance programs with that of the Michigan Department of Health. Such coordination is es-sential for health agencies to be able to verify the continuing adequacy of their environmental surveillance."

Response

While nonaquatic foodstuffs are not ccanon in the area affected by the plant, applicant intends to obtain representative samples of those nonaquatic foodstuffs that are found in this area. Since the plant vill have an essentially zero release liquid radvaste system, it is not antici-pated that I-131 vill be released to the river from ths plant in measurable quantities. However, water downstream of the plant vill be closely moni-tored with respect to the ability of I-131 to expose the population through the food chain.

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The Michigan Department of Health (MDH) conducts independent surveillance programs in addition to the Company's programs at the Big 3ock Point and Palisades Plants. Similarly, it is expected that this will be done at the Midland Plant. Coordination with MDH involves an annual exchange of data and meetings to determine if changes should be made in either MDH's or the Company's program based upon the operating and release experience of the plant.

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DEPARTeEiT OF HEALTH, EDUCATION & WELFARE Comment:

"The emergency planning infomation presented by the applicant in the PSAR appears to be quite comprehensive, especially with respect to the coordination with the Dow Chemical Company and the local police and civil defense authorities. The State Departznent of Health has the re-sponsibility for evaluating offsite conditions and directing all actions to protect the public in the event of non-routine releases of radioactivity.

The arrangement between the company and the State Department of Health has not been clearly delineated in regard to this aspect of the emergency plan."

Response

Details of emergency plans are generally not completed until the final design stage following issuance of the construction permit.

Applicant vill attempt at that time to detail arrangements with the Michigan Department of Health regarding the emergency plan. However, as provided in the AEC's Draft Guide to the Preparation of Environmental Reports for Nuclear Plants (February 1971) footnote 7, page 11:

"The adequacy of... emergency plans will be evaluated in the context of the Part 50 licensing procedure and need not be discussed in the en-vironmental report."

DEPARTMENT OF INTERIOR Comnent:

" Site Planning--It is-evident that Consumers Power Company has not yet developed a final site plan for this facility. The applicant states that the entire 1,190 acre site which includes an 880 acre cooling pond vill be confined to the generation of power and process steam. Al-i though the land was previously zoned for industrial and residential develop-ment, this should not preclude public access to those onsite areas where personal health and safety would not be endangered. We therefore view the applicant's contemplated inforeation center as a desirable feature of the plant, and we suggest that the final environmental statement assess the recreation and esthetic potential of the 880 acre cooling pond."

Response

The cooling pond vill not be accessible for recreational purposes.

The water temperature in the pond vill be in the range of 100 F to 120 F during the varm months of the year. The pond temperature vill be unsuit-able for recreational uses.

The property line of the plant will be planted with a 10-foot evergreen hedge and a line of evergreen trees. This screen of trees and shrubs vill line the pond dike and scIwen it from a residential subdivision nearby. This vill create an aesthetic boundary which will enhance the ap-pearance of the plant site.

DEPARTMENT OF INTERIOR Comment:

" Esthetics--The statement inadequately treats the visual-esthetic effects of the facility and related structures such as transmission lines.

Since there was no architectural treatment of the project in this report it was impossible to evaluate this espect.

"Oraphic and narrative material is undoubtedly available which if included vculd aid in the review of the statement. Comments from other interested parties on visual esthetic effects should be attached to the report."

Response

A photograph of an architectural model of the plant has been attached hereto as an aid in evaluation of the visual-esthetic effects of the plant. The plant as pointed out in the Draft Statement will not have coal storage, high stacks or ash storage ponds which might be found esthetically less acceptable. Applicant has not yet fixed its transmission line design and vill certainly consider visual-esthetic effects in deter-mining such design. The design and construction of the transmission lines will be in conformance with the Federal Power Ccanmission's " Guidelines for the Protection of Natural, Historic, Scenic, and Recreational Values in the Design and Location of Rights-of-Way and Transmission Facilities" adopted by Order No. 414, 35 F.R.18585 (12/8/70).

l The grounds surrounding the plant will be landscaped and a ten-foot I

l evergreen hedge and line of evergreen trees vill be planted along the prop-erty line. This screen of trees and shrubs vill line the pond dike and l

screen it from a nearby residential subdivision.

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DEPARTMENT OF IEERIOR Comment:

Geological and Hydrologic Safety--Nuclear plants are as a rule located in isolated or semi-isolated places away from major population centers.

It is reasonable to presume that this is done as a means of lessening public exposure should there be a major accidental release of radioactive contaminants. While it can be postulated that in the case of Midland, Class I structures are used for the reactor and radioactive vaste containment buildings and that the utmost effort 'ias been made to preclude a major accident, it cannot be said that such an accident is impossible.

Locating this plant so near a town of approximately 30,000 persons would seem to be contrary to established practice.

Therefore, the consequences of the worst possibic accident needs to be more fully evaluatedfiom the standpoint of its effect on both the people and their environment.

This drait environmental statement contains no geologic information with which to make an evaluation of the impact of the construction and operation of the plant on the environment.

Response

Detailed information concerning the geology and the hydrology of the site _is presented in the Preliminary Safety Analysis Report, Chapter 2.

This information is suitable for making an evaluation of the impact of the construction and operation of the plant on the environment.

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2 AEC's Draft Guide to the preparation of Environmental Reports for Nuclear Power Plants (February 1971) specifically i

excludes the discussion of the results of accidents at the plant as follows in Footnote 7 on Page 11.

"The adequacy of structures, systems and components provided for the prevention of accidents and the mitigation of consequences of accidents, post-accident monitoring, and emergency plans vill be evaluated in the context of the Part 50 licensing procedure and need not be discussed in the environmental report."

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DEPARTMENT OF INTERIOR Comment:

" Monitoring--The draft environmental statement and the applicent's envimnmental report indicate that meteorological, ecological and radiological sv neillance programs have been formulated. However, these studies will not begin until after the AEC issues a construction permit. It appears that some of the data obtained in these studies vill influence the location and Further-design of structures associated with nuclear power plant operation.

more, ecological studies are necessary to document the present status of the environment and to estimate the effect of the construction on the en-vironment, a certain amount of data should be available prior to issuance of the construction pemit."

Response

Sufficient environmental infomation is presently available for location and design of the plant. As indicated in response to the comment of the Assistant Secretary of Commerce, sufficient meteorological infomation is available from The Dov Chemical Company and Tri-City Airport. During the construction period an on-site meteorological study vill be made in order to refine the present meteorological data. It does not appear that any in-formation obtained from the on-site meteorological study vill influence location or design of the plant. It is conceivable that such infomation 1

could influence operation of the plant and to the extent it does, the plant's technical specifications vill reflect this. Radiological studies are per-fomed prior to plant operation for the purpose of establishing the natural background radiation level in the area so that it can be used as a standard against which to evaluate impact of radiological emissions frca the plant on background radiation.' Such studies cannot be exp cted to influence the

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2 design or location of the plant. Those studies which affect location and design of the plant, e.g. geology, soils analysis, hydrology, population, have been completed and are included in the PSAR (Chapter 2 and Amendments Nos. 1, 5 and 6 (Items 2.4, 2.6, 2.12, 2.17, 8.0, 4.0, 7 0 and 10.0 and attached reports), 9, and 10) because of their relation to safety of the plant. Construction at the plant site would not significantly affect either the meteorology or back round radiation in the area and is not 6

expected to have more than temporary effects on the environment in the Applicant has not designed a study to measure these effects.

area.

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DEPARTMENT OF IhTERIOR Comment:

Alternatives to the Proposed Action--In covering alternatives there should be a discussion of the siting of this facility on the Tittabawassee River versus other locations particularly since there may be insufficient flow to meet the projected demand. There should also be a discussion of alternatives to supplying process steam.

One of the alternatives to be considered should be the installation of air pollution control devices on the chemical plant.

Indiscussing these alternatives sufficient evidence should be presented to substantiate that these actions have minimal environmental impact.

Response

The draft Environmental Statement discusses the river flow in Section 5.2.2, Thermal Effects.

It should be pointed out that the Tittabawassee Hiver is not being used for once-through cooling of the proposed plants' condensers.

Condenser cooling is accomplished by using a cooling pond as described in this section. The only consumptive use of river water is for replenishing the pond evaporation.

Section 5.2.2 discusses the applicant's plans for use of the Tittabawassee River under all flow conditions.

The conditions e,onsidered include even the worst drought. Our analysis and the resultant plans have taken river flow variations into consideration.

liiver flow is adequate for operation of the plant at this site.

A more detailed discussion of a

this can be found in Amendment No. 5 to the PSAR, Page 2.6-1.

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The alternative of using air pollution equipment on Dow Chemical Company's steam generators is not feasible. The primary reason for this is energy cost. If Dow is to continue full scale operations at the Midland location a lower cost source of energy' than fossil fuels is needed. Additional details on energy cost comparisons are included in Applicant's response to Assistant Secre-tary of Commerce comments.

The alternative of using air pollution equipment on fossil fueled steam generators would only partially improve the air quality in the Midland area.

A table is attached which shows the atmospheric emissions of Dov's steam generators compared to the proposed plant.

Currently available air pollution equipment for Dov's plants could remove about 99% of the particulates and radioactive emissions.

This would reduce the radiation dose to.Old of ICRP limits (upon which AEC limits are based) which is still greater than the expected dose from the proposed nuclear plant. The sulphur dioxide and nitrogen oxides would be unaffected.

Generation of steam from the proposed nuclear plant would eliminate emissions of all air pollutants except for trace quantities of radioactive noble gases.

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3 Annual Atmospheric Emissions Midland Nuclear Dow Coal Fired Plant Steam Plants Particulates O

2.08x10 tons ( }

4 Nitrogen Oxides O

1.37xlO tons 3 tons (

Sulphur Oxides 0

1.1x10 Radioactive radium -

thorium isotopes nil

.2 curies Redisactive noble gases 12 9 Curies (2) nil (1.04xlhCi)(3)

Fraction ICRP Radiation dose

.003%(1 4%(1)

(6.4)(3)

Note 1:

This information from Statement of Position of the Michigan Air Pollution Control Commission presented by Donald E. VanFarove to the Atomic Safety and Licensing Board, Decenber 1, 1970 at Midland, Michigan.

Note 2: This is an estimated actual annual release based on the discharge rate per megawatt electrical experienced at the Connecticut Yankee Nuclear Plant in 1968.

Note 3: These are =

possible releases while operating at the upper limit of 1% failed fuel for a full year. Dose fraction is at the site boundary.