ML19331A772

Comments on Des Emphasizing That Adequate Evaluation Requires Consideration of All Environ Impacts Including Those Removed Physically from Plant

ML19331A772
Person / Time
Site:	Midland
Issue date:	06/04/1971
From:	Roisman A BERLIN, ROISMAN, KESSLER & CASHDAN, ENVIRONMENTAL DEFENSE FUND
To:	US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8007230796
Download: ML19331A772 (15)

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Before the UNITED STATES ATOMIC ENERGY COMMISSION In the Matter of )

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CONSUMERS POWER CO. )

(Midland Units 1 and 2) Docket Nos'. 50-329

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50-330

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COMMENTS UPON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR MIDLAND UNITS 1 AND 2 SUBMITTED BY THE ENVIRONMENTAL DEFENSE FUND The Environmental Defense Fund takes the position that under uppropriate circumstances nuclear energy offers environ- .

mentally sound means of meeting the nationk requirements for energy. It recognizes, however, that nuclear energy sources are by far the most dangerous and complex objects to have been developed by modern society for use outside of national defense.

l Because of the extreme potential danger associated with nuclear power plants, the extremely long life of the radiocative by-

products, and the extreme public concern which nuclear power has l engendered among the general public our view is that it is in-cumbent upon the proponents of any particular power plant to demonstrate in extreme detail that their proposed installation i

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2 has been planned in sufficient detail and contains sufficient engineering and other safeguards as to lay to rest even the objections of the skeptical (rational) critic. .

. t In expressing this view we are aware that for certain types or locations of installation adequate assurance may not presently be possible. Under such circumstances (and location of a nuclear power plant in the center of a large city is an example) we hold that construction of nuclear power plants should not be undertaken. We are also aware that development of new types of energy production is proceeding rapidly, so that there may well be advantages accruing to society through delay in construction of nuclear power plants. As examples of the type of power source we have in mind, we mention thermo '

nuclear fusion sources and magnetohydredynamical sources of energy.

Finally, in evaluating a nuclear plant for a particular location we emphasize that adequate evaluation of the environ-mental impact requires consideration of all impacts, including those that are removed physically from the plant. As examples of this type of impact we mention l

j a) fuel transportation ,

b) fuel processing,. including breeder reactors required to render the plant economical c) power transmission lines ,

d) long term storage and disposal of waste.

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3 EXPECTATIONS FOR AN ADEQUATE ENVIRONMENTAL IMPACT STATEMENT The intent of the National Environmental Policy Act (NEPA) is, among other things, to compel a complete examination of all ,

possible environmental impacts of a particular course of action, ,

including'the consequences of failing to take the proposed action, irreversible environmental degredation, and alternatives to the proposed action. As a corollary to these requirements we infer

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that the NEPA statement should not only make categorical assertions that the requirements of the act have been complied with, but should provide sufficient support for the assertions that competent persons may fully evaluate the impact of the i proposed action without recourse to addition'al research and .

without recourse to additional documents of an obscure or diffi-cult to obtain sort. The NEPA statement should be essentially self contained. All assumptions made, and the critical facts behind conclusions, should be explicitly stated.

The above requiremen't is not to be taken as a request for inclusion within the NEPA statement of the complete details of all studies which were undertaken, all engineering drawings, computer print out, etc. Not only would such material be unduly bulky, but it would also present severe difficulties for analysis, since essential facts are all too readily lost in an overabundance of detail. .

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4 What we seek, rather, is a concise listing of critical facts bearing upon the five questions of Section 102 (2) (C) of NEPA plus these additional related queries: -

a) The components required in a complete analysis of safety and environmental impact.

b) The assumptions which have gone into each experiment made in answer to item a).

c) Detailed itemization of the safety factors associated with each identifiable risk.

d) An economic and environmental analysis of the con-sequences of failing to take the required action (a ,

social cost / benefit estimate). .

In our detailed comments upon the Midland proposal we will deal with a number of consequences of these points. At this stage in our comments we mention explicitly a critical region of concern which is entirely omitted from the document:

an evaluation of the need for this power plant from a national energy viewpoint, and evaluation of alternative sources of energy-located in regions remote from the proposed plant. That is,

the analyses performed do not even approach the role the Midland units perform in meeting our national energy needs. Clearly, an answer to this question would entail detailed projections of national energy needs for the next several de' cades.

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5 SITING LOCATION 4

There is considerable question as to whether or not the .

AEC's population density requirements for.the location of a nuclear reactor are satisfied with respect to Midland, Michigan, insofar as Midland is a population center of approximately 35,000 and since the facility itself is one of the largest, with a total generating capacity of 1,600 megawatts, to be proposed to date. These questions should be explored thoroughly in the applicant's impact statement.

Special attention should also be given to the residential subdivision located near the western boundary of the 880-acre water cooling and storage pond. Meteorological and monitoring system information is insufficient to provide an estimate of

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impact upon the residents of this area. Future population trends in the area of the plant should also be tahms into consideration.

An adequate site location analysis should be prepared long in advance of any construction in the proposed site. area. ,

Failure to undertake and report such an effort demonstrates a lack of concern for essential environmental considerations.

Such a site location analysis should give a detailed l l

breakdown of the site and adjacent property in terms of zoological and botanical life, the topography of the land and its, influence l

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6 upon hydrology and seasonal meteorology of the area, soil conditions and their relationship to the hydrology and the water table of the a ea, the river flow as well as te'mperature and height at all times during the year, including its variations and effects upon ground water flow and water table, the aquatic life of the area, including plants and microorganisms which exist in the waters of the Tittabawassee River for an area at least one mile up-and-downstream from the facility, and bird and insect populations. The site analysis should describe feeding areas, nesting areas, and other semi-permanent and permanent animal habitats. .

The site location analysis should also include analysis .

of nearby sources of radioactivity and river pollutants such as hospitals, medical and dental clinics, X-ray machines, laboratories, municipal sewage treatment facilities, industrial pollutants, air, water and the like.

The site location analysis should be sufficiently thorough in the environmental statement to make certain that all relevant '

considerations and factors have been examined.

RADIATION Estimated radioactive releases and exposures during acci-dnet conditions as well as during normal operations should be presented and related to the AEC limits of 10 CFR 20 and 10 CFR 100.

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7 Detailed information regarding environmental monitoring is not contained within the statement. The specifications of sample types, as well as their frequency, s.hould be included in the environmental statement.,

A monitoring program which would assess the effectiveness of waste control and study possible effects on the environment should be instituted to include parameters observed, the location and frequency of samples taken,.and possible alternatives and their effects. .

The applicant should name the agency to do the testing and should document the provisions to be made for sampling such non-aquatic foodstuff as milk and various crops grown in

.the area. An example of this would be answering such questions as to whether or not dairy cattle can obtain drinking water downstream from the plant so that I-1.31 can reach and expose the population.

Moreover, the applicant shou.d indicate the degree of coordination between his proposed eavironmental surveillance ,

programs and the Michigan Department of Public Health, insofar l

as such coordination is vital to the evaluation of environmental surveillance programs of health agencies.

l l The safety of the products of the Dow plants utilizing l

l process steam from the-nuclear facility should be ascer.tained by appropriate agencies which have regulatory or other vested interests regarding the consumer utilization of these products.

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8 RADIOACTIVE WASTES l

The repart fails to comment either upon potential radio-nuclide buildup or bioconcentrations in aqyatic life, both plant and animal, and does not show maximum and average concentra-tions anticipated at various seasons, especially during the summer when stream flows are low. Quantities of effluents to include specific radionuclides and seasonal river flow rates should be presented to allow a more comprehensive appraisal of the effects of radionuclide discharge upon the environment.

The radiological effects of the operation of a nuclear power plant include not only planned and inadvertent radioactive discharges at the site, but also radioactivity related to trans-portation, reprocessing and the eventual storage of radioactive wastes.

The mere fact that this radioactivity is to be transported from the plant by licensed haulers does not mean it can be dis-counted as an environmental impact of that nuclear facility.

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( Accidents or leaks during shipment and eventual disposition l of those wastes should be considered an integral part of the impact statement.

THERMAL EFFECTS A more thorough study of thermal effects on the' aquatic life in the Tittabawassee River is necessary; for example, more I

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9 references to published data on limnology and to studies on heat dissipation are necessary to adequately appraise thermal effects on the environment and should be included in such a study.

To be more specific, a study of thermal effects should consider such factors as low, average and high river flows; anticipated maximum temperatures and temperature rises above the receiving water; size of the mixing zone; equilibrium temperatures after adequate mixing; rate of heat dissipation; and circulation of cooling water in the pond.

This would entail a detailed analysis of waste heat discharge both on water quality and aquatic life, and would include not only a discussion of possible algae growth in the cooling pond but also any resulting problems and controls ' hat could be applied toward solving such problems. The environmental statement should express these concerns, raflecting especially the potential problem of the addition of waste heat to the river.

Additional questions need to be answered at this point.

Why wasn't the cooling pond acreage designated with a comfortable i

safety capacity? If such a capacity is built in, what 9ould its size be? What alternative solutions are available should the addition of waste heat to the river prove to be a serious problem? What if the rate of evaporation is greater than expected?

How long will it take to fill the pond initially? We simply do not know what the effects of the pond will be, for eNample,

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10 in terms of steam, fog, and humidity, and it is necessary to know the answers to these questions. The environmental impact statement should include answers to these questions. -

The report refers to the area of tho' coo 34.ng pond as 880 acres (as compared to the need for a 660-acre pond for a comparable coal-fired plant). In arriving at this specified area, one is led to believe that some calculations have been made on the amount of heated water that will be discharged from the pond into the Tittabawassee River. Yet on page 12 it is stated that "Although it is anticipated that use of the cooling pond will prevent the discharge of substantial amounts of heated  ;

water into the River, its precise degree of effectiveness is unknown at this time." Extensive studies should be made on this aspect of the operation of Midland Units 1 and 2, before con-struction is approved.

i OFFSITE RADIOACTIVE WASTES The report makes absolutely no mention of the procedures ,

and facilities for the handling, storage, and shipment of spent fuel elements. This highly radioactive material must be handled with extreme care, stored for some months in a canal of water or other shielding material to allow the decay of some of the

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11 short-lived radionuclides, and eventually shipped in special-shielded containers for processing at one of the AEC's chemical separations plants. Since this phase represents one of the most potentially hazardous aspects of reactor operation, with the possibility of serious environmental effects if not properly regulated, it is difficult to understand why it has been ignored in the report.

CHEMICAL WASTES More information on the effects of chemicals used for such purposes as condenser cleaning and demineralization of filters is needed. This data should include such considerations as procedures, environmental concentrations and the effects of the chemicals on water quality and aquatic life.

METEOROLOGY l The environmental impact statement cannot be completed l

until technical data on the meteorological aspects of the site are submitted. This additional information is necessary in order l

to determine relative atmospheric dif fusion rates and the dis-position of discharged radioactive gaseous wastes.

No mention is made in the report of problems resulting l .

from steam, fog, humidity, etc. Stress should be placed upon i

ascertaining the effects of excess humidity and fog generated l

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12 by the cooling pond and tower on the residential area directly I to the west of the facility. This study should include possible degradation of property and the impairment of the property value.

WATER SUPPLY The Michigan Water Resources Commission considers the water requirements in the Midland area to have already exceeded the supply. The applicant has not demonstrated in the report that the planned consumptive use of water by the plant would not adversely affect the river environment.

EMERGENCY PLANNING Detailed emergency plans are a necessity, and should consist c f a greater degree of coordination with the Michigan Department of Public Health. The applicant's impact statement fails to clearly show the relationships between the operator and the health department in the event of a catastrophe or other non-routine. release of radioactivity. '

ALTERNATIVES TO THE PRCPOSED ACTION In Section IV, " Alternatives to the Proposed Action", the applicant mentions only four alternatives and summarily, proceeds to discount each without a single hard economic statistic to support the position taken.

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• 13 Some constructive alternatives which should be considered are:

(1) In the summer months the Tittabawassee River may prove to be of insufficient flow to meet the projected demand. There-fore, alternatives should include the possibility of other more suitable sites.

(2) In the impact statement, the applicant maintains.

there is a growing demand for electrical energy and states that there is the alternative of not meeting the demand. The alternative that the applicant fails to investigate is that of a rational program of conservation of electrical energy and I the resulting impact upon the environment.

(3) One of the prime factors in site selection appears to be the resulting sale of process steam to the Dow Company.

The suggestion was made that this would alleviate the necessity for Dow to operate its own steam generation facility. The alternative to this process is, of course, air pollution control-devices for the Dow plant.

In the draft statement a judgment is made about the need for power in this area which does not reflect the fact that there is not a power crisis which this plant must meet but rather a projected power demand in the mid-1970's for which this plant is only one of many possible solutions. There is no thorough l

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14 explanation of why clean fossil fuel plants, imported power, etc. are not better solutions. In addition, there is no dis-cussion of reducing power demand through programs wh'ich dis-courage the waste of electricity. It is not sufficient to assume that the need for power i firm.

The draft statement doas not contain any discussion of the reliability of nuclear power as a source of electricity.

Comparison to nuclear plants where substantial non-operating time has occurred (such as Indian Point No.1) as well as plants, if any, with good records should be made. The discussion should include analysis of the differences between the Midland Units I and other units already in service with special emphasis on -

untried or relatively new features of this plant which will affect reliability. In this regard the interaction between the requirement that radioactive release levels be kept "as low as practicable" and the need to run the plant continuously to meet power demands should be discussed.

The discussion of the plant's ability to meet power needs i

must include a discussion of the realistic completion date for the plant based upon the frequent need for extensions of time as evidenced in other nuclear plant construction. The impact l

of the construction of a steam delivery system (a relatively new system for nuclear pla,nts) should also enter into these M 'S A

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15 construction delay considerations. The impact of CFR Part 50 Section 50.109 (backfitting) should be considered given the fact that several important test programs of the AEC (particularly the LOFT program) are scheduled to be completed before this plant is constructed and may necessitate design changes. See for instance WASH 1146 for a description of these programs.

Finally, inasmuch as the operating license hearing will be the first time at which non-radiological environmental issues can be raised the delay allegedly inherent in the raising of such issues (see 10 CFR Part 50 Appendix D) will delay the date on i

which operation can begin.*

Respectfully submitted, BERLIN, ROISMAN AND KESSLER 1910 N Street, N.W.

Washington, D.C. 20036 Attorneys for the Environmental Defense, Fund, Inc. _

By S N Anthony Z. Ro syan g,

• Most of the comments contained herein were pa ed by Dr.

H. Lewis Batts, Professor of Biology, Kalamazoo College, Kalamazoo, Michigan l June 4, 1971 .

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