ML19338C030

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Comments on 691229 Psar,Vol 6
ML19338C030
Person / Time
Site: Midland
Issue date: 02/04/1970
From:
COMMERCE, DEPT. OF
To:
Shared Package
ML19338C029 List:
References
NUDOCS 8007310591
Download: ML19338C030 (2)


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-Midland Plant Units 1 cnd 2 Consumers Pows.r Company-Prelim 4-y Safety Analysis Reprt Amendment No. 6 dated December 29, '.969 Prepared by Air Resources Environmental Laboratory Envirormental Science Services Administration February 4, 1970 We do not' necessarily gree with' the statement in AmeM=nt 6 that the.use of the Dow Chemical Building 47 wind data would be

" conservatively representative of the site meteorology". As described in the PSAR, the wind system is on' top of a 30-ft mast on the western edge of the flat roof of a 3-story building. Total height above the ground is 60 feet. The area from the northwest through northeast to the southeast is an entirely built-up urban area either of the city of Midland or the Dow Building complex itself. Also to the west and south, at least for-a distance of-several thousand feet to the Tittabawassee River, the area is within the Dow Building complex.

The site is essentially undeveloped marshland for 1500 feet in all directions and for many miles to the southwest, south and east the terrain is rural. The critical exclusion distance of 1500 feet is towards the north since the site boundary to the south is at least 1 mile. Thus, a ground release-in the critical direction (to the north) would be carried by air having a ru.'t.1 bajectory. In contrast,-

the Dow data is taken 60 feet above the ground and presumably is affected by the turbulence generated by the rough and heated urban environment.-

In addition to the reservations stated by the applicant-with regard to the use of Dow data (see p. 2A-32, PSAR) and those' reservations as stated'in our comments'of Feb. 3, 1969, we feel that a surface (10 meter height) measurcment of wind over th'e marshy terrain of the site would be considerably 'more appropriate for site evaluation than the Dow Building 47 data.

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