ML20042C132
| ML20042C132 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/23/1982 |
| From: | Thibodeau W AFFILIATION NOT ASSIGNED |
| To: | Hernan R NRC |
| References | |
| RTR-NUREG-0586, RTR-NUREG-586 NUDOCS 8203300244 | |
| Download: ML20042C132 (1) | |
Text
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h st s March 23, 1982 k'
J Mr. Honald W. Hernan
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Liscensing Plant Manager 6
wegD Office of Nuclear Heactor Regulation 2
Q g083 Jggg U.S. Nuclear xegulatory commission gk washington, D.C.
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Dear Mr. Hernan,
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v i am writing to question the contents of Section 511, "D %ia ioning", of the NRC's Freliminary Draf t Heport on the Environmental Impact of the Midland (Michigan) Plant.
The statement, "The technology for decommissioning nuclear facilities is well in hand and, although technical improvements in decommissioning techniques are to be expected, at the present time decommissioning can be performed safely and at re-seasonable cost...", is a particularly bothercome comment.
what principles of syllogistic reasoning and scientific analysis were used in determining the cost of decommissioning this facility as " reasonable" 7 Is the public, and especially the Consumers Power ratepayer, to assume onat the cost of decommissioning equal to, and in all likelihood, in far excess of the original construction costs, is " reasonable" ?
Is the reviewer of the Preliminary Draf t Report expected to endorse the assumption that "...pecommissioning costs for reactors are a small f raction o f the present-worth commissioning costs..." after being referred to NUREG-0586, " Draft ueneric Environmental' Impact S tatement on Decommiss-ioning of Nuclear Facilities", which indicates that the Elk River, Minn-esota plant cost 5.2 million more that the original construction cost of 56 million?
Using the formula suggested in NUREG-0586, one can easily estimate an approximate cost of decomissioning the Midland nuclear facility as well beyond 44 billiont construction costs to date are 83.39 billion and will undoubtedly exceed 54 billion by the time the plant goes on line in 1983 or 1984 Did the NRC factor in the impact of inflation in their estimate? Was the fact that the Midland plant is much larger that the Elk River facility and therefore will require greater decommiss-ioning costs, included in the analysis? If so, how is it possible the hRC could re fer to these exhorbitant costs as " reasonable" 7 as an agency of the U.S. Federal Government, the NRC is responsibic to ' the American people for any evidence of environmental impact Ghat may cause physical or economic nurm.wnen considering the liscensing of a nuclear power plant.
It appears those who prepared the preliminary environmental impact draf t for the Midland nuclear facility nave failed to carry out this charge.
Sincerely, gga s.dNahw coo 1 WILLI AM A. THIBODEAU 3245-weigl Road
/O Saginaw, Michigan 8203300244 820323 PDR ADOCK 05000 D
1 William A. Thibodeau f'*k d' I.'7
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5 Mr. Ronald W. Hernan Licensing Plant Manager Office of Nuclear Reactor Regulation
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U.S. Nuclear Regulator Commission Washington, D.C.
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