ML20050B587

Requests That NRC Reconsider Methodology Utilized in Des

ML20050B587
Person / Time
Site:	Midland
Issue date:	03/31/1982
From:	Hearron T AFFILIATION NOT ASSIGNED
To:	Hernan R Office of Nuclear Reactor Regulation
References
NUDOCS 8204060092
Download: ML20050B587 (1)

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. 4579 S. Washington

. Saginaw MI 48601

1. March 31, 1983 Ronald W, Hernan Licensing Plant Wanager Office of Nuclear Reacor Regulation U.S. Nuclear Regulatory Commission Washington D.C. 20555 Dear Mr. Hernan!

I have read the NRC staff's Draft Environmental Statement on the Midland Nuclear Plant. I am shocked and appalled at the report's questionable methodology, its narrow focus and its minimizing of the enviromental consequences of a nuclear plant in Midland. I make reference to the following areas:

Economics: the report considers only generating costs, ignoring the enormous construction costs which ratepar ra such as I will have to be responsible for. Using such a methodology, one would also conclude that buying a diesel-powered Mercedes is cheaper than buying a Chevette because the Mercedes gets better gas mileage. Further, the report compares the cost of nuclear-generated electricity with that of purchased power--normally the most expensive electricity--while specifically not considering the economics of converting the plant to coal or other fuels.

Finally, the NRC staff apparently accepts Consumers Power's assertion that an excess generating capacity of 23 per cent is necessary. On the other hand, Standard and Poor recently downgraded Consumer's bond rating, precisely because of a fear that Consumers was building too much generating capacity.

Environmental impacts: the report's section on radiological impacts is based on data which is questionable at best and outdated at worst; more recent studies suggest that the present allowable radiation limits are too high to bring about the safety desired. Further, the degradation of water quality in the Tittabawassee River foreseen in the report is quickly glossed ober. However, users of water downstrean from the plant (e.g. , the city of Bay City, Michigan) will be saddled with additional costs for purification, while such costs could stultify the growth and development of new industry. Finally, the findings on effects to watedowl are based on pure speculation, while the section on anticipated fogging from the plant's cobling pond underestimates the seriousness of the matters area school buses and trucks carrying hazardous wastes from Dow Chemical Company will be using the roads affected.

All in all, the report is shoddy and inadequate. I ask, as a concerned citizen living downwind and downstream from the plant, that the NRC reconsider the position presented in the report. To this end, I ask for public hearings in Midland, so that those citizens most directly affected by the plant may more easily participate.

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