ML20050C213
| ML20050C213 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/04/1982 |
| From: | Savage A AFFILIATION NOT ASSIGNED |
| To: | Hernan R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0537, RTR-NUREG-537 NUDOCS 8204080292 | |
| Download: ML20050C213 (3) | |
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,030' Midland J4I'48690 SD Apri 1 Vl982J 91 Ronald W. Hernan j
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Office of Nuclear Reactor Regulation r
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NUREG-053 h-J0*
dockets 50-32
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Dear Sir Draft Environme y(
t Consumers Power Co.
Midland, Michigan In a time of high unemployment and depression, it is highly inapprop-riate that gover.nment funds should have been spent to prepare this re$rt. Instead, it should have been prepared by CPCo at its own ekphnse. The report itself is prepared to tr anquili7e the u4 suspecting v
public. Unmeaningful terms of reference are used, invalid assumptions are ma.de, risks are diluted by excessive areas, and certain problems have been ignored.
T estimated capital cost of the project is now $3 44 billion, a s
endous and u njustified overrun. And yet more expenditure will o
b required. Over 30 years, by linear calculation, the capital cost is 0113,111,111 per year. Similarly, interest at 10% on the capital cost is $340,000,000 per year. False costs are given in sec. 2.1. In reality, for the two significant years:
1984 1988 Interest, at 1% /yr.
340,000,000
$340,000,000 Tayes/yr./yr.
Principal 113,111,111 113,111,111 121,700,000 121,700,000 Fue l + 0 & M
/yr.
135,000,000 179,000,000 decommission, once,/yr.
261,000 267.000 Total cost / year
$ 710,074,111
$754,074,111 The report blandly 16,nores all costs except takes + 0 & M!
These other costs will be paid by the ratepayers and stockholders. The report assumes a savings in fuel cost to the company, but this comes out of the ratepayer's hide.
Alleged replacement energy C267,000.000
$466,000,000 fuel + 0 & M 135,000,000 287.000.000~
alleged savings
$132,000,000
$287,000,000 These figures are meaningless. They are but part of the cost to the hapless ratepayer. Using figures of mills /kw from tho' same table, we Mnd the costs to be:
710 xP1/135= 111 mills /kw 754x28/179=117 mills /kw The power-will cost in 1984 111x100/21=5 3 117 7100/28=4.15 ti pos the costs from table 2.2. Steam costs will be proportionate.
s The steam cost to Dow is excessive, and the ratepayer and stockholder cannot be expected to subsidi 2Le this to the extent of the difference between these figures and those in 2.2. I recall that when the plant was proposed that the projected steam cost was six times that then in effect in the Dow Co.
A factor not touched upon in the statement is the demonstrated unrel-iability of stainless steel heat exchanger and condenser tubes. This cop 1 is obvious in plants all over the_ country.This causes environmental y
risk duce to leakage and adds to plant unreliability. The CPCo.
Palisades plant _is a case in point.
- O Stainless steel properly heat treated and of suitable composition has some corrosion resistance, but under conditions of high temp-erature, high velocity and in the presence of gases the passive film is eroded and intercrystalline corrosi on occurs. The passivity cannot
~1nt restored if the steel is pitted. While I do not have direct inform-8204080292 B20404 PDR ADOCK 05000329
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April 14, p.2-j iiUhEG-0537 mation on very high temperature corrosiq,n tests, tantalum, Durichlor, Durimei, Hastelloy and DuriFon are much more suitable materials. As repeated replacement may be necessary anyway, a steel clad on both sides with high chromium-nickel alloy containing some copper might be usable.There is also probability of corrosion of tube sheets and baffles. These certainly should be of the same material as the clad-ding, and in no circumstances should dissimilar metals touch. Any electrolysis must be avoided.
Thepracticeofinsertingasmallertubewitktn a corroded tube reduces heat transfer surface and 1,ncreases liquimd velocity. It should not be permitted.
Indeed no further installation or startup of nuclear facilities should be permitted until this problem is resolved.
The Michigan State Department of Natural Resources has recently reported a "high danger" of failure of the upstream dams on the Tittibawassee river at Sanford andBeaverton. Such failu,re cf earthen da#b could result in sudden flooding with damage to installations and leave the unit with inadequate cooling water.
o Hydrazine is to be used as a scavenger. It decomposes at 329 F. into ammonia and nitregen with explosive violence. Hydrazine sulfate also decomposes explosiovely at 482 F into gas and sulfur. Hydrazine like 3
ammonia, is flammable. It boils at 235 F and freezes at 0 C (32 F.)
It is toxic and carcinogenic.
The hagards due to icing and fogging caused by the cooling pond are grossly underestimated. Not only nearby roads but the entire city are likely to be covered by fog and smog, which will concentrate toxic contaminants.
As to highway safety within the immediate area CPCo should be regired to provide fog-dispersing devices, suchg as the propellors along the New Jersey Turnpike, at dangerous intersections, and to see to it that the roads affected are kept salted and sanded, and otherwise maintained.
The data in Table 4.2, compared with monthly high and low atmospheric temperatures, on the basis of hu midity indicate that throughout the year, during the day, the volume of fog generated by moisture outfall
- will be relatively constant, and that quantities at night during January through March and in November will be in much the sane range. In April the volume will increase 25% at night, in May, Sept-ember and October 50%, and in July through August, 130%. This means that in January through March and in November and December severe
- icing conditions may be expected day and night in a relatively constant area around the pond. In April and October and i.n part of May and September, severe icing may arise over a 25-50% greater area, if the height of the fog remains the same, and in the warmer months severe fog will extend-over a much greater area, perhaps the entire city, at night. Hazard due to toxic and radioactive materials born in the fog will be much greater during the warm months of the year, when more people are outside and windows are open.
There is danger of polution.of the municipal ~ water supply.
L 3
m.
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kpril 14, page 7 NUREG-0537 i
The.use of pop-valves, which do not generally reseat properly, for pressure : relief is a hazard. Prangible safeties in parallel should be required.
Insistance'on nuclear energy ignores the high rate of lung cancer am6ng uranium miners, such as the Indians in New Mexico.
.The greater hazards are duasto an accident, resulting in direct Fradiation and loss of water-soluble isotopes..The effect of lead time, age, sex and exposure to low doses remains unknown.
By' calculating risk over a large(50 km radius) area the specific threat to the residents of Midland is soft-pedeled. The use of such terms as person-rems over a large area dilutes the hazard. The danger is to the residents of Midland and their property. The Price-Anderson act with low values excludes them from any chance of compensation in case of an accident. and insurance cannot be obtained. The ratepayers not only bear the burden of excessive costs at the beginning, but in j
case of accident will be without compensation.
Cntaminati on of the aquifers in case of an accident could endanger also the cities of Bay City and Saginaw, and the great lakes.
I urge. consideration of all these factors.
Sincerely, C L 73,S e o
A,B Savage
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