ML20050D343
| ML20050D343 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/01/1982 |
| From: | Walker B MICHIGAN, STATE OF |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0537, RTR-NUREG-537 NUDOCS 8204120137 | |
| Download: ML20050D343 (3) | |
Text
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STATE OF MICHIGAN WILLIAM G. MILLlKEN, Governor DEPARTMENT OF PUBLIC HEALTH m
3500 N. LOGAN f
P.O. BOX 30035. LANSING. MICHIGAN 48909 Bailus Walker, Jr., Ph.D., M.P.H.
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U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Director Division of Licensing Gentlemen:
We have received and reviewed the Draft Environmental Statement Related to the Operation of the Midland Plant, Units 1 and 2 (DES), NUREG-0537, published in February 1982.
It is our understanding that safety issues, particularly the radwaste system and the plant emergency response plan will be addressed in the U. S. Nuclear Regulatory Conunission Safety Evaluation Report (SER), scheduled for completion in May 1982, and we will review those aspects of the plant when the SER is received.
Coninents on the DES are noted below:
1.
Soil Stability - Apparently due to inadequate soil preparation, a building and some structures have experienced gross settling and some cracking of structural parts. The plant has been working with the NRC for several years on a solution which combines repair, additional support, and a soil dewatering system. This problem should be addressed in the Final Environmental Statement, along with the impacts of the corrective actions on the environment.
2.
Cogeneration - The plant abuts the Dow Chemical Company property so that steam produced at the Midland Plant can be piped to Dow for processing needs, thereby allowing the retirement of an old, air-polluting coal-fired steam plant. The Midland Plant will have pressurized water reactors, in which the primary water which contacts the fuel is used to produce steam in another, separate secondary system for the production of electricity in turbine-generators. Although the primary and secondary systems are separate, there is normally some leakage between the two.
Therefore another, tertiary, system is to be used to produce steam for Dow. This tertiary system will use steam from the secondary coo 7 G5
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U. S. Nuclear Regulatory Commission April 1, 1982 Page 2 4
system as the heat source.
Since Dow produces aspirin and other chemical products which are consumed by the public, it is imperative t
that the tertiary system not be contaminated with radioactive materials. The plant plans an extensive continuous monitoring and control program for the Dow steam, but because of the inherently gross nature of the continuous monitoring system as compared with a laboratory analysis, a continuous sampling system should be installed so that sensitive analyses can be run on continuously composited samples. The Michigan Department of Public Health is also interested in analyzing such samples on a continuing basis.
3.
Plant Siting and Plant Emergency Plan - According to the DES the NRC review of the plant emergency plan will be part of the SER.
Coordination of the plan with State and county plans is the responsibility of the Department of State Police under Act 390 (1976).
However, the Department of Public Health has identified some siting / emergency problems that are unique with the Midland Plant. The plant is located within the Midland city limits and directly across the Tittabawassee River from the Dow Chemical Company.
In fact, a portion of the Dow property is within the exclusion area.
In the event of a major catastrophe with unfavor-able meteorological conditions, there could be a choice of (1) evacuation of the entire Dow property with loss of equipment and, possibly, with loss of control of plant processes that could be dangerous, or (2) evacuation of all Dow personnel except those essential for a safe shutdown.
In the latter case radiation exposures could be excessive. Dow has pledged to evacuate upon i
word from the Plant or the State, but has stated that some Dow processes require attendance for a safe shutdown, preventing a complete evacuation for hours after the order.
In fact Dew has indicated that persons (primarily from plant security) will be required even 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the initiation of evacuation.
1 Although Dow has had an evacuation plan for years, it is being revised especially for a nuclear catastrophe. We are concerned that these persons be protected from excessive radiation exposure.
Also, the DES indicates that Midland Plant sewage will be sent to Dow for processing. The processing system is directly across from the reactors, and some of the processing area is within the exclusion zone of the Midland Plant. During an incident with unfavorable meteorological conditions, maintenance of the sewage system could only be performed by traveling directly into the radioactive plume from the Reactors, less than 1/3 mile away.
We believe that this sewage system should not be used during a major Midland Plant emergency, unless it can be accomplished with no maintenance.
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o U. S. Nuclear Regulatory Commission April 1, 1982 Page 3 The DES indicates a potential problem with fogging and icing that may have more severe consequences than those contemplated in the plant Environmental Report. We are particularly concerned about the effect of such conditions as they might affect an evacuation or the travel of emergency personnel in the event of a major catastrophe, and this problem should be fully addressed by the applicant and the NRC.
4.
Dose Assessment - The DES cannot stand alone for adequate review of the risk assessment, since there are too many references to the NRC risk assessment document and the BEIR III report. The extrapolation model used is not the most conservative model available; however, the authors do claim that cancer and genetic problems for the population are comparable to those calculated in the BEIR III report, which uses a generally accepted extra-polation model.
Although the authors claim that " worst case" assumptions for exposure were employed, there were several areas where average or " realistic" doses and meteorology were used. No possible or projected levels of exposure are given for accidents. Also, the authors assume the safety systems will work and prevent worker and general public exposure.
In particular, all calculations assume that the primary containment will be completely functional, leaking only at the regulatory leakage rate, in spite of the fact that the containment could be breeched and numerous valve leakage problems have been experienced by operating plants.
Thank you for the opportunity for comment.
Sinchrely, l
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Bailus Walker, Jr., Ph.D., M.P.H.
Director
MICHIGAN DEPARTMENT OF PUBUC HEALTH 3500 N. LOGAN. P. O. BOX 30035 j.
LANSING. MI 48909
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~.1 1,sy u U. S. NRC Washington, D.C.
20555 Attn:
Director, Division of Licensing
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