ML20052A722

Comments on Des.Des Is Attempt to Justify Need for & Acceptability of Nuclear Plant by Denying Existence of Significant Safety Concerns.Deficiencies Will Reduce Capability to Operate at Intended Capacity & Safety

ML20052A722
Person / Time
Site:	Midland
Issue date:	04/28/1982
From:	Stamiris B AFFILIATION NOT ASSIGNED
To:	Hernan R Office of Nuclear Reactor Regulation
References
NUDOCS 8204290072
Download: ML20052A722 (8)

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• J 2 4 RESPONSE TO NRC DRAFT ENVIRONMENTA FOR MIDLAND PLANT FROM BARBARA STAMIRIS g cy

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$# ~ s)Tl GENERAL g The NRC's DES for Midland is not only flawed by unc servative data base assumptions, but is an attempt to justify the need for and acceptability of a nuclear plant by denying the existance of signifi-cant safety concerns and by advancing artificial economic analysis.

The unresolved safety issues regarding soil settlement problems and their remediation at this plant are., according to NRC statements in 1981, serious, extensive, and unprecedented..These soils issues set forth in the NRC Dec. 6, 1979 Order, have yet to be resolved by the ASLB hear-ing the case, yet the DES notes the absence of compelling safety concerns arising since the construction permit review.and goes on to say "In the absence of any significant environmental or safety objection, the decision .

is an econom.ic one."

The NRC then sets forth an econom.ic analysis which considers the S3.4 billion construction costs to be not " relevant for consideration now" despite the fact that these costs will become a part of the energy ratebase to the public as soon as the plant operates according to MPSC policy. Only production and operation costs are considered, resulting in a cost savings conclusion.

Although the NRC ignores the capital investment of the Midland plant, it does consider those factors for non nuclear alternatives.

Saying "these alternatives would require significant environmental and .

I capital commitments 'in addition to their cost of operation', it rules Coo 2

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than out by using a double standard.

Unrealistic data base assumptions are apparant in the acceptance of a decommissioning estimate for Midland which represents less than 1%

of its construction costs, in the face of Consumar's 1980 decommissioning request to the MPSC for Big Rock and Palisades which represented 100%

of their original costs. Although inflation accounts for a portion of this difference, the discrepancy remains significant.

These are among the most flagrant examples of the extent to which the NRC feels compelled to go to justify the operation of a nearly. complete facility. Consumers chose to proceed without predetermined acceptance criteria or NRC approval in their soil settlement remediation. Ytt these and other construction practices undertaken supposedly at the Appitcant's own risk, carry no risk at all when " sunk costs" are used in the mannar l

the NRC has here elected, to justify the need for this plant. The denial of the existance of significant safety concerns at this plant is a virtual abdication of NRC regulatory responsibility to the public.

GEOLOGIGAL CONSIDERATIONS

1) The effect of the probable maximum flood (PMF) has not been adecuately accounted for in that the cooling pond dika embankment was l

l not designed and constructed as a Category I structure resulting in l

questionable freeboard allowance, according to NRC testimony in the OM-l OL hearing. The following 4/3/82 newspaper article raises further cuestions about the adequacy of PMF calculations for this plant.

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Da.._, mm..at Sanford~on, id E t ,,.mw,.s. _., , , .

hcizard potential list? .

' From Assestated press below the dams should be aware of the5 AsHf De'ly News staff reports potential damage if the dam does fall, he Six dams ~:In 'ltidland 'and Gladwin said.

counties would create ."high hazard . He also said re'sidents should be aware potential'.' If they faged, according to a that dam failure does not occur only report issued ~by a state environmental during periods of flooding.

essioner.** m+ .e , - - - ,"We've had dams. . just give way," he

! Af'high'* metJoean the dags' - agg; ip j i, leak giatif 4 does W huse ont ne esteestye Ten / Power

' : were Conots miswered Friday

- si aus . et ebe' Wolverine d . Cuestgy at#whisin _eyerales the Sanfbed dam, na j 11 .W: met manager Jim Wesley seg u q

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assir Constaaelmo'la St. Joseph

&ained last wookend when an henkJ.weshed away, but no

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ma=amt Daniereps Causkey sekree ratings'is the ev necessacy.

sert ly. - anym am(low. A' - frigideming!h=== . you don't-

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stel mean if the n It's eemhig." Croskey said'

$q t would . the dams haven't been touched

@ in eqM d D. some damage,$possutlellessminor domes.'*leeP*

Threagh neglect, many of them w interna %. In amost cases, ratlag* 1 4 .-> -hav p# is no feeds for their upkeep."

aosinning pat " ratingd:ars. based c osteC possible ey said  ; .there

. dam owners and' cemetthes r- for' ~ flooding . ope wlR ~ meet.next month with occur lat (the dage , Creekey said. statett officials to discuss maintenance

' Engineers h echted trhat property 'and safety programs. He said the state, or persans Eiul&Waffected below the servey was part of a nationawide safety dam. - , . .t ~c heck authorized by Congress after a The report dewast,mean residents 1977 dam failurain Georgia caused a 30 should expect the dams to fail, Croskey foot-high wall otwater toldt dormitories saki. It does mean that residents living of a small college, killing e people.

2) Artesian water pressure, and its relationship to the under-lying acuifers discussed in Appendix D to the 1970 SER, has not been addressed and resolved as a possible source of groundwater problems.

(8/12/81 transcript p4293, OM-OL proceeding)

3) "The Water Resources Commission, State of Michigan (1960) has stated that the water recuirements in the Midland area for cooling, processing, and waste assimilation have already exceeded the supply",

according to Appendix D of the 1970 SER, yet the DES f ail's to consider

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this finding and in fact accepts the elimination of the additional cooling capacity offered by the original cooling tower design.

4)The cause and effects of the unusual corrosion of stainless steel safety piping identified in 1979 near the BWST has not been resolved .

5) The effect. of possible contaminants from seepage from the Dow pond have not been adecuately analyzed in relation to corrosion or other synergestic effects with radioactive emmissions from the nuclear plant.

MITIGATION OF ACCIDENT CONSECUENCES Section 5.9.4.4 of the DES credits Midland with possessing stan- i dard Engineered safety Features designed to mitigate accident consequences, however these specific safety feature 3 are not analyzed as they exist at Midland.

The discussion of design features notes the passive. mitigating capacity of the " steel lined, pre-stressed post-tensioned" concrete con-tainment structure.

There is a bulge in the steel liner plate of Unit II (55e 74-01, i

77-01). Structural reinforcing bars and Shear reinforcement were found {

f lacking in the containment in 1975 and 1981 respectively (55e 81-05).

Tendon sheath ommissions occurred in 1977 and in 1979, containment post- I tensioning errors occurred ( I&E 79-19).

The component cooling water system, the next safety feature dis-cussed, was found defective in 1980(55s 80-06) as was the reactor cavity cooling system.In 1981(55e 81- 06) .

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Lastly the DES states,."all the mechanical systems mentioned above

.are supplied with emergency power from.onsite diessi generators". The integrity of the diesel generator system itself is a major unresolved safety question of the ongoing soil settlement proceeding.

In addition to these deficiencies, the reactor pressure vessel anchor bolts have cracked and f ailed requiring extensive permanent design modifications (55e 79-10) . During the investigation of this problem B&W requested confinnation of the Bechtel design input and discovered that the Bechtel NSSS Seismic-LOCA Analysis was defective (55e 80-07 #4)

Errors were also found in Bechtels design input for the reactor building internal wall models which remain unresolved final 55e report (80-07 #5).

On top of these site specific problems with the reactor contain-mant,.the Unit I B&W reactor has been identified as one of 12 manufactured with a defectively high copper content in the welding making it sensitive to overcooling and embrittlement problems. Add to that the generic B&W  ;

system sensitivity and TMI problems,.and the combined effect is overwhelm-ing. Yet the NRC does not systematically address the combined and inter-related effect of these weaknesses. \

The second section on Accident Mitigation in the DES concerns Midland site characteristics. This site was considered marginal even by 1969 standards according to the ACRS on 2/6/69 because of the Dow popu-lation within the exclusion zone anc part of the city of Midland within the low population zone. According to this report"the site received a

-34 index rating when compared to the hypothetical reference site".

The DES st1tes that "although a portion of the city is within the 1-1/3 mile (limit), it consists almost entirely of the Dow Chemical Property."

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The NRC interprets CFR100 population distance requ.trements to be based on the " population center distance" thereby justifying the location.

The 1969 Foundation Investigation Report by the Applicant notes that the reactor site had to be relocated twice "because of subsurf ace conditions encountered" before returning to the original location.

Located on a floodplain which had to be built up with up to 35 feet of fill soils, it is apparant that the controlling factor in the location of the Midland plant was the need to be near the Dow complex to provide It with process steam. Despite the Applicant's failure to meet the compensatory design requirements regarding removal of loose surface sands, fill soil procedures,.and ground water analysis.for this site. which.bave resulted inithe sitswide soll settlement problems facing us today, the NRC continues to defend and Justify the construction of this plant.

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NEPA CONSIDERATIONS NEPA requires that a federal agency make a " good faith" effort to predict reasonably forseeable environmental 12 pacts af ter taking a hard look at potential impacts. (PSC of Oklahoma, LBP78-26, 8NRC 102,141)

It also recuires that the NRC give " considerable weight to action taken by another competent and responsible governmental authority in enforging i an environmental statute". (Ibid p281,282) The DES does not represent a good faith effort to take a hard look at environmental impacts likely from.this plant. H'pefully o before it final Environmental Impact Statement the NRC will take a hard look at the studies by the Michigan Attorney Ge neral indicating that the Midland plant is neither necessary or cost f affective compared to environmentally safer alternatives and at the.

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recent criticisms of the Michigan Environmental Review Board to the DES.

The overall effect of the safety and environmental deficiencies at the Midland Plant will reduce its capability to operate at its intended capacity at the least,,and threaten the health and safety of the public at the worst. The analysis performed by the NRC in its DES falls far short of NEPA and Atomic Energy Act mandates it is required to uphold in the public interest.

Respectfully Submitted Barbara Stantris 5797 PT. River Freeland, Mich. 48623

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