ML20207M410

Comments on Draft Suppl to Geis.Both GEIS & Suppl Using Obsolescent Views on Alternatives.Shelf Technology for Widley Used Fuel Cells Mfg by United Technologies Can Replace Grid Supplied Energy for Bldgs

ML20207M410
Person / Time
Site:	Calvert Cliffs
Issue date:	03/08/1999
From:	Samuel S AFFILIATION NOT ASSIGNED
To:	Matthews D NRC
References
FRN-64FR11071 64FR11071-00003, 64FR11071-3, NUDOCS 9903190084
Download: ML20207M410 (1)

Text

] _CCElS - comry"nts on drcft supplirnent _ Pag 31ll l

From: "sheldon samuels" <sheljean@olg.com> b b *//

To: OWFN_DO.owf2_po(CCElS) fg'j g ,

g 1 Date:

Subject:

Mon, Mar 8,1999 2:00 PM comments on draft supplement h,@y0q To: David B. Matthews From: S.W.Samuels Ramaniniinstitute Re: Comments on Draft Supplement to GEIS for CCNPP N.B., the following are personal comments and do not reflect the views of the Ramanini institute, which takes no positions on regulatory or legislative issues.

I Alternatives to license renewal '

Both the GEIS and the supplement are using obsolescent views on alternatives. Shelf technology for widely used fuel cells manufactured by United Technologies inter alia, can replace grid supplied energy for buildings throughout BGE market, with grid supplies as back-up. This is a reversal [nonetheless feasible

] of their usual applicatinn. The range of fuel- from LNG to hydrogen - and inherent fuel efficiencies provides a range of altematives each of which has less environmentalimpact than any of the other alternatives discussed.

Waste Disposal Given the continued objections of the states of Nevada and Utah to long or short term storage of waste, the draft is defective in not discussing the impact of on-site alternative disposal. The nationally-distributed costs of waste disposal at Yucca Mountain and so-called short-term disposal sites are not calculated or included.

On 5.2.2.1 BGE Risk Estimates l This is a defective analysis for the following reasons. -

1] while there is little data available, itself a notable item to be included, the effects of aging on the  ;

risks of abnormal operation need documentation. /

2] the averaging over a 50 mile radius is totally inappropriate. Windrose analysis within a ten mile 0 radius, with calculations of the spectrum of impacts on the intra-radial high density, clearly identifiable  !

communities needs to be done. The impacts need to be separated further in each community by age group, especially ages 0 through 12, during which time iodine uptake would be greatest. An estimate must be made of impact on children at home, e.g infants and pre-schoolers.

National Environmental Impact it is not possible to ignore the locally-located nationally distributed impacts of the national burden of ,

continued uranium mining, milling and fuel rod manufacture. I I am disappointed in the failure of the statement to discuss these issues. You may have grounds for  !

dismissing these points, but none exist for not noting or discussing their relevance.

It is not necessary to appear at the hearing to make these points. However, at your invitation, I would be '

willing to elaborate or answer questions in the forum of the hearing .

March 8,1999 l

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