ML19331B195
| ML19331B195 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/30/1971 |
| From: | Roisman A BERLIN, ROISMAN, KESSLER & CASHDAN, ENVIRONMENTAL DEFENSE FUND |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8007280781 | |
| Download: ML19331B195 (16) | |
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BEFORE THE UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION
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In the Matter of ) fC '. C '
)' Docket Nos. 50-329 -]
/ Y(ky; CONSUMERS POWER COMPANY ) 50-330 ga (Midland Units 1 and 2) % -> '#j7%4 on ENVIRONMENTAL DEFENSE FUND'S STATEMENT OF SUBJECTS WHICH MUST BE THOROUGHLY EXPLORED AS PART OF AND INCLUDED IN THE
__ APPLICANT AND STAFF ENVIRONMENTAL ANALYSIS Safety Design
- 1. To what extent has safety creditibility been verified by the Staff and the Applicant for each engineered safety system?
- 2. For each such system indicate what part of the system has been experimentally verified, the conditions (i.e. prescure, temperature, etc.) under which the tests were conducted and th,e similitude between those tests and actual pa-*" laced accident conditions. Discuss planned and prepared testing programs which are intended to verify system performance and explain what uncertainties they are intended to eliminate.
- 3. For each such system indicate what part of the system has been mathematically modelled, the assumptions used in the programs, which of those assumptions have been verified by experiments and the similitude of those experiments to actua.1 postulated accident conditions.
- 4. Discuss in detail the basis for the cre'dit given for each of these systems in light of the lack of experimental verification '
or the lack of experimental verification which duplicates
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postulated accident conditions, the conservative assumptions used in determining that credit and the basis for concluding that the assumptions are conservative, the design margins if any built into the system and the basis for concluding that the margin is adequate.
Particularly include in this discussion the compensation for uncertainties in system performance which are the subject of planned proposed experimental verification.
- 5. Discuss to the fullest extent possible the risk associated with operation of the plant at the selected location including the probability of the maximum credible accident and the probable con-sequences of the maximum credible accident if the engineered safety fea,tures should fail.
- 6. Discuss the likelihood of various types of accidents less serious than maximum credible. Enumerate the safety features designed to deal with these accidents and the consequences to health and to the environment of failure of'the safety features, both singly and in combination.
Meteorological Effects ,
'7. What meteorological studies have been conducted with respect to possible fogging from the cooling pond?
- 8. During what time of year is fogging likely to be the greatest and what is the prevailing wind direction, average wind speed and precipitation during that period?
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- 9. What are the effects of fogging on the birds, animals and plants as well as on the materials used in the homes in the area affected by fogging?
- 10. What is the interaction between the existence of fogging and the radioactive gas releases from the plant? Will fog increase or decrease the dosage at and beyond the site boundary?
- 11. What is the likely impact of fogging upon the lives of residents and travelers in the vicinity of the plant? Will the visibility occasionally be impeded sufficiently to cause driving hazards?
- 12. Discuss the fogging and gaseous radiological releases in light of the projected growth of the area near the plant which will be ~affected by these conditions. In particular the dis-tribution and composition of growth over the next 10, 20, 30 and 40 years.
Site
- 13. Explain in detail what factors other than the proximity of the Dow Plant were considered in selecting this over other sites, I
what other sites were considered and upon what basis were they rejected.
- 14. Describe in detail the studies being conducted and to be conducted for determining the present environment of the site and surrounding areas including:
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- a. animal populations including human;
- b. fish and other aquatic organisms, including micro-organisms;
- c. plants both in the water and on land;
- d. insects and birds;
- e. soil composition including percolation tests and the impact on hydrology and the local water table;
- f. geological formations and general topography in-cluding their effect on hydrology and meteorology;
- g. river flow and temperatures throughout the year;
- h. feeding, nesting, mating, spawning and other permanent and semi-permanent animal habitats;
- i. the background radiation in the area and non-background sources of radiation (X-ray machines, dental clinics, hospitals, etc) includihg location of source and quantity and extent of exposure of special population groups such as young children, pregnant mothers, etc.
to the radiation; and .
- j. other sources of pollution in the area including sewage, septic tank and industrial pollutants in the air and water. -
Radioactivity - At the Site
- 15. State the maximum instaneous release and the maximum hourly, daily, monthly and yearly release of radioactivity which ,
the Applicant, guarantees (i.e. will shut down plant if level is excee'ed, d or it is predictable that it will be exceeded) it will not exceed during the normal operation 'of the plant. What methcd of monitoring will be used to fulfill this guaran, tee and how will it operate.
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- 16. Describe the exact radioact'ive nuclides and the amounts of each which make up the total release for the periods stated in the previous questions.
- 17. What will be the doses which will be received to the thyroid of a child whic.h is exposed to the releases during the periods stated in the previous question at the site boundary? What will be the doses to a human fetus in the first trimester from the same releases and for the same stated periods at the site boundary?
- 18. Describe in detail the program for monitoring the presence of radioactivity in the food chain including frequency and location of monitors products monitored, equipment used (includi'ng the level of sensitivity), federal or state' agencies who oversee or conduct this work and the reason for selecting.the particular monitoring program. .
- 19. What program exists for advising the public of the results of this monitoring. Explain why anything less than full public disclosure is proposed.
- 20. Explain how the growing, distribution and consumption habits for food products were taken into account in selecting ,
the monitoring program used.
- 21. What monitoring will exist during and after construction to determine changes in this environmen't? Discuss in detail the equipment to be used, its degree of sensitivity, the location of ,
the equipment, maintenance of the equipment, frequency of recording of data, availability of data for public inspection and action to
, be taken with respect to operation of the plant on the basis of the monitoring including the criteria to be used in taking the action.
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- 22. What controls and monitoring exist with respect to the radiologl,:al contamination of Dow products which are either exposed to normal plant releases in the air and water or are exposed to the process steam from the plant? What criteria are used in monitoring the steam beiore it reaches Dow?
- 23. What are the biological concentration factors for the plants, animals, fish, birds, insects, etc. which will come in contact with the radiological discharges from the plant?
- 24. How is the uptake of radiological discharges from the plant in river sediment and in plants, fish and other organisms in the river effected by river flow and by the discharges of solids from the cooling pond?
Radioactivity - Off-Site
- 25. How much radioactive wastes by weight, total radio activity and radioactive nuclide content will this plant produce each year of operation? If plutonium fuel is to be used at any time, answer this question with respect to that fuel also.
- 26. Describe in detail the route that radioactive wastes will .take from the time they leave the reactor. Inc'lude a discussion of the method of handling the wastes, the. time they will be stored at any given location, the conditions under which they will be stored, the time of storage and the containers in which they will be stored. -
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- 27. Discuss the radiological releases which will occur from these wastes including releases from reprocessing of the waste as well as reletses associated with storage of the wastes.
- 28. Generally describe the environment where the fuel wastes will be reprocessed and where they will be stored.
- 29. Discuss the risk of greater radioactive releases occuring from these wastes during transportation, reprocessing and storage than that assumed in the previous answers. To the extent these matters are fully discussed in other licensing proceedings provide the precise references to the data upon which you rely.
- 30. In general describe the incremental effect dn the environ-ment as well as the incremental e'ffect on the risk of an accident (i.e. the unplanned release of radioactivity) of the shipment, reprocessing and eventual storage of the radiological wastes from this plant during its 40 years of operation.
- 31. Describe contingency plans in the event of major release, including the mode of warnin'g and removing the population, and provision of medical attention if required.
I Fuel
- 32. Describe in detail the effect on the environment of producing the fuel for this plant including the commitment of resources involved, the mine wastes products, the.effect on the health and safety of mine workers and fuel fabri5ators.
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- 33. Describe in detail the projected source of fuel for this plant including its location, method of production and anticipated cost. Explain the basis for each element discussed. For instance, if the LMFBR is an integral part of the future fuel supply explain the basis for your reliance on this source and the time at which fuel would run out or fuel costs would rise if the LMFBR were not available.
34., What studies have been conducted which have assessed the future availability of fuel for this plant and to what extent do they consider future costs, the growing number of reactors needing fuel, the development of LMFBR or other sources of fuel other than mining and the consequences of a failure to obtain. the necessary fuel and when that would occur if developments such as the LMFBR or new, but as yet unproven, uranium sources were ,
not successful?
- 35. Upon what. studies and analyse's do you rely in projecting
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how much fuel and at what cost will be aval1able for this plant?
Thermal Effects
- 36. Discuss the capacity of the Tittabawsee River to absorb ,
thermal and other discharges. To what. degree does the installation of this plant preclude alternative uses of the river, including other power plants, recreational uses, etc'.
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- 37. What studie's have been done on limnology and heat dissipation related to the thermal discharges from this plant?
- 38. Discuss the thermal effects of the discharges from the plant in light of:
- a. low, average and high river flows;
- b. maximum discharge temperatures, quantity to be discharged, temperature and quantity of receiving water;
- c. size of the mixing zone if any to be used and basis for its selection;
- d. rate of heat dissipation; e
- e. circulation of cooling water in the pond; and
- f. temperature statificati'on in the river from the discharges and its effects.
- 39. Compare the pre-plant water qual'ty i to that anticipated after plant operation begins with special emphasis on algae growth and oxygen content and to the effect of these changes upon the .
aquatic life of the river.
- 40. What minimum thermal standards must the plant comply with under Federal or State law? What permits are required and
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from what agencies for the use of the river water or discharges into it? Indicate the current status of obtaining those permits.
- 41. What are the presently projected plans of State or Federal agencies for the use of the river? For instance, is the Anadromous Fish Restoration Program planned for this river or is the river part of any recreational developments in the area? Discuss also -
current uses of the river both by industry and by the general public.
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- 42. Explain in detail the basis for selection of the cooling pond size and design including alternatives considered in both size und design. Discuss the reasons for selection of the pond ovet .31 other cooling methods including cooling towers (wet and
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dry) and once through cooling.
- 43. What is the minimum and maximum quantity of water and temperature of water which will be discharged from the cooling pond to the river?
- 44. How much water will be removed from the river and not returned to it as the result of the operation of the plant? Compare this to the total flow of the river on a month by month basis.
- 45. Describe the flow of water into the pond from the river including rate, quantity, variations in these figures for different seasons and the number of living organisms which will be drawn into the pond from the river.
- 46. Will the pond have to be dredged or cleaned from time to time and if so, describe the frequency of these occurrences, ibe methods to be used and the disposition of the materials taken from the pond. ,
Other Discharges
- 47. Describe in detail the composition of the water to be discharged from the cooling pond including heavy metals, other solids, chemicals, algae, oxygen content, coliform' count, etc. and
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In particular compare the relative concentration of the metals and other solids and chemicals in the intake and discharge.
- 48. Describe in detail the effect on the river of the discharges from the plant and the pond particularly the effect caused by the concentration of materials in the discharges.
- 49. What chemicals and in what quantity are used for cleaning the condenser tubes and demineralizing the filters?
What alternatives exist to the use of these chemicals including mechanical cleaners? For instance compare the proposed use at the Calvert Cliffs Plant of mechanical clea~ners for the condenser tubes.
- 50. Discuss the use of water by the plant upon the water needs of the Midland community. ,
Energency Plans
- 51. Describe in detail the procedures for coping with .
radiological emergencies. Discuss the methods to be used for public warning, the evacuation plans, training and information for State and local officials and the public and anticipated reaction time in the event of an emergency and the basis for that prediction.
- 52. What arrangements have been,or will be made for alternate food and water supplies in the event o'f an emergency? Describe the monitoring procedures to be used and the procedures for advising the public in the event of contamination. -
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- 53. What would be the permanent effect upon the land and water in the area in the event of an emergency which produced offsite radiological releases which were twice as high as the maximum allowed under 10 CFR Part 20?
Transmission Lines
- 54. Describe the route and distance of the transmission lines which will be constructed as a result of the construction and operation of this plant. Include discussion of the tower design and criteria to be used in selecting tower location as well as a description of the areas through which the line wi'11 pass.
- 55. What is the status of your ownership of the necessary rights of way for this line? Describe a'lternate routes and designs for the proposed line including direct current transmi'ssion and underground transmission.
Alternatives
- 56. What studies have been conducted to justify the site selected, the method to be used for generating electricity and the need for the electricity.
- 57. Discuss alternative proposals to providing more electricity.
For instance, public programs to discourage the unnecessary'use of electricity by the general public au3 industry, rate schedules which impose substantially higher charges for elec'tricity use during peak demand periods, rationing of electricity during peak periods, .
etc.
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- 58. Discuss alternative means for providing.the electricity which it is predicted will be needed including bringing in power from Canada or other power systems or ccnverting to more efficient means of transmitting electricity including direct current transmission and undergEound transmission.
- 59. In discussing any alternatives in the previous questions explain the time needed to implement such alternatives compared to the time required to pursue the present plans. Also discuss the permanency of the alternative as a means of solving the problem as compared to the permanency of the present proposal as a solution.
- 60. If the construction permit for this plant is not granted, what specific plans exist for dealing with the alleged needs for
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which the plant is being constructed.
- 61. Describe the extent to which,the plan by Dow Chemical to purchase steam from the plant effects the decision to build the plant and build it at this location.
- 62. What alternatives are available to Dow if the plant is not built including improved fossil plant production of steam and ,
discontinuation of operations in Midland which require steam?
- 63. What are the benefits and detriments of a decision by Dow to discontinue those aspects of its operations in the Midland area which depend upon the production of steam? ,
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- 64. What are the factors other than the presence of steam generation from this plant which influence Dow'n decision to keep its plant in Midland including cost of labor, cost of raw materials, cost of moving, existing plans to move to other locations for
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reasons unrelated to the presence of steam including discontinuing uneconomical and/or outmoded operations?
- 65. What are potential effects on the Midland community of the construction of this plant? Discuss the possible. advantages to the community if both Dow and the plant were located elsewhere and thus the city was relieved of two major sources of pollution.
What effect would this have on the economy of Midland including the possible development of a tourist and recreation industry to replace Dow.
- 66. Describe in detail the basis upon which the projected power needs of the area served by Applicant have been determined.
Do those projections include the possibility of utilizing any techniques to reduae the demand for electricity.
- 67. Discuss in detail the operating experience of comparable sized PWRs and how this effects the reliability of the power to be, generated by this plant. In particular discuss the new systems on this plant and possible outages which might occur as a result of these new systems.
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- 68. What special measures have to be taken for this nuclear plant and for plants of this size to deal with unplanned outages?
Are higher reserves required? Are pumped storage facilities required?
- 69. What are the predicted non-operating days for this plant?
What is the predicted average number of full operating days for this plant?,Upon what facts and studies are both predictions based?
- 70. Describe the criteria to be used in deciding at any given time whether to keep radioactive releases as low as possible or to continue operating the plant in order to meet electric needs.
- 71. What is the proposed schedule for completion of this plant and the obtaining of an operating" license? Discuss the extent to which you have considered the record of delays in construction associated with other nuclear plants and how much time have you allowed for a thorough review of the plant at an operating license hearing.
- 72. To what extent does the completion schedule take account of delays which could be caused by design modifications resulting from yet to be completed tests by the AEC? See for instance, ,
WASH-ll46 and compare the recent modifications in ECCS necessitated by the semi-scale tests.
Documentation
- 73. For each answer or comment provide full documentation and reference to sources, including names of experts consulted whose opinions are utilized in arriving at positions.
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- 74. In addition to further comments which we may have on this subject after seeing the Environmental Report and the Draft Environmental Statement we do stress that the analysis must not only weigh total costs against total benefits with respect to any alternative which requires denial of a construction permit.
As to alternatives which involve possible plant modifications, a cost benefit analysis should be made involving only those costs and benefits associated with the propcsed modification. The cost benefit analysis should be separate from the statement and discussion of the facts upon which that analysis i's based.
Re'spectfully submitted, e
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By $1 L?ovl ] W~
Knthony Z./Roi,sman BERLIN, RQISMAN and KESSLER 1910 N Stree,f, N. W. -
. Washington, D. C. 20036 Counsel for the Environmental Defense Fund l
September 30, 1971 '
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