ML20062K080
| ML20062K080 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/31/1982 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-0537, NUREG-0537-02, NUREG-537, NUREG-537-2, NUDOCS 8208170006 | |
| Download: ML20062K080 (480) | |
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.I ADDENDUM TO SAFETY ANALYSIS REPORT FOR THE HN-100 SERIES 3A RADWASTE SHIPPING CASK !
I l Docket. Number 71-9151
\
l Referencing !
l 10 CFR 71 Type "A" Packaging Regulations i
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STD-R-02-004 E Hittman Nuclear 5 Development Corporation g Columbia, Maryland 21045 l_
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1 j 8208170053 820727 j PDR ADOCK 07109151 C PDR I
t _ __ _ _ __ _____._ _ _ _____ ____-.__ _______ _ _ .._.______._ _ __ _ ___.--_._ _ _ ____...._ _ _ _ _ _ ___
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! ADDENDUM TO l SAFETY ANALYSIS REPORT j FOR THE i j , HN-100 SERIES 3A RADWASTE SilIPPING CASK 1
i i Docket Number 71-9151 ,
l 1
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l Referencing
)5 10 CFR 71 Type "A" Packaging Regulations l
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IIl STD-R-02-004 i
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i liittman gggg,& ggg}gggeng3ggporation l l
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'I Document Number: Rev: Rev Date:
HITTMAN NUCLEAR & STD-R-02-004 0 1-13-82 DEVELO PMENT CORPORATION
Title:
ADDENDUM TO SAFETY ANALYSIS REPORT FOR THE HN-100 SERIES 3A RADWASTE SHIPPING CASK Supervisor Prepared Directo r Trans- QA R;;v. Rev Date by Engineering portation Manager Dr ft n 0 7-13-82 B M .yf /I' .-
-323 lI lI i
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I HNDC-Ol(A) Page of
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PROPRIETARY DATA I
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I NOTICE
' I This Safety Analysis Report and the associated drawings are the property of Hittman Nuclear & Development Corporation, I Columbia, Maryland. This material is being made avai1able for the purpose of obtaining required certifications by the U. S. Nuclear Regulatory Commission, enabling utilities and I other firms producing radioactive waste to be registered users of equipment and services supplied by Hittman Nuclear
& Development Corporation, and enabling equipment to be manufactured on behalf of and under contracts with Hittman Nuclear & Development Corporation. Parties who may come into possession of this material are cautioned that the information is PROPRIETARY to the interests of Hittman I Nuclear & Development Corporation, is not to be reproduced from this report and the associated drawings, or facsimiles made of these drawings without the express written consent of the Hittman Nuclear & Development Corporation.
I I
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I PROPRIETARY DATA 1.0 PURPOSE AND BACKGROUND The purpose of this suppliment is to provide the information and engineer-
. ing analyses to demonstrate that the HNDC HN-100 Series 2 radwaste shipping casks (Certificate of Compliance 71-9079) can be upgraded to meet the per-formance capabilities and structural integrity of the HN-100 Series 3 Rad-waste Shipping Cask (Docket 71-9151). The HN-100 Series 2 cask when modi-I fied will be designated as HN-100 Series 3A casks and will be operated under the same Certificate of Compliance as the HN-100 Series 3 casks.
The HN-100 Series 3A casks (formerly HN-100 Series 2) were fabricated in I 1976 and 1979. The designation for the individual units are as follows:
Unit Designation Year of Fabrication
.g
'E HN-100-6 1976 HN-100-7 1976 3 HN-100-8 1979 g HN-100-9 1979 HN-100-10 1979 HN-100-11 1979 The casks are constructed primarily of A36 carbon steel.
I
2.0 DESCRIPTION
The HN-100 Series 3A Shipping Cask is a top-loading, shielded container de-signed specifically for the safe transport of Type "A" quantities and I greater than Type "A" LSA radioactive waste materials between nuclear facilities and waste disposal sites. The radioactive materials can be packaged in a variety of different type disposable containers. Typical configurations for the internals and their model designations are as fol-lows:
Model Number Cask Internals HN-100/170 One large disposable container HN-100/2-80 Two large stackable liners HN-100/18 Eighteen 30 gallon drums HN-100/14 Fourteen 55 gallon drums HN-100/8 Eight 55 gallon drums The HN-100 Series 3A Shipping Cask is a primary containment vessel for radioactive materials. It consists of a cask body, cask lid, and a shield plug being basically a top-opening right circular cylinder which is on its vertical axis. Its principal dimensions are 81-3/4 inches outside by 81-1/2 inches high with internal cavity of 75-1/2 inches inside diameter by I 73-3/8 inches high.
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PROPRIETARY DATA I
2.1 Cask Body The cask body is a steel-lead-steel annulus in the form of a vertical oriented, right circular cylinder closed on the bottom end. The side walls consist of a 3/8 inch inner steel shell, a 1-3/4 inch thick con- E centric lead cylinder, and a 7/8 inch thick outer steel shell.
g The bottom is four inches thick (two 2 inch thick steel plates welded together) and is welded integrally to both the internal and external steel body cylinders. The steel shells are further connected by velding to a concentric top flange designed to receive a gasket type seal. Positive cask closure is provided by the gasket seal and the required lid hold-down ratchet binders. Four lifting lugs are welded to the outer steel shell. A plugged drain in the base and a stainless steel cavity sleeve are optionally provided.
2.2 Cask Lid The cask lid is four inches th ck (two 2 inch thick steel plates l welded together) which is stepped to mate with the upper flange of the E cask body and its closure seal. Three steel lug lifting devices are welded to the cask lid for handling. The cask lid also contains a
" shield plug" at its center.
2.3 Shield Plug The shield plug is five inches thick (two 2 inch thick steel plates and one 1 inch thick steel plate welded together) fabricated in a design similar to the cask lid. It has a gasket seal and uses eight hold-down bolts to provide positive cask closure. The shield plug g
5 also has a lifting device located at its center to facilitate han-dling.
2.4 Cask Closure The shipping cask has two closure systems: (1) the cask lid is closed with eight high-strength ratchet binders and a gasket seal, (2) the shield plug is closed with eight 3/4 inch bolts and the same seal system used for the cask lid but smaller.
2.5 Cask Tiedown System The shipping cask tiedown system consists of two sets of crossed tiedown cables (totaling 4). Four shear blocks or a shear ring (af-fixed to the vehicle load bed) firmly position and safely hold the cask during transport.
2.6 Cask Internals The internals of the llN-100 shipping cask can be any one of an exten-sive variety of configurations. Some examples are given in terms of weight in 2.7. Other arrangements are possible, providing the gross weight and the decay heat rate limits are observed, and the material f
PROPRIETARY DATA I secured against movement relative to the cask with an internal struc-tural members such as bottoms and pallets. liasically, the internals consist of the waste, contained if process waste is being transported, l and the structures used to fix the waste relative to the cask. The
! container may be constructed of high integrity plastics, steel or other metals. Shoring is used with small secondary container to prevent movement during normal conditions of transport.. Shoring is not required for containers and pallets designed to fit the cavity.
2.7 Gross Package Weights The respective gross weights of the cask components and its designated
! radwaste loads are as follows:
l Cask body 27,897 pounds Closure lid 5,537 pounds Shield plug 366 pounds i
Total cask (unloaded) 33,800 pounds l HN-100 - Large container (s) and waste 19,205 pounds HN-100 - 55 gallon size containers (up to 14 18,800 pounds drums of radioactive waste)
I HN-100 - 30 gallon size con-tainers (up to 18 drums of radioactive waste) 8,100 pounds 2.8 Radwaste Package Contents l
l 2.8.1 Type and Form of Material l
The contents of the various internal containers can be l
process solids in the form of spent ion exchange resins, filter exchange media, evaporator concentrates, and spent filter cartridges. Materials will be either dewatered, solid, or solidified.
2.8.2 Maximum Quantity of Material Per Package Type A materials and greater than Type A quantities of low j specific activity radioactive materials in secondary con-tainers with weights not exceeding 19,205 pounds. Radio-l l active materials may include source and transuranic ma-terials in Type A quantities or greater than Type A quan-tities of low specific activity materials. The contents may also include exempt quantities of fissile material as de-fined in 10 CFR 71.9.
3.0 DESIGN CONDITIONS 3.1 General Standards (Reference 10 CFR 71 Section 71.31) llu&%V
PROPRIETARY DATA I
3.1.1 Chemical Corrosion _
The cask is constructed from heavy structural steel plates.
All exterior surfaces are primed and painted with high quality epoxy. There will be no galvanic, chemical, or
- other reaction among the packaging components.
3.1.2 Positive Closure System As noted, the primary lid is secured by means of eight high strength ratchet binders. The secondary lid is affixed with eight 3/4 inch diameter bolts. Therefore, the package is equipped with a positive closure system that will prevent inadvertant opening.
3.1.3 Design Criteria on which Structural Analysis is Based 3.1.3.1 Stresses in material due to pure tension are com-pared to the minimum yield of that material. The safety factor is found by dividing the minimum yield by the calculated stress. A safety factor greater than 1.0 is required for acceptability.
Material used is A36 with f of 36,000 psi, A516 Gr 70 with f of38,000 psi {andA311 Grade 1137 with fyof8E,000 psi. =
g 3.1.3.2 Stresses in material due to shearing is analyzed using the " Maximum Energy - Distortion Theory" which states the shearing elastic limit is 1/J3 =
57.7% of the tensile elastic limit.1 As with 3.1.3.1, a factor of safety greater than 1.0 is required for acceptability.
3.1.3.3 Weld filler material rod is E70 Grade or better.
Analysis is based on American Welding Society Structural Code Dl.1-79. For fillet welds, shear stress on effective throat regardless of direction of loading is 30% of specified minimum tensile strength of weld metal. For complete joint pene-tration groove welds with tension normal to the l effective area the allowable stress is the same as the base metal.
Fillet weld allowable stress = (70,000 psi)(0.3)
= 21,000 psi l
In order to be more conservative, a weld ef-I ficiency of 85% is also added.
I Design and Behavior of Steel Structures, Salmon & Johnson, page 47.
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1 PROPRIETARY DATA j
3.1.4 Lifting Devices 3.1.4.1 Package Weight I The package weights used for analysis are as follows:
I Empty package Payload: large container and waste 33,800 lbs 19,205 lbs Gross Weight 53,005 lbs 3.1.4.2 Cask Lifting Lugs
, Material A-516 Grade 70 with a minimum of 38 KSI Tension Yield Strength. 21,926 psi shear yield strength (57.7% of 38,000 psi).
There are two types of lifts that the cask may undergo. The cask will be designed for a 3 g lift for either case. The first is a vertical lift using a 2 point lift beam. The second case is a 4 point lift at a 45 sling angle. At no time will f
the cask be lifted by a 2 point /45 sling angle.
2 point / vertical lift (53,005 lb)(3 g)/(2 lugs) = 79,510 lb.
4 point /45 sling angle
- (53,005 lb)(3g)/(4 lugs)(sin 45 ) = 56,220 lb For the lug, the two point vertical lift is worst
- case.
Tear-out 2" thick a = (79,510 lb)/(2)(2)(3.25-1.25) n o = 9,938 psi S.F. = 21,926/9,938 = 2.2
- 3("
[ f Bearing 2"Dia. o = 79,510 lb/(2)(2.5) = 15,902 psi
_ 3-1/4".m 2-3/4": S.F. = (38,000)(.9)/15,902 = 2.15 I
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PROPRIETARY DATA !
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Tension (79,510 lb)/(2)(6-2.5) = 11,358 psi F.S. = 38,000/11,358 = 3.35 2" thick 3.1.4.3 Cask Lifting _ Lug Welds (Worst Case) 79,510 lb f Pure shear - (3/4" groove weld) a ;
- Total weld length = 28 inches t o = (79,510 lb)/(28)(.75)(.85) 2 -
. -3/4"_ ,
ga s o = 4,454 psi 3/4" groove % tioment -
weld g- - --' floment = (79,510 lb)(2.75 in) = 218,652 in-lb
~ ~
l 3 -
' Centroid of weld = (10)(11)10++(7)(12.5) 7 + 9 + 6
+ (9)(4.5) + (6)(3) l -
p 7, a. y = 8 inches 8" 218,652 in-lb = 20 [(1/2)2(1/2)(2)(2/3)+(5-1/2)2(1/2) E (2/3)(2)+(2)(8)] (.85)(.75) 5 5" c = 4,720 psi
, Total o = J(4,454)Z + (4,720)2 = 6,490 psi r ; ,, F.S. = 21,000/6,490 = 3.2 3.1.4.4 Tie Down Lugs for Lifting Cask (Inadvertant Use)
If it is assumed the entire load is carried by the tiedown lug, the section modulus (S) = (b h 2)/6; E where b=2 inch, thickness of tiedown lug; and h=6 5 inch, width of tiedown lug. S=12 in3 t!aterial is A311, Gr 1137 with fy = 85,000 psi The maximum distance from the applied load to the edge of the backing plate and tiedown lug weld is g 4 inches. g II I
E=US
= (79,510)(4 in) = 26,503 psi 12 F.S. = 85,000/26,503 = 3.2 Weld - (see 3.1.5.4)
Shear - 79,510 lb/[(21.5)(J2)(.85)(.75)+(13)(.75) i (0.85)(sin 45)l
= 3,150 psi
~6- ,
PROPRIETARY DATA i= [(.707)(6.5)(2)(8+3.25)+(7.75)(2)(14.5+3.375)
(4)+(6)(d)(22.25)+(5.5)(1)(14.5)+(8.5)(1)
(11.9)] + [(6.5)(2)(.707)+(7.75)(2)(4)+(6)
(4)+5.5+8.5]
i = 865/53.6 = 16.13 in.
I = (6)(8)(.75)(6.15)2+(2)(7.75)(4 )(.75)(2.275)2+ l I (5.5)(1)(1.6)2(.75)+(.75)(8.5)(1)(4.2)2+(6.5)
(sin 45)(2)(.75)(4.8)2 = 607 in4 o = ld = (79,510)(16.1)(Cos 37*)(6.15)/607 = 10,358 psi I I o Total = 43,1504 + 10,358Z = 10,826 psi 3.1.4.5 Lid Lifting Lugs (Secondary and Primary)
A. Secondary Lid Lifting Lug
= 2" .
. Material A36 I .
g ay = 36,000 psi a shear = 20,785 psi Maximum Load 370 lbs.
I ' o Isp' ig" Carried by one lug 9
TEAR OUT Area = 2[(1-1/2 - 15/16) - 7/32] (3/8) fid' DIA. Area = 0.258 in.2 3/3" THK. Stress = 3 g's X 370/0.258 in.2 = 4,310 psi 4,310 psi << 20,785 F.S. = 4.8 TENSION Area = (2.0 - 7/16) 3/8 = 0.586 in.2 Stress = 3 X 370/0.586 = 1,900 psi 1900 psi << 36,000 psi F.S. = 18.9 B. Secondary Lid Lifting Lug Weld 1/2" fillet weld with allowable 21,000 psi Effective size Sin 45 (.5) = 0.353 in Area of weld (2 + 2 + 3/8 + 3/8) = 0.353 I A = 1.68 in.2 Stress = 3 X 370/1.43 o = 660 psi 660 psi << 21,000 psi F.S. = 31.8 llD006M
1:
PROPRIETARY DATA :
Therefore, the secondary lid lug is able to resist g a load of three times its weight without rcaching g a yield stress. j C. Primary Lid Lifting Lugs f f
Material A36. r I" THK. Maximum Load = Primary Lid 5,537 lbs.
Secondary Lid 336 lbs.
5,903 lbs. :
f q -
2Y4 1"DIA.
I l
T ?
4 6" = f TEAR OUT (Vertical Lift) I!i i
Area = 2 x [(2-3/4) 1/2) - 1/2] (1) i 3(
g}
Area = 1.5 in.2 and stress = 5903/1.5 o = 3,940 psi 3,940 psi << 20,785 F.S. = 5.2 h TEAR OUT (45 sling angle) IIl
}
Area (short path) = ( J.752 + .752) (1) = 1.06 in.2 Load = 5,903 J2 = 8,350 lbs.
f Stress = (1/2) (8350)/1.06 = 3,940 psi 3,940 psi << 20,785 psi F.S. = 5.2 {
TENSION (Vertical lift)
Area = (6 - 1) (1) = 5 in.2 ,
Stress = 5903/5 = 1,181 psi f
1,181 psi << 36,000 psi F.S. = 30.5 l l
r l -g- (
5 PROPRIETARY DATA TENSION (45 S1ing Angle)
Area (short path) = (42) (1.25)2 - 1/2 = 1.2678 in2 Stress = (1/2) (8350)/1.2678 = 3,295 psi 3,295 psi << 36,000 psi F.S. 10.9 F. Primary Lid Lifting Lug Weld 1/2" weld at shear of 21,000 psi
- a) shear stress due to vert = horz component.
j ov = ch = 5903/(6+6+1+1)(Sin 45*)(0.5)(0.85)
= 1403 psi l-b) Stress due to moment Total Moment = Compression Moment + Tensile Moment Compression Moment + Tensile Moment Total Moment = 2(Tensile Moment)
= 2(2x3x2/3xfx0.5x0.707x0.85) o
!l iW = 3.6a o = 8,855/3.6 = 2,460 psi Combined Stress = J (2460 + 1403)2 + 1403 )
] = 4110 psi i l l F.S. = 21,000/4110 = 5.1 Therefore, it can be concluded that the lifting lugs for the lid are more than adequate to resist
] a load at three times its weight.
t
! 3.1.4.6 Lifting Lug Covers 3 Since the primary and secondary lid lifting lugs lg are not capable of resisting the full weight of the package they will be covered during transit.
3.1.5 Tie Downs Lug material is A311 Grade 1137 with a minimum yield of 85 KSI and a 49 KSI usable shear (57.7%). The cask shell has a minimum yield of 36 KSI.
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PROPRIETARY DATA A
I 91.38 I
14.03 _ 26.84 a I; 64.54 _
I 7.439 l
33.44 g .9 ,
1 Z 1 8. 12 33.44 -
, X l 9 7.43 65.66 54.03 26.84 5 2 l A
I I
g 70.12 l
" 66.87 Y
40.1
"/ .
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l I VIEW A-A
l l
PROPRIETARY DATA A system of tie downs are provided as part of the package. They will be utilized as in View A-A.
3.1.5.1 Cask Center of Gravity i Item Weight Arm Moment i
Cask 33,800 lbs -
42.36" = 1,431,768 in-lb 4
Liner 1,325 lbs -
35.70" = 47,302 in-lb i
l Waste 17,880 lbs -
36.20" = 646,256 in-lb j 53,005 lbs 2,125,326 in-lb J
Center of Gravity = 2,125,326/53,005 CG - 40.1 in.
3.1.5.2 Tie Down Forces Reference f rame with respect to the trailer is l shown on the tie down drawing (Page 10)
)
up - down Y; front - rear X; side - size Z
- l lE accelerations
- Y axis - 2 g's
- X axis - 10 g's Z axis - 5 g's I
Tie Down Lengths Long tie downs (high trailer attachment points)
- length = V65.62 + 52.42 + 64.62 = 106.0 inches Short tie downs (low trailer attachment points) length = V64.5* + 51.5" + 63.5Z = 104.1 inches Tie Down Tensions Tie down tensions resolved by vector direction Long tie down at tension T g i 64.6 Along Y axis T g = 0.6094 T 106.0 I Along X axis 65.6 T = 0.6188 T 106.0 L g l
l l
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l PROPRIETARY DATA l Along Z axis _52.4 T = 0.4943 T b b j 106.0 Short tie down at tension T l 3
63.5 Along Y axis Tg = 0.6100 T g i 104.1 Along X axis Tg = 0.6196 T g 104.1 I*
Along Z axis T = 0.4947 T 3
104.1 10W Force (front-rear)
Overturning (front-rear) due to 10W along X axis Overturning moment =
10(53,005 lb) 40.1" = 21,255,000 in-lb Each of the two rear (or front) tie downs (one long and one short) must restrain hal f the above 10,627,500 in-lb Tension in the long tie down 10,627,500 in-lb = (70.12)(0.6188 T g)
+ (67.7)(0.6094 Tg)
T = 125,551 lb.
Tension in the short tie down 10,627,500 in-lb = (66.87)(0.6196 T 'q)
+ (67.7)(0.6100 T3 )
Tg = 128,460 lb SW Force (side-side)
Overturning (side-side) due to SW along Z axis Overturning moment =
5(53,005 lb)(40.1") = 10,627,500 in-lb l
l l
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PROPRIETARY DATA l
Each of two side tie downs (one long and one i short) must restrain half the above moment or i
5,313,750 in-lb
! i i Tensioa in the long tie down 1
5,313,750 in-lb = (70.12)(0.4943 T )L
+ (7.43)(0.6094 Tg)
T g = 135,595 lb l l
t j Tension in the short tie down i
5,313,750 in-lb = (66.87)(.4947 T g)
+ (7.43)(0.6100 TS )
i T = 141,275 lb 3
2W Force (up-down)
Lifting (up) due to 2W along Y axis Lift = 2 (53,005 lb) - 53,005 = 53,005 lb l
Ig Each of two long and two short tie downs carry the load or quarter the load per tie down.
!g l !
l 13,251 lb = 0.6094 T g l
Tg = 21,745 lb l 13,251 = 0.6100 T g T = 21,725 lb
, 3 Total Tension
- Total tension with all forces acting simul-taniously
. Tg = 125,551 + 135,595 + 21,745 l l
j T = 282,891 lb T g = 128,460 + 141,275 + 21,725 T = 291,460 lb 3
i l
1lDAVR 1
I PROPRIETARY DATA I
3.1.5.3 Tie Down Lugs E
3 The tie down lugs are constructed of A311 GR 1137 steel, having a minimum yield of 85 KS1 and an ultimate tensile of 90 KSI. The following values are used in the design of the tie down lugs.
Tensile Yield = 85,000 psi Bearing Yield = (85,000)(0.9) = 76,500 psi Tensile Ultimate = 90,000 psi Shear Yield = (85,000)(0.577) = 49,075 psi Shear Ultimate = (90,000)(0.577) = 51,962 psi Allowable Shear Stress for Welds = 21,000 psi Hole Diameter = 2.25 in, pin diameter = 2 in fea r Out -
o = 291,460 lb/(2)(2)(1.985)
= 36,710 psi f
[ . l h
^
{ , , o. sis" F.S. = 49,075/36,710 = 1.3 Bearinj }g ; f,9 gg a o = 291,460 lb/(2)(2) = 72,865 ' b EO '
7 /
F.S. = 76,500/72,865 = 1.05 Tension u o = 291,460/(2)(6-2.25)
= 41,637 psi
- -Z/z #4*
F.S. = 85,000/38,861 = 2.18 b" a
(
.jg 3.1.5.4 Tie Down Lug Welds I 1f /
a) Pure Shear
[291,460 lb]/[(21.5)(V'2)(.85)(.75)+(13)(.75)
(.85)(sin 45)] = 11,545 psi 1
l I l PROPRIETARY DATA b) Moment forces (lug is 2 inches thick, therefore moment arm
- is 1 inch.) <
Moment = (291,460 lb)(1 inch) = 291,460 in-lb '
6 " Min. -
6" X _ (2)(6 )(11) + 2 (7.75)(3.875) 2(6-1/2 + 7-3/4) i y 3/4"
- p4.Mj i = 7.125 ~ 7" j 3/4"
-7,,
291,460 = 2a [(6)(7)+(7)2(2)(2/3)(1/2)]
(.75)(.85)(J2) o = 2,165 psi Combined stress = J (11,545)Z + (2,165)Z
- g - 11,746 psi
! S.F. = 21,000/11,746 = 1.78 3.1.5.5 Analysis of Tiedown Loads on Cask Shell
- E The tiedown loads are transmitted into the cask l5 shell as external moments. These moments are the product of the tiedown forces and the offset
- distance between the line of action of the tiedown force and the attachment plate.
I E
!m Offset 2.0 in.
.I e Z
=c ___
s ') M c F '
x il
!I
- libm7N
i
! I j PROPRIETARY DATA i
l F = 291,460 X Cos 37-1/2 = 231,230 lb F = 291,460 X sin 37-1/2* = 177,430 lb I
- M = Circumferential moment = (231,230 lb)(2.0 in)
- 462,460 in-lb
. M = Longitudinal moment = (177,430 lb)(2.0 in) =
j 354,660 in-lb l Reference for method of calculation: Welding Re-i search Council, Bulletin No. 107 (WRC 107), " Stress
- in Cylindrical Pressure Vessels f rom Structural Attachments."
l y = r/t = radius tr> thickness ratio = 40.9/0.875 =
{-
46.7 C) = plate 1/2 the circmaferential width of the loaded
= 18/2 = 9 in C = 1/2 the longitudinal width of the loaded 2
plate = 24 in/2 = 12 in i
B = C /r = 9/40.9 = 0.220 3 3 B2 = C2/r = 12/40.9 = 0.293 Check that 5 $ y 5 100 l
I I
I
I PROPRIETARY DATA Nomenclature Appiscable to Cylindrical $heHs V, u comentrated shear load in the cir-
[B b2 1 B
2 2
-< 1
' *" N'""' i"I d i" i""' I h
+ Vt com ent rated shear load in the lon.
I
=
gitudinal direct ion. Ih (0.3) 1.2) AI, - external overturning mument in the circumferential direction with re-spect to the shell, in. Ib l
W General Nomenclature SI L = external overturning moment in the a, -
normal stress in the ith direction on '""E " " ' ""'.d o n w th m-the surface of the shell, p3i meet W dw sheH, in. H\
ro -
shear stress on the ith face of the jth
" ~ *# "*""" C ,
'C'" shell, m, .
I = length of cylindr.Y"" ical shell, m..
direction S stress intensity - twice maximum c, half length of rectangular loadmg in I
shear stress, psi circumferential direction, in.
N. - membrane force per unit length in c, - halflength of rectangular loading in the ith direction, Ib/in. longitudinal direction in.
Af. - bending moment per unit length in T - wall thickness of cylindrical shell.
the ith' direction, in. Ibiin. in.
K. -
membrane stresa concentration fac- x - coordinate in longitudinal direction tor (pure tension or compression) of shell K. - bending stress concentration factor y - coordinate in circumferential direc-i -
denotes direction. In the case of tion of shell spherical shells, this will refer to + = cylindrical coordinate in circum-( the tangential and radial direc. ferential direction of shell tions with respect to an axis a -
I R.,
normal to the shell through the s = attachment parameter center of the attachment na si - cv R.
shown in Fig.1. In the care of d, r c / R-cylindrical shells, this will refer y += R 'T; she I paiameter to longitudinal and circumferen. C,, C, = multiplication factors for N, and l tial directions with respect to the N, for rectangular surfaces given j
= axis of the cylinder as shown in in Tables 7 and 8 i Fig. 2. K,, K, - coemeients given in Tables 7 and 8
+ -
denotes tensile stress (when asso. Af,, AI, - bending moments in shell wall in ciated with ,,) the circumferential and longi-
- - denotes compressive stress (when tudinal direction with respect to l associated with ,,) the shell E
modulus 'of elasticity, psi N N' " " "" I* I *" I" P -
concentrated radial lond or total " *'.d"" ? " E
" I " *I I""" ." " '" "" I
<hmtion with mspnt to the syH distributed radial load, Ib I
,, = normal st ress m the circumferential direct ion with respect to the shell, psi 2 General Equation ,, - nornial sim s in the longit udinal di-rection with respect to the shell, in the nnalysis of stresses in thin shells, one pro- psi reeds by considering the relation between internal ,, ,-
shear st ress on the x fare in the +
membrane forces, internal bending moments and dis ertion with respect to the
, stress concentrations in accordance with the follow-shell, psi ang( r., = shear stiess on the o face in the 1
' . dimt on with m4&t to the K* T
- K. T .
shell, psi jgg
L a c: '-
'I-' I _II I I' _,_ _ _ iM __
PROPRIETARY DATA I I 1 1 I 1 I.I I l
_{,)y a __(, Q.__ _ _.. _ { __ _ g.(.J_{._ I
, ] _
-m .
{.__._ p .
-2 g
..!4 4 F
hi!, * , . ,; : : ! 7 pi r.~..-.p . i , i .-i,
= _: +
.m L F y .,. Et.: , ~t-m y,q_
.7 7 r4 y u-
.-9+7 r 3
+-
j- +-.t--
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e r -
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- 2 ..
; 7 -f- 7-t- --f,- t-+[ t ti,.'
--. 9. f,i.+ z +{:j'4,--- f4. -d :_!-+, 4 3 ,
w 'p_e _ _ _
--~ 1 + ..
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- u. 4 .-t
+ +-
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m g 2-g"" 1 i
- 1-
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, 7 j--- p b- _ -
; _gt --T -ith:t--j:.. .ph J-t : ' i.:: r.--
; .L- =* -
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.~d~.* 1
' ii
;=
hj M'I 1 :_tJ n!.4 :* -* = 2 :
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- I7_ .:- :!-* * --+~* 4 ; 2 !' -*-*.;*-*Z*_.-_.
4_* 2 - . -
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_+
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.. 4
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7 - 7 *%,. L 4._._Kl_4 s li - !. ?% ?h l_
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, * -t i H- -
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. - . -n: -
.+=Ql%Q 15 _._ .,g@._-
; ,e i wa
+ mb x. n. -i b- id N_.b I h
- N.j -ic:. -$'-NNEN 5hf.kiM:5IINd
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4 _._. .y
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--_.%*~ _--.g_.
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- ,' .__,_--w e
% .,4. _w.-. .~ 5. m -*"'. _ .v.-c_. T . 4,,, _.
_ q _. ._
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1 w.-_ x['~~%-$Am-+f- ,g- --._ - u - 'i
=
b Q ~ p-+ :
-g w-- a 7 y -
w: #- 7 r W ! I N4 A -
- N d.
r ia I /i
-1 7 g i i :s i 7 %C ::-_+.
.1 _i t-m :
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f -: A- .- 3
+m._u
. . . J-Lc-n _ '^ a d[F ft =-i-
-i-fi = . i- .
4- W : :s YT E-" T f )-/-ffit- jf.-by:-::t-!:JP15jie"7fc rjd p - ci - i- i .i. 8- . j_ g
, N E
#i m ggn r- ,
, -r a n
/ q-n.y+ -
.r 4 _,_i_
42np- 3. j ! ! E c__ N;gig
.'; f_r7 b::hEL [h:= : p. - M M-p
* * ' l I % "
~
pi_+ _!_4_ - 2
=
r p_ : .-
. 1 e !- .
u :- t= - M- I d-6
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-. i - : 1 - . _ht-
,yl-iEEEi -M. S_... i ih_ T4 .#_ p.:.il_ l. E._ __ . M-
- =
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/ / -- m - ---
=nM . a.__; r -.y .
,j ll- f ,% - - . . ._ t:*: L _.~ 1in-~ t t t y-.f :l .
.,/ ,- . p. -4,-
--$._._,..A.+_.._..__.__._g. 4
-*~M.-----. - - . - , _ _ . - . -- - ~ - - - . - - . + _ -+
^
N , ,, . . ,fU. .> "p' , A + - r - i . 1 -
,, f f -
I = I a-' s :2E 'V l _ ! Iy" Y '1 E- -7 _] .
] $' --I-- 1' i^x-I__ 1 1.L= :/= iiY 3= -! i ?--i~ ji 1.
e .. y - f -- f F ;'-i =- f J/i - 2 _bi , j
,- i. [ Zf- / 'q- i/ }_ ,,/- j _f , .. 's -i c d. . , _, y_ .. H.
~
+. j=irl ?/- ;- q:.:p 4 -~~
a E-/Tc-/i- - i-M -i ': ~.hf :- - - _ i- ? -r n R~
%[I' [fh N- h -- -'
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-[ -[ { -
=L-- e_Qg 7 M N-s ^I il_ .
l_ . ' *I
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??!
n-
,! _! s._ ;-- _ +- -ij_r,. .
;pp _
g; = _. _7 1
=
i; L t= f ^yptw m-r - i = -u+- n-. -
-- . n= g .- rw-~ -- m ;
s r :. fin I;::_:- r: ~ f ;T-- #2 :- 2C-^3n : :: :_ s __- + - : :-:_ . -._.-_-.
. - :2 ::r : r
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+- .
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~
j 3-1 [ r- ~ 1-
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= -
u. I
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;-3-2 .~. _:: -:--3=i -
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.}
} _y [
d.p -- i :. _r; $_ : ,.'f.d. - .d_ N-k_. , i_ ' [p ri -r,.
,. . _. 4
% f. - ' ,. _-t .g . U,y!g d-- .y d3_L.g g-2
,_ _t ,
-pj:
+ -- E hi -- i H. : i_:+ , : , -[& .[ r _ ti.j t E 2%-11 -
. _1
,_ kN-N.Uld?-~~'*~5. I ii _: . I '-i '. I.c h b ds . j -i - -jy:pj- t[2L(jp{ ,
= = = ===_m.__===_nntn= :=:= m === =.=:-- _.unnz: :_=-
"-^ *-* : . ni ._. a:L nndn
- p. - :2n= .
;r;
.n-- ..
- ;-=; ; ; ;
. .-n-. - _ ___-
+-+ *~-
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_._. . _ . . _ . . . . . _ ~ .:-ta.u -~_=r:- .__., : 4=_- =._-+.T . . . . _. u r g
~-t-:
.-p._.--. .
0 0 05 010 0 15 0 20 02S 0 30 0 35 040 0 45 050 Fig. 3A-Membrane force N,/(MJR M) due to an external cucumferential moment M, on a circular cyhnder l stresses in Shells t i 1 1 l
j . PROPRIETARY DATA L _ . . 1- _h h .d -._ . ..ff, -... h _ h_ . m . h.. _4.u. ,4 4.m_ um% y pL 3_. 4_.h ycg j ; Ap#_.pg_
. _ + _ e g_. _H.l M _4 .W9. _,.
.p_.
. r uv.i;:.44 1 MA4. _4 u i ! . . p j l - _ + . p.u_4m4_ 44_ .4_ L .p 4
- .--q -.- _ .
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._ ._ K_,_j,g. _b. y. .
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D -
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, _s -
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--+- y b-y. s- + 4..._.t'- t1_
, e ; i i < 1 , -: -
r - i ;
+ - Q i ;. i
._+--. - -p _+ * *, _~t -
- t p- _+
.-.r._ 4 -. a 4- .h L. . t L. _-+:_
.,-I a_ 4 [ ' g _+- - * -+ ' i___ 4_ __g : - - l_i_ f_ L,_q _; t t-h _d-h c.:
.-M-piga-m _
_.'. g__ q ._ .- f. u Mh. . _i- i. _di. '
. i.7!1l ..
1[ r:] l .. . . . . . . . . . : _ ;- . !~* . . 1 . ... .
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!:! .?_.- 1" '- -*M . - -. ...
.- .i.. . ]:: .?*7: . ".! T.
. .... r M.. n-. .t-t !. :
_ . . + _ - . . 4 _. , . . . . .
..-_. .r... . . 4 .. .
,..g y
g g . q -,- p_ g g y--. - - + - -
- -_h-,
j._._
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; _l._ 1._$_i_ _i. _-_ - -._ .-- - ..--
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t ?
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h j.__. .. ... } y.{ _ {_h.4J_ 1-_._- I 4-
- 1. .~._/ . . . . - .- . . - - -
l . 4
' h-I-f ;I .;! ! ! + ? : 4- A
~.- -- __L .
7 44 - {_._ _ f_ __: -.
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.t_l. _t - -- --
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+
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,- -. ._ Z_ .- +! '.'_.1.
.. . . .L. 2. L 7. . _* 1_1_ _7. _* . ~ 1. __C.- . ...__ ...._...i . C ' *- T. *. !. ~ *. -* .12. T CZ-
. - - . . _. _ ~ . . + - - . _ .
+- -p i .
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.+ _,__.-.%.-._.. _ . - ~ . .- ,. . . . - . _ _ . . .+. .. _. .._._. .. ._. .-- _._ - - ._-._., - - . .~+.
e.- _. ++_.. _. . .
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4 _ . _ . . . . - . ..--+- m..~+-+
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p_' f_.. ._ . .. ;_... L ...-. ._ ._ __ - . .. . _ , _
. r -a -
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.h .~ j_.[ 7._ i .h'g_;il {._{
f
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b I-u_. a_ _.n :.-..n_.-:;n .:d_ ,:r.e.' i
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. _4 : - _ . _
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. _1 I . %.:. x,hm[ .
., w % _m .
.:.: . = .
1 m, -, s m
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- -,- * - * = = +:.=.=.:.=d=;d+M.-t.-
a w t , 4 c_ _ '___p. r: 41_w .
~
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wI z{. t-pf ]J .
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n:_ 1:: -:::: -: 2. :2 n --
; , E_n: ::n;-- r .2 1 r::_rr r:2: --:n : :
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=L~====**=
l E _._ s._
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g-_. -.
~~~=^'I-*-*~__-*#==r~*~_=(~~~~~~~~~"~~
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.._T--_.m-._-_._- _f __ ._ . _
u . w _. . + ._ i_._.--._- _ , - 4 1e[. 2 2 J .,
,ia,p 1 -+- r, r r r r
-p- }1,
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. i i 1
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, . . t . .. . . .
+ +
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.t _ _.
, N O- hF i.dii
- sII I E5 . i-!- -ld5' 3
' N-I i'i 9I [ # '
'~$ NN[5 n:.:u=229-~:nar::. :_t n:_: .nurr 2,- :- p r a: L -
. .:nr : _.: : c:n 2 : ... .nn: =
r : != - *C ;-*.2-*; J* *r_T 221 ~* * :-~*i.- ,+._-. ^1_* Z aa_Cm. -*1*._-+ -
- rIC: L. M r=+T n-
_.__ . _ _ i . __ ._ 4_.y _ . _..-_.#. _ . . u. _d, ~_ ... _.1. c. - . _t .; .. . _. , _._me_._.-_._ .
+
._o._...._
._4.u._ . . . . . . .
4-+-7--.-..._._.__._.._.._..
- . - - . . . - . . - - - .-F._.--+_.-_._ .
_.+_-q_4_,_._._-._ ._ . + . ..._....._._% . . . 4 0 0 06 00 0 :5 020 0 25 030 035 040 045 0 50 Fig. IA-Moment M,/(M /R,,J) due to an enternal circumferental moment M on a circular cyhnder Stresses in Shells 0I T t Wo
l l
\
L -, PROPRIETARY DATA I' t- I I i i i i J i . , .. 1 a-__. ! !! !> ! ii i I4 , 1 1.-__ p a = 4; a i s_. i 21 8 r I s__-'.-'a._m b - I ug_.-
.{.p.- . . .. _ . __. g:q___
_.-_..g
, . : . -+ 4-I~ M I db.h . .hf- '
E'M - ' _j h-hp $
._=;.= :: 'n: .::_:: s n.- 2w 4 .. . .
1 .c . _ .=-,-
~~
m t- - . . L.
$[ $ h lilx(achiE:~:i.
, ~ : f- ".-- i ; . ,-. . -
. :-:a=ra .
y- " a N g '.- 7
-W w .9,_ _ . 3 =._=_=:_: =_. = =.. : : g =_ -. . .=_ = =. ._ ;_ :_2=_ n. __.:= :. .:=..__.:
t- .
. _ __ .__.u
_ . . . _ . _-__ . _ _=: ._.__ ._: . 7 b y % -. w _._;_w.g.-y-_ %- . ._...._._.4___.__.. _ . . . . _ . , _ ._ . . __._ _ ._.. _ _ . . _.__ -._._ ._. 4 . - . _ _ . _ . _ . 5 y. ._y_ q-.-.__.-.m- . . . ___ . - _ _ . _ . _
,; ,7j-g_ .~ _ ~ _
el.~ [ J I- [Q MM - s,._Q Ljy ]i! t ' 4 f .. ! I i11
', _i1-s_+ ]E,g=_-
=
L __.p,p,_gg_y - A m t-g- N.% i
,_ i y / 3 ;
2 - I I=EHi38 N- _~, 4 A.'L N Nb
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1i e . 1 1 , i t-
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{-- - e
- hbb &.vdk. . .,I n~ Q '
s_ : -- G : z= =. = y. - .7, m m N --'+ mr .m .
. . . _ t , - -
- m. n , .g,
- - :r :=:- .u w: _:: . .:._.- M : --- :
'C. q- w. .. .- - ,
rr '. - .. . .=_ _t m a :- - . . . . . -
. = = .= ; . - . . .._,_._ ... .. J h .; % W __. N :% Q M ! = -:: 9 - ~.H:.2;-
E]~{i--h=f--~T_ w. u :r: .= t=: ; ~..( p :% ----== ___.. . x. 5h. w_.3.. _m .- 1-., f~ ,4 *- V. -
. _-__M~.-_ ^
'-M %, . .-.
p ' mr ' ' [ [1 ,' [7 , ' t Q _ --** ~_..d
.- 1 ; _ _ i e!_t ar p ..
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, 1 w L J l% I '. : 7 *I f- i 24 ra i.i !l- %., i 1i;p i i E ,7 L1 h f= E r -
6= T F-f : ,.J .- 4 :- 4- 2 !j j. 43 . t5
- et
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_4 i- +- 1-id Z D p4 a
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- :_p_..q gh 2 hy
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.z. 'fgj /! i Lv' i j- , u-g -g, Jifi < -
* !=> F /W tE: -= ? = fT + 4' +. = t- - ],' .L1 , &
n w i_ - 1 1 :- n .=
, s
- h. M E$Es.i: M.E1_ _ _c.J.h F -.~:- . : :- _.,.:._ ._: ar; :_p b fe-7 4(-I_
sff$ I , _ _/*_ C-C2 LC. EEf:fr . 1- iO- E J- t' i _:i;E-i -' M M - 3 E .:Ms 31__~p.!$ 2.sd{-lh
. r-
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-+
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a~ - 2 1J 2 : ._ ! 7_ i L 1 .1 - ra >3 .,1 - 33 7,
- I ,-
s_ 4 I - ( _- F 1> =' gn _g_
.ju; r. -t 1, = 3 i
=
y -
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2- #. --t r # e t-s - - ~. g M . _- i _ a _g , g +_ _ j i .._ E~ ~ N ii ^i 9
- Md"i 2 2 hN_-.+ -
s f g':-l ;, 4 .q_' 3;3: i m F-~ = bbii :' y -_ u 1 . q g. . - . - .- 9._ . ,
--. y p 4 3 i
^ -
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s fpj)p-{-' 2r-j [
; r.-d . - 19.~ i-j . j ;3 -- _ _ . . . .
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.5 = =: :: =5-: :=__.= 5 _m3 55y 3 ; _.
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~
t - : : - :' n
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u , _ .- . . _ -. _ _ __ _ E L, ,' _, __._, _ n_._
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._ __ _ _ _ _ . . _ ,m
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c: .. :~ T T--- _
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- = : : : *: . - --
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# . .'._ ._._._ _. _ . . . _ ._.. . 2_ m. ... . _
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. - . _ , . _ .-- ..._s
+ _ . _ . . .
i - i 0'5
~
l 0 0 05 OIO O i5 0 it0 2 030 03'5 0 ho O 45 050 Fig. 38-Mernbrane force N,/(M,fR,,,9) due to an externallongitudinal moment M , i on a circular cylinder i , Stresses in Shells
I t a
'- - ~ ' ' '
' 1, , ._44 _{_ . ._.gd.i T_ j Jib .Li -U4._ ._j_ .l { .,_{.
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- { ! . :... L .. Q*.-.- p {_.._.u .-{ _
q.. --H- {p R I- + -f + +-
~
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s_ ;ri _4 _ ._-
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t t s__ .)t. 3: c
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t :-.. . r -
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. . + . __ .-..,....
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, - t- . :-
+ % +<=, 1 - d..N..._.m. ' %. 2. _s=m,_ m- s .=~. = :_2 . ;s_._%_A. . wm. .
a=m._e._.u :..= :=-- . . _ . .m - O.O I _ - . m . m._._N.x .m. 4
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l _ . . _ i
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> -L !4_lQ_ pb pg!
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~ ~ ~~
E-Gie li-i=_u_ :1; -
. _ . _ _ _ . _=M --
=-
M_W isih b: K% 4 us: : :? +-- .;3 2 .. m v.3i.++1a .= : ++5 ,= a
- +- . - - -
t~ _ aym. := -- fwny%=
; m M y N ~- x__: ,.u g--r:=t, . -.+ .-- .--
- . - . - . _ .- ,.- .s
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+:
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.f m ._. . _
p^M*
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._u_=_.--.,:2.=- . . . - . _ q u_= =. =. -_p_r_ . .. . .. .
_-_n.=_. _ _w__. j . :1. . .q_ . u. _r : =_ =. . ... . t_'
. ._ r. . 4u.:._:.;...p.u..=.._:. .
== .a 7t=J" E i:=j, n j .
wgg ' i~g . . . L_._.
. _ . . . _ ._._ t _. . . .
u -+ . m.-._.-.- _... . _. , . r._.- .a1 5 . .. O 0 00 0 10 015 020 i. 02S 0 30 i. 0 55 t 040
.i 0 45
. t._.
0 50
+ - +-+- . . ~ - + - -
Fig.18-Moment M,/(M /R. t 5)due to an esiternallongitudmal moment Mt on a cucular cybnder J Stress on the longitudinal plane of symmetry) Stresses in Snelis RDSM
. 4 n r imr i- rrr cr n ir r ri s PROPRIETARY DATA l
_p r-i r i a 1 i [a *L'" -pp 4__pp ', ... _ . _ _ . . ... . - _ - t
;ll' sj -
L- L - E 1-9* -
- 1_e- -7
- y. ...
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~~{ .
xfL.i_ ,LF .I ;" h ! QQ,-. .f Qy[
~
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w
. . 1 L Jy:
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[ I:[~~ ~T P m-f }.G. m.
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~m
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-{J... !y__ a g--.-3. . 4- . {._g.3: gl{--]f .-.- ._.
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,"r 1 L ht:StrC iii
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o
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g T.e. _a y-- n_ngFpf ~ w ~
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m- ..
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a l=/V /'=2 WM=# sj3%R_& > i: Wk =
# -Y : - -
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2
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t
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- =_. .... ___:.n=._- _ , . _ , _ + _ .
+= t 0
0 05 OIO 0 15 020 0 25 0 30 0 35 040 045 0 50 Fig. 4A-Membrane force N./(M,/R,,,9) due to an external circumferential moment M, on a circular cyhnder Stresses in Shells I 1
^-
I ---_l-.
-f!~'~f
{' il}l - J!l PROPRIETARY DATA {' f{j'; T ll! ! I b-
, ;a n-,r,--- -~ tt '+
F-- ._. j!._ y i_ . t e_ , . ; ;_ , _ i p., - 4 _1
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- j -.m 7
8 c._.*%.c
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g ;;.-- I-Y" " ' * * ' " -
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- : ;i-
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s u E I~I
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i
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_L .-.__ .__ _ . _ _ _ . , _.
+
- ii I 3 .=.u::* .. _-: ..::_=..... _
_ _ _ _ _ _ . _ . 1. . _. :.. .- L :_._; 1 I J'c: t
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L I.- T.
- J._ -
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_ , = 0, - - - " -
- 7'~~:. '.* ~ ~ ~ * .
_r__.....
. _.. 4 .
0 00S olo 0 :5 020 0 25 030 0 35 040 045 0 50 Og. 2A-Moment M /(M./R.J)*due to an external circumferential rnoment M, on a circular cylinder Stresses in Lells Nbb
5e 1 '
' I PROPRIETARY DATA l1
_f.]' - l 1 l L -' :
.. ....__m -
i ! .a L _i_?_p_L;_ R - { _._ .. 9 1 ,
.1 -- ' -' ,! ! <--,_r. . _
M t- --- -
. . . - . _ , - _. ~- - ---~ ~ - * "
7
.:4. 7_ _ _ _ _ . _ . -- - _ .Q Q. . . -Q ,
.f_l., -j_! s.
) 1-
.t.
1 ,
'- ' 4 . ._ [. .J & , I j jj.
,1.'~ . ._1. ' Q h
1.1} j_.L E'
, : I- .._h. _ .
.m-
- WJ . '_- 1 - 31 il Ti
,I :
i ! ! . .4_..~ ; " l' 'l - y_v "- * - ~ m._.Jr :+t *t-t ::5+
/.1.*_-~-_- ; .
- - - * - ~
1 r: : - . ;tn-.- . . . _";d.=* C. rn *==:t 2_:' UI.- -*-+-
- t--
w._
._._w_...
n _.,_.. M D 2._ .. _.-.w-. ._ __. 4 _ - . _ . _ . _ . _ _._._m .
--,_.,_ % - ,- ...-._.4_.
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#_ '-t
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.+
. 9.-
p- -+.-.
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- - ~ -*
p
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+
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. . .5 . _ . . - , . - . -
. - r_ ( .. + -.-
- bt+_
_; ;f._;_ _;A_ . u j f p ;_m : 4_;- . ir.-.i_
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_ _:. - --. - . , --c_ v- . ._ qq:. F+.._._;
;%. . . r ,_. _m_ .
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,-r.,
_~ g. . ... i:i Li-i M.-__ . 12 hi- M-Ed _=__- ==/_ . :=:== - /.1=_ r. ...== g_:_ -- ---. d.;u. _ :r:r.=....=_:._=._,=_ :_ =._ d.--A
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r
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pg; g. p g 3 M,d I - p,!_
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~
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^ ^ _=-
.= 2
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- ::n .: t : ~.:.:::2- '. ._. = c
': ::. =~$ 3 -i_; _._. ._._. +_. 4
) b : C -._.-~ C" : -
_ . _ _ - - . _. ~.~_'_.~,~~-.: h.__._._..._..-.. '.J.
.a _". i_-**! .*:; ;-- _.*.
L.
+! - , t .
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9-.. I I 1- , .. {_..f l' F.. _l- N w '
,_ .n l~
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.f.,
f '
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+ r ff f 1
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- f
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)-
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= 4
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4.. . . _ _ y .
. .m .
0 005 0 10 0 15 020 025 0 30 03S 040 045 0 50 Fig. 48-Membrane force N./(M /R.9) due to an enternallongitudinal moment M .t on a circular cyhnder t Stresses in Snells e _ PROPRIETARY DATA - a 1 "! I f Y ! I I T I I i i # ' I f 1.I Y I I iY I I I
+- ---
-t. ._
p'I, I,
; , r , j I, _
i a 2 J_- . _. . - y
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}
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+ .j -}:
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g j l Q_ ._}
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m l y _.--jb , j;
.; O ; +,
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. }_.__...
t._
;- y 2
. r r -
.r -
- ; - ; ,. 1
, -;, .},
. f:tI:,b
-f i !i b
- - d- ~i_ L i.Ei T i_ _n L: : : 2_ : u - - i'+d
_..: ~_ _ f -L_z -
- p2r _.rr = ug# .-. - 3 .:_2.__; A.. .g.__.. . t._4_4. c .- ._ . . ._. . . .
4_ u.1_p .t _.-m_3 f .. .. ..
. :. ._r: ... .... t'._ -_._.#._.
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, . : :-+;
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sp 4-d 3p . 3g- _Ej. t . - T .,
, Mi. VE _3 n p4:+ 4-. 4 _
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m ;- , --
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a 52b ^.:=:Y - tij-mW -E' V WW. %ndi--- -I
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=. !i=
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. 13
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n
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I g isL=E2T EVO@ 4%i-M IN=Mth 4= thy **= -- : =bbM M=bia
@Q T _ _u -~. {T*,2 "W E==:;1=> 9;j=_ij-- fQ-y_
_m.- . _ _ _ v._ - M gQ:- - m , N a._ p.-t - gri' h[15-4-m: + M -iihi . d$dEiE
.,, h.-_ __
i i
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x - ~
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<y ~.%.
,; ! ~ i X: .%8 C (-*-+-*-*-*- -- NgC wm-*
e 1 i x -c mT -.s e i
.- 1 i. ., . w ,t = r-- mv m -1.tN
;1 I_1. ' , ' i 1 . -rf _. r -i._1, i e
<+ .g - -
..- t e % - A. -
Pi N _1 N _i 1 ! - i . r 'li_- ! - 1- ' = i -
'~ = 4 O* W ^ s +iN 4-7 EN **' ? N@ ' s -
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? : #._-t.==. .= -- W 3.-1 L = }=+G, f-
=
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-+-N 2_' - =r m= ++ 7 -
My
= = -
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-a g
__ __ . . _ _._~ ~ ~
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-- q =_m ' qq%
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---* u I bm _
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7
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r
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6 v
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2 2 - _- - sa- m. I 2 ; __-i - 2 . F r J.._ 4 ,,..,..:
- J - E* 4 4: _.
y_ . _ . m _ aq- ,, _ ..-..; e u, s _- u
=4=y=E-=1 "DVhn= =hb 1+ -2+== := = =4 - -
- - = - # ' '= - == =
- - g q y- m-y e 1 3 4- I' 1-- h f- ' - " - - 2 ' - 'I'- ' l I
Q 3 -W ' .j_y_
^
- 2. -. .
{ f ; f.[j: . .
=3-? = b ' i:__- I - :': - - - - --
. . . . . . . .. ~
2...__._ .._r__.. . -- .ug m , _:g g-.
-.u-m-
__ :::::.7-
. n 1
+--- -:- +- T :. ;c:. ..7
.,_, q m^ _. ..
x ;_ . ..:_----_ := __:. r;.
*- - -'l-.~. '.".*.-'*i-.CT- .---1~ _ . . - ?T. l . _ . .1~- - * -'*T I.J ;- 'T 1 '
8 _ _ . i. . _ _ "_
-n-' _ - - . . - - ..;._._._ : .C--
^
-+-+ ; :n;:. :- -~ 2:
I ! . . . . . . I O 0 05 OJO 0 15 O20 0 25 0 30 035 040 0 43 0 50 Fig. 28. Moment Md(Mi ./R.J) due to an externallongitudinal moment M .on i a circular cyhnder (Stress on longitudinal
- r. Jane of symmetry)
Stresses in Shells MUR l l l
l l'HUPNitFARY DATA Tchl) 5-Compt:ti:n Shxt f:r Lecti Stressso in cylindricsl Sh:lls P YTLM g l L A,,s.4L. .* 3. c.....P.........
. Ve &
a.d..: i.. a. P- i6 .. ,M L/ M I
- c. .
L.......
. .. M"tg""
.t :Mp.. ib.
_o,.
... 2 T- :
,N,by -[v"5 ROUND T...........
sk... L. 4
- m. ;
We . rb. is. g ; 0,26 DL A u g, 77TacHutNT
% ,,,g,
- ~
sk L. 4 v6 :( .. r s... .. c . .... . 4.. .. j -~ i~~#0
- 2. C a.m., .) . 6,... i . 4. u .
T - g gg y ,. @@.7[. b) b"d as lad. Rb Rm L v.... 6. 6 . . .. Cu C L A weeh. . 4.... ..,*'"...
- NoT t . t .. .ii e.... ..i. .. ..
v .. ..i 4.... a. 4Q.3 ... .u4......6............ CE $W
. h= 8 4 c. .. C . . 6..h,. . ..i .. . .s 5 Y a E 5 5 E 5 - 8 8..d . . .. . ... . h .a. -a. .. . . . .. ... .s ..
F** s.. .....4......i.* .., .t a,, at c ct o,. no l scl- , ,3 = ..(g).g,, _ __ _. _ .-
; n ;' J2 ,
- (?) *6 = -
i$4 &
+ -
+ - + -
+ l
..e ,9 -(..h)..:n,=.
~
Yi$$ M -20 6-20M fl%5+2%S
..h -(. 5 ) i m .= Nw MM e eMum Sr a
2%. -(a ".'.'.g) driv = -M4H543 6#3 +393MM MM
- .L4, a). : ;. - . -3 e3usw -3ai MMtai M
- .r.r.:x--- 7tos //a 7zo4 tie zufe zW zFe mee
.c r":= = " (,i.) h, =
~ - - - - - - -
U?, ;- =
-(?) E - -
+ - - + - +
.:;...,o -(..,::.g) ..s .
..: o. -(..:.,) .:r,. -
psgm a M -m -f esa ma Sirms we m -w2 esa 454 -em l a . ";..a lh "(~ a! s)' .~k, * -AM -/42 +/4% +/42 DNAID3ENN
- .::.. a ,
........i...
L ::o) .:; . - -sei 1sn +sn sa pegMMM
.r. ...... . 7it, 3ai3 7/69 sei3 /4,e, sist /gese eiu
... ._... . . 1. o 1. .g + e e , t e +
. .;;. :" '- r.a .J,7 +7.54 +7340 -734o -7540RJ(3g[M M tr :: x*
-&r >)%%??jft >}ll 47zS t2is yz25 +4rz_r
'"..'n.:."":7.'-*- 734t 7su 7340 1340 42zS 4 275 42y 4725-connInto STarss 3NTENSITY - 1 \b jf. 47 5.1 4.7 5.1 82.8 8.3 2.s .3 QlnifS it) KSI) 4.N 9 (4, 95 26 21 26. 21.
- 1) When T / 0, S = 1argest absolute maanitude of either S= [cx + 0g + /(cx -0 4)2 + 41 or /(cx - 04)2 + 4T2, ,
v ., o b
- 2) When T = 0, S = largest absolute magnitude of either S=0x, og or (0 x ~UI* $
l N./(Af,./R '4) so determined by (C,.) from Table u caicuimen or strus s ! 8 (see para. 4.3). 4.3.1 STRESSES RESULTING FROM R4n:4i. Loan. 4.2.2.5.2: When considering bending moment P. l (Af.): # = Km.fssiwhere K,. is given in Table 4.3.1.1 Circumferential Stresses (a.):
- 8. Step 1. Using the applicable values of s and y Stresses in Shells l
l l
l PROPRIETARY DATA At the highest stress location on the outer shell,
! the stress is 26.1 KSI; for ASTM A36, the steel used on the outer shell, generic minimum yield is 36 KSI. The outer shell will not be overstressed due to the forces calculated in 3.1.5.2.
3.1.5.6 Failure Under Excessive Load j The tiedown lugs are designed to fail under exces-l sive load and preclude damage to the package. Based on ultimate strength of the shell material, j the force required to initiate damage to the shell would be: F = (291,460) (58,000)= 647,690 lb (26,100) The lug is designed such that it will fail before j the 647,690 lb limit is reached. 1 The mode of failure will be tear out of the tie-down lug. The force required to cause tear out 1 is: J F = (51,962)(2)(2)(1.985) = 412,57a lb. l Compared to the force required to damage the shell, the margin of safety will be: MS = 647,690/412,578 = 1.57 l l l l l l 9 1 lD00fD?ll
PROPRIETARY DATA 3.2 Normal Conditions of Transport (Appendix A-10 CFR 71) 3.2.1 Heat Since the package is constructed of steel and lead, tem-peratures of 130 F will have no effect on the package. l' W 3.2.2 Cold Same as 3.2.1, above. 3.2.3 Reduced Pressure An 0.5 atmosphere pressure will produce an equivalent inter-nal pressure of 7.35 psi. This pressure acting over the lid will produce a load of: F = (75.5)2 (n) (7.35)/4 = 32,906 lbs Since there are eight binders, the load per binder will be: P = 32,906/8 = 4,113 lbs/ binder Each binder has an ult.imate strength of 125,000 lbs. Therefore, it can be concluded that the reduced pressure will produce no detrimental effects. 3.2.4 Vibration All components are designed for a transportation environ-ment. No loss of integrity will be experienced. 3.2.5 Water Spray Not applicable. 3.2.6 Free Drop Since the package weighs in excess of 30,000 lbs., it must be able to withstand a one foot drop on any surface, without loss of contents. 3.2.6.1 One Foot Drop on Bottom Corner Energy to be absorbed = 53,005 lb X 12 in. Maximum energy = 6.36 X 105 in-lb Volume of steel = 6.36 x 10 5 /36,000 = 17.66 in 3 1 1 1 PROPRIETARY DATA l Energy will be absorbed by crushing of corner. N t
\
\g\
P. l .,a, l N <
~
g. i N
%q;,.<be'e. -f, 7
k :, [ [,. j/
\g'l 1 ll BOTTOM g\s CORNER \ '
A
\ /
iE N / i6 N,/ J 1 ll The volume of the crushed ungula, assuming the j 3 worst case of a 45 impact angle is calculated by the following equation: 3 " V, = R Sin 4 - - &Cos&
& = 16.6' when V, = 17.66 in 3
~
! s ,
ll
'\
l i i
! n > \ ~
u A 1lB00 N T
PROPRIETARY DATA The maximum amount of steel crushed will be: b = R(1 - Cos $) = 1.69 The effect on the cask body due to the corner impact event is shown below. Even though the weld will be crushed locally, there will be no loss of the cask's integrity. t,
'47%
nj #7 h
/*eg / e' ,,
\
1.19" -- _= 1.69" o eq *e,
- 69 ,,
The decelleration force exerted on the cask is calculated as the product of contact surface area and the yield strength of the steel (36,000 psi) Au = - (xy + ab sin ~ *) where_for 45* angle = 0: i R = 40.5 in a = R/cos 45 = 57.275 in b = R = 40.5 in h = 1.69 in C = R-h = 40.5-1.69 = 38.81 in j y = JRZ-CZ = 440.5Z - 38.8% = 11.58 in l x = C/cos 45 = 54.90 in _ Au = n(57.275)(40.5) - (54.9)(11.58)+(57.275)(40.5) sin -1 (54.9) (2) , (57.275), Au = 34.60 in2 ; F = (34.6)(36,000 psi) = 1,245,611 lb. i g force = 1,245,611/53,005 = 23.5 g's I:1
i I PROPRIETARY DATA I 3.2.6.2 Effects of Bottom Corner Drop on Balance of Cask The 23.5 g decelleration will be transmitted to the outer portions of the cask. This force will be composed of two components, one force will act i laterally with respect to the bottom plate. The other component will act axially with respect to the plate.
- I il g Cask Cover Inner Container Dece11eration \\
Fo rces Contents s ?g e s o.p
- Upper @@od, ^g /
4
- j Bottom -
Plate Inner Shell
! Lower Lead Shield Bottom -
p Plate
-: Outer Shell Corner Impact
\bhh\ h\h.\\\
Reaction Fo rce !I Hottom Corner Drop
- I
-31
PROPRIETARY DATA Summary of cask component weights as used in the following drop analyses l Primary Lid 5,563 lb , Shield Plug 366 lb l Outer Body Shell* 6,065 lb Inner Body Shell 1,900 lb Upper Bottom Plate 2,645 lb Lower Bottom Plate 2,864 lb 1 Lead Shield 14,397 lb Waste Contents 19,205 lb
*This includes the weight of lid ratchet binders, tiedown lugs, etc.
The following design criteria and assumptions are the basis for the bottom corner drop analysis. The following load distributions are considered: 1- Load from primary lid and shield plug will be distributed to the inner and outer shells in accordance with the shell cross sectional areas. 2- The inner shell will receive loadings at its connection to the upper bottom plate consisting of: Load from lid and shield plug Load from self weight of inner shell Load from waste considered to act on one-half of the shell perimeter nearest corner of impact. Load from one-half lead shield considered to act on the half of inner shell perimeter not receiving waste loading. All other loads on the inner shell will be considered to act uniformly around shell perimeter. 3- The outer shell will recieve loadings at its connection to the lower bottom plate consisting of: Load from lid and shield plug Load from self weight of outer shell Load from one-half of the lead shield considered to act on that half of the shell perimeter nearest the corner of impact. 4- The upper bottom plate will receive loadings consisting of: Loads transferred through the inner shell weld Load from self weight of the upper bottom plate. Due to the rigidity of the upper bottom plate, all loadings on this plate will activate the entire perimeter weldment to the lower bottom plate. i PROPRIETARY DATA I Cask Analyis 1 - Load from Primary Lid and Shield Plug Decelleratio Forces JE Shear Area
-g of Weld II ;
s / 7 4 to to OO g &, e, %,, 4 Decelleration
; Forces 2
Detail "A" i l /
. 1/2" k 3/4" Reactit lg Fo rces
!3 Loading = (5,563 + 366)23.5 = 139,331 lb Lateral force = 139,331 (sin 45 ) = 98,522 lb. Axial force = 139,331 (cos 45 ) = 98,522 lb. Inner shell area = (n/4)(76.252 - 75.5 2) = 89.388 in2 2 il Outer shell area (n/4)(81.75 2 - 602) = 222.317 in lE Total area = 311.704 in2 i , Inner area = 89.388/311.704 = 28% Outer area 222.317/311.704 = 72% I
PROPRIETARY DATA I Force on inner shell = (98,522)(0.28) = 27,586 lb lateral and axial Force on outer shell = (98,522)(0.72) = 70,936 lb lateral and axial = 2- Stresses Developed in Inner Shell and Attachment Welds i I Decelleration g r'o rces E Upper " " " " """
" "" 8 Bottom Plate I
1/8" wel NP7, Detail "B" a Reaction on Inner Shell V l W
~
1/2" welds Stress in weld around perimeter of inner shell at cask lid (27,586 lb)/n(75.5)(3/8)(0.707)(0.85) = 516 psi Tota? stress = 8 (516) = 730 psi Safety Factor = 21,000/730 = 28.7 Stress in weld connecting inner shell to upper bottom plate Total force = 1/2 self weight of inner shell
+ 1/2 lid and shield plug (1/2 of weight acting on 1/2 of shell)
+ waste Total force = (1900/2)(23.5)(sin 45 )+(27,586/2)+(19,205)(23.5)(sin 45 )
= 348,709 lb Lateral Weld stress = (348,709)/n(75.5/2)(2)(3/8)(sin 45*)(0.85) E
= 6,523 psi (lateral) 3 ll PROPRIETARY DATA il Axial weld stress is caused only by lid load and shell self weight.
; 27,586 + 31,572 = 59,158 psi Axial weld stress = 59,158 lb/n(75.5)(3/8)(sin 45 )(0.85)(2) = 553 psi Total Stress = 46,523" + 553" = 6,546 psi Axial shell stress = 59,158/(76.252 - 75.5 2)(n/4) = 662 psi which is less than weld stress.
Shear shell stress = lateral force / area [(1900)(23.5)(sin 45 )+(27,586)+(19,205)(23.5)(sin 45*) = 8,462 psi lg (76.252 - 75.52)(n/4)(1/2) 4 l Safety Factor = 20,772/8,462 = 2.45 j
; 3- Stresses Developed in Outer Shell & Attachment Welds
\, Decelleration Force
[
!l -
Inner Shell Upper Bottom Plate Outer Shell Lower - Bottom Plate
/ / Crush Depth
/ d Weld Area in Shear Detail "C" Shear of Outer Shell Weld Stress in weld around perimeter of outer shell at cask lid (70,936 lb)/n(80.875)(0.5)(sin 45 )(0.85) = 929 psi both axial and lateral Total stress = 4 (929) = 1,314 psi Safety Factor = 21,000/1,314 = 16.0 I ~
libudFN
l l PROPRIETARY DATA I Stress in weld connecting outer shell to lower bottom plate Lateral force = 1/2 load of outer shell
+ 1/2 lead shield
+ 1/2 lid and shield plug (the 1/2 supported by 1/2 outer shell)
= (6065/2)(23.5)(sin 45 )+(70,936/2)+(14,397/2)(23.5)(sin 45 ) -
= 205,476 Lateral stress = (205,476)/n(80/2)(0.5)(sin 45 )(0.85) = 5,441 psi Axial Load = (6,065)(23.5)(sin 45 ) + 70,936 = 171,718 lb Axial stress = 171,718 lb/n(80)(0.5)(sin 45*)(0.85) = 2,273 psi Total stress in weld = 4(5441)2 + (2273)2 = 5,897 psi Safety Factor = 21,000/5,897 = 3.56 Axial stress in outer shell = 171,718/(81.752 _ go2)(n/4)
= 772 psi < 36,000 psi yield Lateral shear stress in outer shell
= (205,476)/81.752 - 802 )(n/4)(1/2)
= 1,850 psi < 20,772 psi yield I
I I I 1 PROPRIETARY DATA E l 4- Stress in Weld Joining Upper to Lower Bottom Plates 1 I' Decel1 erat ion Fo rces Inner Cont a iner Upper I Bottom Platu -
.. Contents f
l
/
/
/ '
'l/ 8" l
Detail "D" ,gy . we l y. f Reaction on Inner Shell T I -
//
I Load on weld = Upper bottom plate - 1/2" we ld:
+ Inner shell
+ Shear from lid on inner shell
+ Waste
+ 1/2 lead Load = [2,645 + 1,900 + 19,205 + (14,397/2)](23.5)(sin 45 ) + 27,586
= 541,857 lb Stress due to lateral load OL = 541,857 lb/(76)(n)(sin 45 )(0.5)(0.85) cL = 7,551 psi Since all axial loads are transferred in bearing, the maximum weld stress l
will be equal to 7,551 psi. This is within acceptable limits. l l I I l I
I PROPRIETARY DATA I 3.2.6.3 One Foot Drop on Top Corners A drop on the upper corners of the cask would decellerate the cask and would result in axial and transverse decelleration forces between the cover and the balance of the cask. I I Contents Decelleration Cask Tran svers e ccelleratiognner Shell m Outer Shell Cask Axial I Decelleration Cover I 3/8" % 1/2" x I I Impact Point I I I
1 I PROPRIETARY DATA l I i I The top cover is stepped and the inner plate has a nominal clearance of one-eighth inch. Upon im-pact, this plate would immediately contact the inner shell. The transverse decelleration force must be resisted by the bearing stress between the inner cover plate and the cask wall and by the weld between the two cover plates. The magnitude of the transverse decelleration force will be _g equal to the axial force which will depend upon g the orientation of the cask and the corresponding decelleration forces. As shown later, the maximum decelleration force will occur when the cask is I dropped on the long flat edge. The maximum decel-1eration for this case is 16.3 g's. g The weight of the cask less the upper cover plate
-3 is 53,005 - 3,260 = 49,745 lbs. The transverse decelleration force acting on the weld between the two plates is 49,745 x 16.93 = 842,183 lbs. The I weld is a 1/2 inch weld, 75-1/4 inches in diameter.
The stress in the weld: 842,183 E f _ 75.25(n)(0.5)(0.85)(0.707) = 11,856 psi 3 Safety Factor = 21,000 = l,77 11,856 The weight of the cask less the cover and shield
.g plug is 53,005 - 5,563 - 366 = 47,076 lbs. The 5 tr nsverse force between the inner cover plate and the inner shell of the cask will be:
F = 47,076(16.93) = 796,997 lbs. The bearing area between t::e two surfaces will ll equal the diameter of the inner plate times the
'E thickness of the plate.
Area = 75.25(2) = 150.5 in2 The bearing stress between the two plates will be: f = 795,997 + 150.5 = 5,296 psi
- I
-l libudM
PROPRIETARY DATA I 3.2.6.4 One Foot Drop on Top Corner of the Long Flat Edge In a top drop on a corner, one of the extreme con-ditions would be the impact of the cask along the top edge on one of the long flat sides of the cover. Angle drop of 45* is considered to be worst case. m 37.4" m 34.4" y s s s d, h impact .5" An impact in this orientation will cause minimum bending of the cover and will result in high im-pact loads on the cover. The majority of the energy will have to be absorbed by crushing of the steel. The bending and crushing of the cover will occur in steps as illustrated below. Crushing y Following impact the edge of F the corner will begin crushing until inelastic rotation around 1 ' r, the bend point occurs. g, - - The point at which this will I occur is calculated as follows:
, Neut ral
^*I" Width at bend = 37.4 in Thickness = 2 in i , 1.50" M = (36,000 psi)(1 in)(37.4 in)(1 in) =
1,346,400 in-lb. I 38,0p0 psi < j 1 l" , e---. 38,000 psi 1 1 i
I PROPRIETARY DATA 'I F* - M/X = ' '
= 897,600 lb 1.5 897,600/53,005 = 16.93 g's (axial and lateral)
F, = Force required to initiate bending i I F=F a ([i) = 1,269,400 1,269,400/53,005 = 23.95 g's (total) Area crushed steel F 36,000 = 35.26 in z Width of crushed steel 35.26 + 34.4 = 1.025 in Depth of crushed steel 1.025/2 = 0.512 in Volume crushed steel = ( ' }(* ( 2
= 9.036 in3 Energy absorbed in crushing 9.036(36,000) =
325,296 in-lb l Bending i5 When the force due to crushing reaches the above value noted, the cover will bend inelastically. The bending will occur around the impact limiter ring Fa l and with the shell of the cask
'A
'I , 1.5 inch
- The balance of the energy will be absorbed by 4
bending of the lid [ Total Energy] - [ Energy Absorbed in Crushing] [(53,005 lb)(12 in)] - [325,296 in-lb] 310,864 in-lb = Energy Absorbed in bend j, With an axial force of 897,600 15 required to cause bending, this amount of energy will be ab-sorbed by an axial displacement of g
- 3 310,864 in-lb/897,600 = 0.346 in.
1l%QWR
PROPRIETARY DATA I The g forces developed during the bending process is calculated using a kinematic approach. Velocity at start of bending is 2 KE g (2)(310,864)(386.4) 3 W y (53,005)
= 67.3 in/see As calculated before, the inelastic bending de-formation is 0.346 in.
The time it takes the cask to move this distance, based on average velocity is AX/V avg -- (0.346 in)/[(67.3)(0.5)in/sec] = 0.0103 sec g force = (AV/At)/386.4 in/sec)
= (67.3/0.0103)/(386.4)
= 16.93 g's (both axial and lateral direction)
The above shows the maximum g force is 16.93 g's in crushing and bending in both axial and lateral I directions. The force of impact on the corner is 897,600 lb. (axial component) Contents 947,467 lbs a 40.2" u o th d il if 2R F2R p2R
- 1. 5,,j 19,205 x 17.86 lbs g ,
+ 23" -
34.4" - 2 3'l--- The loads on the ratchet binders will be propor-tional to their distance from the pivot point of the cover on the cask.
!I i PROPRIETAilY DATA !I
- g Forces tending to open the lid consists of weights
!E 4 fr
- waste, lid, and shield plug.
l (19,205 + 5,563 + 366)(16.93) = 425,520 l Summing the moments about point 'A' - (897,600)(1.5) + (425,520)(40.2) = 18,452,250 in-lb 18,452,250 in-lb = 2R(23)(23/80.4) lg + 2R(57.4)(57.4/80.4) 'g 4 + 2R(80.4) j 18,452,250 in-lb = 255.92R i l R = 72,100 lb (in farthest binder f rom impact) ] R = 72,100 (57.4/80.4) 1 51,475 lb (in middle binder) R = 72,100 (23/80.4) fi = 20,626 lb (in hinder closest to impact) 1
;I t
i
}
I i !I i i 1
- I i
lI 1
- ! lib 6W7
l l PROPRIETARY DATA The 1/4 inch thick seal ring, made of AISI 1008 steel, located on the g outer periphery of the top of the cask wall will experience some 3 pressure resulting from a top corner drop. This worst case appears in a top corner drop on a large flat. The force exerted is equal to that which is required to bend the lid, or 947,467 lb. f y I e " W,.e, s
"s - t 1
, 4 -
4 . I 29 l 3 . c gg i, , y The yielding surface area reacting against this force is proportional to the angle 0 and the radius. (39.62 ! ) (25,000 psi) = pressure (psi) 5 9 (Pressure) *(
} in /degrc = force / degree 360 As seen from Table 3-1, the entire force is distributed over a 132* g arc of the ring. This is less than the angle between three of the g large flats.
By dividing the incremental pressure by Young's Modulus (E=30 x 106 ), the ratio of the strain may be calculated, and by multiplying by the ring thickness, an actual deformation may be predicted. As seen in Table 3-3, the maximum deformation is 0.10 mils. This causes no great deformation or damage to the spacer ring. The force will be transmitted to the shell by the double one-half inch weld to the outer shell and the double three-eighth inch weld on the inner shell. Based on a 132 distributed load, the effective area of these two welds is: Area = n[(79.5)(0.5)+(76.23)(0.375)]2 = 157 in2 f = 897,600/157 = 5,700 psi The actual stress values will be lower since the upper ring will cause the load on the weld to be distributed over a larger area. I PROPRIETARY DATA I i l I TABLE 3-3. PRESSURE EXERTED ON 1/8" SEAL RING DUE TO TOP DROP l Angle Pressure Force / Degree IF Press /E Strain (Degrees) (psi) (psi / Degree) (ib) (Percent) (in) 1 24.842 8,590 8,590 0.000830 0.000103 l 2 24,835 8,587 17,178 0.000828 0.000103
- E 3 24,819 8,582 25,760 0.000827 0.000103 4 24,797 8,575 34,335 0.000826 0.000103 g 5 24,766 8,564 42,900 0.000825 0.000103
- g 6 24,728 8,550 51,450 0.000824 0.000103 7 24,683 8,535 59,985 0.000823 0.000103 8 24,630 8,517 68,502 0.000821 0.000102
- 9 24,570 8,496 77,000 0.000819 0.000102 10 24,502 8,473 85,473 0.000816 0.000102 11 24,427 8,447 93,920 0.000814 0.000101 12 24,344 8,418 102,338 0.000811 0.000101 13 24,254 8,387 110,725 0.000808 0.000101 14 24,156 8,353 119,080 0.000805 0.000100 l 15 24,051 8,317 127,397 0.000802 0.000100 i 16 23,940 8,278 135,675 0.000798 0.000099 17 23,820 8,237 143,912 0.000794 0.000099 18 23,693 8,193 152,105 0.000789 0.000098
- l l 19 23,559 8,146 160,252 0.000785 0.000098 ie 20 23,418 8,098 168,350 0.000780 0.000097 21 23,276 8,049 176,400 0.000780 0.000097 22 23,115 7,993 184,393 0.000770 0.000096 lI 23 24 22,952 22,782 7,937 7,878 192,330 200,208 0.000765 0.000759 0.000095 0.000095 25 22,606 7,817 208,025 0.000753 0.000094 26 22,423 7,753 215,778 0.000747 0.000093 l 27 22,233 7,688 223,466 0.000741 0.000092 28 22,036 7,620 231,086 0.000734 0.000091
- g
- 29 21,832 7,550 238,635 0.000727 0.000090 f5 30 21,622 21,405 7,477 .46,111 0.000720 0.000090 31 7,402 253,512 0.000713 0.000089
- g 32 21,182 7,325 260,837 0.000706 0.000088
!g 33 20,952 7,245 268,082 0.000698 0.000087 l 34 20,716 7,163 275,245 0.000690 0.000086 35 20,474 7,079 282,325 0.000682 0.000085 ll 36 20,225 6,993 289,318 0.000674 0.000084 l5 37 19,970 6,905 296,223 0.000665 0.000083 38 19,709 6,815 303,038 0.000657 0.000082 l 39 19,442 6,723 309,761 0.000648 0.000081 l 40 19,169 6,628 316,390 0.000639 0.000080 1 41 18,890 6,532 322,921 0.000630 0.000078
- 42 18,606 6,433 329,354 0.000620 0.000077 43 18,316 6,333 335,687 0.000610 0.000076 (Continue <!)
- I 1lB00MI
l l PROPRIETARY DATA g TABLE 3-3. (Continued) Angle Pressure Force / Degree IF Press /E Strain (Degrees) (psi) (psi / Degree) (lb) (Percent) (in) 44 45 18,020 17,719 6,231 6,127 341,918 348,045 0.000600 0.000590 0.000075 0.000074 I 46 17,412 17,100 6,020 5,913 354,066 359,980 0.000580 0.000570 0.000072 0.000071 3 47 5 48 16,783 5,803 365,783 0.000559 0.000070 49 16,461 5,692 371,475 0.000548 0.000068 50 16,134 5,579 377,054 0.000538 0.000067 51 15,802 5,464 382,518 0.000526 0.000066 52 15,465 5,347 387,865 0.000515 0.000064 53 15,123 5,229 393,094 0.000504 0.000063 54 14,777 5,109 398,204 0.000492 0.000061 55 14,426 4,988 403,192 0.000480 0.000060 56 14,071 4,865 408,058 0.000470 0.000058 57 13,711 4,741 412,800 0.000457 0.000057 58 13,348 4,615 417,415 0.000445 0.000055 59 12,980 4,488 421,903 0.000432 0.000054 60 12,608 4,360 426,263 0.000420 0.000052 61 12,233 4,230 430,493 0.000408 0.000051 62 11,854 4,099 434,592 0.000395 0.000049 63 11,471 3,966 438,559 0.000382 0.000047 64 11,085 3,833 442,392 0.000370 0.000046 65 10,695 3,698 446,090 0.000356 0.000045 66 10,302 3,562 449,652 0.000343 0.000043 The spacer ring has a width of 0.5 inches compared to a combined width of 1.25 inches for the inner and outer shell. Accordingly, the stresses in the shells will be 40 percent of the stresses in the spacer ring. Lid Ratchet Binder Assembly Based on the 72,100 lb developed in the far ratchet binder during a top corner drop, the ratchet binder, the ratchet binder pin, and lug assemblies are analyzed as follows: Ratchet Binders The ratchet binder will have a shank diameter of 1-3/4 inches and rated generically for an ultimate failure load of 125,000 pounds. The binders will generally fail in the threaded portion of the shank. The shank is fabricated from Grade C-1040 cold worked steel or equivalent having a generic yield strength of 70,000 psi and an ultimate strength of 85,000 psi. The minimum root diameter of the thread portion of the shank is 1-1/2 inches. The strength of the shank is calculated as follows: I I PROPRIETARY DATA 1 Yield Strength = 70,000 x 1.5 2 x n + 4 = 123,700 lbs Ultimate Strength = 85,000 x 1.5 2 x n + 4 = 150,207 lbs Based on yield strength the factor of safety will be: 123,700 + 72,100 = 1.71 . Ratchet Binder Pin
- Pin is 1-1/8 inch diameter bolt made of SAE Grade 5 or equivalent having a yield strength of 74,000 psi. Based on double shearing of the bolt during loading, A
72,000 72,100 b 2 2 1-1/8" j j j , , , j R ltant Force = 76,105 lb
. 5esu ll c, = (72,100/2)/1.125)2(n/4) = 36,266 psi Safety Factor = (74,000)(0.577)/(36,266) = 1.81 Lid Ratchet Binder - Upper Lug - (A516 Gr 70)
- ----> b b '
V v I 3/4" \ n
\
1.90" 2 hl k" 4 _ _ _ _ _ _ DIA
.x 5/
ll , 1- - Hs-9-3/8" _ is ,
- 3-1/4 )
llU0dhN
I PROPRIETARY DATA ! Tear Out - Shear - o, = 72,100 lb/(1.5)(2 - 0.0625 - 0.27)(2)
= 14,412 psi SF = (38,000)(0.577)/(14,412) = 1.52 9/16 Bearing -
oR = 72,100 lb/(1.125)(1.5) 42,725 psi T L _ f 1/16" SF = Le/d = 2/1.125 = 2.9 '27" 2" o/fu 42,725/70,000 5/8 Tension - # 8 OT = 72,100/(1.9 + 1.375 - 1.25)(1.5) SF = 38,000/23,736 = 1.6 Weld 1/2" double groove weld, complete joint penetration with tension normal to effective area. Allowable stresses same as base metal. 1/2" full groove and 1/2" fillet (both sides) U ') h " full groove
- x f
, 1.83
,p 455; ;1-1/8")
e i " 76,105 lb Neutrt 1 Axis Neutral Axis l 1(2)(3h)(4
+ (2)(3k) )(2.125)
({2 ) = 1.83 1 I: I,
!I PROPRIEIARY DATA ll ]g Tension - ig l oT = 72,100/[(1/2)(1-1/2)+(2)(1/2)(4 )(3.25)](0.85) fl oT = 15,866 psi i Moment - !E (72,100)(0.455) = 20 (1/2)(1.5)(1.83)+(2)(1/2)(1.33)2 l5 (E/3)(d)(1/2)](0.85) 0,= 8,746 psi c tot = 0, + T = 24,612 psi lI F.S. = 36,000/24,612 = 1.46 !I ig !I jI i !I i II l lI lg 15 llD00FN
I PROPRIETARY DATA I Lid Ratchet Binder - Lower Lug (A516 Cr 70) Tear out 1-3/8" - "= 1 q _ Shear - l a o, = 72,100(1.5)(1.75-0.0625-0.27)(2) 1-3/4 s
= 16,954 psi B SF = 21,926/16,954 = 1.29
,, Bearing -
n .DIA B
= 42,725 psi SF = *! ! '
o g/fu = ((42' ,72M 70,000) 1 " Thk = 2.55 " 9,. Tension b" 72,100/(3.5-1.25)(1.5) = 21,362 psi SF = 38,000/21,362 = 1.78 Weld Shear - u u o, = 72,100 lb/(9+1.5)(1/2)(4 )(.85)(2) lh;" o, = 4,040 psi Moment - (72,100)(2.625) = 76,105 li 2a [(1/2)(1.5)(4.5)+(2)(1/2)(4.5)2
^
g q,, (273)(1/2)}(0.85)(4) o, = 7,775 psi
,__ I _ _ _ _ Neutral oT =4 + = 8,762 psi Axis SF = 21,000/8,762 = 2.4 2-1 l J .
I I PROPRIEIARY DATA . l i Lid Ratchet Binder - Lower Lug (Optional Design) aC 3/16" < 1,, w y A 3/16"N n 1-11/1( lli " s\ Nr [# 1-11/16" it;" \1" 3 1/8]
-3/ DIA 1/8 I y C l'4 "
d N MXXM>%Wh 1L 9" \ N N I N N N N
\
N I - M ,,.. .
> Section C-C f
I Weld holding 1/4" thick plates to lug Assume each circumferential weld must support 1/2 the load - o = (72,100/2)/(8.5+2.5+0.5+2.25+6.75+0.25)(3/16)(sin 45 )(0.85) l c = 15,416 psi SF = 21,000/15,416 = 1.36 Tear Out - (Optional design) Shear of the sleeve - o = 72,100/(1.6875)(1.25)(2) = 17,090 psi SF = 21,926/17,090 = 1.28 I
I. PROPRIETARY DATA I Shear of the pin - o = 72,100/[(1)(1.6875-0.27-0.0625)+(0.5)(1.6875-0.27-0.25-0.0625)](2) o = 18,900 psi SF = 21,926/18,900 = 1.16 bearing of pin - o = 72,100/(1.125)(1.25) = 51,271 psi SF _ Le/d _ 1.6875/1.125 = 2.0 o/fu 51,271/70,000 Tension - (Optional Design) o = 72,100/(3.5 - 1.5)(1.25) = 28,840 psi SF = 38,0J0/28,840 = 1.32 1 " Tlik k' eld (Optional Design)
~]
Shear o, = 72,100/(9+1)(2)(1/2)(f2)(0.85) ' o, = 6,000 psi Moment (72,100)(2.625) - 2-5/8" en g 20,[(1)(d)(1/2)(4.5)+(2)(4.5)2(2/3) g, , (1/2)(4)(1/2)](0.85) . Axis 0,,= 8,747 psi ., oT
- 4# s * "m
= 10,607 psi i
SF = 21,000/10,607 = 1.98 gl l 4'i" ml l I N l g
I PROPRIETARY DATA !I
- g 3.2.6.5 One Foot Drop on Top Corner at One Inch Flat
- g In a top drop on a one inch corner, the other extreme condition would be the impact of the cask
- on one of the one inch corners of the cover over l= one of the tie down lugs.
25.14" 1" 5"
=
.i 1 Impa ct The energy absorption sequence will be the same as that previously shown for the drop on the long flat edge and will consist of the intial crushing, bending, and crushing. Because the cover over-hangs the cask to a greater extent, the cover will act more as an energy absorber. Crushing Width at bend = 25.14 in. (Depth of 5.0 inches) Fa f
- 3 l Thickness = 2 in.
e Fb m i.
! k l
I l j 5" l
! M = (36,000 psi)(1 in)(1 in)(25.14 in) = 905,040 in-lb l 1
Fa = M/x = 905,040 in-lb/ 5 in. = 181,008 lb. F = 181,008([f) = 255,984 lb Area of crushed steel = F/36,000 psi = 255,984 lb/36,000 psi
= 7.11 in2 1
PROPRIETARY DATA I The area of the trapazoid is described in (1.4d + 3.44d 2 ) where d/[l = depth of crush. 7.11 = 1.4d + 3.44d2 or d = 1.25 in. therefore, (d/[2) = 0.882 in. Width of crush = 1 + 4.87d = 7.08 in. Volume of crushed steel = d2 /2 + 1.925d + 1 = 4.18 in 8 Energy absorbed in crushing = (4.18 in 3 )(36,000 psi)
= 150,480 in-lb Decelleration Force During Initial Crushing I
} y
/ Energy absorbed 150,480 in-lb d] "
Energy remaining = 485,580 5" f _ h (, ' Force = (7.11 in 2)(36,000 psi)
= 255,960/53,005 = 4.83 g's 3-3/4" 3/8"_/
35" 120 m 3" 1-1/P-Bending of Cover Af ter the initial crushing of the corner and the build-up of force noted above the corner of the cover will bend inelastically until the lug under the corner g contacts the shell of the cask. The amount of axial 3 displacement will be 1.05 inches and the energy absorp-tion and decelleration forces will be as follows: g 50 Fa Bending of lid (15' until lug 5 u 1.3 hits outer shell of cask) m : Energy remaining = 485,580 in-lb E Fb Energy absorbed in bending (1.3" travel) E = (Fa)(d) = (181,008 lb) (1.3") l = 235,310 in-lb Energy remaining = 250,270 in-lb. l l !
- I
~ PROPRIETARY DATA lI Failure of the Lug After coming in contact with the shell, the lug will fail due to tensile shear in the weld to the cask cover. The moment which will cause failure of the weld is calculated as follows:
!I 3.75"
, w
- centroid I tension l
.{gl , compression w '2 " weld a l l a round [
/
- I F
/
- I 4
M = 20, [(1.5)(1/2)(1.875)+(1/2)(J2)(0.875)2(2/3)(1/2)(2)]0.85 M = 5.2(21,000 psi) = 109,368 in-lb
- The compressive strength of the shell of the cask will be equal to or
! greater than the tensile yield strength of 36,000 psi. The lug is 1.5 inch wide and will come in contact with the cask about 4.5 inches from the spacer ring. The lug will locally deform the shell until the moment that will shear the weld is attained. 'I
- I i
)lb0h6b
. PROPRIETARY DATA l
- _ 0.375" l J
. y2 y n yi L S d
I F=36,000(1.5)yi)f=27,000yi Ib y2 = 4.5 - y in. l M = (F)(y2)
= (F)(4.5 - ) in-lbs
= 121,500y1 - 9,000 y} = 109,368 in-lbs 9,000 y 2 - 121,500yi + 109,368 = 0 Y1 ~_ 121,500 - J121,5002 - 4(9,000)(109,368) 2 (9,000) y1 = 0.97 inches The depth of shell deformation or, d, will be as follows:
( d _ y,_ 0.97 O.375 4.5-y1 4.5-0.97 i d = 0.10 inches l Deflec* ions or deformations of this magnitude in the shell will not affect the integrity of the cask. 1 1 1 I
il PROPRIETARY DATA il i Secondary Hending i During the following the shearing of the tiedown lug weld, the corner i of the cask cover will continue to bend and absorb energy. Neglecting j the energy that would be absorbed in the shearing of the tiedown lug l from the cover, the amount of energy to be absorbed in secondary bending will be: Initial Kinetic Energy 636,060 in-lbs 4 !g Less Initial Crushing 150,480 in-lbs Ig Less Initial Bending 235,310 in-lbs Remaining Energy 250,270 in-lbs j In secondary bending, the bending of the corner of the cover vill reduce { the moment arm for the axial force and the force required to cause bending j will increase. i !I i
!I l
/
/
?.
] d i 4
'I .
i i 1 = /25 - d2 M = F E = 905,040 in-lbs a a j F, = 905,040/425 - dd
'l libnWI
PROPRIETARY DATA I I The energy absorbed is computed as follows: displacement 2 Fa Fa(avg) d E IE 1.3 4.83 187,454 1.5 4.77 189,748 188,600 .2 37,720 37,720 2.0 4.58 197,495 193,622 .5 96,811 134,531 2.5 4.33 209,010 203,252 .5 101,626 236,157 g 2.6 4.27 211,911 210,460 .1 21,046 257,203 3 (103%) The secondary bending is capable of absorbing the remaining energy. The additional displacement of the lid during secondary bending is 2.6 - 1.3 = 1.3 in Decelleration Forces - It was calculated that the initial crushing caused a decelleration force of 5.0 g's. Calculate the decelleration forces of secondary bending since this is the shortest distance travelled in any of the phases discussed. v_-}2(KE)(g)_)2(250,270)(386.4)=60.41in/sec W 53,005 v,y = 30.2 in/sec At = AX/v = 1.3/30.2 = 0.043 sec a = AV/At = 60.41/0.043 = (1,403 in/sec 2 )/(386.4 in/sec2 ) = 3.63 g. This indicates that the maximum decelleration force during a 12 inch drop on a short flat corner on the lid is 4.83 g's. This does not exceed the g forces calculated in the drop on a long flat. I I l I 1
PROPRIETARY DATA !I
! 3.2.6.6 Side Drop on Ratchet Binder I
l The cask is dropped on its side. The energy is i - , asswaed to be absorbed entirely on the lid edge.
- This is the worst case with respect to the ratchet binders in that their load consists of the waste
> and the lid weight, f Total energy = 636,060 in-lb
- Initial velocity 636,060 in-lb = 1/2 mv2 v = 96.3 in/see f Let d = depth of crush Volume of steel required to absorb energy 636,060 in-lb/36,000 psi = 17.66 in a lI W = d Tan 67.5" 67 40 y u 2" thick 1"
.I Volume of steel described by
- [2(1/2 dw)(2 in)] + [(1 in)(d)(2 in)]
= 4.82 d2 + 2d Final depth = 4.82 d2 + 2d = 17.66 in3 d = 1.72 in As shown on Table 3-2, the highest g force exerted on the lid is 11.83 g, say 12 g's.
0
TABLE 3-2 Energy Energy Incremental d Vol. Absorbed Remaining Velocity Time Decelleration (in) 3 (in ) (in-lbs) (in-lb) (in/sec) (sec) (in/secZ) (g's) (based on avg. velocity) , 0 0 0 636,060 96.3 0.1875 0.54 19,600 616,460 94.8 0.00196 765 1.98 0.375 1.43 51,400 584,660 92.33 0.0020 1,235 3.2 5 0.5 2.21 79,380 556,680 90.09 0.00137 1,635 4.23 0.75 4.21 151,605 484,455 84.04 0.0029 2,086- 5.4 1.0 6.82 245,520 390,540 75.46 0.0031 2,767 7.16 1.25 10.03 361,125 274,935 63.31 0.0036 3,375 8.73 1.5 13.85 498,420 137,640 44.8 0.0046 4,023 10.4 1.72 17.66 636,060 0 0 0.0098 4,571 11.83
- =
~
l H 2 sti tll3 3:n. M M M M M M M M M M l
, PROPRIEIARY DATA If we conservatively assume that the total payload and lid weight to be solely reacted by the binders then each must carry the following:
)
p _ (19,205 lb payload + 5,903 lb lid) 12 g's 7 binders P = 43,042 lbs/ binder The ratchet binders are designed to take a load I greater than those calculated for a top corner drop on a long flat (76,105 lb). Therefore, the binders will withstand a load of 43,042 lb from a side drop. 3.2.7 Penetration Impact from a 13 pound rod will have no effect on the pack-age. 3.2.8 Compression This requirement is not applicable since the package exceeds 10,000 pounds. I CONCLUSION From the analysis, it can be concluded that the llN-100 Series 3A Cask is in full compliance with the requirements set forth in 10 CFR 71 for Type "A" Packaging. 1 I I liba0FN
l I PROPRIETARY DATA ! I, 1 l 4.0 THERMAL EVALUATION The HN-100 3eries 3A casks will be used to transport waste primarily from l nuclear electric generating plants. The principal radionuclides to be transported will be Cobalt 60 and Cesium 137. The shielding on the cask will limit the amount of these materials that can be transported as follows. Gamma Specific ( Total ( Isotope Energy Activity Activity Mev pCi/ml Ci Cobalt 60 1.33 5.0 23.2 Cesium 137 0.66 140.0 650 (1) Based on cement solidification waste and 10 mR at six feet from cask. (2) Based on 164 cubic feet of solidified material. With the maximum amount of these materials that can be transported in the HN-100 Series 3 cask, the heat generated by the waste will be as follows: Heat Total Generat!.on Activity Total Heat (Watts / Curie) (Curies) (Watts) (BTU /HR) Cobalt 0.0154 23.2 0.35 1.19 Cesium 0.0048 650 3.14 10.7 The weight of waste per container will be about 17,500 pounds. Based on a specific heat of 0.156 BTU per degree F., 2,730 BTU's or over 10 days with cesium would be required to heat the waste one degree Fahrenheit. Ac-cordingly, the amount of heat generated by the waste is insignificant. I I 1 l I
I PROPRIETARY DATA I ' l 5.0 CONTAIh?iENT The shipping cask is a vessel which encapsulates the radioactive material and provides primary containment and isolation of the radioactive material from the atmosphere while being transported. The cask is an upright circular cylinder composed of layers of structural I steel with lead for radiation shielding, between the steel sheets. The lamina are of 3/8 inch inner steel, 1-7/8 inch of lead shield and a 7/8 inch outer steel shell. The heavy steel flange connecting the annular steel shells at the top provides a seat ior a Neoprene gasket seal used to I provide positive atmospheric isolation when the lid is closed by tightening the eight (8) ratchet binders which are equally spaced at 45* intervals on the outer circumference of the cask. The shield plug is located in the center of the cask lid, has a Neoprene gasket and is bolted to the outer portion of the lid with 8 equally spaced 3/4 inch studs on a 20-7/8 inch diameter circle. There is a drain plug in the base of each HN-100 Series I 3A cask consisting of either 1/2 in. or 1-1/4 in. pipe plug, depending on the unit. 5.1 Primary Lid Gasket I Determine the amount of compression of the primary lid gasket due to tightening of the ratchet binders. I Gasket 0.D. = 80 inches I.D. = 78.5 inches 2 Area = n(Ro - Ri2 ) = n(402 - 39.25 2) = 186.73 in 2 Gasket is equivalent to 3/8 inch thick by 3/4 inch wide Durometer 40. I Based on past experience from the manufacturer, a 100 pound force exerted on the handle of the ratchet binder will develop about 3,500 pounds of tension in the binder. Therefore, force downward on lid compressing the gasket (8 binders)(3,500 lb/ binder) + 6.000 lb lid weight = F = 34,000 lb Equivalentpressureofgasket=f=34,000lb/186.7in 2 = 182.1 lb/in 2 As shown on Appendix D-1, the compression of the gasket due to tighten-ing of the ratchet binder is 20% of the gasket thickness, or about 3/32 inch. 5.2 Shield Plug Gasket Similarily, the compression for the shield plug is calculated. Based on the stud torquing procedure for the shield plug, the minimum torque value is 80 ft-lb.
~' ~
l llD M N
PROPRIETARY DATA I The gasket dimensions are 22.75 in. OD, 20.25 in. ID, and 3/8 in. thick. The gasket is equivalent to a Durometer 50. Area = n(Ro 2 - Ri 2) = n(11.3752 - 10.1252) = 84.43 in z Force downward on lid is the sum of the weight of the lid plus the force of the studs (P). P= = (80 ft/lb)(12 in/ft)/(0.15)(0.75 in) P = (8,533 lb/ stud)(8 studs) = 68,266 lb W = 400 lb Total force = 68,266 + 400 = 68,666 lb Pressureongasket=f=68,666lb/84.43in2 = 813.3 psi As shown on Appendix D-2, the compression of the shield plug gasket is 25% of the initial thickness or 1/8 inch. 5.3 Seal with Internal Pressurization The inner steel shell is designed to act as a pressure vessel when the cask lid is in place and tightened. As shown in Section 3.2, the cask l u will withstand an internal pressure of 7.5 psig as required by 10 CFR 71, Appendix A. As described in Seciton 1.0, the nature of the waste being transported is such that phase change or gas generation which may over-pressurize the cask, will not occur. The stepped flange surface at the end of the cask body has been designed to minimize effects of columnated radiation streaming and problems associated with gasket damage during impact. If the cask is pressurized to 7.5 psig, the resultant force on each ratchet binder (as calculated in Section 3.2) is 4,113 pounds. The resultant strain on the steel ratchet binder (1-3/4" diameter) is: P/AE = (4,113)/(1.76)(30 X 10 6) = 0.000078 in./in. P = 4,113 lb A = Area of 1-1/2" minor diameter = 1.76 in2 E = Youngs t!odulus = 30 X 10 8 l and for a 24 inch long binder, total strain is: l (24 in.)(0.000078 in./in.) = 0.0018 in This is less than 2% of the initial compression of the gasket. l I PROPRIETARY DATA I I I The full compression of the gasket from a free drop on the lid is prevented by a 1/8 inch thick and 1/2 inch wide steel ring running the circumference of the lid. If the lid is compressed more than 1/4 inch, the steel will absorb the energy of the fall. 5.4 Casket Compression Test I A compression test to check resiliency was done on Items 4 and 5 on Drawing STD-02-020, the primary lid and secondary shield plug gaskets. The samples were each 1 in2 by 3/8 inch thick made of Durometer 40 I neoprene and Durometer 50 neoprene respectively. Each sample was put in a compression device and compressed. The final results indicated l that it required about 4,500 lb to compress the 1 in 2 Durometer 40 sample to a thickness of 1/8 inch. After removing the sample from the l I test stand, the sample returned to its original thickness of 3/8 inch. 2 Similarly, the 1 in Durometer thick, and it required 10,000 lb. 50 sample was compressed to 1/8 inch It also returned to its original thickness when the load was removed. The test compressed each gasket material 66 percent of its original height and each survived. The spacer rings have a thickness to 1/8 inch which limits the compression of the gasket which is the value demonstrated in the test.
- 5.5 Warping of Covers ll The possible distortion of the cover and possible leakage due to dis-ig tortion has been addressed on a cask of nearly identical design fea-l tures. A cask having an octagonal cover secured by ratchet binders was dropped on the extended corner by Nuclear Packaging, Inc. The identification number of the package which was dropped is 71-9130.
The package, Model No. 50-256, had a weight of 17,160 lbs and was , loaded with a liner containing sand with a weight of 4,200 lbs for a 3ross weight of 23,360 lbs. The package was dropped on an essentially l unyielding surface from a height of 46 inches. The package was pres-sure tested before and after the drop test and no leakage was de-tected. The deformation of the corner subjected to the drop test is shown below: o" 1" 2" 3" 4" 5" 6" 6.75"
, , , o p- l, Corner j '
Deformation /
/
/
o o o 994@ o o o
~~
-l llbudNI
PROPRIETARY DATA I I The energy absorbed in dropping a 23,360 lb package from 46 inches is ' 1.07 x 106 in-lbs. The energy to be absorbed in a one foot drop of an HN-100 Series 3A cask is 12 x 53,005 = b.36 x 105 in-lbs or less than i 60 percent of the unit tested. The covers are the same thickness and the overhang of the corners are l approximately the same. Accordingly, the HN-100 Series 3A should ex-perience less deformation. All of the deformation occured outside of g the impact limiter and no deformation of the cover was found in the g( areas which could affect the seal. [ Ii : I ; I! , I r i l I t I i i [ Il i II I 1 1 1 l e _ Ii .
- S PROPRIETARY DATA
.I ! I 6.0 OPERATING PROCEDURES Customers that use the HN-100 casks are supplied a copy of the Rad Services Manual. This manual describes the services that will be supplied and con-j tains a section on operating procedures. Included in this manual are the
= weight limitations, and type and quantity of licensed material limitations.
The operating procedures describe the inspection of the trailer and cask 'g upon arrival at the site, the opening, loading, closing procedures, and the forms that need to be filled out prior to the cask leaving the customer's 3 site. An example is shown in Appendix A. This is all in accordance with Subpart D to 10 CFR 71. Inspections performed under the operating procedure are done by the custo-mer prior to loading the cask, by the driver prior to leaving the site, at I scheduled stops during transit, and after arriving at the cosignee's site. Inspection includes that cask has not been sigificantly damaged, closure of the package and any sealing gaskets are present and free of any defects, checking of the maximum loose and fixed contamination levels on the cask, and that the cask has been loaded and closed in accordance with written procedures. This is all in accordance with Section 71.54 of Title 10. Radioactive Shipment Record describing the shipment and giving the informa-tion required by Section 71.62 of the Title 10 are required to be filled out in triplicate. One copy is telecopied to HITTMAN prior to shipment leaving the site and a copy is mailed to HITTMAN as soon as possible after the shipment leaves the site. The other two copies accompany the shipment to the cosignee. An example is contained in Appendix B. I I I I I I I llDERTT
PROPRIETARY DATA I 7.0 ACCEPTANCE TESTS & MAINTENANCE PROGRAM The HN-100 Series 3A casks have been in service from four to six years (as HN-100 Series 2 cask) have been subject to the requirements of Subpart B of 10 CFR 71. The materials used in the original construction and in the modification of these casks are specified under ASTM and ASME codes. Welder qualifications and weld procedures are in accordance with ASME or equivalent codes. The modifications to these casks will be performed using the same pro-cedures and standards used in the construction of the HNDC HN-100 Series 3 casks. Specifically: o Welding qualifications and we:d procedures will be in accordance with ASME Code, Section IX. o The tie-down lugs, lift lugs and ratchet binder lugs will be removed from the cask body and lid. o Reinforcing plates with lift lugs and tie-down lugs will be installed on the cask. o Ratchet binder lugs will be installed on the cask body and lid and the present ratchet binders will be replaced with larger units. o Upon completion of the modifications, a gamma scan will be conducted of the cask wall in those areas which may have been affected by weld-ing. o Acceptance criteria for the gamma scan will be based on maintaining c nominal lead thickness of 1-3/4 inches with no individual reading greater than.a factor of three greater than the average readings for the overall cask. o After modifications are complete, the cask assembly will be subjected to a pneumatic pressure test of 8 psig using the test fixture and procedures contained in Appendix E. While under pressure, seating surfaces and gaskets will be checked for leakage. If leakage is fcund and cannot be eliminated, the cask and/or covers will be modified or replaced to attain a satisfactory seal repeatedly. The modifications of the HN-100 Series 3A cask will be implemented and l documented under an approved Quality Assurance program in accordance with 3 the requirements of 10 CFR 71, Appendix E. Cask maintenance and repair is controlled by the Quality Assurance Program. The casks and trailers undergo a routine technical inspection at least once l every four months. These inspections involve checking cask for contamina-tion, damage to interior or exterior, gaskets, studs, signs and placards, shielding and tiedowns. These inspections are covered by Cask Maintenance and Repair procedures. An example is shown in Appendix C. I I
l f NUREG-0537 i Final Environmental Statement . related to the operation of Midland Plant, Units 1 and 2 Docket Nos. 50-329 and 50-330 Consumers Power Company U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation July 1982
,p * ** % ,,
s i
? PJ a c _ _-_ - - - - _ _
i NOTICE Availability of Reference Material: Cited in NRC Publications Most documents cited in N RC publications will be available from one of the following sources:
- 1. The NRC Public Document Room,1717 H Street, N.W.
Washington, DC 20555
- 2. The NRC/GPO Sales Program, U.S. Nuclear Regulatory Commission, Washington, DC 20555
- 3. The National Technical Information Service, Springfield, VA 22161 Although the listing that follows represents the majority of documents cited in NRC publications, it is not intended to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Docu-ment Room include NRC correspondence and internal NRC memoranda; NRC Office of inspection and Enforcement bulletins, circulars, information notices, inspection and investigation notices; Licensee Event Reports; vendor reports and correspondence; Commission papers; and applicant and licensee documents and correspondence. The following documents in the NUREG series are available for purchase from the NRC/GPO Sales Program: formal NRC staff and contractor reports, NRC-sponsored conference proceedings, and NRC booklets and brochures. Also available are Regulatory Guides, NRC regulations in the Code of Federal Regulations, and Nuclear Regulatory Commission issuances. Documents available from the National Technical Information Service include NUREG series reports and technical reports prepared by other federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission. Documents available from public and special technical libraries include all open literature items, such as books, journal and periodical articles, and transactions. Federal Register notices, federal and state legislation, and congressional reports can usually be obtained from these libraries. Documents such as theses, dissertations, foreign reports and translations, and non-NRC conference proceedings are available for purchase from the organization sponsoring the publication cited. Single copies of NRC draft reports are available free upon written request to the Division of Tech-nical information and Document Control, U.S. Nuclear Regulatory Commission, Washington, DC l 20555. - l Copies of industry codes and standards used in a substantive manner in the NRC regulatory process j are maintained at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland, and are available there for reference use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, from the American National Standards Institute,1430 Broadway, New York, NY 10018. GPO Printed copy price: $10.00 _
NUREG-0537 Final Environmental Statement . related to the operation of l r Midland Plant, Units 1 and 2 , Docket Nos. 50-329 and 50-330 i Consumers Power Company ; U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation July 1982 7"'*%, I l l i a 4
ABSTRACT This final environmental statement contains the second assesse. cat of i the environmental impact associated with operation of the Midland Plant, Units 1 and 2 pursuant to the National Environmental Policy Act of 1969 (NEPA) and 10 CFR Part 51, as amended, of the NRC's ' regulations. This statement examines: the purpose and need for the Midland project, alternatives to the project, the affected envi-ronment, environmental consequences and mitigating actions, and environmental and economic benefits and costs. Land-use and terrestrial- and aquatic-ecological impacts will be small. Air-quality impacts will also be small. Impacts to historic and pre-historic sites will be negligible. Chemical discharges are expected to further decrease the existing marginal water quality of the Tittabawassee River and may adversely affect future downstream water use, but will be required to meet conditions of the plant's NPDES permit. The effects of routine operations, energy transmission, and periodic maintenance of rights-of-way and transmission line facil-ities should not jeoparoize any populations of endangered or threat-ened species. No significant impacts are anticipated from normal operational releases of radioactivity. The risk associated with accidental radiation exposure is very low. The net socioeconomic effects of the project will be beneficial. The action called for is ( the issuance of operating licenses for the Midland Plant, Units 1 and 2. Further information may be obtained from: Mr. Ronald W. Hernan, Licensing Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 301/492-8395 i l iii l l l .
. . _ _ _ . _ _ _ - _ b
3 SUMARY AND CONCLUSIONS . l This Environmental Statement was prepared by the U.S. Nuclear Regulatory l l Commission (NRC), Office of Nuclear Reactor Regulation (hereinafter referred to as the staff).
- 1. This action is administrative.
- 2. The proposed action is the issuance of operating licenses to Consumers Power Company for the startup and operation of Units 1 and 2 of the i Midland Plant (NRC Docket Nos. 50-329 and 50-330), located just south of {
the City of Midland in Midland County, Michigan. Both units will employ pressurized water reactors to produce a rated 2468 megawatts thermal (MWt) each. This rated power level includes 2454 MWt generated in the core plus an additional 16 MWt added to the nuclear steam supply system (NSSS) by the four reactor coolant pumps. The maximum j core design output (excluding pump heat) is 2552 MWt. This power level is referred to as the stretch level and is the value used in the radiological accident analyses. The Midland Plant is unique in that the heat generated will be used not only to produce electrical energy but also to produce steam for the adjacent Dow Chemical Company Plant. The facility's turbine generators will produce 505 megawatts electrical (MWe) from Unit 1 and 852 MWe from Unit 2. The remaining heat from Unit 1 will normally be l used to produce 460 kg/s (approximately 0.4 x 108 lb/hr)* at 1200 kPa ' gauge (175 psig) and 50 kg/s (approximately 0.4 x 108 lb/hr) at 4100 kPa gauge (600 psig) of process steam for use at the Dow Plant. The process steam system is a tertiary system utilizing heat extracted from the secondary steam system of the Midland Plant. The exhaust steam from power generation will be cooled by a once-through flow of water pumped from a 360-ha (880-acre) cooling pond. The Tittabawassee River will be the source of makeup water for the cooling pond and will receive the cooling pond blowdown.
- 3. The information in this statement represents the second assessment of the environmental impact associated with the Midland Plant Units 1 and 2 pursuant to the guidelines of the National Environmental Policy Act of 1969 and 10 CFR Part 51 of the Commission's regulations. After receiving an application on January 13, 1969, to construct this plant, the staff carried out a review of impacts that would occur during its construction and operation. That evaluation was issued as a Final Environmental Statement in March 1972. After that environmental review, a safety review, an evaluation by the Advisory Committee on Reactor Safeguards,
*Throughout the text of this document most values are presented in both metric and English units. For the most part, measurements and calculations were ori-ginally made in English units and subsequently converted to metric. The number of significant figures given in a metric conversion is not meant to imply greater or lesser accuracy than that implied in the original English value.
v
and public hearings in June-July 1971 and May-June 1972, the U.S. Atomic Energy Commission (now U.S. Nuclear Regulatory Commission) issued construc-tion permit Nos. CPPR 81 and CPPR 82 on December 15, 1972, for the con-struction of Units 1 and 2. As of December 1981, the plant was about 73% complete. The staff estimates fuel-loading dates of December 1983 and July 1983 for Units 1 and 2, respectively. The applicant tendered a Final Safety Analysis Report and an Environmental Report in support of operating licenses ,on August 29, 1977, and March 1, 1978, resoectively.
- 4. The staff has reviewed the activities associated with the proposed opera-tion of the plant and the potential impacts, both beneficial and adverse, I which are summarized as follows:
- a. [This paragraph in the DES dealt with the need for power and alternate energy sources. Due to recent NRC rulemaking, the comment is no longer applicable. See Sections 2 and 3.]
- b. Alteration of about 500 ha (1235 acres) of land for the plant has been necessary. Of this, about 360 ha (880 acres) will be used as a cooling pond. About 289 ha (715 acres) of prime farmland will be lost from agricultural production for at least the operating lifetime of the station, or beyond (Sec. 4.2.2).
- c. The average consumptive water use of the plant (by evaporative losses from the cooling pond) will be about 0.8 m a/s (28 cfs) (maximum loading, average flow) (Sec. 4.2.3).
- d. Alteration of total dissolved solids concentrations in the Tittabawassee River due to plant discharges may produce small to moderate impacts on existing and potential new water users (Sec. 5.3.1). However, only negligible chemical impacts on biota are expected (Sec. 5.5.2.3).
- e. The heated water from the cooling pond blowdown will be assimilated rapidly in the Tittabawassee River; thus no thermal impact on down-stream water users (Sec. 5.3.2) or biota (Sec. 5.5.2) is expected.
- f. The Midland Plant is located in the floodplain of the Tittabawassee River. However, provisions have been made so that the increase in flood levels will be very small. In addition, plant construction necessitated relocation of Bullock Creek. Flood levels in this relocated channel will be lower than before. Thus, impacts of plant operation are expected to be minor (Sec. 5.3.3).
- g. Atmospheric impacts from cooling pond operation will include fogging and icing. Under some conditions fogging is likely to have an adverse impact on road traffic adjacent to the cooling pond; however, icing impacts to vegetation are expected to be small (Sec. 5.4.1).
- h. The cooling pond will attract waterfowl; however, the impacts on waterfowl will be small in terms of population effects (Sec. 5.5.1).
If locally large adverse impacts.are observed, the applicant will be required to take action (Sec. 6.1).
- i. Adverse impacts on terrestrial biota along the transmission-line 1 right-of-way will be minor (Sec. 5.5.1).
vi
- j. Changes in the Midland Plant intake design are expected to resvit in less severe impacts on aquatic biota than predicted in the FES-CP (Sec. 5.5.2).
- k. No adverse impact on Federal or state endangered or threatened species is expected (Sec. 5.6).
- 1. The staff is currently seeking a determination of eligibility of two archeological sites for inclusion in the National Register of Historic Places (Sec. 5.7).
- m. Attraction of waterfowl to the Midland Plant cooling pond may result in occasional agricultural losses on nearby farms during years when harvesting of crops is delayed due to adverse weather conditions (Sec. 5.8).
- n. Impacts on employment, the local economy, and on community and county services are expected to be minor (Sec. 5.8).
- o. Very small (much less than from normal background radiation) radio-logical impact on man or on biota other than man is expected to result from routine operation of the plant (Sec. 5.9.3).
l
- p. The risk associated with accidental radiation exposure is very low (Sec. 5.9.4).
- q. Area gaseous emissions are expected to be reduced as a consequence of Midland Unit 1 providing process steam for the Dow Chemical Company (Sec. 5.4.2).
- 5. The draft of this environmental statement was made available to the public, to the Environmental Protection Agency, and to other specified agencies in February 1982.
- 6. On the basis of the analyses and evaluations set forth in this statement, and after weighing the environmental, economic, technical, and other benefits against environmental and economic costs and after considering available alternatives at the operating-license stage, the staff concludes that the action called for under NEPA and 10 CFR Part 51 is the issuance of operating licenses for Midland Plant Units 1 and 2 subject to the following conditions for the protection of the environment (Sec. 6.1):
- a. Before engaging in additional construction or operational activities that may result in a significant adverse impact that was not evaluated or that is significantly greater than that evaluated in this statement, the applicant shall provide written notification of such activities to the Director of the Office of Nuclear Reactor Regulation and shall receive written approval from that office before proceeding with such activities.
- b. The applicant shall carry out the environmental monitoring programs identified in Section 5 of this statement, as modified and approved by the staff, and implemented in the Appendix B Environmental Protection l
i Plan (nonradiological) and Appendix A Technical Specifications vii
I (radiological) that will be incorporated in the operating licenses for Midland Units 1 and 2.
- c. If adverse environmental effects or evidence of irreversible environ-mental damage occurs during the operating life of the plant, the applicant shall provide the staff with an analysis of the problem and a proposed course of action to alleviate it. 3 1
viii
TABLE OF CONTENTS l Pg ABSTRACT ............................... iii
SUMMARY
AND CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . . v CONTENTS ............................... ix LIST OF FIGURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . xii , i LIST OF TABLES ............................ xiii FOREWORD ............................... xv
- 1. INTRODUCTION ........................... 1-1 1.1 Administrative History . . . . . . . . . . . . . . . . . . . . . 1-1
- 1. 2 Permits and Licenses . . . . . . . . . . . . . . . . . . . . . . 1-2
- 2. PURPOSE AND NEED FOR ACTION . . . . . . . . . . . . . . . . . . . . 2-1
- 3. ALTERNATIVES ........................... 3-1
- 4. PROJECT DESCRIPTION AND AFFECTED ENVIRONMENT ........... 4-1 )
4.1 Rssums . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 ' 4.2 Facility Description . . . . . . . . . . . . . . . . . . . . . . 4-1 4.2.1 External Appearance and Plant Layout . . . . . . . . . . . . 4-1 4.2.2 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2 4.2.3 Water Use ......................... 4-2 4.2.4 Cooling System . . . . ................... 4-2 4.2.5 Radioactive-Waste-Management System ............ 4-3 4.2.6 Nonradioactive-Waste-Management Systems .......... 4-4 4.2.7 Power-Transmission Systems . . . . . . . . . . . . . . . . . 4-9 4.3 Project-Related Environmental Descriptions . . . . . . . . . . . 4-9 4.3.1 Hydrology ......................... 4-9 4.3.2 Water Quality ....................... 4-9 l 4.3.3 Climatology and Air Quality ................ 4-10 4.3.4 Ecology .................... ..... 4-11 ? I 4.3.5 Endangered and Threatened Species ............. 4-12 4.3.6 Historic and Prehistoric Sites . . . . . . . . . . . . . . . 4-13 4.3.7 Socioeconomics . . . . . . . . . . . . . . . . . . . . . . . 4-14 l References ............................. 4-17
- 5. ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS . . . . . . . . . 5-1 5.1 Resums . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.2 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.2.1 Plant Site . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 ,
5.2.2 Transmission Lines . . . . . . . . . . . . . . . . . . . . . 5-2 4 5.3 Water ............................. 5-2 5.3.1 Use ............................ 5-2 5.3.2 Quality .......................... 5-3 5.3.3 Floodplain Aspects . . . . . . . . . . . . . . . . . . . . . 5-5 ix
l l l CONTENTS (Cont.) _P.jLqe 5.4 Air Quality .......................... 5-6 5.4.1 Fog and Ice ........................ 5-6 5.4.2 Emissions and Dust . .................... 5-7 5.5 Ecology ............................ 5-8 5.5.1 Terrestrial ........................ 5o 5.5.2 Aquatic .......................... 5-10 5.6 Endangered and Threatened Species . .............. 5-12 5.6.1 Terrestrial ........................ 5-12 5.6.2 Aquatic .......................... 5-13 5.7 Historic and Prehistoric Sites . . . . . . . . . . . . . . . . . 5-13 5.8 Socioeconomics . . . . . . . . . . . . . . . . . . . . . . . . . 5-13 5.8.1 Population . . . . . . . . . . . . . . . . . . . . . . . . . 5-13 5.8.2 Local Economy and Labor Market . . . . . . . . . . . . . . . 5-13 5.8.3 Taxes ........................... 5-14 5.8.4 Housing .......................... 5-15 5.8.5 Transportation . . . . . . . . . . . . . . . . . . . . . . . 5-15 5.8.6 Offsite Land Uses ...... .............. 5-15 5.8.7 Community Services and Institutions ............ 5-16 5.8.8 Summary of Socioeconomic Impacts . . . . . . . . . . . . . . 5-16 5.9 Radiological Impacts . . . . . . . . . . . . . . . . . . . . . . 5-16 5.9.1 Regulatory Requirements .................. 5-16 5.9.2 Operational Overview . . . . . ............... 5-17 5.9.3 Radiological Impacts from Routine Operation ........ 5-19 5.9.3.1 Radiation Exposure Pathways: Dose Commitments . . . . . 5-19 5.9.3.1.1 Occupational Radiation Exposure for PWRs . . . . . . 5-20 5.9.3.1.2 Public Radiation Exposure ............. 5-22 Transportation of Radioactive Materials . . . . . . . . . . . 5-22 Direct Radiation for PWRs . . . . . . . . . . . . . . . . . . 5-22 Radioactive Effluent Releases: Air and Water . . . . . . . . 5-22 5.9.3.2 Radiological Impact on Humans ............. 5-24 5.9.3.3 Radiological Impact on Biota Other Than Humans . . . . . 5-26 5.9.3.4 Radiological Monitoring . ............... 5-26 5.9.3.4.1 Preoperational . . . . . . . . . . . . . . . . . . . 5-27 5.9.3.4.2 Operational .................... 5-27 5.9.4 Environmental Impacts of Postulated Accidents ....... 5-28 5.9.4.1 Plant Accidents .................... 5-28 5.9.4.2 General Characteristics of Accidents . . . . . . . . . . 5-28 (1) Fission Product Characteristics ............. 5-29 (2) Exposure Pathways .................... 5-30 (3) Health Effects . . . . . . . . . . . . . . . . . . . . . . 5-31 l (4) Health Effects Avoidance . . . . . . . . . . . . . . . . . 5-31 5.9.4.3 Accident Experience and Observed Impacts . . . . . . . . 5-32 5.9.4.4 Mitigation of Accident Consequences .......... 5-34 (1) Design Features ..................... 5-34 (2) Site Features ...................... 5-35 (3) Emergency Preparedness . . . . . . . . . . . . . . . . . . 5-36 5.9.4.5 Accident Risk and Impact Assessment .......... 5-37 (1) Design-Basis Accidents . . . . . . . . . . . . . . . . . . 5-37 (2) Probabilistic Assessment of Severe Accidents . . . . . . . 5-39 ' (3) Dose and Health Impacts of Atmospheric Releases ..... 5-42 X I
CONTENTS (Cont.)
. P_ag (4) Economic and Societal Impacts . . . . . . . . . . . . . . 5-43 (5) Releases to Groundwater ................. 5-44 l (6) Risk Considerations ................... 5-45 (7) Uncertainties ...................... 5-48 5.9.4.6 Conclusions ...................... 5-49 5.10 Impacts from the Uranium Fuel Cycle . . . . . . . . . . . . . . 5-50 5.11 Decommissioning . . . . . . . . . . . . . . . . . . . . . . . . 5-50 5.12 Emergency Planning Impacts. ,................. 5-51 References ............................. 5-51
- 6. EVALUATION OF THE PROPOSED ACTION . . . . . . . . . . . . . . . . . 6-1 -
6.1 Unavoidable Adverse Environmental Effects . . . . . . . . . . . 6-1 6.2 Irreversible and Irretrievable Commitments of Resources . . . . 6-1 6.3 Relationship Between Local Short-Term Uses of Man's Environment and the Maintenance and Enhancement of Long-Term P roducti vi ty . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2 6.4 Benefit-Cost Summary . . . . . . . . . . . . . . . . . . . . . . 6-2 6.4.1 Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2 6.4.2 Costs ........................... 6-3 6.4.3 Conclusions ........................ 6-3
- 7. LIST OF CONTRIBUTORS ....................... 7-1
- 8. LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS ENVIRONMENTAL STATEMENT ARE SENT . . . . . . . . . . . . . 8-1
- 9. RESPONSES TO COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT . . . . 9-1 APPENDIX A. COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT . . . . . . A-1 APPENDIX B. DRAFT NPDES PERMIT FOR CONSUMERS POWER COMPANY, MIDLAND PLANT ...................... B-1 APPENDIX C. EXAMPLES OF SITE-SPECIFIC DOSE-ASSESSMENT CALCULATIONS . . C-1 APPENDIX D. NEPA POPULATION-DOSE ASSESSMENT . . . . . . . . . . . . . D-1 APPENDIX E. REBASELINING 0F THE RSS RESULTS FOR PWRs . . . . . . . . . E-1 APPENDIX F. CONSEQUENCE MODELING CONSIDERATIONS . . . . . . . . . . . F-1 APPENDIX G. IMPACTS OF THE URANIUM FUEL CYCLE . . . . . . . . . . . . G-1 APPENDIX H. INFORMATION CONCERNING ENDANGERED AND THREATENED SPECIES ......................... H-1 APPENDIX I. CORRESPONDENCE RELATIVE TO HISTORIC AND PREHISTORIC SITES IN THE VICINITY OF MIDLAND PLANT UNITS 1 AND 2 . . . I-1 l
X1 l l
i LIST OF FIGURES Figure a Paqe 4.1 Map Showing Location of Site Relative to City of Midland, Dow Chemical Plant, and Other Local Features ......... 4-20 4.2 Maximum Allowable Blowdown Flow Rate vs. Blowdown Excess Temperature at Various River-Flow Conditions ......... 4-21 4.3 Surface Wind Rose at the Midlared Plant ............ 4-22 4.4 Estimated Year 2020 Population Distribution for 0-10 and 10-50 Miles from the Midland Plant .............. 4-23 5.1 Tittabawassee River 100-Year Floodplain . . . . . . . . . . . . 5-56 5.2 Potentially Meaningful Exposure Pathways to Individuals . . . . 5-57 5.3 Schematic Outline of Atmospheric Pathway Consequence Model .. 5-58 5.4 Probability Distributions of Individual Dose Impacts ..... 5-59 5.5 Probability Distribution of Population Exposures ....... 5-60 5.6 Probability Distribution of Early Fatalities ......... 5-61 5.7 Probability Distributions of Cancer Fatalities ........ 5-62 5.8 Probability Distribution of Mitigation Measures Cost ..... 5-63 5.9 Individual Risk of Dose as a Function of Distance . . . . . . . 5-64 5.10 Isopleths of Risk of Early Fatality per Reactor Year to an Individual .......................... 5-65 5.11 Isopleths of Risk of Latent Cancer Fatality per Reactor Year to an Individual ....................... 5-66 F.1 Probability Distribution of Early Fatalities for No Evacuation .......................... F-6 f xii
LIST OF TABLES Table P_ag_e 4.1 Monthly Cooling Pond Performance for One Unit Operating . . . . . 4-24 4.2 Monthly Cooling Pond Performance for Both Midland Units Operating . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-25 4.3 Maximum and Minimum Temperatures during Hourly Simulations for 40-Day Period . . . . . . . . . . . . . . . . . . . . . . . . . . 4-26 5.1 Incidence of Job-Related Mortalities. . . . . . . . . . . . . . . 5-67* 5.2 Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor (Table S.4) . . 5-68 5.3 Radiological Environmental Monitoring Pro Phase . . . . . . . . . . . . . . . . . . gram - Operational ............ 5-69 5.4 Activity of Radionuclides in a Midland Reactor Plant at 2552 MWt ............................ 5-70 5.5 Approximately 2-Hour Radiation Doses from Design Basis Accidents at Exclusion Area Boundary .............. 5-72 l 5.6 Summary of Atmospheric Releases in Hypothetical Accident Sequences in a PWR (Rebaselined) ................ 5-73 5.7 Summary of Environmental Impacts and Probabilities ....... 5-74 5.8 Average Values of Environmental. Risks Due to Accidents per Reactor-Year .......................... 5-75
- 5. 9 Uranium-Fuel-Cycle Environmental Data (Table S.3) . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-76 6.1 Benefit-Cost Summary for the Midland Plant ........... 6-4 C.1 Calculated Releases of Radioactive Materials in Gaseous Effluents from the Midland Plant Units 1 and 2 ......... C-5 C.2 Summary of Atmospheric Dispersion Fac. tors and Relative Deposition Values for Maximum Effluent-Control-Boundary and Receptor Locations near the Midland Plant Units 1 and 2 . . . C-6 !
C.3 Nearest Pathway Locations Used for Maximum Individual Dose Commitments for the Midland Plant . . . . . . . . . . . . . . . . C-7 ; C.4 Calculated Releases of Radioactive Materials in Liquid ' Effluents from the Midland Plant Units 1 and 2 ......... C-8 C.5 Summary of Hydrologic Transport and Dispersion of Liquid Releases from the Midland Plant Units 1 and 2 . . . . . . . . . . C-10 C.6 Annual Dose Commitments to a Maximally Exposed Individual { near the Midland Plant ..................... C-11 C.7 Calculated Appendix I Dose Commitments to a Maximally Exposed Individual and to the Population from Operation of the Midland Plant . . . . . . . . . . . . . . . . . . . . . . . . . . C-12 C.8 Calculated RM-50-2 Dose Commitments to a Maximally Exposed Individual from Operation of the Midland Plant ......... C-13 i C.9 Annual Total-Body Population Dose Commitments, Year 2000 .... C-14 xiii
TABLES (Cont.) Table E.1 Key to PWR Accident Sequence Symbols .............. E-6 G.1 Radon Releases from Mining and Milling Operations and Mill Tailings for Each Year of Operation of the Model 1000-MWe LWR . . G-8 G.2 Estimated 100-Year Environmental Dose Commitment for Each - Year of Operation of the Model 1000-MWe LWR . . . . . . . . . . . G-8 G.3 Population-Dose Commitments from Unreclaimed Open-Pit Mines for Each Year of Operation of the Model 1000-MWe LWR ...... G-9 G.4 Population-Dose Commitments from Stabilized-Tailings Piles for Each Year of Operation of the Model 1000-MWe LWR ...... G-9 t xiv _ _ _ _ _ _ _ _ \
FOREWORD This environmental statement was prepared by the U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor Regulation (the staff), in accor-dance with the Commission's regulation,10 CFR Part 51, which implements the requirements of the National Environmental Policy Act of 1969 (NEPA). This environmental review deals with the impacts of operation of the Consumers Power Company's Midland Plant Units 1 and 2. Assessments relating to operation that are presented in this statement augment and update those described in the Final Environmental Statement-Construction Phase (FES-CP) that was issued in March 1972 and the Final Supplement issued in June 1977 in support of issuance of construction permits for Midland 1 and 2. The information to be found in the various sections of this statement updates the FES-CP in four ways: (1) by evaluating changes in facility design and operation that will result in different environmental effects of operation (including those which would enhance as well as degrade the environment) than those projected during the preconstruction review; (2) by reporting the results of relevant new information that has become available subsequent to the issu-ance of the FES-CP; (3) by factoring into the statement new environmental policies' and statutes that have a bearing on the licensing action; and (4) by identifying unresolved environmental issues or surveillance needs which are to be resolved by means of license conditions. (No unresolved environmental issues or surveillance needs have been identified in this statement for the case of Midland 1 and 2.) Introductions (rssumds) in appropriate sections of this statement summarize both the extent of updating and the degree to which the staff considers the subject to be adquately reviewed. Copies of this statement, the FES-CP (1972), and the Final Supplement (1977) are available for inspection at the Commission's Public Document Room,1717 H Street NW, Washington, DC, and at the Grace Dow Memorial Library,1710 West St. Andrews Road, Midland, Michigan 48640. The latter two documents may be reproduced at either location. Single copies of this statement may be obtained by writing to: division of Technical Information, Document Control Office U.S. Nuclear Regulatory Commission Washington, DC 20555 (or as stated on the front cover of this document) t Ronald W. Hernan is the NRC Licensing Project Manager for this project. He may be contacted at the above address or at 301/492-8395. t Xv L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - _ _ . . _ _ - - - _ _ . _ . - - _
l l
- 1. INTRODUCTION The proposed action is the issuance of operating licenses to the Consumers Power Company for startup and operation of the Midland Plant Units 1 and 2 (Midland 1 and 2) in Midland County near Midland, Michigan.
Each generating unit consists of a pressurized-water reactor, a steam turbine-generator, a heat-dissipation system, and associated auxiliary facilities and engineered safeguards. Waste heat will be dissipated to the atmosphare from a 360-ha (880-acre) cooling pond. Makeup water will come from, and wastewater will be discharged to, the Tittabawassee River. The maximum design power levels of the Midland Plant reactors are 2568 MWt (FES-CP, Sec. III-4). Unit 1 will produce about 505 MWe, plus process steam for the Dow Chemical Co.; Unit 2 will produce about 852 MWe. The rated core operating power level requested in the application is 2452 MWt. 1.1 ADMINISTRATIVE HISTORY On January 13, 1969, the Consumers Power Company (the applicant) filed an application with the Atomic Energy Commission (AEC), now Nuclear Regulatory Commission (NRC), for permits to construct Midland 1 and 2. The conclusions resulting from the staff's environmental review were issued as a Final Envi-ronmental Statement--Construction Phase in March 1972. Following reviews by the AEC regulatory staff and its Advisory Committee on Reactor Safeguards, public hearings were held before an Atomic Safety and Licensing Board in June-July 1971 and May-June 1972. Construction Permit Nos. CPPR 81 and CPPR 82 were issued on December 15, 197;, fsv Units 1 and 2. On August 29, 1977, the applict"t L. :nitted applications for operating licenses for the Midland Plant Unit & coe The applicant tendered a Final Safety Analysis Report (FSAR) ano F5v;cc, catal Report (ER-OL),* in support of the licenses on August 31, 1977, and March 1, 1978, respectively. The ER-OL has been updated and is current to December 1981. The ER-OL was docketed on April 14, 1978. Operational safety and environmental reviews were then ; initiated, i As of December 1981, construction of the Midland P}3nt was approximately 73% complete. The staff estimates that Unit 1 will be ready for fuel loading in December 1983, and Unit 2 will be ready for fuel loading in July 1983.
*" Midland Plant Environmental Report, Operating License Stage," issued by Consumers Power Company in March 1978. Hereinafter this document is cited in the body of the text as the ER-OL, usually followed by a specific section, page, figure, or table number. The Final Enviromental Statement--Construction Phase, published in March 1972, is referred to as the FES-CP.
1-1
1-2
- 1. 2 PERMITS AND LICENSES The applicant has provided in Section 12 of the ER-OL, as updated, a status listing, as amended through Revision 10, November 1979, of environmentally related permits, approvals, and licenses required from Federal and state agencies in connection with the proposed project. The staff has reviewed the listing and other information and has determined that all major permits and approvals have been obtained except certification pursuant to the Clean Water Act of 1977. The issuance of such certification by the State of Michigan Water Resources Commission is a necessary prerequisite for the issuance of an operating license by the Nuclear Regulatory Commission unless this requirement has been waived as provided in the Act. The State of Michigan is proceeding with the review of the application for the NPDES permit and has prepared a draft permit. This draft permit is included as Appendix B of this report and has been issued by the State of Michigan for public comment. The final permit, when issued, will also satisfy the requirements of the 401 Certification. If the permit, in its final issued form, contains significant changes from the draft permit contained herein, a supplement to this statement will be issued by the NRC to document the changes.
The staff is not aware of any potential non-NRC licensing difficulties that would significantly delay or preclude the proposed operation of the plant. 4 l _____________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ - - - _1 l
- 2. PURPOSE OF AND NEED FOR ACTION The Commission has amended 10 CFR Part 51, " Licensing and Regulatory Policy and Procedures for Environmental Protection," effective April 26, 1982, to provide that need for power issues will not be considered in ongoing and future operating-license proceedings for nuclear power plants unless a showing of "special circumstances" is made under 10 CFR Section 2.758 or the Commis-sion otherwise so requires (47 FR 12940, March 26,1982). Pursuant to the amended regulations, need for power issues need not be addressed by operating license applicants in environmental reports to the NRC, nor by the staff in environmental impact statements prepared in connection with operating license applications. See 10 CFR Sections 51.21, 51.23(e), and 51.53(c).
This policy has been determined by the Commission to be justified whether or not the additional capacity to be provided by the nuclear facility may be needed to meet the applicant's load responsibility. The Commission has deter-mined that the need for power is fully considered at the construction permit (CP) stage of the regulatory review where a finding of insufficient need could factor into denial of issuance of a CP. At the operating license (OL) review stage, the proposed plant is substantially constructed and a finding of insuf-ficient need would not, in itself, result in denial of the operating license. The Commission was further influenced by the substantial information which supports the conclusion that nuclear plants are lower in operating costs than conventional fossil plants. If conservation, or other factors, lowers antici-pated demand, utilities remove generating facilities from service according to their costs of operation, with the 'most expensive facilities removed first. Thus, a completed nuclear plant would serve to substitute for less economical generating capacity (47 FR 12940, March 26,1982). See also 46 FR 39440, August 3, 1981. Accordingly, this final environmental statement does not consider "need for power." Section 6 does, however, consider the savings associated with opera-tion of the nuclear plant. 2-1
- 3. ALTERNATIVES The Commission has amended its regulations in 10 CFR Part 51, effective April 26, 1982, to provide that issues related to alternative energy sources will not be considered in ongoing and future operating license proceedings for nuclear power plants unless a showing of special circumstances is made under 10 CFR Section 2.758 or the Commission otherwise so requires (47 FR 12940, March 26, 1982). In addition, these issues need not be addressed by operating license applicants in environmental reports to the NRC, nor by the staff in environmental impact statements prepared in connection with operating license applications. See 10 CFR Sections 51.21, 51.23(e), and 51.53(c).
In promulgating this amendment, the Commission noted that alternative energy source issues are resolved at the CP stage and the CP is granted only after a finding that, on balance, no obviously superior alternative to the proposed nuclear facility exists. The Commission concluded that this determination is unlikely to change even if an alternative is shown to be marginally environ-mentally superior in comparison to operation of the nuclear facility because of the economic advantage which operation of the nuclear plant would have over available alternative sources (47 FR 12940, March 26,1982). See also 46 FR 39440, August 3, 1981. . By earlier amendment (46 FR 28630, May 28,1981), the Commission also provided that consideration of alternative sites will not be undertaken at the OL stage, except upon a showing of special circumstances under 10 CFR Sec-tion 2.758. Accordingly, this final environmental statement does not consider alternative energy sources or alternative sites. I o 3-1 L.. ..
- - - . - - - - - - - - - - - I
- 4. PROJECT DESCRIPTION AND AFFECTED ENVIRONMENT 4.1 RESUME Several changes made in plant operating characteristics and design since the FES-CP was issued are described in this section: plant layout is slightly modified due to the relocation of agricultural drains and the elimination of a cooling tower (Secs. 4.2.1 and 4.2.4.3); the amount of land used for the plant is slightly increased (Sec. 4.2.2); the dewatering wells used to control groundwater levels in the power-block area will discharge to the cooling pond
'(Sec. 4.2.3); the cooling system intake structure location has been moved from a stilling basin to the Tittabawassee River shoreline (Sec. 4.2.4.1); the plant discharge structure will now terminate at a new location (Sec. 4.2.4.4);
less sulfuric acid will be employed to control scaling, resulting in smaller waste discharges (Sec. 4.2.6.1); sodium'hypochlorite will be used as a biocide rather- than gaseous chlorine, resulting in increased discharges of sodium (Sec. 4.;2.6.1); plant discharges of phosphate will be less than previously expected (Sec. 4.2.6.1); and the 138-kV startup transmission lines have been rerouted (Sec. 4.2.7). New or updated information relevant to the operational phase of Midland 1 and 2 is also provided in this section: the amount of prime farmland contained within the site boundaries- is given (Sec. 4.2.2); nonradioactive gaseous emissions are described (Sec. 4.2.6.3); the average flow of the river is slightly higher than originally estimated (Sec. 4.3.1.1); water quality data originally presented in the FES-CP are confirmed (Sec. 4.3.2); information on severe weather and site atmospheric dispersion characteristics is now provided (Sec. 4.3.3.1), as is information on air quality (Sec. 4.3.3.2); the terrestrial and aquatic faunal composition cf the cooling pond has been re-reviewed in light of new monitoring data (Secs. 4.3.4.1 and 4.3.4.2); new information concerning the occurrence of endangered and threatened species is discussed (Sec. 4.3.5); and the socioeconomic characteristics of the site area are. updated and projected to when operation will begin (Sec. 4.3.7). Historic and prehistoric sites are considered in Section 4.3.6. In addition, the staff has used different and improved assessment methodology plus new information to re-evaluate the thermal performance of the cooling pond as it relates to the elevated _ temperature in the pond blowdown to the river (Sec. 4.2.6.2).
<4.2. FACILITY DESCRIPTION 4.2.1 External Appearance and Plant Layout The external appearance and layout of the plant remain essentially unchanged i from what was described in the FES-CP (Sec. III. A), with the exceptions that two agricultural ~ drains that were located in the area now occupied by the cooling pond have been relocated to the plant site boundary, and a cooling 4-1
w . 4-2 tower included in the original design (FES-CP, Fig. III-2) will not be built. The applicant plans to construct emergency preparedness facilities to meet the Commission's upgraded emergency planning requirements contained in Appendix E to 10 CFR Part 50, " Emergency Planning and Preparedness for Production and Utilization Facilities." These plans include an Emergency Operations Facility (EOF), which will be located in the Bay City Service Center approximately 18 miles east of the plant in Bay City, Michigan. The design specifications for the EOF are formulated utilizing the requirements of NUREG-0696 as a basis. The offsite alternate EOF is expected to be in a conventional building that meets applicable building and zoning requirements and, therefore, it not expected to adversely impact the area. A map showing the location of the site in relation to the City of Midland, the Dow Chemical Plant and other features is presented in Figure 4.1. 4.2.2 Land Use The plant site comprises about 500 ha (1235 acres) (ER-OL, Sec. 2.1.3.1), rather than the 480 ha (1190 acres) reported in the FES-CP (Sec. I.1). This includes about 360 ha (880 acres) developed as a cooling pond (ER-OL, Sec. 4.3.1.1), as well as 4 ha (10 acres) for the power block. Approximately 289 ha (715 acres) of the plant site have been identified as prime agricultural land by the U.S. Soil Conservation Service (Ref. 1). The site also contains a permanent access road to the plant northwest of the facilities. The remainder of the land is being left in its natural state or landscaped to screen the plant from adjacent areas. 4.2.3 Water Use Plant consumptive water use will result mainly from evaporation of plant condenser cooling water from the cooling pond, about 0.8 m s /s (28 cfs) (maxi-mum plant loading, average river flow). The approximately 0.42 m 8 /s (15 cfs) of purified water used for generation of process steam for the Dow Chemical Co. (see Sec. 2.5) is provided by Dow and is not appropriate to a discussion of Midland Plant water use. Plant water use estimates have not changed appre-ciably since issuance of the FES-CP (Secs. III.D and V.8). No groundwater will be used for normal onsite plant operation. The offsite visitor / training center will use about 2.1 x 10 4 m3 /s (4875 gpd) and the outage building will use about 3.3 x 10 4 m3 /s (7500 gpd) of groundwater when this facility is in use. This water will be obtained from private wells (Ref. 28). Groundwater collected from the power block dewatering system will be routed to the cooling pond. 4.2.4 Cooling System 4.2.4.1 Intake Structure The river intake structure, originally to be located in a stilling basin (FES-CP, Sec. III.D), has been placed on the Tittabawassee River shoreline (ER-OL, Fig. 3.4-8). River water is supplied from the river intake structure l to the makeup pump structure through a single 240-cm (96-in) diameter pipe. l The makeup water is pumpet from the pump structure into the cooling pond through a 180-cm (72-in) diameter concrete pipe (ER-OL, Sec. 3.4.4). The intake structure desion includes trash racks with 76 mm (3-in) openings and l
4-3 intake structure design includes trash racks with 76-mm (3-in) openings and three traveling screens with 9.5 mm (3/8-in) mesh to prevent debris from entering the system (ER-OL, Sec. 3.4.4). Depending on makeup flow rates (Sec. 4.2.6.2), approach velocities at the screens will vary from 0.12 m/s (0.42 ft/s) to 0.3 m/s (1.0 ft/s) (ER-OL, Table 3.4-7). 4.2.4.2 Cooling Pond The description of the approximately 360-ha (880 acre) cooling pond presented in the FES-CP (Secs. III.A, D) remains valid. 4.2.4.3 Cooling Tower
- A cooling pond-blowdown cooling tower originally proposed to provide additional cooling of pond water prior to its discharge to the Tittabawassee River (FES-CP, Sec. III.D) has been excluded from the current plant design (ER-OL, Sec. 3.4.5).
4.2.4.4 Discharge Structure The discharge structure will be at a different location than initially planned (FES-CP, Sec. III.D). The new location is about 90 m (300 ft) downstream of the discharge point for Dow Chemical Company's tertiary treatment holding pond and about 180 m (600 ft) downstream of the Midland intake structure (ER-OL, Fig. 5.18-1). The Midland blowdown-discharge system will include three parallel concrete pipes of 90-cm (36-in) diameter originating in the coolest portion of the cooling pond (ER-OL, Sec. 3.4.5) which combine into a single pipe. The river discharge structure consists of three valved 80-cm (30-in) diameter dicharge pipes to the Tittabawassee River.* Riprap will be placed in front of the outfall at the river to protect the riverbed from erosion. A concrete apron with riprap around the edges also protects the riverbed from erosion (ER-OL, Sec. 3.4.5). 4.2.5 Radioactive-Waste-Management System Under requirements set by Part 50.34a of Title 10 of the Code of Federal Regulations, an application for a permit to construct a nuclear power reactor must include a preliminary design for equipment to keep levels of radioactive materials in effluents to unrestricted areas as low as is reasonably achievable (ALARA). The term ALARA takes into account the state of technology and the economics of improvements in relation to benefits to the public health and safety and other societal and socioeconomic considerations and in relation to the utilization of atomic energy in the public interest. Appendix I to 10 CFR Part 50 provides numerical guidance on radiation dose design objectives for light-water-cooled nuclear power reactors to meet the requirement that radio-active materials in effluents released to unrestricted areas be kept ALARA. To comply with the requirements of 10 CFR 50.34a, the applicant provided final designs of radwaste systems and effluent control measures for keeping levels
- Blowdown is that portion of the cooling pond water discharged to the river to maintain predetermined chemical concentrations in the pond.
l ) .
4-4 of radicactive materials in effluents ALARA within the requirements of Appen-dix I to 10 CFR Part 50. In addition, the applicant provided an estimate of the quantity of each principal radionuclide expected to be released annually to unrestricted areas in liquid and gaseous effluents produced during normal reactor operations, including anticipated operational occurrences. The NRC staff's detailed evaluation of the radwaste systems and the capability of these systems to meet the requirements of Appendix I will be presented in Chapter 11 of the staff's Safety Evaluation Report, which is to be issued in May 1982. The quantities of radioactive material that will be released from the plant (as calculated by the NRC staff) are presented in Appendix C of this statement. Appendix C also contains calculations of doses to individual members of the public and to the general population resulting from these effluent quantities. The staff's detailed evaluation of the solid radwaste system and its capability to accommodate the solid wastes expected during normal operations, including anticipated operational occurrences, are presented in Chapter 11 of the SER. As part of the operating license for this plant, the NRC will require Tech-nical Specifications limiting release rates for radioactive material in liquid and gaseous effluents and requiring routine monitoring and measurement of all principal release points to ensure that the plant operates in conformance with the radiation-dose-design objectives of Appendix I. 4.2.6 Nonradioactive-Waste-Management Systems 4.2.6.1 Chemical Amounts of chemicals expected to be used annually are listed in Table 3.6-6 of ER-OL, and the expected chemical characteristics of plant waste streams are given in Tables 3.6-2, 3.6-4, and 3.6-5 of the ER-OL, as modified in the application to the State of Michigan for the NPDES permit (Ref. 2), the draf t NPDES permit (App. B), and elsewhere (Ref. 3). Changes in these estimates since the FES-CP was issued are discussed below. Cooling Pond Blowdown The cooling pond will be the intermediate sink for many plant chemical wastes prior to their discharge to the Tittabawassee River. Such wastes will include iron removal sump effluents, clean waste sump effluents, spent circulating and service water treatment chemicals, and wastes from the hypochlorite generation system. Detailed listings of chemicals that will be in the cooling pond blow-down are provided in the sources cited above. An automatic control system will be used to regulate the total dissolved solids (TDS) concentration in the cooling pond by adjusting blowdown and plant makeup-water flow rates. The applicant has stated that blowdown will be released only when: (1) the Dow Chemical Plant discharge does not utilize the entire TDS capacity of the river, or (2) ambient river temperatures are less than the monthly maximum allowable, or (3) makeup water compensates for cooling { pond water losses caused by evaporation and seepage, or (4) blowdown flow 3 rates are above 0.14 m /s (5 cfs), in order to meet State of Michigan National Pollutant Discharge Elimination System (NPDES) permit limitations on effluents (see Appendix B). I
l I 1 4-5 Blowdown will be continuously discharged at variable rates in March, April, and May of each year of operation, the period of highest river flow; the staff agrees with the applicant (ER-OL, Secs. 3.4.5 and 5.1.2) that during the remaining months, blowdown discharge is likely to be intermittent, depending on flow conditions. These conclusions are based on recent studies of a long-term (82 yr) daily simulation of cooling pond operation as discussed in Sec-tion 4.2.6.2 and the ER-OL (Sec. 3.4 references). As discussed previously, current plans do not call for the use of a cooling tower to remove heat from cooling pond blowdown prior to its discharge to the Tittabawasse River. Aside from thermal considerations, another effect of a blowdown-cooling tower on effluent chemistry would have been to bring the oxygen concentration of the blowdown into equilibrium with air at the mean temperature of the cooling system. Without cooling-tower aeration, the dis-charge will contain a somewhat lower oxygen concentration, representative of concentrations in the cooling pond at the point of the blowdown-line intake. However, the applicant is committed to maintaining a dissolved oxygen concen-tration of 5 mg/L in the river, in accordance with Michigan Water Quality Standards. Process Water Demineralizer Regeneration Plant process water will be provided by the makeup-demineralizer system, which will initially utilize water from the Midland Municipal Water District. After the first year of plant operation, either municipal water or Dow Chemical Company deionized water may be used at the plant. Discharges of demineralizer regeneration wastes (characterized in Table 3.6-2 of the ER-OL) will be directly to the Tittabawassee River, except during periods when the river contains hich levels of TDS. Under these conditions, the demineralizer regenerant wastes will be discharged to the cooling pond (ER-OL, Sec. 3.6.4). This wastewater stream discharge will be regulated to meet the limitations of the NPDES permit. Cooling Water Treatment Sulfuric acid will be added to the recirculating cooling water before passage through the condenser to control scaling (ER-OL, Sec. 3.6.6). It is currently estimated by the staff that about 3100 metric tons (3400 tons) of sulfuric acid per year will be needed for this purpose compared with the estimate of approximately 4700 metric tons (5100 tons) given in the FES-CP (Sec. III,
- p. III-37), resulting in smaller discharges of sulfate wastes to the cooling pond and the river. These will be discharged in the cooling pond blowdown and will be regulated indirectly via TDS limitations to meet the requirements of the NPDES permit.
The procedure for condenser and service water chlorination has been changed from the use of gaseous chlorine (FES-CP, Sec. III.D.3) to the use of sodium hypochlorite solution (ER-OL, Sec. 3.6.4.2) for engineering, economic, and safety considerations. The biocidal action of sodium hypochlorite is essen-tially identical to that of gaseous chlorine. Normally, the maximum level of equivalent chlorine will be about 2 mg/L in summer and less than 0.5 mg/L in winter. As stated in the FES-CP (Sec. III.D.'3.a) and in agreement with the applicant's conclusions (ER-OL, p. 3.6-7), the staff believes that the cooling pond blowdown discharge will contain no detectable free residual cholorine. However, use of sodium hypochlorite will increase the amount of sodium in the combined plant discharge by about 135 metric tons (150 tons) per year. 1
4-6 Miscellaneous Chemical Wastes As discussed in the ER-OL (Sec. 3.7.2.3), Midland Plant sewage will be proces-sed by the nearby Dow Chemical Plant. Treatment and subsequent discharge of the sewage will be covered by Dow Company permits and therefore will not be further discussed in this environmental statement. A zero phosphate laundry detergent will be used in the plant laundry facility (ER-OL, Sec. 3.7.2.1) instead of the phosphate-containing detergent originally planned (FES-CP, Sec. III.D.3.C). This will eliminate a source of plant-related phosphate additions to the Tittabawassee River. Effluent from the oily waste treatment and laundry waste system will be discharged directly to the Tittabawassee River through the river discharge system. Evaporator blowdown will be transferred to the Dow Chemical Plant for disposal (ER-OL, Sec. 3.6.5.1) and will be covered by Dow permits; therefore, evaporator wastes will not be further discussed in this environmental statement. Several minor waste streams will be discharged either to the cooling pond or to the river, depending on the river flow and TDS content. These streams include treated neutralizing sump and clean waste sump discharges from the evaporator building, and Units 1 and 2 magnetic filter backwash; their expected chemical compositions are listed in Table 3.6-2 of the ER-OL. The waste streams will be regulated to meet the conditions of the NPDES permit. These waste streams will normally be discharged directly to the river, but can be discharged to the cooling pond during periods when the river contains high levels of TDS. 4.2.6.2 Thermal Since the FES-CP was issued, the applicant has reanalyzed the thermal perfor-mance of the cooling pond and the thermal effects of blowdown discharge on the Tittabawassee River. This recnalysis was undertaken because of (1) the adop-tion by the State of Michigan in 1973 of surface-water quality standards that establish heat load limitations for receiving water bodies, (2) the change in plant cooling system design involving elimination of the cooling pond blowdown cooling tower, and (3) the advancement in thermal-field predictive techniques. The staff has reviewed the applicant's analysis, and, as discussed below, generally concurs with the applicant's use of methodology and the resulting conclusions. Cooling Pond The applicant re-evaluated the monthly average pond thermal performance by use of a numerical model that simulated the steady-state heat balance of the pond with the atmosphere (Ref. 4). The pond was represented by two horizontal well-mixed layers, a longitudinally advected heated layer at the surface, and an underlying layer of returning backflow combined with ambient pond water. The pond heat loss due to evaporation was calculated using Meyer's evaporation equation (Ref. 4). The resulting pond thermal performance (calculated by use of monthly average meteorological conditions) is shown in Tables 4.1 and 4.2 for the following plant operating conditions: (1) Unit 1 operating at maximum 1 (
4-7 l l r 1 guaranteed load; (2) Unit 2 operating at maximum guaranteed load; (3) both t units operating at maximum guaranteed load; and (4) Unit 1 back-end limited * ! and Unit 2 with the valves wide open. I The applicant also used a transient two-dimensional model to obtain daily 1 blowdown temperatures that would have been expected in 1966, when meteorological conditions would have produced unusually high water temperatures (Ref. 4). The short-term responsiveness and variability of the cooling pond to meteoro-logical conditions is shown in Table 4.3. River Discharge There are no suitable analytical models known to the staff that can be used to predict the extent of isotherms for very shallow submerged ports in a flowing stream. As a result of varying river depths, the discharge can at times be at the surface. In addition, the Dow Chemical Co. also discharges its tertiary pond effluent into the Tittabawassee River about 90 m (300 ft) upstream from the location of the Midland blowdown discharge. Both discharges are at the south bank of the river. To assess the thermal effects on the river of blow-down in combination with a second upstream discharge, hydraulic modeling is required. The combined thermal effects of both the Dow and Midland discharges were taken into consideration in the modeling study. The applicant has relied on hydraulic modeling not only to delineate the expected size and extent or the thermal plume, but also to determine the operating parameters (blowdown flow rate, number of discharge ports) as a function of river flow, TDS, and blowdown temperature. The staff has reviewed the hydraulic modeling study, as described in Appendix 5.1B-1 of the ER-OL and in Reference 5, and concurs with the approach used by the applicant, as dis-cussed below. A reach of the Tittabawassee River extending from about 30 m (100 ft) upstream to about 610 m (2000 ft) downstream of the Midland Plant's river intake struc-ture was modeled. The Dow Chemical Company tertiary pond discharge and Midland Plant cooling pond makeup and blowdown were simulated in the physical model. For each test, the Dow discharge flow rate was set at 1.8 m 3 /s (65 cfs), with an excess temperature of about 2.7C (4.9F ). River flows modeled range from 26.0 3to 103 m8 /s (920 to 36503 cfs). The plant withdrawal flow rates were 4.3 m /s (150 cfs) and 5.7 m /s (200. cfs)._ The results of the model test are presented in Figure 4.2, which shows the maximum allowable blowdown flow rate for a given blowdown excess temperature for each river flow rate for both one pipe and two pipe operation with equal' flow in each pipe. Thermal plumes for the worst-case of each of the river flows were also tested. However, no values were presented by the applicant to indicate the sizes of the river cross-sectional area or volume of river flow enclosed by the various isotherms. Based on the surface temperature isotherms (ER-OL, Figs. 5.1-1 through 5.1-5) and the applicant's field observation of full vertical mixing in the river, the staff calculated the river cross-sectional areas enclosed by the 2.8C' (5.0F*) isotherm. The results indicated that the maximum area with a water
- Limitation imposed by turbine design on the maximum amount of steam that can be accepted by the low pressure section of the turbine.
4-8 temperature differential higher than 2.8C (5.0F ) would only be about 8% of the entire river cross section. The applicant also simulated daily cooling pond operation for a period of 82 years to estimate the fraction of time that discharge limitations imposed by'the state would not permit blowdown to the river. Input and calculated parameters that determine the blowdown flow rate for each day are: (1) daily average ambient river temperature, (2) daily average ambient river flow rate, (3) daily average ambient river TDS, (4) Dow Chemical Plant discharge flow, excess temperature, and TDS, (5) cooling pond makeup flow rate, (6) cooling pond discharge temperature and TDS, and (7) cooling-pond surface level. The simulation results indicated that the cooling pond blowdown discharge is likely to be continuous during March, April, and May. For the remaining months, the simulation results indicate that the blowdown will have to be intermittently withheld when the following conditions occur: (1) when the Dow Chemical Plant discharge will utilize the entire TDS capacity of the river, or (2) ambient river temperatures are equal to or greater than the monthly maximum allowable specified in the NPDES permit, or (3) makeup cannot compensate for pond water losses caused by evaporation and seepage, or (4) calculated blowdown flow rates will be below 0.14 m3 /s (5 cfs). 4.2.6.3 Other Gaseous Emissions Principal sources of nonradioactive gaseous combustion product emissions during plant operation will be the testing of four standby diesel generators and one fire pump diesel and the use of two auxiliary and three temporary boilers [ Consumers Power Co. comment letter dated April 2, 1982 (see Appendix A)]. The revised duty cycles and expected operating modes of these systems are described in Consumers Power Co. comment letter of April 2,1982 (see Appendix A). Annual emissions from the diesels (using No. 2 diesel oil) are estimated by the applicant to be about 1400 kg (3100 lb) of sulfur dioxide and 13,800 kg (30,400 lb) of nitrogen dioxide. Some particulates will also be emitted by these engines. The auxiliary boilers, which will supply energy for space heat, testing, and startup load requirements, will burn natural gas (ER-OL, Sec. 3.7.1.3). Expected emissions of oxides of nitrogen from these boilers under worst-case (maximum fuel use) conditions have been calculated by the applicant to be about 88,000 kg/yr (195,000 lb/yr) during the startup and testing period and up to 20,900 kg/yr (46,000 lb/yr) when both units are on line (ER-OL, Sec. 3.7.1.3). The three temporary boilers will be used for preoperational testing of the process steam evaporators and will use natural gas. The applicant estimates that annual emission rates for oxides of nitrogen during the testing operations will be 511,000 kg (1.1 x 106 lb) [ Consumers Power Co. comment letter dated April 2, 1982 (see Appendix A)]. The staff has reviewed the applicant's calculated values and finds them typical for the kinds of combustion units that will be employed, l l
i 4-9 Dust Another source of air pollution during station operation will be fugitive dust from vehicle operation. Fugitive dust emissions will be substantially less during plant operation than during the construction phase because most site roads and permanent parking lots will be paved, and almost all earth-moving activities will have been completed. 4.2.7 Power-Transmission Systems Since publication of the FES-CP (Sec. III.B), no changes have occurred in the routing or design of the major (345-kV) transmission lines that run from the Midland Plant to the Tittabawassee Substation to the existing Kenowa/Thetford 345-kV lines. However, changes have occurred in the routing of two 138-kV startup lines. The changes are related to a construction phase condition imposed by NRC, as summarized in item 7.b in the Summary and Conclusions of the FES-CP. Originally, both lines were to cross the Tittabawassee River just west of the railroad bridge, connecting to the proposed Dow South Substation. To conform with condition 2.E.b of the construction permit and to minimize visual impacts, the applicant rerouted one of the 138-kV startup lines to cross the Tittaba-wassee River at the same location as the two 345-kV lines. The second 138-kV startup line extends to a single-circuit lattice steel type-TH tower located east of the cooling pond dike. This line then crosses under the two 345-kV lines and over a roadway and railroad spur to a self-supporting steel pole located on the pond side of the dike berm. The remainder of this line runs south to Gordonville Road along the dike. 4.3 PROJECT-RELATED ENVIRONMENTAL DESCRIPTIONS 4.3.1 Hydrology The discussion of surface water hydrology in Section II.E.3 of the FES-CP remains essentially valid except [ based on 44 years (1936-1980) of river flow records (Ref. 6)] that the average flow of the Tittabawassee River at the gaging station about 1500 m (1 mi) upstream of the plant site is now estimated 3 to be 46.6 m /s (1647 cfs) rather than 43.6 m3 /s (1540 cfs). The discussion of groundwater hydrology in Section II.E.3 of the FES-CP is still valid. At the CP stage, it was anticipated that the perched water table beneath the plant would rise to a level about equal to that of the cooling pond. As expected, this has occurred. However, the applicant now proposes to lower the perched groundwater level during operation. The method by which the water table will be lowered and the resulting environmental effects are described in Section 5.3.1. 4.3.2 Water Quality In the FES-CP (Sec. II, Tables II-2 and II-3) water quality data for the , Tittabawassee River were presented based on three years of measurements prior ' to 1971; da'1 for the river above, below, and at the plant site were given. More recen: water quality data have become available from monitoring studies
4-10 conducted by the applicant (ER-OL, Sec. 6.1.1.1), Central Michigan University (ER-OL, Sec. 2.2C), Dow Chemical Co. (ER-OL, Sec. 2.2B), and from a STORET compilation done by the Michigan Department of Natural Resources. These contemporary data indicate no significant changes in water quality since the construction permit was issued. 4.3.3 Climatology and Air Quality I 4.3.3.1 Climatology The general climatic description of the site presented in Section II.E.5 of the FES-CP remains valid. Information on severe weather, which was not dis-cussed in the FES-CP, is summarized below, and data on site dispersion charac-teristics are discussed. Severe Weather Because of the location of the site with respect to principal storm tracks and contrasting air masses alternating over the area, severe weather is not uncom-mon. Thunderstorms can be expected to occur in the area about 33 days annually, with about 67% of these days occurring from May through August (Ref. 7). Hail is expected to occur on one or two days each year (Ref. 8). The " fastest-mile" windspeed reported at Flint was 36 m/s (81 mph) (Ref. 7). Tornado data for the period of 1953 through 1974 indicate that 61 tornadoes were reported within a 26,O]0-km2 (10,000-mi2) area containing the site (Ref. 9). Using the methods of Thom (Ref.10), the recurrence interval for a tornado at the plant site is 1270 years. Ice storms are not uncommon in the vicinity of the site. During the ten year period of 1939 through 1948, 127 days with freezing rain were reported in the site area; an ice accumulation of 13 mm (0.5 in) or more from freezing rain can be expected every two years (Ref. 11). In the period of 1936' to 1970 there were about 17 atmospheric-stagnation cases, totaling about 75 days, reported in the site area (Ref. 12). Additional information on the climate of the area can be found in Section 2.3 of the ER-OL and in climatological reports of the National Weather Service. Atmospheric Dispersion Data on the dispersion characteristics of the site have become available since the FES-CP was issued. For the two year period of March 1,1975, through February 28, 1977, the windflow over the site, as measured at the 10-m (33-ft) level of the onsite meteorological tower, was from the southwest through west about 30% of the time. The directional trequency of onsite winds is shown in Figure 4.3. Winds were calm [ wind speeds less than 0.3 m/s (0.7 mph)] 0.2% of the time at the 10-m level. The applicant has provided joint frequency distributions of wind speed and direction by atmospheric-stability class, based on a vertical temperature difference, from data collected onsite during the period of March 1,1975, through February 28, 1977. These data include wind speed and direction at the 10-m level and vertical temperature difference between the 60-m (197-ft) and 10-m levels (ER-OL, Sec. 2.3.2.5).
i l 4-11 l Estimates of average atmospheric dispersion conditions have been made for the Midland Plant site using the available onsite meteorological data as input to the atmospheric-dispersion model presented in NUREG-0324 (Ref.13), which is based on the straight-line-trajectory model described in Regulatory Guide 1.111 (Ref. 14). Releases were considered partly elevated and partly ground level, depending on wind speed, except for the turbine-building-vent release, which was considered as ground level only. An estimate of increase in relative concentration (X/Q) and relative deposition (D/Q) due to spatial and temporal variations in airflow, not considered in the straight-line model, was included as presented in NUREG-0324. Radioactive decay of effluents and depletion of the effluent plume were considered as described in Regulatory Guide 1.111. 4.3.3.2 Air Quality Air quality data for the Midland area through 1980 have become available since the FES-CP was issued (Refs.15-17 and Consumers Power Co. comment letter, April 2,1982, Appendix A). Data for total suspended particulates (TSP) and for sulfur dioxide (50 )2have been collected in the county; carbon monoxide (CO), ozone (03), and nitrogen dioxide (N02) readings are available from Saginaw County. The data show that Midland County is in compliance with National Ambient Air Quality Standards (NAAQS) for 502 and N02 . In Saginaw County, the 8-hr NAAQS for C0 (10,000 pg/m3, not to be exceeded more than once per year) was exceeded four times in 1980 and six times in 1979; the 1-hr C0 standard (40,000 pg/m3 ) was achieved. TSP concentrations were in compliance with the primary NAAQS in 1979 and 1980, but the 24-hr secondary standard (150 pg/m3 , not to be exceeded more than once per year) was not achieved in 1977 or 1978. No ozone / oxidant data are available for the region. The annual NAAQS for N02 and 03 were met in Saginaw County in 1980 (Consumers Power Co. comment letter, April 2,1982, Appendix A). 4.3.4 Ecology 4.3.4.1 Terrestrial The descriptions of site-area vegetation and wildlife given in the FES-CP (Sec. II.F.2) remain valid; however, some animal species are likely to have been excluded and populations reduced by site construction activities. Much of the 345-kV transmission route from the plant to the Kenowa/Thetford transmission corridor passes through agricultural fields (ER-OL, Sec. 3.9.4.4); natural vegetational communities constitute about one quarter of the total, while about three quarters is agricultural land. The Midland cooling pond attracts shore birds and waterfowl during spring and fall migrations. More than 50 waterbird species have been observed on the cooling pond (Refs.19 and 20). A number of the migrants remain during the summer, but leave when colder weather approaches. A large population of ring-billed gulls has become established at the pond and leaves only when the pond begins to freeze (ER-OL, Sec. 5.6.1). The staff expectc that some water-fowl and shorebirds will remain at the pond for an extended period, or perhaps 3 overwinter, once the Midland Plant becomes operational and the discharge of heated water prevents the pond from freezing. l
4-12 A staff evaluation of a faunal survey of the plant transmission route (Ref. 18) indicates that the species composition of the natural vegetational areas along the rights-of-way is similar to that at the plant site. 4.3.4.2 Aquatic The biotic composition of the Tittabawassee River in the vicinity of the site has remained similar to that described in the FES-CP (Sec. II.F.3). A staff evaluation of more recent surveys (summarized in the ER-OL, Sec. 2.2.2.5) indicates a more diverse species assemblage in the site vicinity, but the staff concludes that this may be primarily related to sampling methodologies and frequencies. It is the staff's opinion that the characteristic low biological productivity contiguous to the plant continues because of (1) water qucaity degradation from municipal and industrial effluents, (2) fluctuating water levels from upstream hydroelectric facilities, (3) elevated suspended solid levels, and (4) flash flooding. Additionally, recent biological monitoring indicates that low biological productivity also results from substrate instability, substrate particle-size composition (predominantly sand), and substrate organic content (Ref. 29). The plant cooling pond has been developing as an aquatic ecosystem since initial filling operations in April 1978. The biotic composition of the pond is derived from the Tittabawassee River; however, the ecosystem is typical of one changing from a lotic (flowing) to lentic (standing) water condition. At least 15 species of fish (with juvenile carp and other minnows dominating) were identified during monitoring of the initial filling phase (ER-OL, Sec. 5.6.2). 4.3.5 Endangered and Threatened Species 4.3.5.1 Terrestrial Based on available information (summarized in Appendix H.2) the staff has determined that the prairie fringed orchid is the only federally proposed plant species that occurs in the tri-county (Bay, Midland, and Saginaw) area encompassing the Midland Plant site and transmission route. No federally listed plant species occur in the area. A staff examination of the applicant's recent monitoring survey (Ref. 18) indicates that this species has not been found on the plant site or transmission route. Furthermore, none of the species listed bybthe state (Appendix H.2) has been found on the plant site. Also as indicated in Appendix H.2, three federally listed bird species occur in the tri-county area of the Midland project: Kirtland's warbler, two sub-species of the peregrine falcon, and the bald eagle; however, a staff evalua-tion, including a review of the applicant's survey (Ref.18), indicates that none of these species is likely to inhabit the plant site or transmission corridor. It is the staff's opinion that these species could occasionally visit these areas during migrations or in search of food. Of the several state-listed bird species known to occur in the tri-county area (see Appendix H.2), only the marsh hawk has been observed along the transmis-sion line route (ER-OL, Sec. 4.2.6).
4-13 i j A staff review of the literature (Refs. 19,20) indicates that the cooling pond is attracting some state-listed species: the double-crested cormorant, common tern, and caspian tern. It is the staff's opinion that other water birds not presently common to the area may be attracted as well. Appendix H.1 is a Fish and Wildlife Service response to an NRC request regarding proposed or listed plant and animal species in the areas associated with the plant. This letter implied concurrence with Table 2.2-la in the ER-OL, which in turn agrees with Appendix H.2. 4.3.5.2 Aquatic No endangered or threatened aquatic species are reported to occur in the water bodies near the plant site or in the water bodies crossed by the transmission corridors (see Appendix H). 4.3.6 Historic and Prehistoric Sites Since publication of the FES-CP, four historic sites in Midland County have been added to the National Register of Historic Places. These are the Oxbow Archeological District in eastern Midland County and the Herbert H. Dow House, the Bradley House, and the Little Forks Archeological District in Midland (Ref. 21). In 1977 the applicant, in consultation with the State Historic Preservation Officer (SHP0), conducted an archeological survey of the transmission right-of-way through western Saginaw County and southeastern Midland County. The survey identified 25 sites (Ref. 22). In 1979 the applicant, in consultation with the SHP0, carried out a program of archeological mitigation and avoidance related to some of the sites. Four sites were omitted from consideration for avoidance or mitigation because their integrity had been demolished because of sand mining which occurred in the past. Twelve sites were conserved by avoid-ance,11 of which required protection by routing right-of-way traffic around the sites, and by fencing. Nine sites which could not be avoided were mitigated by salvage of cultural material by the University of Michigan Museum of Anthro-pology. This effort is documented in " Report of Archeological Mitigation and Avoidance on a Consumers Power Right of Way in Saginaw and Midland Counties" (February 1980), which was reviewed and approved by the SHP0 (Appendix I, Item 2). In May 1979 the applicant conducted an archeological survey on the tie line right-of-way from the Midland Plant to the Tittabawassee substation. No sites are recommended for consideration of mitigation or avoidance. This survey was performed by the University of Michigan Museum of Anthropology and documented in " Report of a Preliminary Archeological Survey of a Transmission Right-of-Way from the Midland Plant to the Tittabawassee Substation for the Consumers Power 1 Company" (July 1979), which was reviewed and approved by the SHP0 (Appendix I, ! Item 3). In 1978 the applicant, in consultation with the SHP0, conducted a cultural resources survey of the floodplain area, which also included the route of the proposed pond blowdown discharge line. This survey was performed by Common-wealth Associates and documented in " Report No.1966, Archeological and His-torical Investigation of the Floodplain Area, Midland, Michigan." The survey
l 4-14 i identified two significant sites which are considered to be eligible for inclusion to the National Register of Historic Places. The NRC, in consulta-tion with the SHPO, is seeking a determination of eligibility of the two sites in the National Register (Appendix I, Items 1 and 5). 4.3.7 Socioeconomics 4.3.7.1 Population The population in the region has increased since issuance of the FES-CP (Sec. II.C). In 1970, the estimated population within 80 km (50 mi) of the site [ including transient population within 8 km (5 mi)] was 1,044,558 persons; this is projected to increase to about 1,218,760 by 1990 (17%) and to about 1,471,408 by 2020 (ER-OL, Tables 2.1-6 and 2.1-8 combined). The projected distribution of the population in the year 2020 is shown in Figure 4.4. This area includes all or parts of 21 counties (ER-OL, Table 2.1-7). j In the Final Supplement to the FES-CP (Sec. 2.4.1.2), the staff expected most of the labor force for the plant to come from the four counties nearest the plant (Midland, Bay, Saginaw, and Genesee). Portions of three of these, Midland, Bay, and Saginaw, are within 8 km (5 mi) of the plant. The combined population of these counties increased by about 3% (from 846,440 to 871,967) between 1970 and 1980 (Ref. 23). Midland County experienced the largest growth, about 15% to a 1980 total of 73,578; this high rate still was lower than the county's increase of about 2*% from 1960 to 1970 (ER-OL, Sec. 2.1.3.3). Bay, Genesee, and Saginaw counties grew only 2%, 19%, and 4%, respectively, in the 1970-1980 decade. Midland County's 1970-1980 growth was considerably higher than the overall state population increase of about 4% (Ref. 23).
~
State population projections to the year 2000 indicate that of the four coun-ties, only Midland County will continue to grow steadily (by a total of about 13% to about 83,000 people), although the rate of growth is projected to be slower than in the past two decades. Much of this future increase is expected to be from migration into the area (Ref. 24, pp. 10, 12). Populations of Bay, Genesee, and Saginaw counties are expected to decrease by about 5%,17%, and 8%, respectively, by the year 2000, mostly as a result of substantial emigra-tion (Ref. 24, pp. 10, 12). Between 1970 and 1980, the population of the City of Midland increased by about 6% (2095 persons) te 37,250, while the population of the surrounding Midland Township decreased 5% (132 persons) to 2389 residents (Ref. 23). Ingersoll Township (immediately south of both the Midland city limits and the Midland Plant site boundaries) increased from 2285 people in 1970 to 3011 in 1980 (32%); Tittabawassee Township (directly southeast of the city and the plant site boundaries) increased from 4031 residents to 4908 (22%) during the period (Ref. 23). 4.3.7.2 Local Economy and Labor Market Local Economy As discussed in the FES-CP (Sec. II.C), employment in the area of the Midland Plant is concentrated in industry and agriculture. The largest employer in the
4-15 City of Midland continues to be Dow Chemical Co. The next largest employment sources in 1980 were the construction work force for the Midland Plant, pro-jected to peak at about 2000 persons in 1980 (Final Supplement to the FES-CP, Sec. 2.4.1), and Dow Corning, which presently employs about 2300 employees. The staff generally concurs with the estimates made by the applicant (Final Supplement to FES-CP, Sec. 2.4.4) that from 1973 through near completion of plant construction in 1982, salaries paid members of the construction work force will have totaled about $331 million. Local expenditures for subcontracts and equipment are projected at $20 million, about one-fifth of total project expenditures of these types (Final Supplement to the FES-CP, Sec. 2.4.4). Labor Market Information on the labor force has been updated since the FES-CP (Final Sup-plement, Sec. 2.4.1.2). The 1980 labor forces for Midland /Gladwin, Bay, Saginaw, and Genesee/Shiawassee counties were about 29,000, 53,000, 102,000 and 199,000 people, respectively. Unemployment rates were about 10%, 15%, 14%, and 18%, respectively (Ref. 25). Only the Midland /Gladwin area has a lower unemployment rate than the overall state rate of 12.6% (Ref. 26), reflecting the continuing stable employment with Dow Chemical Company (ER-OL, Responses to Questions). 4.3.7.3 Taxes As stated in the Final Supplement to the FES-CP (Sec. 2.4.3), the City of Midland annexed 129 ha (319 acres) of the plant site. The staff has deter-mined that local property taxes collected on the site for fiscal year 1980 (July 1980 through June 1981) totaled about $7 million, compared with the
$11 million estimate that was projected in the Final Supplement to the FES-CP (Sec. 2.4.3). The staff estimates that the $7 million figure represents about 20% of the total assessments paid to the city in fiscal 1980 and is a sixfold increase in local property taxes paid annually on the plant since construction began in 1975. The impact of replacement of these taxes with operation-related taxes is discussed in Section 5.8.3.
4.3.7.4 Housing Additional information on local housing conditions has become available since the Final Supplement to the FES-CP was issued. In 1980, there were about 14,000 households in the City of Midland and 26,000 in Midland County. In 1978, about 70% of all housing units in Midland were single-family homes. In 1981, about 260 single-family units and 70 apartment units (of a total 1713) were empty, representing vacancy rates of about 3% to 4%. The stcff has determined that although area housing construction has decreased as it has elsewhere in the United States, area vacancy rates have remained fairly stable since the FES-CP was issued, and housing supply has kept up with area needs. 4.3.7.5 Transportation As described in the FES-CP (Sec. V.3) and Final Supplement (Sec. 2.4.2.1), the plant site is accessible from the local area via Poseyville and Gordonville Roads (Fig. 4.1), which intersect near the southwestern corner of the site. However, the Poseyville Road has now been widened to four lanes to accommodate
4-16 an increased traffic volume. The applicant has consulted with local officials on traffic problems related to the Midland project and constructed an onsite access road (Stewart Road) to reduce traffic on Miller Road. In addition, in 1976 and 1977, the applicant granted an additional right-of-way to the County Road Commission to allow for future widening of Gordonville Road from two to four lanes. A new bridge on Gordonville Road across the Tittabawassee River has been built to improve plant access (ER-OL, Sec. 2.1.3.3.2, and Responses to Questions). Despite the above, some traffic delays still exist during peak periods at the intersection of Poseyville and Gordonville Roads (Fig. 4.1). 4.3.7.6 Offsite Land Use Use and zoning of the land around the site and along transmission corridors remains essentially as it was described in the FES-CP (Secs. II.B and II.C): industrial directly north and east of the site, mixed residential and agri-cultural to the west, agricultural to the south of the site, and industrial and agricultural along the transmission lines. As discussed in Sections 5.2.2, 5.5.1, and 5.5.2, since construction of the transmission lines is completed, most of the land along the lines is being returned to its original uses (ER-OL, Sec. 2.1.3), except for a small amount occupied by the transmission tower bases and that subjected to maintenance clearing. 4.3.7.7 Community Services and Institutions Schools The enrollment decline in local school districts since 1972 described in the Final Supplment to the FES-CP (Sec. 2.4.2.3) has continued. The staff has determined that as of October 1980, the two school districts in the Midland Plant area (Midland and Bullock Creek) had enrollments of about 10,300 and 2200, respectively, compared to about 12,600 and 2400 in 1971 (FES-CP, Sec. II-D). It is the staff's conclusion that despite the influx of construction workers and their school-aged children, facilities have not been strained; the impact of operation on school facilities is discussed in light of this factor in Section 5.8.7.1. Health, Safety and Recreation Health, police, and fire protection facilities remain essentially unchanged from the descriptions in the FES-CP (Secs. 2.4.2.4 and 2.4.2.5) and Ref. 27. Midland Hospital facilities (305 beds) and city police and fire department staffs (each with 46 officers) have not significantly changed in response to recent population changes or needs. Other Services Although water-supply and waste-treatment systems in Midland were operating near capacity in the mid-1970s (Final Supplement to FES-CP, Sec. 2.4.2.7), l water, sewer, and landfill facilities have been adequate to handle temporary l population increases during recent years. The capacity of the water-filtration l plant is presently being doubled, with the work likely to be completed in i July 1983. I
l l 4-17 l References for Section 4
- 1. Letter from H.R. Hilner, State Conservationist, Soil Conservation Service, to G. Dawson, Consumers Power Company, related to soils that qualify as prime farmland on the Midland Plant site, January 13, 1982.
- 2. Letter from P.C. Hittle, Consumers Power Company, to J. Courchaine, Michigan Water Resources Commission, November 16, 1981.
- 3. Letter from R.L. Fobes, Consumers Power Company, to S. Casey, Michigan Department of Natural Resources, January 6, 1982.
- 4. " Cooling Pond Thermal Performance Summary Report; Midland Plant Units 1 and 2," Bechtel, Inc., prepared for Consumers Power Company, August 1973.
- 5. " Investigation of a Thermal Plume in a Shallow River--Hydrothermal Model Studies--Cooling Pond Blowdown Discharge--Midland Nuclear Power Station,"
Alden Research Laboratories, research sponsored by Bechtel Power Corporation for Consumers Power Company, April 1979.
- 6. " Water Resources Data for Michigan, Water Year, 1980," United States Geological Survey, 1981.
- 7. " Local Climatological Data, Annual Summary With Comparative Data, Flint, Michigan," U.S. Department of Commerce, NOAA, Environmental Data Service, 1976.
- 8. J.L. Baldwin, " Climates of the United States," U.S. Department of Commerce, NOAA, Environmental Data Service, 1973.
- 9. " Listing of Tornadoes for the Period 1953-1974," National Oceanic and Atmospheric Administration, National Severe Storms Forecast Center, Kansas City, M0 (unpublished).
- 10. H.C.S. Thom, " Tornado Probabilities," Monthly Weather Review, pp. 730-737, October-December 1963.
- 11. I. Bennett, " Glaze, Its Meteorology and Climatology Geographical Distri-bution and Economic Effects," Technical Report EP-105, pp. 59-69, U.S.
Army, Quartermaster's Research and Engineering Command, Natick, MA,1959.
- 12. Julius Korshover, " Climatology of Stagnating Anticyclones East of the Rocky Mountains, 1936-1970," U.S. Department of Comeerce, NOAA, Technical Memo-randum ERL ARL-34, October 1971.
- 13. J.F. Sagendorf and J.T. Goll, "X0QD0Q Program for the Meteorological Evalu-ation of Routine Effluent Releases at Nuclear Power Stations," (Draft)
U.S. Nuclear Regulatory Commission, NUREG-0324, 1976.
- 14. " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Regulatory Guide 1.111, U.S. Nuclear Regulatory Commission, Office of Standards Development, 1976.
4-18
- 15. " Air Quality Data - 1977 Annual Statistics," U.S. Environmental Protection Agency, Research Triangle Park, EPA-450/2-78-004, September 1978.
- 16. " Air Quality Data - 1978 Annual Statistics," U.S. Environmental Protection Agency, Research Triangle Park, EPA-450/5-79-037, November 1979.
- 17. " Air Quality Data - 1979 Annual Statistics," U.S. Environmental Protection Agency Research Triangle Park, EPA-45/4-80-014, September 1980.
- 18. " Terrestrial Ecological Survey for Midland Nuclear Plant - Tittabawassee Substation - Gary Road Substation 345 kV Transmission Right-of-Way for Consumers Power Company," Asplundh Environmental Services, November 1979.
- 19. "Waterbird Use of the Midland Plant Cooling Pond and Dow Chemical Company's Tertiary Treatment Pond - Annual Report - 1979," Michigan State University, 1980.
- 20. "Waterbird Use of the Midland Plant Cooling Pond and Dow Chemical Company's Tertiary Treatment Pond - Annual Report - 1980, Michigan State University, 1981.
- 21. "The National Register of Historic Places,1976," U.S. Department of the Interior, National Park Service, and "The Federal Register" of February 6,1979, March 18,1980, February 3, 1981, and its monthly supplements.
- 22. " Report of the Archeological Survey of the Consumers Power Company Right-of-Way Through Western Saginaw County and Southeastern Midland County for the Midland Plant," Museum of Anthropology, University of Michigan, August 1977.
- 23. "1980 Census of Population and Housing, Michigan, Final Population and Housing Counts," Bureau of the Census, U.S. Department of Commerce, March 1981.
- 24. " Population Projections for Michigan to the Year 2000. Summary Report.
State, Regions, Counties," Michigan Department of Management and Budget, Lansing, 1978.
- 25. " Employment and Unemployment in States and Local Areas 1980," Bureau of Labor Statistics, U.S. Department of Labor, BLS/LAUS/AR-81/01, June 1981.
- 26. " State Unemployment, Employment and Labor Force Changes in 1980," Bureau of Labor Statistics, U.S. Department of Labor Press Release USDL 81-68, January 29, 1981.
- 27. Letter from J.H. Schroeder, Planning Director, City of Midland, to T. Cushard, General Control Administrator, Midland Project--Consumers Power Co., June 6, 1978. (As reproduced in ER-OL, Responses to Questions,
- p. 50C 9-2.)
- 28. " Michigan NPDES Permit Application - Midland Plant Units 1 & 2," Consumers Power Company, Rev. 3, September 1981.
- 4-19
- 29. " Aquatic Assessment of the Tittabawassee River, in the Vicinity of Midland, Michigan," Prepared by Lawler Matusky and Skelly Engineers for Consumers Power Company, May 1980.
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4-21 25 RIVER FLOW RATE l o MINUS MAKEUP 3 FLOW RATE (m h) l g 20
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" Investigation of a Thermal Plume in a Shallow River--
Hydrothermal Model Studies-Cooling Pond Blowdown Discharge--Midland Nuclear Power Station," Alden Research Laboratories, 1979.]
4 i 4-22 ' l i , N l NNW NNE ! 16 % l 14 NW NE 12 10
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ENE 4 - l W EEE O o E WSW ESE SW lll SE lll SSW lll SSE s Figure 4.3. Surface Wind Rose at the Midland Plant. (Onsite data 1 at 10-m above ground, March 1, 1975, through February 28, 1977. Bars show the direction from which the wind blows. Calms are hourly average windspeeds less than 0.3 m/s.)
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saw s io so 0-10 Figure 4.4. Estimated Year 2020 Population Distribution for 0-10 and 10-50
- Miles from the Midland Plant. [From ER-OL, Fig. 2.1-8.]
[ Note: 1 mile = 1.6 kilometers.] I
Table 4.1. Monthly Cooling Pond Performance for One Unit Operatingt ! Unit 1 Operating at Maximum Guaranteed load Unit 2 Operating at Maximum Guaranteed Load Imposed Heat Load: 2.14 x IOS Btu /he Imposed Heat Load: 5.55 x 10' Btu /hr Circulating Water Flow Rate: 264.300 ope Circulating Water Flow Rate: 389.600 ape Percent Percent Total Imposed Total Imposed Condenser Average Evapo- Heat Load Condenser Average Evapo- Heat Load Inlet Pond Surface ration Lost by Temperature Temperature Inlet Pond Surface ration Lost by Month (acre- Evaporation Temperature Temperature (acre- Evaporation (*F) (*F) ft/ day) (%) (*F) (*F) ft/ day) (%) J:nuary 32.5 35.3 6. 3 31 48.5 54.3 18.9 39 February 34.0 37.2 7.8 32 50.0 55.6 20.6 40 March 43.0 46.1 11.5 39 56.0 61.9 26.0 46 April 54.5 57.8 16.2 49 65.5 71.3 32.9 55 May 67.0 70.2 24.1 58 76.5 81.8 42.9 62
. June 75.0 78.2 28.1 63 83.0 87.1 48.1 67 July 78.0 81.0 27.1 64 86.0 91.4 47.7 68 August 77.0 80.3 24.6 4 65 85.5 91.3 45.3 69 September 69.5 ~ 72.5 20.1 62~ 78.5 84.1 39.6 65 4
October 58.5 61.8 15.2 53 70.0 75.6 '32.8 58 November 46.0 49.1 9.8 43 59.0 64.8 25.1 50 December 34.5 37.8 7.1 33 50.5 56.3 20.2 41 tl Adapted from Ccepany, sumers Power Bechtel, Inc., August" Cooling 1973. Pond Thermal Performance Summary Report; Midland Plant Units 1 and 2," prepared for Con-Note: 3 Joules = Btu x 1055; m /s = gpm x (0.3 x 10 5); "C = (*F-32) x 0.555; m8 = acre /f t x 1234.
Table 4.2. Monthly Cooling Pond Performance for Both Midland Units Operatingtl Unit 1 Back-End Limitedt* Maximum Guaranteed Load and Unit 2 valves Wide Open Imposed Heat Load: 7.69 x 10' 8tu/hr Imposed Heat Load: 9.05 x 10' Btu /hr Circulating Water Flow Rate: 653,900 gpm Circulating Water Flow Rate: 653,900 gpm Percent Percent Total Imposed Total Imposed
~ Condenser- Average Evapo- Heat Load Condenser Average Evapo- Heat Load Inlet Pond Surface ration Lost by Inlet Pond Surface ration Lost by Temperature Temperature (acre- Evaporation Temperature Temperature (acre- Evaporation Month (*F) ('F) ft/ day) (%) (*F) (*F) ft/ day) (%)
J nuary 59.0 64.1 29.0 44 63.5 69.4 35.9 46 February 60.5 65.8 31.6 46 64.5 70.0 37.2 46 March 65.0 69.9 36.5 50 ~ 69.0 74.6 44.0 52 April 73.5 78.3 44.4 57 76.5 82.3 52.5 59 May 83.0 87.9 55.4 64 86.0 91.6 63.8 66 June 89.5 94.2 61.1 68 92.0 97.5 70.2 69 4 92.0 96.8 60.8 69 94.5 100.1 69.8 70 July 4 August 92.0 %.5 57.4 68 94.5 100.0 66.5 70 September 85.5 90.4 53.0 67 88.0 93.9 61.6 69 October 78.0 82.9 45.2 61 81.0 87.0 53.6 63 November 68.0 73 0 36.5 53 71.5 77.6 44.2 55 December 60.5 65.8 30.5 46 65.0 71.0 37.7 44 t8 Adapted from Bechte), Inc., " Cooling Pond Thermal Performance Summary Report; Midland Plant Units 1 and 2 " prepared for Con-sumers Power Company, August 1973. 12 Limitation imposed by turbine design on the maximum amount of steam that can be accepted by the low pressure section of the turbine. Note: Joules = Btu x 1055; m 8 /s = gpm x (6.3 x 10.s); oc = ('F-32) x 0.55%: m8 = acre /ft x 1234. l 1
i 4-26 I Table 4.3. Maximum and Minimum Temperatures ( F) During Hourly Simulations for 40-Day Periodt1 l Equilibrium Condenser Inlet Temperaturet2 Temperaturet3 Maximum Minimum Maximum Minimum Hourly 113.2 35.9 97.7 87.6 Daily average 80.2 59.9 97.0 88.3 Six-day average 75.1 65.7 95.1 90.4 Period average (40 days) 71.0 89.9 Average - last 30 days 72.5 92.0 t1 Adapted from Bechtel, Inc., " Cooling Pond Thermal Performance Summary Report; Midland Plant Units 1 and 2," prepared for Consumers Power Company, August 1973. " t2 Equilibrium temperature is the temperature of a water body at which there is no net heat transfer across the water surface. Equilibrium temperature is determined solely by meteorological conditions. t8 Figurer. represent last 30 days of simulation period to allow for adjustment to assumed initial conditions. The heat load in Stu/hr was 7.62 x 109 Note: *C = ("F - 32) x 0.555.
S. ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS 5.1 RESUME Most of the staff assessment in the FES-CP concerning the environmental impacts of operation of the Midland Plant remains generally valid. However, because of changes in design parameters, availability of new information, the use of improved assessment methodology, or new legal requirements, there have been several reevaluations and, in some cases, changes, in the staff's assessments of the environmental effects of plant operation. Land-use impacts related to prime farmland on the site is addressed (Sec. 5.2.1); transmission lines are evaluated in light of proposed maintenance clearing practices (Secs. 5.2.2 and 5.5.1); future downstream water users may be affected due to plant discharges of total dissolved solids to the Tittabawassee River (Secs. 5.3.1 and 5.3.2); compilance of thermal discharges with currently applicable effluent limitations is determined (Sec. 5.3.2); the effect of the plant on the Tittabawassee River floodplain is evaluated pursuant to Executive Order 11988 promulgated since issuance of the FES-CP (Sec. 5.3.3); cooling pond fogging and icing effects will be greater than previously estimated (Sec. 5.4.1); new information is used to estimate air quality impacts from auxiliary combustion sources and dust (Sec. 5.4.2); discussions of the impacts of the cooling pond on waterfowl and of potential transmission line operation impacts on wildlife are expanded (Sec. 5.5.1); impingement and entrainment impacts are reevaluated, the former because the intake has been relocated and the latter because plant water withdrawal will now be intermittent (Sec. 5.5.2); the potential for thermal impact on river fishes is reevaluated because the cooling pond blowdown cooling tower has been eliminated from plant design and the blowdown discharge point relocated (Sec. 5.5.2); new information is used in a reevaluation of impacts of plant operation on listed species (Sec. 5.6); historic and prehistoric sites are discussed in Section 5.7; the socioeconomic impact of the plant operation work force is newly considered using new or updated socioeconomic 3 information (Sec. 5.8); and radiological impacts are reevaluated in light of new information and legal requirements (Sec. 5.9). 5.2 LAND USE 5.2.1 Plant Site Because plant operation will not involve the removal of site vegetation oeyond that committed during construction (ER-OL, Sec. 4.3.1.1), the site land-use impacts discussed in the FES-CP (Sec. V. A. , p. V-1) remain essentially valid; however, loss of prime farmland from potential agricultural use was not addressed. This land (Sec. 4.2.2) will not be available for agriculture for at least the operating lifetime of the plant. Furthermore, it is unlikely that the portion of prime farmland inundated by the cooling pond can be returned to equivalent preconstruction agricultural use after the plant is decommissioned. This is because (1) the topsoil of the pond area was removed 5-1
5-2 prior to pond filling, (2) the silt that will be deposited in the pond during plant operation will not be equivalent in agricultural productivity to the topsoil removed, and (3) high concentrations of dissolved solids inimical to agricultural use of the land will be deposited in the pond-bottom subsoil during operation (ER-OL, Sec. 4.3.1.1).
.About 50% of the plant site, including its prime farmlands, was in crop produc-tion prior to plant construction (FES-CP, Sec. II F.1); however, this consti-tuted only about 0.016% of the agricultural land in the East Central Michigan Planning and Development Region (ER-OL, Sec. 4.3.1.1). For this reason, the staff concludes that the loss of such lands from crop production for the 30 year lifetime of the plant, or longer, is an unavoidable, but small, impact.
5.2.2 Transmission Lines Construction of the 345-kV transmission route required the clearing of 45 ha (111 acres) of land (ER-OL, Sec. 4.2). Of this total, only 2.3 ha (5.6 acres) is occupied by the tower bases (ER-OL, Sec. 3.9.4.4). The majority of the remaining agricultural land is being returned to agricultural uses; much of the vegetation of the natural communities will be left undisturbed during operation, except for those portions requiring periodic right-of-way maintenance to control vegetation. As discussed in Section 5.5.1, vegetation controls will involve only a small portion of the natural vegetative communities along the transmission route. Virtually no such treatment will be necessary under the transmission lines that will pass through agricultural fields. For these reasons, the staff concludes that operation of the Midland Plant will only slightly impact land uses under the associated transmission lines. 5.3 WATER 5.3.1 Use Section V.B of the FES-CP is still valid and is updated by the following discussion. The level of the perched water table beneath the station has risen to an elevation of about 191 m (627 ft) mean sea level (MSL) due to seepage from the cooling pond. During operation, this water level will lowered to 181 m (595 ft) MSL, or lower, by pumping from wells that are being installed for this purpose. Water that is pumped from the wells will not be released to the Tittabawassee River. Instead, it will be returned to the cooling pond, thus avoiding impacting the river or other water users below the plant. As concluded in Section 5.3.2, plant chemical discharges will be within regula-tory limits. Nevertheless, plant operation may produce small to moderate impacts on existing and potential new water users in terms of additional water-treatment costs. The total dissolved solids (TDS) concentration in the river is often near or exceeds the regulatory monthly average limit of 500 mg/L (FES-CP, Table II-2, ER-OL, Sec. 6.1, and others; see Sec. 4.3.2); thus, the future use of the river as an economical sink for dissolved solids depends on the regulation of such discharges. At times when operation of the Midland Plant increases river TDS levels to the regulatory limit, downstream discharges of TDS will be precluded, thus unavoidably impacting other water dischargers below the plant.
5-3 5.3.2 Quality 5.3.2.1 Chemical , A staff evaluation of the information discussed in Sections 4.2.6.1, 4.2.6.2, 4.3.2, and presented in the draft NPDES permit (Appendix B) indicates that plant chemical discharges (including TDS, sulfate, chlorine, sodium *, phosphate (as phosphorus), ammonia, and other entities) will be in conformance with the NPDES permit and Michigan water quality standards. The draft NPDES permit requires that river TDS at Freeland Bridge shall not exceed 500 mg/L as a monthly average nor 750 mg/L as an instantaneous maximum as a result of plant discharges. The plant will be operated in such a manner as to comply with NPDES permit limitations and Michigan Water Quality Standards for TDS. Plant discharges will be monitored by the applicant as required by the NPDES permit. 5.3.2.2 Thermal The State of Michigan has not promulgated specific effluent limitations or guidelines governing point-source wastewater discharges to receiving waters. However, Michigan Water Resources Commission (MWRC) General Rule 323.2137, provides that conditions of NPDES permits issued by the MWRC shall be adequate to ensure compliance with effluent limitations promulgated by the U.S. Envi-ronmental Protection Agency and shall include such other more stringent limit-ations necessary to meet applicable state water quality standards. The MWRC has issued a draft NPDES permit for the Midland Plant (Appendix B), and the requirements in the permit are equivalent to the Michigan Water Quality Standards. The staff has evaluated the plant discharge characteristics to determine if the plant discharge will comply with the requirements. The draft NPDES permit and the Michigan Water Quality Standards, which apply at the receiving waters of the Tittabawassee River at the point of discharge of the cooling pond blowdown, and at the edge of a defined mixing zone, respectively, require that: (1) Natural daily and seasonal temperature fluctuations of the receiving waters shall be preserved; (2) The temperature at the edge of the mixing zone shall not be more than 2.8C (SF*) above ambiant river temperatures;
- Increases of sodium due to the substitution of sodium hypochlorite for gaseous chlorine (see Sec. 4.2.6.1) will be nearly undetectable when diluted in the Tittabawassee River below the plant.
5-4 (3) The monthly maximum temperatures of the receiving water body at the edge of the mixing zone must not exceed the following monthly maxi- l mum temperatures (*F): J F M A M J J A S 0 N D 41 40 50 63 76 84 85 85 79 68 55 43 (4) The mixing zone at any transect of a stream shall contain not more than 25% of the cross-sectional area or volume of flow of the stream, or both, unless it can be demonstrated to the MWRC that designation of a greater area or volume of streamflow will allow passage of fish and fishfood organisms so that effects on their immediate and future populations are negligible or not measurable; (5) The thermal plume lengths are limited to 515 m (1700 ft); and (6) The accepted design streamflow to which the water quality standards apply are those equal to or exceeding the 7-day, 10 year recurrence-interval low flow, except where the Michigan Water Resources Commis-sion determines that a more restrictive application is necessary to protect a particular designated use. These standards would apply to the combined effects of both the Dow Chemical Plant and Midland Plant discharges. In order to comply with the above standards, the blowdown to the Tittabawassee River would have to be temporarily withheld when: (1) The Dow Chemical Plant discharge utilizes the entire TDS capacity of the river, (2) The makeup cannot compensate for pond water losses caused by evapora-tion and seepage, and (3) The ambient temperature is equal to or greater than the maximum allowable river temperature. The staff has discussed its evaluation of the applicant's thermal analyses in i Section 4.2.6.2 and endorsed the hydrothermal modeling approach undertaken by I the applicant. The upstream discharge from Dew Chemical Company was taken into consideration in the hydrothermal model studies. The applicant indicated that in all its study cases, the thermal plumes defined by the 2.8C (5F ) isotherm will not contain more than 25% of the river cross-sectional area or volume of river flow at any transect on an average temperature basis. However, no values showing the cross-sectional areas enclosed by various isotherms were presented for the staff to evaluate. As indicated in Section 4.2.6.2, the staff independently calculated the areas enclosed by the 2.8C (5.0F*) isotherms and observed that the maximum area would only occupy aoout 8% of the srti.e river cross-section; this is much smaller than the 25% limit. The surface temperature isotherms presented in the ER-OL for the worst case of each of the river flows tested indicate that during periods of blowdown, the maximum thermal plume length defined by the 2.8C* (5F ) isotherm will be about
5-5 410 m (1350 ft), which is less than the 515-m (1700-ft) limit. Based upon the physical test results, the applicant established the maximum allowable blowdown rate for a given river flow and blowdown excess temperature (Fig. 4.1). The staff expects that a blowdown flow rate equal to or less than the maximum allowable would comply with the thermal standards of the MWRC. The modeling studies indicated that plant discharge would occur in the Tittabawassee River about 27% of the time. For the remaining time, there will be no blowdown discharge primarily because of the thermal plume and TDS limitations discussed previously. The staff agrees with the applicant that because of the wide range of river flow variation within a short time period, an automatic control system to regulate the blowdown discharge in phase with the varying river flow is desirable. In summary, based on the comparison of the applicant's blowdown temperature studies in the river with the limitations specified in the draft NPDES permit and the water quality standards of the MWRC, the staff expects that the appli-cant will be able to operate Midland Plant within thermal discharge limitations. 5.3.3 Floodplain Aspects The objective of Executive Order 11988, Floodplain Management, is ". . . to avoid to the exter.t possible the long and short term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct and indirect support of floodplain development whenever there is a practicable alternative . . . . " The floodplain, as defined in the Executive Order, is shown in Figure 5.1. The Midland Plant is located in the pre project floodplain of the Tittabawassee River. In order to raise the plant grade above the level of the Probable
- Maximum Flood (PMF), the applicant constructed an approximately 10.7-m (35-ft) high zone of compacted fill above the natural soil. Other features of the plant occupying the floodplain are the river intake and discharge structures, a railroad bridge, a pipe bridge which will carry process steam to Dow Chemical Company, and a dike surrounding the cooling pond. In addition, Bullock Creek, which flows into the Tittabawassee River just upstream of the plant, also had to be relocated to accommodate a construction laydown area located immediately west of the plant.
As shown in Figure 5.1, prior to construction of the Midland Plant, the 100 year floodplain inundated a large part of the area on which the plant and its cooling pond are now located. The elevation of this pre project 100 year flood was about 187.2 m (614 ft) MSL. By raising the plant fill area and constructing the cooling pond dikes, the width of the Tittabawassee River floodplain was reduced as shown in Figure 5.1. The effect of this narrower ) post project floodplain is that 100 year flood levels would be raised. How-ever, to minimize this effect, the Tittabawassee River channel was widened from a point about 300 m (1000 ft) above the confluence of the relocated Bullock Creek to approximately 900 m (3000 f t) downstream of the railroad bridge. This channel widening was designed to reduce the back-water effect of the total encroachment to less than 0.06 m (0.2 ft) for a 100 year flood. This means that the level of the post project floodplain will be about 0.06 m (0.2 f t) higher than the pre project floodplain near the site. The effect will be progressively less further from the site.
t i ! i 5-6 l The lower 1100-m (3500-f t) reach of Bullock Creek extendic.g tpstream from the Tittabawassee River was relocated as shown in Figure 5.1. A 100 year flood discharge on Bullock Creek was determined to result in a flood elevation of about 186.8 m (613 ft) MSL in the old channel just upstream of the Tittaba-wassee River. At this same elevation, the relocated channel can carry a discharge about 78% greater than the 100 year flood. Since the relocated channel can carry a greater discharge, the water level resulting from a 100 year flood on Bullock Creek will be lower than it was under pre project conditions. The Midland Plant is designed to withstand the flooding effects of a PMF, a much more severe event than the floods discussed in the Executive Order. Additionally, since the altered 100 year flood level in the Tittabawassee
- River will only be about 0.06 m (0.2 ft) higher and the 100-year flood level 1 in Bullock Creek will be lower than before, the staff concludes that the mitigative actions which have been provided are acceptable and the operation of the Midland Plant will comply with the intent of Executive Order 11988.
5.4 AIR QUALITY 5.4.1 Foo and Ice The data on fogging available to the staff at the time the FES-CP (Sec. V.A.2) was prepared indicated that fog from cooling ponds usually did not extend more than about 100 m (300 ft) inland before evaporating, becoming quite thin, or lifting to form a low stratus cloud deck (Ref.1); these data were derived from observations at cooling ponds with considerably smaller air-water temper-ature differentials than are now expected at the Midland pond. These observa-tions also indicated that during cold weather, rime ice was deposited from the fog on elevated objects near the ponds. Based on these limited observations, the staff concluded that there would be no significant fogging and icing . impacts. However, new information has now become available which causes the ! staff to modify its conclusions concerning the extent and impact of fog from the Midland cooling pond, i Currier et al. (Ref. 2) and Hicks (Refs. 3,4) have developed models to predict l the occurrence and density of steam fog over cooling ponds. These models, which have been confirmed by observations over operating cooling ponds in Illinois and Arizona, predict that fog density increases as the air-water temperature difference increases. Observations made at the Dresden nuclear plant in Illinois since it began closed-cycle cooling operations similar to those that will be used at Midland indicate that there is an increase in the frequency of steam-fog over the water surface and a major increase in the density of the fog as the air-water temperature difference increases (Refs. 3-7). During cold weather, formation of ice on elevated objects also increases in j frequency and amount as the air-water temperature difference increases, and very light snow has been observed to fall from the plume downwind of the pond (Refs. 5-7). . The Dresden studies indicate that when the air is very cold [below -18 C (O'F)] and the water surface very warm [20* to 25*C (70 to 80 F)], the fog over the pond will become very dense. (Dense steam fog at Dresden can momen-tarily reduce visibility to near zero on a road about 100 m (300 ft) south cf and parallel to the edge of the cooling pond.) Wind may carry this fog inland some distance. There are no proven mathematical models to predict the inland
5-7 penetration of such fog, but limited observations indicate -that fog can move inland as much as '.6 to 3.2 km (1 to 2 mi) (Refs. 2,5). However, the restric-tion to visibility and the icing effects in the fog zone decrease rapidly as I the fog travels inland. Based on the above information, the staff now expects a more severe local ; steam-fog effect near the Midland cooling pond than was predicted in the ' FES-CP. Because the heat load on the pond will be higher than that at Dresden, water temperatures in the Midland pond will be even hotter than those at Dresden. .The staff is of the opinion that dense steam fog will be quite common over and near the Midland cooling pond in the cooler part of the year (November through March). During colder winter periods, fog over and just downwind of the water surface is expected to be very dense. Based on the above considerations, the staff expects that plant operation will result in frequent periods of dense fog over and south of Gordonville Road during cool weather. During some of these foggy periods, visibility could be sufficiently reduced to create traffic hazards. No icing of clear road surfaces should occur during cold weather, but deposi-tion of water or light snow and rime ice falling from wires and vegetation on a snowpacked or icy road surface may further decrease traction. The staf f expects that in subfreezing temperatures, thick deposits of light, friable rime ice will form on elevated objects within the steam-fog zone. These deposits are expected to be limited to areas within 200 m (600 f t) of the pond. Because of the known low weight and the crumbly nature of these ice accumulations, the staff expects that little damage will be done to trees, vegctation, wires, or structures. The state-of-the-art does not permit a more precise assessment of the fogging ' and icing impacts of the operation of the Midland cooling pond chan given
'above. The applicant initiated a two year preoperational fog and ice monitor-ing program to measure the frequency, extent, and opacity of pond-induced steam fog and icing near the cooling pond (ER-OL, Sec. 6.1.3.1.8). The appli-cant is committed to resume this monitoring program after the first unit is operational (ER-OL, Sec. 6.2.3.1.2, and Consumers Power Co. comment letter, April 2, 1982, Appendix A). The applicant is also committed to take mitigative actions in the event that hazards to traffic result from operation of the cooling pond (ER-OL, Section 5.1.4.2; Consumers Power Co. comment letter, (April 2,1982, Appendix A). If traffic hazards are observed on any of the highways in the area as a result of pond operation, mitigative measures could include erection of traffic signs, road centerline and edge lights, and plant-ing of trees as a fog barrier between the pond and the road. Should the density of the steam fog under extreme conditions be sufficient to pose a serious traffic hazard despite the mitigating measures discussed above, the option of closing the road should be considered.
5.4.2 Emissions and Dust 5.4.2.1 Emissions The sources of nonradioactive gaseous emissions during normal operation of the plant will be testing of the standby diesel generators, the security system diesel, and the one fire protection diesel and use of the two auxiliary boilers
5-8 (Sec. 4.2.6.3). In addition, three boilers will be used to test the process steam evaporators (Sec. 4.2.6.3). Since the diesels will have limited use (1 hr/mo for each of the four standby generators and 26 hr/yr for the fire pump engine) and since the five boilers will use natural gas, the staff has determined that the impact on local air quality will be minimal and that l no violations of air quality standards will result from plant operation. l Additionally, the production by the Midland Plant of process steam for Dow Chemical Company (see Sec. 2.5) will improve air quality. The process steam is now produced by Dow with fossil-fueled equipment, an air pollution source that will be replaced by nuclear when Midland goes into operation. 5.4.2.2 Dust l Fugitive dust emissions will be substantially less during plant operation than , during the construction phase (Sec. 4.2.6.3), and since such emissions have l caused no discernible impact during the construction phase, the staff expects I no appreciable impact during operation. l 5.5 ECOLOGY 5.5.1 Terrestrial 5.5.1.1 Site The staff presently foresees no significant adverse impact of plant operation on terrestrial biota of the plant site; operation will not involve the removal of any appreciable amounts of vegetation beyond the 500 ha (1235 acres) committed previously (ER-OL, Sec. 4.3.1.1). Although, as discussed in Sec-tion 5.4.1, rime ice may occasionally form on vegetation adjacent to the cooling pond, such ice is light and friable, and the staff foresees no signi-ficant impact to the vegetation. The applicant is committed to a landscaping program to provide screening, esthetics, naturalizing, and fog barriers, and to meet zoning commitments (ER-OL, Sec. 3.1.2.3). Tree rows will be landscaped with native trees or closely related species. The staff believes that these plantings will provide a minor amount of habitat that will support small populations of wildlife species, including most species present before construction began (see FES-CP, Appendix B, for a list of species). ! 5.5.1.2 Cooling Pond It is the staff's opinion that plant operation and the resultant discharge of heated water into the cooling pond may indirectly cause some waterfowl mortality through winter starvation and disease. The staff believes that once the plant becomes operational and the average temperature of the pond increases, use of the pond by waterfowl will increase, mainly because of overwintering of resi-dent or migratory species that ordinarily would not use unheated ponds in the vicinity during the coldest months of the year. When snow cover renders fallen grain unrecoverable in fields near the plant site, some starvation and mortality of waterfowl may occur. However, this is not foreseen to be a major concern, because most waterfowl would be expected to leave the area before starvation becomes a problem. In addition, the staff believes that the heated
5-9 waters of the cooling pond may create conditions conductive to increasing the incidence of waterfowl disease, which could result in increased mortality. l These impacts cannot be quantified at present. It is the staff's opinion that the actual number of birds that could be impacted at the pond would be quite small compared to the total number in the region. For this reason, the staff concludes that regardless of pond-induced impacts related to plant operation, the regional bird populations will not be significantly affected. Nevertheless, if unexpectedly large adverse impacts are observed (Sec. 5.5.1.4), the applicant will be required to initiate action as outlined in Section 6.1. Increased waterfowl use of the cooling pond, especially by species such as Canada geese, may also result in some crop loss to nearby farms. This poten-tial impact is discussed in Section 5.8. The geographic location of the Midland site ensures an adequate natural seed source for marsh and wetland plant species. It is the staff's opinion that marsh species will be able to colonize the upper-third of the submerged por-tion of the dike and the shallowest portions of the pond bottom, unless vege-tative control measures are used. In addition, most of the pond border is likely to support the growth of marsh species. These features will tend to enhance the biotic resource provided by the cooling pond. 5.5.1.3 Transmission Corridors About three quarters of the Midland transmission lines pass through agricul-tural fields (Sec. 4.3.4.1); vegetation control will be necessary only in selected portions of the remaining quarter of natural vegetative communities transected by the lines. Since only herbicides approved by the EPA will be used for this purpose, and applied by commercial applicators licensed by the State of Michigan (ER-OL, Sec. 5.5.3), the staff concludes that the impacts from vegetation clearance will be small. The transmission system will offer a small hazard to birds (Ref. 8). The staff anticipates that some birds may be killed or injured by colliding with the transmission lines or towers during nocturnal movements or when the sky is overcast. The staff considers this impact to be unavoidable, but small: a study of bird deaths due to transmission line collisions at Lake Sangchris, Illinois, indicates a rate of 0.02 collision deaths per 1000 waterfowl-use-days I (Ref. 9). The staff has made a linear extrapolation of this rate to the l Midland lines, and calculates that deatin due to collisions will be about three orders of magnitude below typical hunter harvest
- for the Midland region.
The staff has reviewed environmental impacts that would be associated with the operation of the Midland transmission system. The potential sources of impacts are (1) ozone production, (2) induced electrical currents, and (3) electric fields. Based on previous staff analysis (Ref.10) and other studies (Refs.11,12), the staff concludes that transmission line operational effects will not adversely impact wild or domestic animals in or near the Midland transmission corridors.
- Estimated at about 30 birds per 1000 waterfowl use days.
l l l l 5-10 l [ 5.5.1.4 Monitoring l The applicant's proposed terrestrial operational monitoring program is described in the ER-OL (Sec. 6.2A). The program has been designed to determine operational impacts on (1) vegetation as a result of icing caused by cooling pond operation and (2) birds as a result of collisions with transmission lines and as a result of cooling pond operation. The staff has evaluated the applicant's proposed monitoring program and concludes that it will permit detection of any significant impact that might occur. The applicant's proposed monitoring program for waterfowl will be incorporated into the applicant's Environmental Protection Program prior to issuance of an operating license. 5.5.2 Aquatic 5.5.2.1 Impingement and Entrainment Due to relocation of the intake at the shoreline rather than in a stilling basin (see Sec. 4.2.4.1), a sweep velocity (due to natural currents) across the intake screens of as much as about 0.4 to 0.6 m/s (1.5 to 2.0 ft/s) will be created. This is greater than the maximum 0.3 m/s (1.0 ft/s) velocity through the screens when both units are operational (ER-OL, Sec. 5.1.3.2). The lowest intake velocities are now estimated to be 0.12 m/s (0.38 ft/s) when only one intake pump is operational. A staff evaluation of studies on fish swimming speeds indicate that most fish should be able to overcome these predicted approach velocities (Refs. 13-18). The absence of the stilling basin will decrease impingement, relative to that estimated in the FES-CP, by reducing the attractiveness of the area to fishes. Some attraction will still occur due to the presence of shade, shelter, feeding habitat, and spawning habitat created by the new onshore intake structure and associated land-stabilization features; however, the staff concludes that this should be much less than that that would have been caused by a stilling basin. The potential for significant levels of impingment will be further reduced by intermittent withdrawal of makeup water. As discussed in Sections 4.2.6.2 and 5.3.2.2, and in the ER-OL (Secs. 3.4.4 and 5.1), little water intake will occur during the warmer months, when there would be a larger proportion of juvenile fishes that could be subject to impingement. The conclusions reached in the FES-CP (Sec. V.C.2) that entrainment impacts will be small remain generally valid because there has been no major change in plant wcter-ir,take volume. Furthermore, the staff additionally concludes that I because little water will be withdrawn in warmer months (See Secs. 4.2.6.2 and l 5.3.2.2), fewer fish eggs, larvae, or small juveniles will be entrained l relative to those that would have been entrained if withdrawal occurred through-l out the year. As indicated on p.16 of the draft NPDES permit, the State of Michigan has i determined that the location, design, construction, and capacity of the intake structure reflects best available technology for minimizing impingement and entrainment impacts in accordance with Section 316(b) of the Clean Water Act. The permit requires a measurement of impingement and entrainment losses after plant startup.
5-11 5.5.2.2 Thermal Discharge Impacts Tittabawassee River As discussed in Section 4.2.4.2, the applicant has modified the design of the heat-dissipation system by eliminating the cooling pond blowdown cooling tower, thus altering the difference between discharge temperature and the ambient temperature, and changing the extent of the thermal plume downriver. The 5F* (2.8C ) thermal-mixing zone will only occupy $25% of river cross section in the discharge vicinity and will not extend beyond 515 m (1700 ft) downstream of the discharge (ER-OL, Sec. 5.1.2). Additionally, when there is a potential for lethally high discharge temperatures (summer), the NPDES permit conditions (Appendix B) will limit the discharges that can be made. The potential impacts to fish that may result from powerplant thermal discharges include effects on survival, growth, and reproduction due either to elevated thermal stress or cold shock due to sudden cessation of discharges to the river during the colder months of the year. Thermal discharges may also alter movement patterns (e.g., migration) by restricting the biotic zone of passage. In light of these potential effects and in light of the above changes in plant design, the staff has reevaluated the potential for thermal impact on Tittaba-wassee River fishes. Based on a comparison of average temperatures expected in the Midland Plant plume (Sec. 4.2.6.2) with upper or preferred temperatures for Tittabawassee River fish species (Refs.19,20, and ER-OL, Table 2.2-2) the staff concludes that these species will be able to occupy the plume during most occasions with negligible impact. Furthermore, adherence by the applicant to the NPDES permit (Appendix B) and Michigan Water Quality Standards (ER-OL, Sec. 5.1.3.3) will ensure that an adequate zone of passage (75% or more) will exist at all times, and thus migration and local movement of fish will not be affected. The temperature differential between the thermal plume and surrounding (ambi-ent) areas of the river is not high enough to produce substantial cold shock effects in the case of a discontinuance of cooling pond blowdown to the river. A staff review of the literature (Refs. 21-23) indicates that the temperature differential of most of the plume will be well below temperature differentials that have been shown to be detrimental by sudden temperature drops. The applicant's operational monitoring program will be conducted in accordance with the NPDES permit, which specifies effluent and instream monitoring require-ments necessary to demonstrate compliance with effluent limitations and the assessment of impacts from intake and discharge operations (ER-OL, Sec. 6.2A). Cooling Pond Staff review of information presented in the ER-OL (Sec. 5.6.2) and information on thermal tolerances of fish (Refs. 19,20) indicates that the biotic community of the Midland Plant cooling pond will become dominated by eurythermal species once operation begins, with substantial reductions in species and numbers; high summer temperatures [60% of the pond area in July will be between 35 C (94.5 F) and 38*C (100 F) and the rest in excess of 38*C] will not support substantial numbers of any resident fish species, and those introduced through entrainment will also be stressed. During other seasons, species such as carp, catfish, and sunfish are likely to dominate. Fish kills or stress of
5-12 these species is also possible from cold shock in the unlikely event that winter shutdowns of both units occur. Elevated chlorine concentrations in portions of the pond are also likely to adversely affect fish in the pond (ER-OL, Sec. 5.6.2). For these reasons the staff concludes that the pond will not become a valuable fisheries resource. 5.5.2.3 Chemical Discharges The conclusions reached in the FES-CP (Sec. V.C.2) that chemical discharge impacts will be negligible remain valid. 5.5.2.4 Dissolved Oxygen Effects As indicated in Section 4.2.6, the dissolved oxygen content of the cooling pond blowdown will be somewhat lower than it would be if a pond blowdown cooling tower were to be used. However, pond blowdown will be terminated if the Michigan water quality standard for a dissolved oxygen concentration of 5 mg/L minimum is not met. This is the minimum concentration of dissolved oxygen required to maintain good fish populations. Additionally aeration will occur within the cooling pond and at the point of discharge, and dilution of the blowdown will occur with the Tittabawassee River. Taking these factors into consideration, the staff believes that no adverse impacts on river biota will occur. 5.6 ENDANGERED AND THREATENED SPECIES 5.6.1 Terrestrial
- 5. 6.1.1 Flora l Because no federal- or state-listed plant species are likely to occur on the site or in the transmission corridors (see Sec. 4.3.5), the staff expects no operational impacts on any such plants.
5.6.1.2 Fauna l l As discussed in Section 4.3.5, federal- and state-listed bird species could occasionally be present at the site and along the transmission corridor during plant operation. The staff has evaluated the potential hazards of collision, electrocution, and exposure to herbicides on such birds. Collisions of listed bird species with transmission lines and other Midland structures are not highly probable in the opinion of the staff because of (1) the rarity of such species in the Midland area (Sec. 4.3.5.1), (2) the expected rate of bird collisions with Midland tranmission structures is very low (see Sec. 5.5.1.3), and (3) collision deaths of listed birds during two years of preoperational monitoring have been negligible (Refs. 24,25). As a conservative case the staff has evaluated the potential for electrocution of the bald eagle, since this bird is generally known to have a wingspread of up to about 1.9 to 2.4 m (6 to 8 ft). Since the minimum conductor spacing of all Midland transmission lines will be 4.9 m (16 ft), the staff concludes that there will be no electrocution hazard to any bird during plant operation. As discussed in Section 5.5.1 and in the ER-OL (Sec. 5.5.3), vegetational clearing of the transmission corridor will be conducted by professional applicators using EPA-approved herbicides. This will minimize the impact of herbicides on listed species that may occasionally visit the corridor.
5-13 5.6.2 Aquatic No endangered or threatened aquatic species are known to occur in the Tittaba-wassee River or water bodies crossed by the transmission corridors, thus no impacts to any listed species are expected. 5.7 HISTORIC AND PREHISTORIC SITES As pointed out in Section 4.3.6, the State Historic Preservation Officer (SHP0) upon review of the floodplain survey report agreed that the two archeo-logical sites 20 MD 13 and 20 MD 17 were of National Register significance. The NRC, in consultation with the SHP0, is seeking a determination of eligi-bility of the two sites for inclusion in the National Register of Historic Places. The applicant is taking appropriate measures to protect the sites during this process. With the exceptioa of the two sites, the NRC staff and the SHP0 agree that the project will have no effect on any cultural resources , either eligible for or listed on the National Register of Historic Places ' (Appendix I, Item 4). 5.8 SOCI0 ECONOMICS 5.8.1 Population The total operation work force is now expected to be about 700 persons (Consumers Power Co. comment letter, April 2,1982). Assuming an average household size of 2.7 persons (1980 City of Midland average household size, calculated from
- p. 17 of Ref. 26), the staff estimates that if all 700 persons were new to the area and brought families, a total of about 1900 persons would be added to the population. The staff concurs with the applicant that most workers and their families would probably settle in the City of Midland or nearby (ER-OL, Sec. 8.1.5). If 70% (about 1300 persons) relocated to the city (as the appli-cant suggests in ER-OL, Sec. 8.1.5, p. 8.1-4), the new population would repre-sent only about a 3% increase in the city's 1980 population and an increase of less than 3% in Midland County's 1980 population and projected 2000 population.
Of the maximum estimated 1900 persons, about 500 would be school-aged children (about 350 in the city). The assumptions used by the staff to make these calculations are conservative: it is unlikely that all plant operation workers would be newcomers. However, even if this conservative estimate proved accurate, population impacts from operation of the plant would be insignificant because the total plant-related population would be only a small fraction of the remainder of the population. In addition, some of the workers who moved to the area temporarily for the construction period will have left; this will further offset any population increases from plant operation. 5.8.2 Local Economy and Labor Market 5.8.2.1 Local Economy Payroll to construction workers, use of local subcontractors and materials, and accompanying service and sales receipts will decrease substantially as construction is completed. However, plant operation will tend to be a
5-14 l l stabilizing factor on the local economy after transition from the construction l phase. The staff concurs with the applicant's estimates that the Midland ! region annually would receive from operation employees about $20 million in i payroll, $7.5 million in retail sales, and $9 million in bank deposits j (1984 dollars) (Consumers Power Co. comment letter, April 2, 1982). Utility purchases of local services and merchandise during operation are estimated at
$6 million annually (1984 dollars) (ER-OL, Sec. 8.1.5). However, in the staff's opinion, although these effects of plant operation on the local economy are stable and positive, they would be relatively small compared to those i generated by larger employers in the area (e.g. , Dow Chemical Company and Dow-Corning).
Based on an expected increase in the number of waterfowl attracted by the cooling pond due to plant operation, consumption of crops by these waterfowl may occasior ally cause some losses of agricultural income for farmers near the site (see Sec. 5.5.1). Although some farmers might suffer more losses than others, the effect on the general agricultural economy of the area would be minor. 5.8.2.2 Labor Market Unemployed persons that were already in the Midland Plant area in 1980 (see Sec. 4.3.7.2.2), combined with the workers who will be left as plant construc-tion is completed, could easily provide a portion of the operating work force. Based on applicant information, the staff estimates that about 100 operation workers are likely to be hired locally. This number represents only about 3% of the unemployed labor force in Midland /Gladwin counties in 1980, but repre-sents a small positive benefit by reducing unemployment slightly. Service employment created by the approximately 600 incoming workers would not be large because the staff expects a compensating decrease in local service employment as the size of the plant construction work force decreases. Taking the above factors into consideration, the staff concludes that the impact on the area labor market of all new workers (direct or indirect) from plant operation would be minor. 5.8.3 Taxes The applicant estimates the annual property tax to the City of Midland in the operation period to be about $67.8 million (1984 dollars), almost ten times more than the amount paid to the city in the 1980-1981 fiscal year (see Sec. 4.3.7.3). In addition, the State of Michigan would receive about
$2.9 million (single-business tax) and the Federal government about $62.7 mil-lion annually over the operation period (Consumers Power Co. comment letter, April 2,1982). Since the City of Midland is not expected to have to pay for any new community services or projects related to plant operation, the staff concludes that this tax income would permit improvement of existing services.
! As stated in the Final Supplement to the FES-CP (Sec. 6.1.2), primary benefi-l ciaries of the extra funds would be Midland Public School, Midland County l operating budget, ambulance service, Delta College, and County Intermediate School District. The staff concurs with this conclusion.
5-15 5.8.4 Housing l If, as the staff presently assumes, 600 of the estimated 700 operation workers l would seek to establish new households, this would represent an incremental i increase of about 4% in the total number of households in the City of Midland in 1980. It is likely that a greater proportion of the operation workers than temporary construction workers would choose single-family residences rather than rental units. On the basis of this alone, it would seem that there would be insufficient single-family residences. Although the City of Midland had only about 260 single-family units available in 1979 (see Sec. 4.3.7.4), a ] number of construction workers are likely to leave the area and relinquish l their single-family residences once their construction-related assignments are completed. If such housing is secured by the incoming operation workers, housing impacts caused by the operation work force will be relatively minor. In parallel with this staff conclusion are the conclusions in a comprehensive development plan for the City of Midland: the authors state that sufficient housing will exist by 1985 to absorb a projected population growth of 6000 to 9000 persons (Ref. 27). Taking the above factors into consideration, the staff concludes that plant operation will cause no appreciable impact on housing. 5.8.5 Transportation It is the staff's judgment that as the transition is made from construction to operation, traffic volume will decrease and then stabilize. Based on about 700 workers for plant operation, the total commuting volume would be about 560 vehicles [at 1.25 workers per vehicle (Ref. 28)], or 1120 trips per average work day, distributed over three work shift changes. The staff estimates that this would be a reduction of about 80% from total peak construction commuting volume. In addition, plant-related road-use of heavy-duty equipment would decrease and then stabilize to the level of equipment use needed for plant maintenance during operation. Taking these factors into consideration, the staff concludes that impacts on the community transportation network will decrease from present levels and be relatively small. Slight delays at the Poseyville-Gordonville Roads intersection, aggravated by operation-related traffic, may continue to inconvenience drivers for a time; however, these delays would be reduced when the planned widening of Gordonville Road takes place (ER-OL, Responses to Questions, p. SOC 11-2). As discussed in Section 5.4.1, the staff believes that on occasion there will be cooling pond-induced fog formation over Gordonville Road, which could increase traffic hazards. The applicant is committed to monitor fog formation and will take mitigative measures if necessary. 5.8.6 Offsite Land Uses As discussed in Section 5.8.2.1, offsite agricultural land use occasionally may be unavoidably impacted due to predation by granivorous waterfowl; however, the impact is expected to be minor. Except for these occasional agricultural losses and the occasional maintenance of transmission facilities and occupa-tion of land by tower bases, the majority of offsite land use would remain as it was before construction. A staff review of the ER-OL (Sec. 3.9.2) indicates that the project is in conformance with current zoning ordinances.
5-16 5.8.7 Community Services and Institutions 5.8.7.1 Schools If as. many as 700 operation workers were newcomers to the Midland area, about 500 school-aged children could be expected (see Sec. 5.8.1). Because local schools currently have excess capacity (see Sec. 4.3.7.6) and enrollments from the existing population are expected to decline further [ projected to drop by about 1000 pupils from the 1980 level to 9330 in 1982-1983 (ER-OL, Sec. 8.2.7,
- p. 8.2-3)], the staff believes that there will be sufficient school capacity to absorb the children of the operating work force. Thus the staff concludes that the impacts of plant operation on schools will be insignificant.
5.8.7.2 Health, Safety, Recreation, and Other Services The staff concludes that because health, safety, recreation, water, sewage, and landfill facilities were adequate to handle construction period population increases, it is unlikely that the smaller replacement operation work force will have any significant impact on these facilities. 5.8.8 Summary of Socioeconomic Impacts On the basis of factors discussed in above, the staff has concluded that plant operation would have positive impacts on the tax base of the local area, an occasionally negative impact on agricultural profits of nearby farms, and generally insignificant impacts on most of the socioeconomic environment. 5.9 RADIOLOGICAL IMPACTS 5.9.1 Regulatory Requirements Nuclear power reactors in the United States must comply with certain regula-tory requirercents in order to operate. The permissible levels of radiation in unrestricted areas and of radioactivity in effluents to unrestricted areas are set forth in 10 CFR Part 20, Standards for Protection Against Radiation (Ref. 29). These regulations specify limits on levels of radiation and limits on concen-l trations of radionuclides in the plant's effluent releases to the air and water (above natural background), under which the reactor must operate. These l regulations state that no member of the general public in unrestricted areas I shall receive a radiation dose, due to plant operation, of more than 0.5 rems in one calendar year, or if an individual were continously present in an area, 2 mrems in any one hour or 100 mrems in any seven consecutive days to the total body. These radiation-dose limits are established to be consistent with considerations of the health and safety of the public. In addition to the Radiation Protection Standards of 10 CFR Part 20, license requirements are set forth in 10 CFR Part 50.36a (Ref. 30) that are to be imposed on licensees in the form of Technical Specifications on Effluents from Nuclear Power Reactors to keep releases of radioactive materials to unrestricted areas during normal operations, including expected operational occurrences, as low as is reasonably achievable (ALARA). Appendix I of 10 CFR Part 50 provides numerical guidance on dose-design objectives for light water reactors to meet this ALARA requirement. Applicants for permits to construct and licenses to
5-17 operate an LWR shall provide reasonable assurance that the following calculated dose-design objectives will be met for all unrestricted areas: 3 mrems/yr to the total body or 10 mrems/yr to any organ from all pathways of exposure from liquid effluents; 10 mrads/yr gamma radiation or 20 mrads/yr beta radiation air dose from gaseous effluents near ground level--and/or 5 mrems/yr to the total body or 15 mrems/yr to the skin from gaseous effluents; and 15 mrems/yr to any organ from all pathways of exposure from airborne effluents that include the radioiodines, carbon-14, tritium, and the particulates. Experience with the design, construction and operation of nuclear power reactors indicates that compliance with these design objectives will keep average annual releases of radioactive material in effluents at small percen-tages of the limits specified in 10 CFR Part 20, and in fact, will result in doses generally below the dose-design objective values of Appendix I. At the same time, the licensee is permitted the flexibility of operation, compatible with considerations of health and safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such small percentages, but still well within the limits specified in 10 CFR Part 20. In addition to the impact created by plant radioactive effluents as discussed above, within the NRC policy and procedures for environmental protection des-cribed in 10 CFR Part 51 there are generic treatments of environmental effects of all aspects of the Uranium Fuel Cycle. These environmental data have been summarized in Table 5.9 and are discussed later in this report in Section 5.10. In the same manner the anvironmental impact of transportation of fuel and waste to and from an LWR is summarized in Table 5.2 and presented in Sec-tion 5.9.3 of this report. Recently an additional operational requirement for Uranium-Fuel-Cycle Facili-ties including nuclear power plants has been established by the EPA in 40 CFR Part 190 (Ref. 31). This regulation limits annual doses (excluding radon and daughters) for members of the public to 25 mrems total body, 75 mrems thyroid, and 25 mrems othcr creans from all fuel cycle 'acility contributions that may impact a specific individual in the oublic. 5.9.2 Operational Overview During normal operations of the Midland Plant Units 1 and 2, small quantities of radioactivity (fission and activation products) will be released to the environment. As required by NEPA, the staff has determined the dose estimated to members of the public outside of the plant boundaries due to the radiation from these radioisotope releases and relative to natural background radiation dose levels. These plant generated environmental dose levels are estimated to be very small due to plant design and the development of a program that will be implemented at the plant to contain and control all radioactive emissions and effluents. As mentioned in Section 4.2.5, highly afficient radioactive-waste management systems are incorporated into the plant design. These systems are designed to remove most of the fission product radioactivity that is assumed to leak, in small amounts, from the fuel, as well as most of the activation product radio-activity produced by neutrons in the reactor core vicinity. The effectiveness of these systems will be n.easured by process and effluent radiological monitoring
5-18 systems that permanently record the amounts of radioactive constitutents remaining in the various airborne and waterborne process and effluent streams. The amounts of radioactivity released through vents and discharge points to be further dispersed and diluted to points outside the plant boundaries are to be < recorded and published semiannually in the Radioactive Effluent Release Reports of each facility. The small amounts of airborne effluents that are released will diffuse in the atmosphere in a fashion determined by the meteorological conditions existing at the time of release and are generally much dispersed and diluted by the time they reach unrestricted areas that are open to the public. Similarly, the small amounts of waterborne effluents released will be diluted with plant waste water and then further diluted as they mix with the Tittabawassee River, the Saginaw River, and Saginaw Bay beyond the plant boundaries. Radioisotopes in the plant's effluents that enter unrestricted areas will pro-duce doses through their radiation to members of the general public similar to the doses from background radiations. (i.e. , cosmic, terrestrial and internal radiations), which also include radiation from nuclear weapons fallout. These radiation doses can be calculated for the many potential radiological exposure pathways specific to the environment around the plant, such as direct radia-tion doses from the gaseous plume or liquid effluent stream outside of the plant boundaries, or internal radiation dose commitments from radioactive contaminants that might have been deposited on vegetation, or in meat and fish products eaten by people, or that might be present in drinking water outside the plant, or incorporated into milk from cows at nearby farms. These doses, calculated for the " maximally exposed" individual (i.e. , the hypothetical individual potentially subject to maximum exposure), form the basis of the NRC staff's evaluation of impacts. Actually, these estimates are for a fictitious person because assumptions are made that tend to overestimate the dose that would accrue to members of the public outside the plant bound-aries. For example, if this " maximally exposed" individual were to receive the total body dose calculated at the plant boundary due to external exposure to the gaseous plume, he/she is assumed to be physically exposed to gamma radiation at that boundary for 70% of the year, an unlikely occurrence. Site-specific values for various parameters involved in each dose pathway are used in the calculations. These include calculated or observed values for the amounts of radioisotopes released in the gaseous and liquid effluents, meteoro-logical information (e.g. , wind speed and direction) specific to the site topography and effluent release points, and hydrological information per-taining to dilution of the liquid effluents as they are discharged. An annual land census will identify changes in the use of unrestricted areas to permit modifications in monitoring programs for evaluating doses to individuals from principal pathways of exposure. This census specification will be incor-porated into the Radiological Technical Specifications and satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. As use of the land surrounding the site boundary changes, revised calculations will be made to ensure that the dose estimate for gaseous effluents always represents the highest dose that might possibly occur for any individual member of the public for each applicable foodchain pathway. The estimate considers, for example, where people live, where vegetable gardens are located, and where cows and goats are pastured.
5-19 For the Midland Plant, in addition to the direct monitoring offsite with TLDs, i measurements will be made on a number of types of samples from the surrounding ' area to determine the possible presence of radioactive contaminants which, for example, might be deposited on vegetation, or be present in drinking water outside the plant, or incorporated into cow's or goat's milk from nearby farms. 5.9.3 Radiological Impacts from Routine Operations 5.9.3.1 Radiation Exposure Pathways: Dose Commitments The potential environmental pathways through which persons may be exposed to radiation originating in a nuclear power reactor are shown schematically in Figure 5.2. When an individual is exposed through one of these pathways, his dose is determined in part by the amount of time he is in the vicinity of the source, or the amount of time the radioactivity that he has inhaled or ingested is retained in his body. The actual effect of the radiation or radioactivity is determined by calculating the dose commitment. The annual dose commitment is calculated to be the total dose that would be received over a 50 yr period, following the intake of radioactivity for 1 yr under the conditions existing 15 yrs after the plant begins operation. (Calculation for the 15th year, or midpoint of station operation, represents an average exposure over a 30 year life of the plant.) However, with few exceptions, most of the internal dose commitment for each nuclide is given during the first few years after exposure due to turnover of the nuclide by physiological processes and radioactive decay. There are a number of possible exposure pathways to man that are appropriate to be studied to determine the impact of routine releases at the Midland site on members of the general public living and working outside of the site bound-
)
aries, and whether the releases projected at this point of the licensing process will in fact meet regulatory requirements. A detailed listing of these exposure pathways would include external radiation exposure from the gaseous effluents, inhalation of iodines and particulate contaminants in the air, drinking milk from a cow or goat or eating meat from an animal that feeds , ! on open pasture near the site on which iodines or particulates may have depos- ) ited, eating vegetables from a garden near the site that may be contaminated by similar deposits, and drinking water or eating fish caught near the point of discharge of liquid effluents. Other less important pathways include: external irradiation from radionuclides deposited on the ground surface, eating animals and food crops raised near the site using irrigation water that may contain liquid effluents, shoreline, boating and swimming activities near lakes or streams that may be contaminated by effluents, drinking potentially contaminated waters, and direct radiation from within the plant itself. Calculations of the effects for most pathways are limited to a radius of 80 km (50 miles). This limitation is based on several facts. Experience, as demon-strated by calculations, has shown that all individual dose commitments (>0.1 mrem /yr) for radioactive effluents are accounted for within a radius of 2 80 km from the plant. Beyond 80 km the doses to individuals are smaller than 0.1 mrem /yr, which is far below natural-background doses, and the doses are subject to substantial uncertainty because of limitations of predictive mathe-matical models.
5-20 The NRC staff has made a detailed study of all of the above important pathways and has evaluated the radiation-dose commitments both to the plant workers and the general public for these pathways resulting from routine operation of the plant. A discussion of these evaluations follows. 5.9.3.1.1 Occupational Radiation Exposure for PWRs Most of the dose to nuclear plant workers results from external exposure to radiation coming from radioactive materials outside of the body rather than from internal exposure from inhaled or ingested radioactive materials. Experience shcws that the dose to nuclear plant workers varies from reactor to reactor and from year to year. For environmental-impact purposes, it can be projected by using the experience to date with modern PWRs. Recently licensed 1000-MWe PWRs are operated in accordance with the post-1975 regulatory require-ments and guidance that place increased emphasis on maintaining occupational exposure at nuclear power plants ALARA. These requirements and guidance are outlined primarily in 10 CFR Part 20 (Ref. 29), Standard Review Plan Chapter 12 (Ref. 32), and Regulatory Guide 8.8 (Ref. 33). The applicant's proposed implementation of these requirements and guidelines is reviewed by the NRC staff during the licensing process, and the results of that review are reported in the staff's Safety Evaluation Reports. The license is granted only after the review indicates that an ALARA program can be imple-mented. In addition, regular reviews of operating plants are performed to determine whether the ALARA requirements are being met. Average collective occupational dose information for 239 PWR reactor years of operation is available for those plants operating between 1974 and 1980. (The year 1974 was chosen as a starting date because the dose data for years prior to 1974 are primarily from reactors with average rated capacities below 500 MWe.) These data indicate that the average reactor annual collective dose at PWRs has been about 440 person-rems, with some plants experiencing an average plant lifetime annual collective dose to date as high as 1300 person-rems (Ref. 34). These dose averages are based on widely varying yearly doses at PWRs. For example, for the period mentioned above, annual collective doses for PWRs have ranged from 18 to 5262 person-rems per reactor. However, the average annual dose per nuclear plant worker of about 0.8 rem (Ref. 34) has not varied signi-ficantly during this period. The worker dose limit, established by 10 CFR Part 20, is 3 rems / quarter (if the average dose over the worker lifetime is being controlled to 5 rems /yr) or 1.25 rems / quarter if it is not. The wide range of annual collective doses experienced at U.S. PWRs results from a number of factors such as the amount of required maintenance, and the amount of reactor operations and in plant surveillance. Because these factors can vary widely and unpredictably, it is impossible to determine in advance a specific year-to year annual occupational radiation dose for a particular plant over its operating lifetime. The operational needs that result in high doses can occur, even at plants with radiation protection programs designed to ensure that occupational radiation doses will be kept ALARA. In recognition of the factors menticaed above, staff occupational dose esti-mates for environmental impact purposes for Midland Plant Units 1 and 2 are based on the assumption that the plant will experience the annual average occupational dose for PWRs to date. Thus, the staff has projected that the
5-21 occupational doses for each unit at the Midland site will be 440 person-rems but could average as much as 3 to 4 times this value over the life of the plant. In addition to the occupational radiation exposures discussed above, during , the period between the initial power operation of Unit 2 and the similar startup of Unit 1, construction personne' working on Unit 1 will potentially be exposed to sources of radiation from tne operation of Unit 2. The applicant has estimated that the integrated dose to construction personnel, over a period of 1.3 years, will be about 20 person rems. This radiation exposure will result predominantly from Unit 2 radioactive components and gaseous effluents from Unit 2. Based on experience with other PWRs, the staff finds that the applicant's estimate is reasonable. A detailed breakdown of the integrated dose to the construction workers by the location of their work and its duration is given in Table 4.4 of the ER-OL. The average annual dose of about 0.8 rem per nuclear plant worker at operating BWRs and PWRs has been well within the limits of 10 CFR Part 20. However, for impact evaluation, the NRC staff has estimated the risk to nuclear power plant workers and compared it in Table 5.1 to risks that are published for other occupations. Based on these comparisons, the staff concludes that the risk to nuclear plant workers from plant operation is comparable to the risks associated with other occupations. In estimating the number of health effects resulting from both offsite (see Sec. 5.9.3.2) and occupational radiation exposure due to normal operation of the Midland Plant, the NRC staff used somatic (cancer) and genetic risk esti-mators based on widely accepted scientific information. Specifically, the staff's estimates are based on information compiled by the National Academy of Science's Advisory Committee on the Biological Effects of Ionizing Radiation (BEIR I) (Ref. 35). The estimates of the risks to workers and the general public are based on conservative assumptions (i.e., the estimates are probably higher than the actual number). The following risk estimators were used to estimate health effects: 135 potential deaths from cancer per million person-rems and 258 potential cases of all forms of genetic disorders per million person-rems. The cancer mortality risk estimates are based on the " absolute risk" model described in BEIR I. Higher estimates can be developed by use of the " relative risk" model along with the assumption that risk prevails for the duration of life. Use of the " relative risk" model would produce risk values up to about four times greater than those used in this report. The staff regards the use of the " relative risk" model values as a reasonable upper limit of the range of uncertainty. The lower limit of the range would be zero because health effects have not been detected at doses in this dose-rate range. The number of potential nonfatal cancers would be approximately 1.5 to 2 times the number of potential fatal cancers (Ref. 36). Values for genetic risk estimators range from 60 to 1500 potential cases of all forms of genetic disorders per million person-rems (Ref. 35). The value of 258 potential cases of all forms of genetic disorders is equal to the sum of the geometric means of the risk of specific genetic defects and the risk of defects with complex etiology. However, the value of zero can not be excluded since there is no direct evidence of human effects at doses in this dose rate range (Ref. 36).
l l l 5-22 ; 1 The preceding values for risk estimators are consistent with the recommenda-tions of a number of recognized radiation protection organizations, such as the International Commission on Radiological Protection (ICRP), the National Council on Radiation Protection and Measurement (NCRP), the National Academy of Sciences BEIR III Report, and the United Nations Scientific Committee on ' the Effects of Atomic Radiation (UNSCEAR) (Refs. 36-39). 1 The risk of potential fatal cancers in the exposed work force population at the Midland Plant and the risk of potential genetic disorders in all future generations of this workforce population, is estimated as follows. Multiplying the annual plant worker population dose (i.e. , about 880 person-rems) by the risk estimators, the staff estimates that about 0.12 cancer death may occur in the total exposed population and about 0.23 genetic disorder may occur in all future generations of the same exposed population. The value of 0.12 cancer death means that the probability of one cancer death over the life-time of the entire workforce due to one year of operations at the Midland Plant is about 12 chances in 100. The value of 0.23 genetic disorder means that the proba-bility of one genetic disorder in all future generations of the entire work-force due to one year of operations at the Midland Plant is about 23 chances in 100. 5.9.3.1.2 Public Radiation Exposure Transportation of Radioactive Materials The transportation of " cold" (unirradiated) nuclear fuel to the reactor, of spent irradiated fuel from the reactor to a fuel reprocessing plant, and of solid radioactive wastes from the reactor to waste burial grounds is considered in 10 CFR Part 51.20 (Ref. 30). The contribution of the environmental effects of such transportation to the environmental costs of licensing the nuclear i power reactor is set forth in Summary Table S-4 from 10 CFR Part 51.20, repro-duced herein as Table 5.2. The cumulative dose to the exposed population as summarized in Table S-4 is very small when compared to the annual collective dose of about 60,000 person-rems to this same population or 26,000,000 person-rems to the U.S. population from background radiation. Direct Radiation for PWRs Radiation fields are produced around nuclear plants as a result of radio-activity within the reactor and its associated components, as well as a result of radioactive-effluent releases. Direct radiation from sources within the plant are due primarily to nitrogen-16, a radionuclide produced in the reactor core. Because the primary coolant of a PWR is contained in a heavily shielded area, dose rates in the vicinity of PWRs are generally undetectable (less than 5 mrems/yr). Low-level radioactivity storage containers outside the plant are estimated to make a dose contribution at the site boundary of less than 1% of that due to the direct radiation from the plant. Radioactive Effluent Releases: Air and Water As pointed out in an earlier section, all effluents from the plant will be subject to extensive decontamination, but small controlled quantities of
5-23 l radioactive effluents will be released to the atmosphere and to the hydro-sphere during normal operations. Estimates of site-specific radioisotope release values have been developed on the basis of estimates regarding fuel performance and the descriptions of operational and radwaste systems in the applicant's ER and FSAR and by using the calculational model and parameters developed by the NRC staff (Ref. 40). These have been supplemented by exten-sive use of the applicant's site and environmental data in the ER-OL and in subsequent answers to NRC staff questions, and should be studied to obtain an understanding of airborne and waterborne releases from the plant. These radioactive effluents are then diluted by the air and water into which they are released before they reach areas accessible to the general public. Radioactive effluents can be divided into several groups. Among the airborne effluents the radioisotopes of the fission product noble gases, krypton and xenon, as well as of argon, do not deposit on the ground nor Ere they absorbed and accumulated within living organisms; therefore, the noble gas effluents act primarily as a source of direct external radiation emanating from the effluent plume. Dose calculations are performed for the site boundary where the highest external-radiation doses to a member of the general public as a result of gaseous effluents have been estimated to occur; these include the total body and skin doses as well as the annual beta and gamma air doses from the plume at that boundary location. Another group of airborne radioactive effluents--the fission product radio-iodines, as well as carbon-14, and tritium--are also gaseous but tend to be deposited on the ground and/or inhaled into the body during breathing. For this class of effluents, estimates of direct external-radiation doses from deposits on the ground, and of internal radiation doses to total body, thyroid, bone, and other organs from inhalation and from vegetable, milk, and meat consumption are made. Concentrations of iodine in the thyroid and of carbon-14 in bone are of particular significance here. A third group of airborne effluents, consisting of particulates that remain after filtration of airborne effluents in the plant prior to release, includes fission products such as cesium and barium and activated corrosion products such as cobalt and chromium. The calculational model determines the direct external radiation dose and the internal radiation doses for these contami-nants through the same pathways as described above for the radiciodines, carbon-14, and tritium. Doses from the particulates are combined with those of the radiciodines, carbon-14, and tritium for comparison to one of the design objectives of Appendix I to 10 CFR Part 50. The waterborne radioactive effluent constituents could include fission products such as nuclides of strontium and iodine; activation products, such as nuclides of sodium and manganese; and tritium as tritiated water. Calculations estimate the internal doses (if any) from fish consumption, from water ingestion (as drinking water), and from eating of meat or vegetables raised near the site on irrigation water, as well as any direct external radiation from recreational-use of the water near the point of discharge. The release values for each group of effluents, along with site-specific meteorological and hydrological data, serve as input to computerized radiation-dose models that estimate the maximum radiation dose that would be received
5-24 ) outside the facility via a number of pathways for individual members of the public, and for the general public as a whole. These models and the radiation i dose calculations are discussed in Regulatory Guide 1.109 (Ref. 41) and in ) Appendix D of this statement. Examples of site-specific dose assessment calculations and discussions of parameters involved are given in Appendix C. Doses from all airborne effluents except the noble gases are calculated for individuals at the location (e.g. , site boundary, garden, residence, milk cow, meat animal) where the highest radiation dose to a member of the public has been established from all appli-cable pathways (e.g. , ground deposition, inhalation, vegetable consumption, cow milk consumption or meat consumption). Only those pathways associated with airborne effluents that are known to exist at a single location, are combined to calculate the total maximum exposure to an exposed individual. Pathway doses associated with liquid effluents are combined without regard to any single location, but they are assumed to be associated with maximum expo-sure of an individual through other than gaseous-effluent pathways. 5.9.3.2 Radiological Impact on Humans Although the doses calculated in Appendix C are based primarily on radioactive-waste treatment system capability and are well below the Appendix I design objective values, the actual radiological impact associated with the operation of the plant will depend, in part, on the manner in which the radioactive waste treatment system is operated. Based on its evaluation of the potential performance of the ventilation and radwaste treatment systems, the NRC staff has concluded that the systems as now proposed are capable of controlling effluent releases to meet the dose-design objectives of Appendix I to 10 CFR Part 50 (Ref. 30). The plant's operation will be governed by operating license Technical Speci-fications which will be based on the dose-design objectives of Appendix I to 10 CFR Part 50 (Ref. 30). Since these design-objective values were chosen to permit flexibility of operation while still ensuring that plant operations are ALARA, the actual radiological impact of plant operation may result in doses close to the dose-design objectives. Even if this situation exists, the indi-vidual doses for the member of the public subject to maximum exposure will still be very small when compared to natural background doses (*100 mrems/yr) or the dose limits (500 mrems/yr - total body) specified in 10 CFR Part 20 as consistent with considerations of the health and safety of the public. As a l i result, the staff concluded that there will be no measurable radiological impact on any member of the public from routine operation of the plant. Operating standards of 40 CFR Part 190, the Environmental Protection Agency's Environmental Radiation Protection Standards for Nuclear Power Operations (Ref. 31), specify that the annual dose equivalent must not exceed 25 mrems to the whole body, 75 mrems to the thyroid, and 25 mrems to any other organ, of any member of the public as the result of exposures to planned discharges of radioactive materials (radon and its daughters excepted) to the general envi-ronment from all uranium-fuel-cycle operations and radiation from these opera-tions that can be expected to affect a given individual. The NRC staff con-cluded that under normal operations the Midland site is capable of operating within these standards.
5-25 The radiological doses and dose commitments resulting from a nuclear power plant are well known and documented. Accurate measurements of radiation and radioactive contaminants can be made with very high sensitivity so that much smaller amounts of radioisotopes can be recorded than can be associated with any possible observable ill effects. Furthermore, the effects of radiation on living systems have for decades been subject to intensive investigation and consideration by individual scientists as well as by select committees, occasionally constituted to objectively and independently assess radiation dose effects. Although, as in the case of chemical contaminants, there is debate about the exact extent of the effects of very low levels of radiation that result from nuclear power plant effluents, upper bound limits of deleteri-ous effects are well established and amenable to standard methods of risk analysis. Thus the risks to the maximally exposed member of the public outside of the site boundaries or to the total population outside of the boundaries can be readily calculated and recorded. These risk estimates for the Midland Plant are presented below. The risk to the maximally exposed individual is estimated by multiplying the risk estimators presented in Section 5.9.3.1.1 by the annual dose design objectives for total body radiation in 10 CFR Part 50, Appendix I. This calculation results in a risk of potential premature death from cancer to that individual from exposure to radioactive effluents (gaseous or liquid) from one year of reactor operations of less than once chance in one million.* The risk of potential premature death from cancer to the average individual within 80 km (50 mi) of the reactor from exposure to radioactive effluents from the reactors is much less than the risk to the maximally exposed individual. These risks are very small in comparison to natural cancer incidence from causes unrelated to the operation of the Midland Plant. Multiplying the annual U.S. general public population dose from exposure to radioactive effluents and transportation of fuel and waste from the operation of the Midland Plant (i.e. , 37 person-rems) by the preceding risk estimators, the staff estimates that about 0.005 cancer death may occur in the exposed population and about 0.01 genetic disorder may occur in all future generations of the exposed population. The significance of these risk estimates can be determined by comparing them to the natural incidence of cancer death and genetic abnormalities in the U.S. population. Multiplying the estimated U.S. population for the year 2000 (i.e. , s260 million persons) by the current incidence of actual cancer fatalities (i.e. , s20%) and the current incidence of actual genetic diseases (i.e. , s6%), about 52 million cancer deaths and about 16 million genetic abnormalities are expected (Refs. 35,42). The risk to the general public from exposure to radioactive effluents and transporta-tion of fuel and wastes from the annual operation of the Midland Plant are very small fractions (less than one part in a billion) of the estimated normal incidence of cancer fatalities and genetic abnormalities in the year 2000 population.
*The risk of potential premature death from cancer to the maximally exposed individual from exposure to radioiodines and particulates would be in the same range as the risk from exposure to the other types of effluents.
l l 5-26 l l On the basis of the preceding comparison (i.e. , comparing the risk from expo-sure to radioactive effluents and transportation of fuel and waste from the annual operation of the Midland Plant with the risk from the estimated inci-dence of cancer fatalities and genetic abnormalities in the year 2000 popula-tion) the staff concludes that the risk to the public health and safety from exposure to radioactive effluents and the transportation of fuel and wastes from normal operation of the Midland Plant will be very small. 5.9.3.3 Radiological Impacts on Biota Other Than Humans Depending on the pathway and radiation source, terrestrial and aquatic biota will receive doses that are approximately the same or somewhat higher than humans receive. Although guidelines have not been established for acceptable limits for radiation exposure to species other than humans, it is generally agreed that the limits established for humans are sufficiently protective for other species. Although the existence of extremely radiosensitive biota is possible and increased radiosensitivity in organisms may result from environmental inter-actions with other stresses (for example, heat or biocides), no biota have yet been discovered that show a sensitivity (in terms of increased morbidity or mortality) to radiation exposures as low as those expected in the area sur-rounding the plant. Furthermore, at all nuclear plants for which radiation exposure to biota other than humans has been analyzed (Ref. 43), there have been no cases of exposure that can be considered significant in terms of harm to the species, or that approach the limits for exposure to members of the public that are permitted by 10 CFR Part 20 (Ref. 29). Inasmuch as the 1972 BEIR Report (Ref. 35) concluded that evidence to date indicated no other living organisms are very much more radiosensitive than humans, no measurable radiological impact on populations of biota is expected as a result of the routine operation of this plant. 5.9.3.4 Radiological Monitoring Radiological environmental monitoring programs are established to provide data where there are measurable levels of radiation and radioactive materials in the site environs and to show that in many cases no detectable levels exist. Such monitoring programs are conducted to verify the effectiveness of in plant systems used to control the release of radioactive materials and to ensure that unanticipated buildups of radioactivity will not occur in the environment. l Secondarily, the environmental monitoring programs could identify the highly unlikely existence of releases of radioactivity from unanticipated release i points that are not monitored. An annual surveillance (Land Census) program l will be established to identify changes in the use of unrestricted areas to provide a basis for modifications of the monitoring programs or of the Techni-cal Specification conditions that relate to the control of doses to individ-uals. These programs are discussed in greater detail in NRC Regulatory Guide 4.1, Rev. 1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants" (Ref. 44), and the Radiological Assessment Branch Technical Position, Rev.1, November 1979, "An Acceptable Radiological Environmental Monitoring Program" (Ref. 45).
5-27 I 5.9.3.4.1 Preoperational The preoperational phase of the monitoring program should provide for the measurement of background levels of radioactivity and radiation and their var-iations along the anticipated important pathways in the areas surrounding the plant, the training of personnel and the evaluation of procedures, equipment and techniques. :The applicant proposed a radiological environmental-monitoring program to meet these objectives in the ER-CP and it was discussed in the FES-CP. This early program has been updated and expanded; it is presented in i Section 6.1.5 of the applicant's ER-OL and is summarized here in Table 5.3. The applicant states that the preoperational program was started in November 1978 to document background levels of direct radiation and concentrations of radionuclides that exist in the environment. The preoperational program will
; continue up to the initial criticality of Unit 2 as summarized in Table 6.2A-3-9 ! of the ER-OL, at which time the operational radiological monitoring program will commence.
4 The staff has reviewed the preoperational environmental monitoring plan of the applicant and finds that it is generally acceptable as presented. However,
, the current NRC staff position is that a total of about 40 dosimetry stations (oc continuously recording dose-rate instruments) should be placed as follows:
3 an inner ring of stations in the general area of the site boundary and an outer ring in the 6.4- to 8-kilometer (4- to 5-mile) range from the site with a station in each sector of each ring (16 sectors x 2 rings = 32 stations). The remaining 8 stations should be placed in special interest areas such as population centers, nearby residences, schools, and in 2 or 3 areas to serve j as control stations. 5.9.3.4.2 Operational j 4 The operational, offsite radiological-monitoring program is conducted to measure radiation levels and radioactivity in plant environs or to identify the lack thereof. It assists and provides backup support to the effluent-monitoring program as recommended in NRC Regulatory Guide 1.21, " Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radio-
, active Materials in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants" (Ref. 46).
The applicant states that the operbtlonal program will in essence be a continua-4 tion of the preoperational program described above with some periodic adjust-j ment of sampling frequencies in expected critical exposure pathways. The 4 proposed operational program will be reviewed prior to plant operation. . Modification will be based upon anomalies and/or exposure pathway variations observed durinC the preoperational program. The final operational-monitoring program proposed by the applicant will be reviewed in detail by the NRC staff, and the specifics of the required moni-toring program will be incorporated into the Operating License Radiological i Technical Specifications.
5-28 5.9.4 ENVIRONMENTAL IMPACT OF POSTULATED ACCIDENTS 5.9.4.1 Plant Accidents The staff has considered the potential radiological impacts on the environment of possible accidents at the Midland Plant Units 1 and 2 in accordance with a Statement of Interim Policy published by the Nuclear Regulatory Commissior. on 1 June 13,1980 (Ref. 47). The following discussion reflects these considerations ! and conclusions. ; 1 Section 5.9.4.2 deals with general characteristics of nuclear power plant accidents including a brief summary of safety measures to minimize the prob-ability of their occurrence and to mitigate their consequences if they should occur. Also described are the important properties of radioactive materials and the pathways by which they could be transported to become environmental hazards. Potential adverse health effects and impacts on society associated with actions to avoid such health effects are also identified. Next, actual experience with nuclear power plant accidents and their observed health effects and other societal impacts are described. This is followed by a summary review of safety features of the Midland Plant Units 1 and 2 and of the site that act to mitigate the consequences of accidents. The results of calculations of the potential consequences of accidents that have been postulated in the design basis are then given. Also described are the results of calculations for the Midland site using probabilistic methods to estimate the possible impacts and the risks associated with severe accident sequences of exceedingly low probability of occurrence. 5.9.4.2 General Characteristics of Accidents The term " accident," as used in this section, refers to any unintentional event not addressed in Section 5.9.3 that results in a release of radioactive materials into the environment. The predominant focus, therefore, is on events that can lead to releases substantially in excess of permissible limits for normal operation. Normal release limits are specified in the Commission's regulations at 10 CFR Part'20, and 10 CFR Part 50, Appendix I. There are several features that combine to reduce the risk associated with accidents at nuclear power plents. Safety features in the design, construc-tion, and operation comp' rising the first line of defense are to a very large extent devoted to the prevention of the release of these radioactive materials from their normal places of confinement within the plant. There are also a number of additional lines of defense that are designed to mitigate the conse-quences'of failures in the first line. Descriptions of these features for the Midland plar.ts may be found in the applicant's Final Safety Analysis Report (Ref. ' 48), and in the staff's Safety Evaluation 1 Report (Ref. 49). The most important ' mitigative features are described in Section 5.9.4.4(1) below. These safety features are designed taking into consideration the specific locations of radioactive materials within the plant, their amounts, their nuclear, ' physical, and chemical properties, and their relative tendency to be _ transported' into and for creating biological hazards in the environment. t
5-29 l l (1) Fission Product Characteristics By far the largest inventory of radioactive material in a nuclear power plant is produced as a byproduct of the fission process and is located in the uranium oxide fuel pellets in the reactor core in the form of fission products. During periodic refueling shutdowns, the assemblies containing these fuel pellets are transferred to a spent-fuel storage pool so that the second largest inventory of radioactive material is located in this storage area. Much smaller inventories of radioactive materials are also normally present in the water that circulates in the reactor coolant system and in the systems used to process gaseous and liquid radioactive wastes in the plant. These radioactive materials exist in a variety of physical and chemical forms. Their potential for dispersion into the environment depends not only on mechani-cal forces that might physically transport them, but also upon their inherent properties, particularly their volatility. The majority of these materials exist as nonvolatile solids over a wide range of temperatures. Some, however, are relatively volatile solids and a few are gaseous in nature. These charac-teristics have a significant bearing upon the assessment of the environmental radiological impact of accidents. The gaseous materials include radioactive forms of t'he chemically inert noble gases krypton and xenon. These have the highest potential for release into the atmosphere. If a reactor accident were to occur involving degradation of the fuel cladding, the release of substantial quantities of these radioactive gases from the fuel is a virtual certainty. Such accidents are very low fre-quency but credible events (see Section 5.9.4.3). It is for this reason that the safety analysis of each nuclear power plant incorporates a hypothetical design-basis accident that postulates the release of the entire contained inventory of radioactive noble gases from the fuel into the containment struc-ture. If further released to the environment as a possible result of failure of safety features, the hazard to individuals from these noble gases would arise predominantly through the external gamma radiation from the airborne plume. The reactor containment structure is designed to minimize this type of release. Radioactive forms of iodine are formed in substantial quantities in the fuel by the fission process and in some chemical forms may be quite volatile. For these reasons, they have traditionally been regarded as having a relatively high potential for release from the fuel. If released to the environment, the principal radiological hazard associated with the radioiodines is ingestion into the human body and subsequent concentration in the thyroid gland. Because of this, its potential for release to the atmosphere is reduced by the use of special systems designed to retain the iodine. The chemical forms in which the fission product radioiodines are found are generally solid materials at room temperatures, however, so that they have a strong tendency to condense (or " plate out") upon cooler surfaces. In addition, most of the iodine compounds are quite soluble in, or chemically reactive with, water. Although these properties do not inhibit the release of radio-iodines from degraded fuel, they do act to mitigate the release from contain-ment structures that have large internal surface areas and that contain large quantities of water as a result of an accident. The same properties affect the behavior of radioiodines that may " escape" into the atmosphere. Thus, if
- 5-30 rainfall occurs during a release, or if there is moisture on exposed surfaces, e.g. , dew, the radiciodines will show a strong tendency to be absorbed by the moisture.
Other radioactive materials formed during the operation of a nuclear power plant have lower volatilities and therefore, by comparison with the noble gases and iodine, a much smaller tendency to escape from degraded fuel unless the temperature of the fuel becomes very high. By the same token, such materials, if they escape by volatilization from the fuel, tend to condense quite rapidly , to solid form again when transported to a lower temperature region and/or dissolve in water when present. The former mechanism can have the result of , producing some solid particles of sufficiently small size to be carried some distance by a moving stream of gas or air. If such particulate materials are dispersed into the atmosphere as a result of failure of the containment barrier, j they will tend to be carried downwind and deposit on surface features by gravitational settling or by precipitation (fallout), where they will become
" contamination" hazards in the environment. , All of these radioactive materials exhibit the property of radioactive decay ; with characteristic half-lives ranging from fractions of a second to many days or years (see Table 5.4). Many of them decay through a sequence or chain of decay processes and all eventually become stable (nonradioactive) materials.
The radiation emitted during these decay processes is the reason that they are ] hazardous materials. (2) Expo.iure Pathways
- The radiation exposure (hazard) to individuals is determined by their proximity to the radioactive materials, the duration of exposure, and factors that act
- to shield the individual from the radiation. Pathways from the transport of radiation and radioactive materials that lead to radiation exposure hazards to humans are generally the same for accidental as for " normal" releases. These are depicted in Section 5.9.3, Figure 5.2. There are two additional possible pathways that could be significant for accident releases that are not shown in Figure 5.2. One of these is the fallout onto open bodies of water of radio-activity initially carried in the air. The second would be unique to an accident that results in temperatures inside the reactor core sufficiently
, high to cause melting and subsequent penetration of the basemat underlying the reactor by the molten core debris. This creates the potential for the release of radioactive material into the hydrosphere through contact with ground
- water. These pathways may lead to external exposure to radiation, and to i
internal exposures if radioactive material is inhaled or ingested from contami-nated food or water. It is characteristic of these pathways that during the transport of radioactive material by wind or by water the material tends to spread and disperse, like a l- plume of smoke from a smokestack, becoming less concentrated in larger volumes of air or water. The result of these natural processes is to lessen the intensity of exposure to individuals downwind or downstream of the point of release, but they also tend to increase the number who may be exposed. For a release into the atmosphere, the degree to which dispersion reduces the con-centration in the plume at any downwind point is governed by the turbulence characteristics of the atmosphere which vary considerably with time and from place to place.
l l 5-31 This fact, taken in conjunction with the variability of wind direction and the presence or absence of precipitation, means that accident consequences are very much dependent upon the weather conditions existing at the time. (3) Health Effects The cause-and-effect relationships between radiation exposure and adverse health effects are quite complex (Refs. 50,51), but they have been more exhaustively studied than any other environmental contaminant. Whole-body radiation exposure resulting in a dose greater than about 10 rem for a few persons and about 25 rems for nearly all people over a short period of time (hours) is necessary before any physiological effects to an individual are clinically detectable. Doses about 10 to 20 times larger than the latter dose, also received over a relatively short period of time (hours to a few days), can be expected to cause some fatal injuries. At the severe, but extremely low probability end of the accident spectrum, exposures of these magnitudes are theoretically possible for persons in the close proximity of such accidents if measures are not or cannot be taken to provide protection, e.g., by sheltering or evacuation. Lower levels of exposures may also constitute a health risk but the ability to define a direct cause-and effect relationship between any given health effect and a known exposure to radiation is difficult given the backdrop of the many other possible reasons wny a particular effect is observed in a specific individual. For this reason, it is necessary to assess such effects on a statistical basis. Such effects include randomly occurring cancer in the exposed population and genetic changes in future generations after exposure of a prospective parent. Occurrences of cancer in the exposed population may begin to develop only after a lapse of 2 to 15 years (latent period) from the time of exposure and then continue over a period of about 30 years (plateau period). However, in the case of exposure of fetuses (in utero), occurrences
.of cancer may begin to develop at birth (no latent period) and end at age 10 (i.e. , the plateau period is 10 years). The health consequences model currently being used is based on the 1972 BEIR Report of the National Academy of Sciences (Ref. 35). The occurrence of cancer itself is not necessarily indicative of fatality.
Most authorities agree that a reasonable, and probably conservative estimate of the randomly occurring number of health effects of low levels of radiation exposure to a large number of people is within the range of about 10 to 500 potential cancer deaths (although zero is not excluded by the data) per million person-rems. The range comes from the latest NAS BEIR III Report (1980) (Ref. 36), which also indicates a probable value of about 150. This value is virtually identical to the value of about 135 used in the current NRC health-ef fects models. In addition, approximately 220 genetic changes per million person-rems would be projected by BEIR III over succeeding generations. That also compares well with the value of about 258 per million person-rems currently used by the NRC staff. (4) Health Effects Avoidance Radiation hazards in the environment tend to disappear by the natural process of radioactive decay. Where the decay process is a slow one, however, and
5-32 where the material becomes relatively fixed in its location as an environmental contaminant (e.g., in soil), the hazard can continue to exist for a relatively long period of time--months, years, or even decades. Thus, a possible conse-quential environmental societal impact of severe accidents is the avoidance of the health hazard rather than the health hazard itself, by restrictions on the use water.of the contaminated property or contaminated foodstuffs, milk, and drinking The potential economic impacts that this can cause are discussed below. 5.9.4.3 Accident Experience and Observed Impacts
- The evidence of accident frequency and impacts in the past is a useful indicator of future probabilities and impacts. As of mid-1981, there were 71 commercial nuclear power reactor units licensed for operation in the United States at 50 sites with power generating capacities ranging from 50 to 1130 MWe. (The Midland Unit 1 plant is designed for 505 MWe and process steam while the Unit 2 plant is designed for 852 MWe.) The combined experience with these units represents approximately 500 reactor years of operation over an elapsed time of about 20 years. Accidents have occurred at several of these facilities (Refs. 52,53).
Some of these have resulted in releases of radioactive material to the environment, ranging from very small fractions of a curie to a few million curies. None is known to have caused any radiation injury or fatality to any member of the public, nor any significant individual or collective public radiation exposure, nor any significant contamination of the environment.
- With respect to psychological stress impacts, the United States Court of Appeals for the District of Columbia Circuit has held, in People Against Nuclear Energy (PANE) v. NRC No. 81-1131, that the National Environmental Policy Act requires the Commission to evaluate the effects on psychological health of operation of the Three Mile Island Unit 1 facility. On July 15, 1982 ( 47 F.R31762 ), the Commission issued a Statement of Policy "Considera-tion of Psychological Stress Issues" providing guidance on the applicability of the decision to NEPA issues in other reactor licensing proceedings. In the Policy Statement (p. 3), the Commission indicated that, in accordance with the opinion in PANE, cognizability of psychological stress impacts under NEPA hinges on three elements:
"First, the impact must consist of ' post traumatic anxieties,' as distinguished from mere dissatisfaction with agency proposals or policies. Second, the impacts must be accompanied by physical effects. Third, the ' post traumatic anxieties' must have been caused by ' fears of a recurring catasrophe'. This third element means that some kind of nuclear accident must already have occurred at the site in question, since the majority's holding was directed to ' post-traumatic' anxieties and by fears of a ' recurring' catas-trophe. Moreover, the majority clearly had only serious accidents in mind, because of the use of the word ' catastrophe' and its refer-ences in mind, because of the use of the word ' catastrophe' and its references to the ' unique' Three Mile Island Unit 2 accident in the opinion." (Underlining added.)
Since there has been no nuclear accident at the Midland site, the elements necessary for consideration of psychological stress impacts in accordance with the Policy Statement are not present in the connection with the Midland reactors.
i l 5-33 This experience base is not large enough to permit a reliable quantitative statistical inference. It does, however, suggest that significant environmental impacts caused by accidents are very unlikely to occur over time periods of a few decades. Melting or severe degradation of reactor fuel has occurred in only one of these units, during the accident at Three Mile Island Unit 2 (TMI-2) on March 28, 1979. In addition to the release of a few million curies of xenon-133, it has been estimated that approximately 15 Ci of radioiodine was also released to the environment at TMI-2 (Ref. 54). This amount represents an extremely minute fraction of the total radioiodine inventory present in the reactor at the time of the accident. No other radioactive fission products were released in measurable quantity. It has been estimated that the maximum cumulative offsite radiation dose to an individual was less than 100 millirems (Refs. 54,55). The total population exposure has been estimated to be in the range from about 1000 to 3000 person-rems. This exposure could produce between none and one additional fatal cancer over the lifetime of the population. The same population receives each year from natural background radiation about 240,000 person-rems and approxi-mately a half-million cancers are expected to develop in this group over its lifetime (Refs. 54,55), primarily from causes other than radiation. Trace quantities (barely above the limit of detectability) of radiciodine were found in a few samples of milk produced in the area. No other food or water supplies were impacted. Accidents at nuclear power plants have also caused occupational injuries and a few fatalities but none attributed to radiation exposure. Individual worker exposures have ranged up to about 4 rems as a direct consequence of reactor accidents (although there have been higher exposures to individual workers as a result of other unusual occurrences). However, the collective worker exposure levels (person-rems) are a sniall fraction of the exposures experienced during normal routine operations that average about 440 to 1300 person-rems in a PWR and 740 to 1650 person-rems in a BWR per reactor year. Accidents have also occurred at other nuclear reactor facilities in the United States and in other countries (Refs. 52,53). Because of inherent differences in design, construction, operation, and purpose of most of these other facili-l ties, their accident record has only indirect relevance to current nuclear power plants. Melting of reactor fuel occurred in at least seven of these accidents, including the one in 1966 at the Enrico Fermi Atomic Power Plant Unit 1. This was a sodium-cooled fast breeder demonstration reactor designed to generate 61 MWe. The damages were repaired and the reactor reached full power in 4 years following the accident. It operated successfully and com-pleted its mission in 1973. This accident did not release any radioactivity to the environment. A reactor accident in 1957 at Windscale, England,- released a significant quantity of radioiodine, approximately 20,000 Ci, to the environment. This reactor, which was not operated to generate electricity, used air rather than water to cool the uranium fuel. During a special operation to heat the large amount of graphite in this reactor, the fuel overheated and radioiodine and noble gases were released directly to the atmosphere from a 405-ft stack. Milk produced in a 200-mi2 area around the facility was impounded for up to
5-34 44 days. This kind of accident cannot occur in a water cooled reactor like Midland, however. 5.9.4.4 Mitigation of Accident Consequences Pursuant to the Atomic Energy Act of 1954, the Nuclear Regulatory Commission has conducted a safety evaluation of the application to operate Midland Plant Units 1 and 2. Although this evaluation contains more detailed information on plant design, the principal design features are presented in the following section. (1) Design Features The Midland Plant Units 1 and 2 contain features designed to prevent accidental release of radioactive fission products from the fuel and to lessen the conse-quences should such a release occur. Many of the design and operating specifi-cations of these features are derived from the analysis of postulated events known as design-basis accidents. These accident preventive and mitigative features are collectively referred to as engineered safety features (ESF). The possibilities or probabilities of failure of these systems is incorporated in the assessments discussed in Section 5.9.4.5(2). The steel-lined, prestressed, post-tensioned concrete containment is a passive mitigating system which is designed to minimize accidental radioactivity releases to the environment. Safety injection systems are incorporated to provide cooling water to the reactor core during an accident to prevent or minimize fuel damage. Cooling fans provide heat-removal capability inside the containment following steam release in accidents and help to prevent contain-ment failure due to overpressure. Similarly, the containment spray system is designed to spray cool water into the containment atmosphere. The spray water also contains an additive (hydrazine) which will chemically react with any airborne radioiodine to remove it from the containment atmosphere and reduce its release to the environment. ' All the mechanical systems mentioned above are supplied with emergency power from onsite diesel generators in the event that normal offsite station power is interrupted. The fuel-handling building also has accident-mitigating systems. The safety-grade ventilation system contains both charcoal and high efficiency particulate filters. This ventilation system is also designed to keep the area around the spent-fuel pool below the prevailing barometric pressure during fuel-handling operations so that outleakage won't occur through building openings. If radioactivity were to be released into the building, it would be drawn through the ventilation system and any radioactive iodine and particulate fission products would be removed from the flow stream before exhausting to the outdoor atmosphere. There are features of the plant that are necessary for its power generation function that can also play a role in mitigating certain accident consequences. For example, the main condenser, although not classified as an ESF, can act to mitigate the consequences of accidents involving leakage from the primary to the secondary side of the steam generators (such as steam generator-tube ruptures). If normal offsite power is maintained, the ability of the plant to
5-35 send contaminated steam to the condenser instead of releasing it through the safety valves or atmospheric dump valves can significantly reduce the amount of radioactivity released to the environment. In this case, the fission-product-removal capability of the normally operating offgas treatment system would come into play. Much more extensive discussions of the safety features and characteristics of the Midland Plant Units 1 and 2 may be found in applicant's Final Safety Analysis Report (Ref. 48). The staff evaluation of these features are addressed in the Safety Evaluation Report (Ref. 49). In addition, the implementation of the lessons learned fom the TMI-2 accident, in the form of improvements in design, and procedures and operator training, will significantly reduce the likelihood of a degraded core accident which could result in large releases of fission products to the containment. Specifically, the applicant will be required to meet those TMI-related requirements specified in NUREG-0737 (Ref. 56). As noted in Section 5 9.4.5(7), no credit has been taken for these actions and improvements in discussing the radiological risk of accidents. (2) Site Features The NRC's reactor site criteria,10 CFR Part 100, requires that the site for every power reactor have certain characteristics that tend to reduce the risk and potential impact of accidents. The discussion that follows briefly describes the Midland site characteristics and how they meet these requirements. The site has an exclusion area as required by 10 CFR Part 100. The minimum exclusion area distance from either reactor unit is 1702 feet (519 meters). Most of the exclusion area is located within the 1,235 acre site owned by the Consumers Power Company. The remainder consists of two segments of land owned by the Dow Chemical Company, and portions of the Tittabawassee River and Bullock Creek. The control of activities within the portions of the exclusion area owned by Dow is covered by terms of the General Agreements between Dow and the applicants. This includes a revised Dow emergency plan with respect to evacuation and other applicable provisions whenever required to do so by the terms of the applicants' Site Emergency Plan. With respect to the portions of the Tittabawassee River and Bullock Creek within the exclusion area, arrange-ments have been made with local and state law enforcement agencies for removal and exclusion of the public. There are no residents within the exclusion area. Therefore, the applicants have the authority, as required by Part 100, to determine all activities within the exclusion area. Activities unrelated to plant operations that occur within the exclusion area are limited to Dow personnel or Dow contractors performing construction, operation, or maintenance activities on the Dow property or easement portions of the exclusion area. The applicants will be equipped to contact the Dow Emergency Communications and Control Center via a direct hot line for the purpose of evacuating the Dow portions of the exclusion area. There are no railroads or highways traversing the exclusion area. In the event of an emergency, arrangements have been made with local and state law enforcement agencies to evacuate and limit access to the exclusion area, including access via the Tittabawassee River and Bullock Creek. Beyond and surrounding the exclusion area is a low population zone (LPZ), also required by 10 CFR Part 100. The LPZ for the Midland site is a circular area
5-36 with a one mile (1600 meter) radius centered on the centerline midpoint between Units 1 and 2. This area encompasses the property owned by the applicants, a part of the Dow Chemical Company industrial complex to the north, and 64 permanent residents to the southwest. The projected 2020 population within the LPZ is estimated to be 76. Within the zone, the applicant must assure that there is a reasonable probability that appropriate protective measures could be taken on behalf of the residents and other members of the public in the event of a serious accident. See also the following section on Emergency Preparedness. 10 CFR Part 100 also requires that the distance from the reactor to the nearest boundary of a densely populated area containing more than about 25,000 resi-dents be at least one and one-third times the distance from the reactor to the outer boundary of the LPZ. Since accidents more hazardous than those commonly postulated as representing an upper limit are conceivable, although highly improbable, it was considered desirable to add the population center distance requirement in Part 100 to provide for protection against excessive exposure doses to people in large centers. The City of Midland, Michigan, with a 1980 population of about 37,000 (an increase of about 2000 residents since 1970) is the nearest population center. Although a portion of the city is within 1-1/3 miles of the Midlanc plant, it consists almost entirely of the Dow Chemical Company property. Since Part 100 indicates that the population center distance is to be based upon considerations of population distribution, and that politi-cal boundaries are not controlling, the population center distance from the Midland plant is at least 1-1/3 times the distance to the outer boundary of the LPZ. The largest city within 50 miles is Flint, Michigan, with a 1980 population of nearly 160,000, located about 45 miles southwest of Midland. The projected population density within 30 miles of the site when the plant is scheduled to go into operation (1983) is about 194 persons per square mile. The population density within 30 miles is not expected to go beyond about 221 persons per square mile during the life of the plant. The safety evaluation of the Midland site has also included a review of poten-tial external hazards, i.e. , activities offsite that might adversely affect the operation of the plant and cause an accident. This review encompassed nearby industrial, transportation, and military facilities that might create explosive, missile, toxic gas, or similar hazards. A more detailed discussion of the compliance with the Commission's siting criteria and the consideration of external hazards is given in the staff's Safety Evaluation Report. (3) Emergency Preparedness Emergency preparedness plans including protective action measures for the Midland facility and environs are in an advanced, but not yet fully completed stage. In accordance with the provisions of 10 CFR Section 50.47, effective November 3, 1980, a full power operating license will not be issued to the appli-cant unless a finding is made by the NRC that the state of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Among the standards that must be met by these plans are provisions for two Emergency Planning Zones (EPZ). A plume exposure pathway EPZ of about 16 km (10 mi) in radius and an ingestion exposure pathway EPZ of about 80 km (50 mi) in radius are required. Other standards include appropriate ranges of protec-tive actions for each of these zones, provisions for dissemination to the
5-37 public of basic emergency planning information, provisions for rapid notifica-tion of the public during a serious reactor emergency, and methods, systems, and equipment for assessing and monitoring actual or potential offsite conse-quences in the EPZs of a radiological emergency condition, j NRC and the Federal Emergency Management Agency (FEMA) have agreed that FEMA will make a finding and determination as to the adequacy of State and local government Emergency Response Plans. NRC will determine the adequacy of the applicant's Emergency Response Plans with respect to the standards listed in Section 50.47(b) of 10 CFR Part 50, the requirements of Appendix E to 10 CFR Part 50, and the guidance contained in NUREG-0654/ FEMA-REP-1, Revision 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980. Af ter the above determinations by NRC and FEMA, the NRC will make a finding in the licensing process as to the overall and integrated state of preparedness. The.NRC staff findings will be reported in supplements to its Safety Evaluation Report (SER). Although the presence of adequate and tested emergency plans cannot prevent an accident, it is the staff's judgment that such plans can and will substantially mitigate the consequences to the public if an accident should occur. 5.9.4.5 Accident Risk and Impact Assessment (1) Design-Basis Accidents As a means of assuring that certain features of the Midland Plant Units 1 and 2 meet acceptable design and performance criteria, both the applicant and the staff have analyzed the potential consequences of a number of postulated accidents. Some of these could lead to significant releases of radioactive materials to the environment and calculations have been performed to estimate the potential radiological consequences to persons offsite. For each postu-lated initiating event, the potential radiological consequences cover a considerable range of values depending upon the particular course taken by the accident and the conditions, including wind direction and weather, prevalent during the accident. In the safety analysis and evaluation of the Midland Plant Units 1 and 2, three categories of accidents have been considered. These categories are based upon their probability of occurrence and include (a) incidents of moderate frequency, i.e. , events that can reasonably be expected to occur during any year of operation, (b) infrequent accidents, i.e. , events that might occur once during the lifetime of the plant, and (c) limiting faults, i.e. , accidents not expected to occur but that have the potential for significant releases of radioactivity. The radiological consequences of incidents in the first cate-gory, also called anticipated operational occurrences, are discussed in Sec-tion 5.9.3. Some of the initiating events postulated in the second and third categories for the Midland Plant Units 1 and 2 are shown in Table 5.5. These events are designated design-basis accidents in that specific design and operating features as described above in Section 5.9.4.4(1) are provided to limit their potential radiological consequences. Approximate radiation doses to the whole body that might be received by a person at the boundary of the plant exclusion area during the first 2 hours of the accidents are also shown in the table. The results shown in the table reflect the expectation that engineered safety and operating features designed to mitigate the consequences
5-38 of the postulated accidents would function as intended. An important implica-tion of this expectation is that the releases considered are limited to noble gases and radiciodines and that any other radioactive materials, e.g. , in particulate form, are not expected to be released. The results are also quasi probabilistic in nature in the sense that the meteorological dispersion conditions are taken to be neither the best nor the worst for the site, but rather at an average value determined by actual site measurements. In order to contrast the results of these calculations with those using more pessimistic, j or conservative, assumptions described below, the doses shown in Table 5.5 are i sometimes referred to as " realistic" doses. Population exposures which have been calculated for these events range from a small fraction of a person-rem to about 750 person-rem for the population within 80 km (50 mi) of the Midland Plant Units 1 and 2. These calculations for both individual and population exposure. indicate that the risk of incur-ring any adverse health effects as a consequence of these events is exceedingly small. By comparison with the estimates of radiological impact for normal operations shown in Section 5.9.3, we also conclude that radiation exposures j from design-basis accidents are roughly comparable to the exposures to indivi- ' duals and the population from normal station operations over the expected lifetime of the plant. The staff is carrying out calculations to estimate the potential upper bounds for individual exposures from the same initiating accidents in Table 5.5 for the purpose of implementing the provisions of 10 CFR Part 100, " Reactor Site Criteria." For these calculations, much more pessimistic (conservative or worst-case) assumptions are made as to the course taken by the accident and the prevailing conditions. These assumptions include much larger amounts of radioactive material released by the initiating events, additional single failures in equipment, operation of ESFs in a degraded mode,* and very poor meteorological dispersion conditions. The results of these calculations show that for these events the exposures are not expected to exceed 3 rems to the whole body and 183 rems to the thyroid of any individual at the exclusion area boundary over a period of 2 hours. For calculation of the thyroid dose, it will be assumed that an individual is located at a point on the exclusion area boundary where the radiciodine concentration in the plume has its highest value and inhales at a breathing rate characteristic of a person jog ~ging, for a period of 2 hr. The health risk to an individual receiving such a dose to the thyroid is the potential appearance of benign or malignant thyroid nodules in about 6 out of 100 cases, and the development of a fatal thyroid cancer in l about 2 out of 1,000 cases. None of the calculations of the impacts of design-basis accidents described in l this section takes into consideration possible reductions in individual or j population exposures as a result of taking any protective actions.
*The containment structure, however, is assumed to prevent leakage in excess of that which can be demonstrated by testing, as provided in 10 CFR Sec-tion 100.11(a).
5-39 (2) Probabilistic Assessment of Severe Accidents In this and the following three sections, there is a discussion of the prob-abilities and consequences of accidents of greater severity than the design-basis accidents discussed in the previous section. As a class, they are considered less likely to occur, but their consequences could be more severe, both for the plant itself and for the environment. These severe accidents, heretofore frequently called Class 9 accidents, can be distinguished from design-basis accidents in two primary respects: they involve substantial physical deterioration of the fuel in the reactor core, including overheating to the point of melting, and they involve deterioration of the capability of the containment structure to perform its intended function of limiting the release of radioactive materials to the environment. The assessment methodology employed is that described in the Reactor Safety Study (RSS) which was published in 1975 (Ref. 57).* However, the sets of accident sequences that were found in the RSS to be the dominant contributors to the risk in the prototype PWR (Westinghouse designed Surry Unit 1) have recently been updated ("rebaselined") (Ref. 58). The rebaselining has been done largely to incorporate peer group comments (Ref. 59), and better data and analytical techniques resulting from research and development after the publi-cation of the RSS. Entailed in the rebaselining effort was the evaluation of the individual dominant accident sequences--as they are understood to evolve. The earlier technique of grouping a number of accident sequences into the encompassing " Release Categories" as was done in the RSS has been largely (but not com-pletely) eliminated. The Midland plants are Babcock & Wilcox designed PWR's having similar design and operating characteristics to the RSS prototype PWR. Therefore, the present assessment for Midland has used as its starting point the rebaselined accident sequences and release categories referred to above, and more fully described in Appendix E. Characteristics of the sequences and release categories used (all of which involve partial to complete melting of the reactor core) are shown in Table 5.6. Sequences initiated by natural phenomena such as tornadoes, floods, or seismic events and those that could be initiated by deliberate acts of sabotage are not included in these event sequences. The radiological consequences of such events would not be different in kind from those which have been treated. Moreover, there are design criteria in 10 CFR Part 50, Appendix A and 10 CFR Part 100, relating to effects of natural phenomena, and safeguards requirements in 10 CFR Part 73, assuring that these potential initi-ators are in large measure taken into account in the design and operation of the plant. The data base for assessing the probabilities of events more severe than the design bases for natural phenomena and sabotage is small. Hence, inclusion of accident sequences initiated by natural events and sabotage in an accurate manner is beyond the state of-the-art of probabilistic risk assessment. In addition, the staff judges that the additional risk from severe
**Because this report has been the subject of considerable controversy, a discussion of the uncertainties surrounding it is provided in Section 5.9.4.5(7).
l l 5-40 l accidents initiated by natural events or sabotage is within the uncertainty of risks for the sequences considered here. Calculated probability per reactor year associated with each accident sequence or release category used is shown in the second column in Table 5.6. As in the RSS there are substantial uncertainties in these probabilities. This is due, in part, to difficulties associated with the quantification of human error and to inadequacies in the data base on failure rates of individual plant components that were used to calculate the probabilities (Ref. 59). The probability of accident sequences from the Surry plant were used to give a perspective of the societal risk at Midland because, although the probabilities of particular accident sequences may be substantially different and even improved for Midland, the overall effect of all sequences taken together is likely to be within the uncertainties (see Section 5.7.4.5(7) for discussion of uncertainties in risk estimates). The magnitudes (curies) of radioactivity release for each accident sequence or release category are obtained by multiplying the release fractions shown in Table 5.6 by the amounts that would be present in the plant at the time of the hypothetical accident. These are shown in Table 5.4 for a Midland plant at a core thermal power level of 2552 MWt, the power level used in the Safety Evaluation. The 54 nuclides shown in the table represent those, of the hundreds actually present in an operating plant, which are the major contributors to the health and economic effects of severe accidents. They were selected on the basis of half-life of the original nuclide, consideration of the health effects of the daughter products, and approximate relativa off-site dose contribution. The potential radiological consequences of these releases have been calculated by the consequence model used in the RSS (Ref. 60) adapted and modified as described below to apply to a specific site. The essential elements are shown in schematic form in Figure 5.3. Environmental parameters specific to the site of the Midland facility have been used and include the following: l - Meteorological data for the site representing a full year of consecutive i hourly measurements and seasonal variations, [ Projected permanent resident population for the year 2000 extending throughout regions of 80-km (50-mi) and 563-km (350-mi) radius from the site,
- The habitable land fraction within the 563-km (350-mi) radius,
- Land-use statistics, on a statewide basis, including farm land values, farm product values including dairy production, and growing season infor-mation, for the State of Michigan and each surrounding state within the 563-km (350-mi) region,
- Land-use statistics aciuding farmland values, farm product values includ-ing dairy production and growing season information for the adjoining regions of Canada within the 563-km (350-mi) radius, based on comparison with the values for the nearby states of the U.S., and
l 5-41 l As a separate category, the transient population within 8 km (5 mi) of l the site was considered. Transients are defined as visitors, school l populations, or employees, and the number and distribution were determined by weighting the actual number by an appropriate occupancy factor. l For the region beyond 563 km (350-mi), the United States average population was assumed. l To obtain a probability distribution of consequences, the calculations are performed assuming the occurrence of each accident-release sequence at each of 91 different " start" times throughout a 1 year period. Each calculation utilizes the site-specific hourly meteorological data and seasonal information for the time period following each " start" time. The consequence model also contains provisions for incorporating the consequence reduction benefits of evacuation, relocation, and other protective actions. Early evacuation and relocation of people would considerably reduce the exposure from the radio-active cloud and the contaminated ground in the wake of the cloud passage. The evacuation model used (see Appendix F) has been revised from that used in the RSS for better site-specific application. The quantitative characteristics of the evacuation model used for the Midland site are estimates made by the staff and are partly based upon evacuation time estimates prepared by the applicant. There normally would be special facilities near a plant, such as schools or hospitals, where special equipment or personnel may be required to effect evacuation. Several such facilities have been identified near the Midland site, such as the Midland Hospital Center and the Bullock Creek Elementary School. Further, there may be some people who either do not receive notification to evacuate, or who choose not to evacuate. Therefore, actual evacuation effectiveness could be greater or less than that character-ized but would not be expected to be very much less. The other protective actions include: (a) either complete denial of use (interdiction), or permitting use only at a sufficiently later time after appropriate decontamination of food stuffs such as crops and -ilk, (b) decon-tamination of severely contaminated environment (land and pre .y) when it is considered to be economically feasible to lower the levels of < atamination to protective action guide (PAG) levels, and (c) denial of use (interdiction) of severely contaminated land and property for varying periods of time until the contamination levels reduce to such values by radioactive decay and weathering so that land and property can be economically decontaminated as in (b) above. These actions would reduce the radiological exposure to the people from imme-diate and/or subsequent use of or living in the contaminated environment. Early evacuation within and early relocation of people from outside the piume exposure pathway EPZ (See Appendix F) and other protective actions as men-tioned above are considered as essential sequels to serious nuclear reactor accidents involving significant release of radioactivity to the atmosphere. Therefore, the results shown for a Midland reactor include the benefits of these protective actions. There are also uncertainties in each facet of the estimates of consequences and the error bounds may be as large as they are for the probabilities (see Figure 5.3).
5-42 The results of the calculations using this consequence model are radiological doses to individuals and to populations, health effects that might result from these exposures, costs of implementing protective actions, and costs associated with property damage by radioactive contamination. (3) Dose and Health Impacts of Atmospheric Releases The results of the calculations of dose and health impacts for the permanent resident population performed for the Midland facility and site are presented in the form of probability distributions in Figures 5.4 through 5.7 and are included in the impact Summary Table 5.7. All of the accident sequences and release categories shown in Table 5.6 contribute to the results, the con-sequences from each being weighted by its associated probability. l Figure 5.4 shows the probability distribution for the number of persons who might receive whole-body doses equal to or greater than 200 rems and 25 rems, and thyroid doses equal to or greater than 300 rems from early exposure,* all on a per-reactor year basis. The 200-rem whole-body dose figure corresponds ) approximately to a threshold value for which hospitalization would be indicated for the treatment of radiation iniury. The 25-rem whole-body (which has been identified earlier as the lower limit for a clinically observable physiological effect in nearly all people) and 300-rem thyroid figures correspond to the Commission's guideline values for reactor siting in 10 CFR Part 100. The figure shows in the left-hand portion that there are approximately 7 chances i in 1,000,000 (i.e. , 7 x 10 8) per reactor year that one or more persons may receive doses equal to or greater than any of the doses specified. The fact that the three curves run almost parallel in horizontal lines initially shows that if one person were to receive such doses, the chances are about the same that ten to hundreds would be so exposed. The chances of larger numbers of persons being exposed at those levels are seen to be considerably smaller. For example, the chances are about 2 in 10,000,000 (i.e., 2 x 10 7) that 1,000 l or more people might receive doses of 200 rems or greater. A majority of the exposures reflected in this figure would be expected to occur to persons within a 32-km (20-mi) radius of the plant. Virtually all would occur within a 160-km (100-mi) radius.
- Figure 5.5 shows the probability distribution for the total population exposure l in person-rems, i.e. , the probability per reactor year that the total popula-l tion exposure will equal or exceed the values given. Most of the population l exposure up to one million person-rems would occur within 50 miles but the more severe releases (as in the first two accident sequences in Table 5.6) would result in exposure to persons beyond the 50 mile range as shown.
For perspective, population doses shown in Figure 5.5 may be compared with the annual average dose to the population within 50 miles of the Midland site
*Early exposure to an individual includes external doses from the radioactive cloud and the contaminated ground, and the dose from internally deposited radionuclides from inhalation of contaminated air during the cloud passage.
Other pathways of exposure are excluded.
5-43 due to natural background radiation of 140,000 person-rems, and to the antici-pated annual population dose to the general public (total U.S.) from normal l plant operation of 37 person-rems (excluding plant workers) (Appendix C, Tables C.7 and C.9). Figure 5.6 shows the probability distributions for early fatalities, represen-ting radiation injuries that would produce fatalities within about one year after exposure. All of the early fatalities would be expected to occur within a 6.4-km (4-mi) radius and the majority within a 3.2-km (2-mi) radius. The results of the calculations shown in this figure and in Table 5.7 reflect the effect of evacuation within the 16.1-km (10-mi) plume exposure pathway EPZ only. Figure F.1 shows the effects of a much more pessimistic emergency response. Figure 5.7 represents the statistical relationship between population exposure and the induction of fatal cancers that might appear over a period of many years following exposure. The impacts on the total population and the popula-tion within 81 km (50 mi) are shown separately. Further, the fatal, latent cancers have been subdivided into those attributable to exposures of the thyroid and all other organs. (4) Economic and Societal Impacts As noted in Section 5.9.4.2, the various measures for avoidance of adverse health effects including those due to residual radioactive contamination in the environment are possible consequential impacts of severe accidents. Calculations of the probabilities and magnitudes of such impacts for the Midland facility and environs have also been made. Unlike the radiation exposure and health effect impacts discussed above, impacts associated with adverse health effects avoidance are more readily transformed into economic impacts. The results are shown as the probability distribution for cost of offsite mitigating actions in Figure 5.8 and are included in the impact Summary Table 5.7. The factors contributing to these estimated costs include the following: Evacuation costs Value of crops contaminated and condemned Value of milk contaminated and condemned Costs of decontamination of property where practical Indirect costs due to loss of use of property and incomes derived there-from. The last-named costs would derive from the necessity for interdiction to prevent the use of property until it is either free of contamination or can be economically decontaminated. Figure 5.8 shows that at the extreme end of the accident spectrum these costs could exceed several billion dollars but that the probability that this would
5-44 occur is exceedingly small, less than one chance in a hundred million per reactor year. Additional economic impacts that can be monetized include costs of decontami-nation of the facility itself and the costs of replacement power. Probability distributions for these impacts have not been calculated but they are included ) in the discussion of risk considerations in Section 5.9.4.5(6) below. ) (5) Releases to Groundwater A groundwater pathway for public radiation exposure and environmental contami-nation that would be associated with severe reactor accidents was identified in Section 5.9.4.2(2) Exposure Pathways. Consideration has been given to the potential environmental impact of this pathway for the Midland Plant. The principal contributors to the risk are the core-melt accidents associated with the evaluated accident sequences and release categories. The penetration of the basemat of the containment buildings can release molten core debris to the strata beneath the station. Soluble radionuclides in this debris can be leached and transported with groundwater to downgradient domestic wells used for drinking, or to surface water bodies used for drinking, aquatic food, and recreation. In pressurized water reactors, such as the Midland units, there is an additional opportunity for groundwater contamination due to the release of contaminated sump water to the ground through a breach in the containment. An analysis of the potential consequences of a liquid pathway release of radioactivity for generic sites was presented in the " Liquid Pathway Generic Study" (LPGS) (Ref. 61). The LPGS compared the risk of accidents involving the liquid pathway (drinking water, irrigation, aquatic food, swimming, and shoreline usage) for four conventional, generic land-based nuclear plants and a floating nuclear plant, for which the nuclear reactors would be mounted on a I barge and moored in a water body. Parameters for the land-based sites were chosen to represent averages for a wide range of real sites and are thus
" typical," but represented no real site in particular. The study concluded that the individual and population doses for the liquid pathway range from fractions to very small fractions of those that can arise from the airborne pathways.
The Midland site is located above two groundwater systems (Ref. 48, Ref. 49 and ER-OL): an isolated perched groundwater table in the surficial sands and a deeper confined aquifer. A layer of clay approximately 46 meters (150 feet) thick separates these two groundwater systems. The reactor foundation mats are located in this clay layer at an elevation of 176 meters (578 feet) above mean sea level (msl). In the event of a core-melt accident, there could be a release of radioactivity to the clay layer beneath the reactor. However, in order for the confined aquifer to become contaminated, radioactive water would have to travel through the 46-meter (150-foot) thick clay layer which is essentially impervious. It is extremely unlikely that a core-soil mass would penetrate to this depth. The Reactor Safety Study (WASH-1400) (Ref. 57) contained estimates based upon boundary heat transfer calculations that the core-soil mass would form a cylinder about 15 meters (50 feet) high with a diameter of about 21 meters (70 feet). The core-soil mass would thus De expected to remain at least 31 meters (100 feet) above the confined aquifer. In addition, the confined aquifer is a
5-45 under artesian pressure so any penetration of the overlying clay layer would induce outward flow from the aquifer. The groundwater gradient in the surficial sands is toward the Tittabawassee River. There are no wells located in these sands anywhere between the plant and the river. Prior to construction of the Midland Plant, the surficial sands were present over much of the site. During plant excavation activities, these sands were removed from the areas where the containment structures and the auxiliary building are located, however; these sands are still present in areas surrounding these structures. As described above, the reactor mats are located in the clay layer which underlies the surficial sands so it is not likely that a core-melt accident would result in contaminants reaching the surficial sands. However, the staff postulated a situation whereby the radio-activity released from the bottom of the reactor would reach the surficial sand layer and travel toward the Tittabawassee River. Using conservative values of 1050 feet per year for permeability, an effective porosity of 0.25 and a hydraulic gradient of 0.007, the staff determined that the time it would take for the radioactive spill to travel to the river would be long enough so that any contamination of the Tittabawassee River would be virtually eliminated. The staff estimated that the minimum groundwater travel time from the reactors to the river, in the surficial sand layer, would be about 59 years. In addi-tion, the two elements which are shown (Ref. 61) to contribute practically all of the population dose from the liquid pathway in an assumed core-melt accident, are Sr-90 and Cs-137. These chemically active nuclides would, however, travel through the groundwater pathway at a much slower rate because of the process of sorption onto the sand. The staff conservatively estimates that less than 3 x 10 6 of any Sr-90 and virtually none of the Cs-137 released in a core-melt accident would escape the site due to the long travel times relative to the half lives. This result can be compared to 0.87 of the Sr-90 and 0.31 of the Cs-137 escaping the site in the LPGS small river case. Without further analysis the staff can conclude that the liquid pathway consequences of an assumed core-melt accident at Midland would be less than that calculated in the LPGS. The staff, therefore, concludes that the Midland Plant is not unique in its liquid pathway contribu-tion to risk when compared to other land-based sites in the LPGS. Finally, there are measures which could be taken to further minimize the impact of the liquid pathway. The staff estimated that the minimum ground-water travel time from the Midland site to the Tittabawassee River was 59
- years and that the holdup of much of the radioactivity would be much greater.
l This would allow ample time for engineering measures such as slurry walls and well point dewatering to isolate the radioactive contamination near the source.
- (6) Risk Considerations l
The foregoing discussions have dealt with both the frequency (or likelihood of occurrence) of accidents and their impacts (or consequences). Since the ranges of both factors are quite broad, it is also useful to combine them to obtain average measures of environmental risk. Such averages can be particu-larly instructive as an aid to the comparison of radiological risks associated with accident releases and with normal operational releases.
5-46 A common way in which this combination of factors is used to estimate risk is to multiply the probabilities by the consequences. The resultant risk is then expressed as a number of consequences expected per unit of time. Such a quantification of risk does not at all mean that there is universal agreement that peoples' attitudes about risks, or what constitutes an acceptable risk, can or should be governed solely by such a measure. At best, it can be a contributing factor to a risk judgment, but not necessarily a decisive factor. In Table 5.8 are shown average values of risk associated with population dose, l early fatalities, latent fatalities, and costs for evacuation and other protec-tive actions. These average values are obtained by summing the probabilities l multiplied by the consequences over the entire range of the distributions. Since the probabilities are on a per reactor year basis, the averages shown are also on a per-reactor year basis. The values for the resident and transient population are shown separately. Since it is likely that a large portion of the transients are also permanent residents, the results should not be added or substantial double counting would result. The population exposures and latent cancer fatality risks may be compared with those for normal operation shown in Appendix C. The comparison (excluding exposure to the plant personnel) shows that the accident risks are comparable to those for normal operation. There are no early ' fatality or economic risks associated with protective actions and decontamination for normal releases, therefore, these risks are unique for accidents. For perspective and understanding of the meaning of the early fatality risk of 0.000015/ reactor year, however, we note that to a good approximation the population at risk is that within about 16 km (10 mi) of the plant, about 80,000 persons in the year 2000. Accidental fatalities per year for a population of this size, based upon overall averages for the United States, are approximately 18 from motor vehicle accidents, 6.2 from falls, 2.5 from drowning, 2.3 from burns, and 1.0 from firearms (p. 577 of Ref. 50). The early fatality risk of 0.000015/ reactor year is thus 5 x 10 5 percent of the total risk embodied in the above combined accident modes. Figure 5.9 shows the calculated risk expressed as whole-body dose to an indivi-dual from early exposure as a function of the downwind distance from the plant within the plume exposure pathway EPZ. The values are on a per-reactor year basis and all accident sequences and release categories in Table 5.6 contributed to the dose, weighted by their associated probabilities. l Evacuation and other protective actions can reduce the risk to an individual of early fatality or of latent cancer fatality. Figure 5.10 shows curves of constant risk per reactor year to an individual, living within the plume exposure pathway EPZ of the Midland site, of early fatality as functions of distance due to potential accidents in the reactor. Figure 5.11 shows the same type of curves for risk of latent cancer fatality. Directional variation of these curves reflects the variation in the average fraction of the year the wind would be blowing into different directions from the plant. For comparison the following risks of fatality per year to an individual living in the United States may be noted (p. 577 of Ref. 50): automobile accident 2.2 x 10 4, falls 7.7 x 10 5, drowning 3.1 x 10 5, burning 2.9 x 10 5, and firearms 1.2 x 10 5
5-47 The economic risk associated with evacuation and other protective actions i could be compared with property damage costs associated with alternative energy generation technologies. The use of fossil fuels, coal or oil, for example, would emit substantial quantities of sulfur dioxide and nitrogen oxides into the atmosphere, and, among other things, lead to environmental, and ecological damage through the phenomenon of acid rain (pp. 559-560 of Ref. 50). This effect has not, however, been sufficiently quantified to draw a useful comparison at this time. 4 There are other economic impacts and risks which are not included in the cost calculations discussed in Section 5.9.4.5(4) that can be monetized. These are accident impacts on the facility itself that result in added costs to the public, i.e. , ratepayers, taxpayers, and/or shareholders. These costs would be for decontamination and repair or replacement of the facility, and replace-ment power. Experience with such costs is currently being accumulated as a result of the Three Mile Island accident. If an accident occurs during the first full year of Midland 2 operation (1984), the economic penalty associated with the initial year of the unit's operation is estimated (based on THI-2) at between $950 and $1600 million (Ref. 62) for decontamination and restoration, . including replacement of the damaged nuclear fuel. For purposes of this analysis, staff used the conservative (high) estimate of $1600 million and in addition assumed the total cost occurs during the first year of the accident. In reality the costs would be spread over several years thereafter. Although insurance would cover $300 million of the $1600 million, the insurance is not credited against the $1600 million because the $300 million times the risk probability should theoretically balance the insurance premium. Additional fuel costs of $165 million (1984 dollars) would accrue for replacement power during each year the Midland 2 unit is being restored. This estimate assumes that the energy that would have been forthcoming from the damaged unit (assum-ing 60 percent capacity factor) will be replaced 87 percent by coal-fired generation and 13 percent by oil and gas-fired generation in the Michigan area. Assuming the nuclear unit does not operate for 8 years, the total additional replacement power costs would be approximately $1320 million in 1984 dollars. If the probability of sustaining a total loss of the original facility is taken as the sum of the occurrences of a core-melt accident (the sum of the probabilities for the categories in Table 5.6) then the probability of a disabling accident happening during each year of the unit's service life is 4.8 x 10 5 Multiplying the previously estimated costs of $2920 million for an accident to Midland 2 during the initial year of its operation by the above 4.8 x 10 5 probability results in an economic risk of approximately $140,000 (in 1984 dollars) applicable to Midland 2 during its first year of operation. This is also approximately the economic risk (in 1984 dollars) to Midland 2 during the second and each subsequent year of its operation. Although nuclear units depreciate in value and may operate at reduced capacity factors such that the economic consequences due to an accident become less as the units become older, this is considered to be offset by higher costs of decontami-nation and restoration of the units in the later years due to inflation. e economic risk from Midland 1 (in 1984 dollars) is also approximately
#140,000 during its first year and each subsequent year of operation due to the balancing effect of escalation and the present worth discount factor.
Although Midland 1 will be used partially to produce steam and only partially
4 5-48 to produce electricity, the net effect on costs is the same because the steam would be obtained from Unit 2 in the event that Unit 1 were disabled. The
$140,000 annual risk for each unit in 1984 dollars is equivalent to a $96,000 annual risk in 1980 dollars, assuming a 10 percent discount rate.
(7) Uncertainties The foregoing probabilistic and risk assessment discussion has been based upon the metho,dology presented in the Reactor Safety Study which was published in i 1975. There are substantial uncertainties associated with the numerical estimates of the likelihood, as well as the consequences, of severe reactor accidents that are evaluated using this methodology. In the consequence calculations, uncertainties arise from an over-simplified analysis of the magnitude and timing of the fission product release, from uncertainties in calculated energy release, from radionuclide transport from the core to the receptor, from lack of precise dosimetry, and statistical variations of health effects. Recent investigations of accident source terms, . for example, have shown that a number of physical phenomena affecting fission product transport through the primary cooling system and the reactor contain-ment have been neglected. Some of these processes have the potential for substantially reducing the quantity of fission products predicted to be released from the containment for some accident sequences. Such a reduction in the source term would result in substantially lower estimates of health effects, particularly the estimate of early fatalities. One area given considerable recent thought with respect to uncertainty is atmospheric dispersion. Although recent developments in the area of atmospheric dispersion modelling used in CRAC (the computer code developed in the RSS) indicate that an improved meteorological sampling scheme would reduce the uncertainties arising from this source (including the effect of washout by precipitation), large uncertainties would still remain in the calculations of radionuclide concentrations in the air and the ground from which radiological exposures to an individual and the population are calculated. These uncertain-ties arise from lack of precise knowledge about the particle size distribution of the radionuclides released in particulate forms and about their chemical behavior. Therefore, the parameters of particulate deposition which exert considerable influence on the calculated results have uncertain values. The vertical rise of the radioactive plume is dependent on the heat and momentum associated with the release categories, and calculations of both factors have considerable uncertainty. The duration of release which determines the cross-wind spread of the plume is another example of considerable uncertainty. Warning time before evacuation also has considerable impact on the effectiveness of offsite emergency response; and this parameter is not precisely calculated because of its dependence on other parameters (e.g. , time of release) which are not precisely known. The state-of-the-art for quantitative evaluation of the uncertainties in the probabilistic risk analysis such as the type presented here is not well developed. Therefore, although the staff has made a reasonable analysis of the risks presented herein, there are large uncertainties associated with the results shown. It is the judgment of the staff that the uncertainty bounds could be well over a factor of 10, but are not likely to be so large as a factor of 100.
f 5-49 The accident at Three Mile Island occurred in March 1979 at a time when the
, accumulated experience record was about 400 reactor years. It is of interest to note that this was within the range of frequencies estimated by the RSS for an accident of this severity (p. 553 of Ref. 50). It should also be noted that the Three Mile Island accident has resulted in a very comprehensive evaluation of reactor accidents like that one, by a significant number of investigative groups both within NRC and outside of it. Actions to improve the safety of nuclear power plants have come out of these investigations, including those from the President's Commission on the Accident at Three Mile Island, and NRC staff investigations and task forces. A comprehensive "NRC Action Plan Developed as a Result of the TMI-2 Accident," NUREG-0660, Vol. I, May 1980 (Ref. 63) collects the various recommendations of these groups and .
describes them under the subject areas of: Operational Safety; Siting and Design; Emergency Preparedness and Radiation Effects; Practices and Procedures; and NRC Policy, Organization, and Management. The action plan presents a sequence of actions, some already taken, that result in a gradually increasing
; improvement in safety as individual actions are completed. The Midland plants are receiving and will receive the benefit of these actions on the schedule indicated in NUREG-0660. The improvement in safety from these actions has not been quantified, however, and the radiological risk of accidents discussed in this chapter does not reflect these improvements.
5.9.4.6 Conclusions The foregoing sections consider the potential environmental impacts from accidents at the Midland facility. These have covered a broad spectrum of possible accidental releases of radioactive materials into the environment by J atmospheric and grounowater pathways. Included in the considerations are 1 I postulated design-basis accidents and more severe accident sequences that lead to a severely damaged reactor core or core-melt. The environmental impacts that have been considered include potential radiation 3 exposures to individuals and to the population as a whole, the risk of near-and long-term adverse health effects that such exposures could entail, and the
- potential economic and societal consequences of accidental contamination of the environment. These impacts could be severe but the likelihood of their occurrence is judged to be small. This conclusion is based on (a) the fact that considerable experience has been gained with the operation of similar facilities-without significant degradation of the environment, (b) the fact, in order to obtain a license to operate the Midland facility, Consumers Power i
must comply with the applicable Commission regulations and requirements, and l (c) a probabilistic assessment of the risk based upon the methodology developed in the Reactor Safety Study. The overall assessment of environmental risk of accidents, assuming protective action, shows that it is roughly comparable to 3 the risk from normal operation although accidents have a potential for early
- fatalities and economic costs that cannnot arise from normal operations. The
- risks of early fatality from potential accidents at the site are small in comparison with risks of early fatality from other human activities in a comparably sized population. We have concluded that there are no special or unique radiological circumstances about the Midland site and environs that 3
would warrant special mitigation features for the Midland Plant.
5-50 5.10 IMPACTS FROM THE URANIUM FUEL CYCLE The Uranium Fuel Cycle Rule,10 CFR Part 51.20 (44 FR 45362), reflects the latest information relative to the reprocessing of spent fuel and to radio-active waste management as discussed in NUREG-0116, Environmental Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle (Ref. 64) and NUREG-0216 (Ref. 65), which presents staff responses to comments on NUREG-0116. The rule also considers other environmental factors of the uranium I fuel cycle, including aspects of mining and milling, isotopic enrichment, fuel ! fabrication, and nianagement of low- and high-level wastes. These are described 1 in the AEC report WASH-1248, Environmental Survey of the Uranium Fuel Cycle (Ref. 66). The Commission also directed that an explanatory narrative be developed that would convey in understandable terms the significance of releases in the table. The narrative was also to address such important fuel cycle impacts as environmental dose commitments and health effects, socioeconomic impacts and cumulative impacts, where these are appropriate for generic treat-ment. This explanatory narrative was published in the Federal Register on March 4,1981 (46 FR 15154-15175). Appendix G to this statement contains a number of sections that address those impacts of the LWR-supporting fuel cycle , that reasonably appear to have significance for individual reactor licensing I sufficient to warrant attention for NEPA purposes. Table S-3 of the final rule is repro.duced herein in its entirety as Table 5.9. Specific categories of natural resource use included in the table relate to land use, water consumption and thermal effluents, radioactive releases, burial of transuranic and high- and low-level wastes, and radiation doses from transportation and occupational exposures. The contributions in the table for reprocessing, waste management, and transportation of wastes are maximized for either of the two fuel cycles (uranium only and no recycle); that is, the cycle that results in the greater impact is used. On April 27, 1982, the U.S. Court of Appeals for the District of Columbia Circuit issued a decision addressing the validity of the waste management por-tion of Table S-3. Natural Resources Defense Council v. NRC, No. 74-1586 (D.C. Cir., April 27, 1982). The Commission is considering the effect of this decision and intends to issue a policy statement providing further guidance regarding it. 1 Appendix G to this statement contains a description of the environmental impact assessment of the uranium fuel cycle as related to the operation of the Midland Plant. The environmental impacts are based on the values given in Table S-3, and on an analysis of the radiological impact from radon-222 and technetium-99 releases. The NRC staff has determined that the environmental impact of the plant on the U.S. population from radioactive gaseous and liquid , releases (including radon and technetium) due to the uranium fuel cycle is very small when compared with the impact of natural background radiation. In addition, the nonradiological impacts of the uranium fuel cycle have been found to be acceptable. 5.11 DECOMMISSIONING , 1 The purpose of decommissioning is to safely remove nuclear facilities from service and to remove or isolate the associated radioactivity from the environ-ment so that part of the facility site that is not permanently committed can
5-51 be released for other uses. Alternative methods of accomplishing this purpose and the environmental impacts of each method are discussed in NUREG-0586, "Draf t Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" (Ref. 67). Since 1960, 68 nuclear reactors, including 5 licensed reactors that had been used for the generation of electricity,,have been or are in the process of being decommissioned. Although no large commercial reactor has undergone decommis-sioning to date, the broad base of experience gained from smaller facilities is generally relevant to the decommissioning of any type of nuclear facility. Radiation doses to the public, as a result of decommissioning activities, at the end of a commercial power reactor's useful life, should be small and will come primarily from the transportation of waste to appropriate repositories. Radiation doses to decommissioning workers should be well within the occupational exposure limits imposed by regulatory requirements. The NRC is currently conducting a generic rulemaking which will develop a more explicit overall policy for decommissioning commercial nuclear facilities. Specific licensing requirements are being considered that include the development of decommissioning plans and financial arrangements for decommissioning nuclear facilities. Estimates of the economic cost of decommissioning are provided in Section 6.4.2.1 of the statement. 5.12 EMERGENCY PLANNING IMPACTS In connection with the promulgation of the Commission's upgraded emergency planning requirements, the NRC staff (Office of Standards Development) issued NUREG-0658, " Environmental Assessment for Effective Changes to 10 CFR Part 50 and Appendix E to 10 CFR Part 50; Emergency Planning Requirements for Nuclear Power Plants," (August 1980). The staff believes the only noteworthy potential source of impacts to the public from emergency planning would be associated with the testing of the early notification system. The test requirements and noise levels will be consistent with those used for existing alert systems; therefore, the staff concludes that the noise impacts fron the system will be infrequent and insignificant. References for Section 5
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2
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~ _ . . , - - , - - - - ~ - - . - -- , - - - , ,
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- 41. " Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Regulatory Guide 1.109, Revision 1, U.S. Nuclear Regulatory Commission, October 1977.
- 42. " Cancer Facts and Figures 1979," American Cancer Society, 1978.
- 43. 8. G. Blaylock and J. P. Witherspoon, " Radiation Doses and Effects Estimated for Aquatic Biota Exposed to Radioactive Releases from LWR Fuel-Cycle Facilities," Nuclear Safety 17:351, 1976. !
- 44. " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants," Regulatory Guide 4.1, Revision 1, U.S. Nuclear Regulatory Commission, April 1975.
- 45. "An Acceptable Radiological Environmental Monitoring Program," Radio-logical Assessment Branch Technical Position, Revision 1, U.S. Nuclear Regulatory Commission, November 1979.
I
5-55
- 46. "Heasuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Regulatory Guide 1.21, Revi-sion 1, U.S. Nuclear Regulatory Commission, June 1974.
- 47. Statement of Interim Policy, " Nuclear Power Plant Accident Considerations Under the National Environmental Policy Act of 1979," 45 F3 40101-40104, June 13, 1980.
- 48. " Final Safety Analysis Report, Midland Plant Units 1 and 2," Docket Nos. 50-329 and 50-330, Consumers Power Company, Docket date November 18, 1977, as amended.
- 49. " Safety Evaluation Report for the Midland Plant Units No. I and 2,"
Docket Nos. 50-329 and 50-330, NUREG-0793, May 1982.
- 50. " Energy in Transition 1985 - 2010," Final Report of the Comaittee on Nuclear and Alternative Energy Systems (CONAES), National Research Council, Chapter 9, pp 517-534, 1979.*
- 51. C.E. Land, Science 209, 1197, September 12, 1980.
- 52. H. W. Bertini et al., " Descriptions of Selected Accidente That Have Oc-curred at Nuclear Reactor Facilities," Nuclear Safety Information Center, Oak Ridge National Laboratory, ORNL/NSIC-176, April 1980.
- 53. L. B. Marsh, " Evaluation of Steam Generator Tube Rupture Accidents,"
U.S. Nuclear Regulatory Commission, NUREG-0651, March 1980.
- 54. "Three Mile Island - A Report to the Commissioners and the Public,"
Vol. I, Mitchell Rogovin, Director, Nuclear Regulatory Commission Special Inquiry Group, Summary Section 9, January 1980.
- 55. " Report of the President's Commission on the Accident at Three Mile Island," Commission Findings B, Health Effects, October 1979.
- 56. " Clarification of TMI Action Plan Requirements," U.S. Nuclear Regulatory Commission, NUREG-0737, November 1980.
- 57. " Reactor Safety Study--An Assessment," U.S. Nuclear Regulatory Commission, WASH-1400 (NUREG-75/014), October 1975.
- 58. " Task Force Report on Interim Operations of Indiaa Point," NUREG-0715, August 1980.
\
- 59. H. W. Lewis et al., " Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission," NUREG/CR-0400, September 1978.
- 60. " Overview of the Reactor Safety Study Consequences Model," U.S. Nuclear Regulatory Commission, NUREG-0340, October 1977.
*This report was also published in 1980 by W.H. Freemin and Company. Pages cited will differ.
l l 5-55a l
- 61. " Liquid Pathway Generic Study," U.S. Nuclear Regulatory Commission, NUREG-0440, February 1978.
- 62. " Report to the Congress, by the Comptroller General of the United States,"
EM0-81-106, August 26, 1981.
- 63. "NRC Action Plan Develeped as a Result of the TMI-2 Accident," Vol. I, U.S. Nuclear Regulatory Commission, NUREG-0660, May 1980. i
- 64. " Environmental Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle," NUREG-0116 (Supplement 1 to WASH-1248), U.S.
Nuclear Regulatory Commission, October 1976.
- 65. "Public Comments and Task Force Responses Regarding the Environmental Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle," NUREG-0216 (Supplement 2 to WASH-1248), U.S. Nuclear Regulatory Commission, March 1977.
- 66. " Environmental Survey of the Uranium Fuel Cycle," WASH-1248, U.S. Atomic Energy Commission, April 1974.
- 67. " Draft Environmental Impact Statement on Decommissioning of Nuclear Facili-ties," U.S. Nuclear Regulatory Commission, NUREG-0586, January 1981.
- 68. D. Isherwood, "Geoscience Data Base Handbook for Modeling a Nuclear Waste Repository," NUREG/CR-0912, Vol.1, prepared for the U.S. Nuclear Regulatory Commission by Lawrence Livermore Laboratory, January 1981.
1 t
)
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5-58 Veather Data i Release Categories At.tospheric Dispersion >
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Cloud Depletion 4 Property Damage
-9 Population v l d '
I Grouno Contamination & Evacuation Figure 5.3. Schematic Outline of Atmospheric Pathway Consequence Model l 1 l l
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1 l 5-67 Table 5.1. Incidence of Job-Related Mortalities l Mortality Rates Occupational Group (premature deaths per 105 person years) Underground metal miners * *1300 Uranium miners
- 420 Smelter workers
- 190 Mining ** 61 Agriculture, forestry, and fisheries ** 35 Contract construction ** 33 Transportation and public utilities ** 24 Nuclear plant worker *** 23 Manuf acturi r g ** 7 Wholesale and retail trade ** 6 Finance, insurance, and real estate ** 3 Services ** 3 Total private sector ** 10
*The President's Report on Occupational Safety and Health, " Report on Occupational Safety and Health by the U.S. Department of Heal'.h, Education and Welfare," E. L. Richardson, Secretary, May 1972.
**U.S. Bureau of Labor Statistics, " Occupational Injuries and Illness in the United States by Industry, 1975," Bulletin 1981, 1978.
***The nuclear plant workers' risk is equal to the sum of the radiation-related risk and the nonradiation-related risk. The occupational risk associated .
withtheindustry-wideaverageradiationdoseof0.8remisabout11poten-tial premature deaths per 10 person years due to cancer, based on the risk estimators described in the following text. The average nonradiation-related risk for seven U.S. electrical utilities over the period 1970-1979 is about 12 actual premature deaths per 105 person years as shown in Figure 5 of the paper by R. Wilson and E. S. Koehl, " Occupational Risks of Ontario Hydro's Atomic Radiation Workers in Perspective," presented at Nuclear Radiation Risks, A Utility-Medical Dialog, sponsored by the Inter-national Institute of Safety and Health in Washington, D.C., September 22-23, 1980. (Note that the estimate of 11 radiation-related premature cancer deaths is potential rather than actual.)
i l l 1 5-68 1 Table 5.2. (Summary Table S4). Environmental Impact of Transportation of Fuel and Waste to and From One Light-Water-Cooled Nuclear Power Reactori NORMAL CONDjTiONS OF TRANSPORT Enwonmentalampact Heat (per tradiated fuel cask in transst).. 250.000 Btu /hr. Weight (governed by Federal or State restrctions).. 73.000 lbs. per truck; 100 tons per cask per rasi car. Traffe density-Truck.. . _ .
. . . _ . . . Less than I per day.
Rail .. . . . . . Less than 3 per montn. Estimated Range of doses to Cumulative dose to Exposed populaton number of exposed andmc;aals ' exposed population persons (per reactor year) (per reactor year) a exposed Transportaten workers.. 200 0 01 to 300 mdirem... 4 man-tem. General pubhc: Onlookers .. 1,100 0 003 to 1.3 mitrem... .. 3 man-rem. Along Route 600,000 0 0001 to 0 06 milwem., ACCIDENTS IN TRANSPORT Enwonmentalnsk Radologcal effects . . .... Small *. Common (nonradiological) causes .. . _ . . . 1 fatal snjury e 100 reactor years,1 nonfatal enfury en 10 re-actor years, $475 property damage per reactor year.
' Data supporting this table are grven in the Comrnissson's Envronmental Survey of Transportaten of Radcactive Matenals to and from Nuclear Power Plants," WASH-1238. December 1972, and Supp l. NUREG-75/038 Apni 1975. Both documents are avadable for inspecten and copying at the Comrnesson's Pubhc Document Room.1717 H St. NW., Washingtun, D.C., and may be obtained from National Technical Informaton Sennce, Spnngfield. Va 22161. WASH-1238 is available from NTIS at a cost of $5 45 (mcrofche, $2 25) and NUREG-75/038 ss avadable at a cost of $3 25 (mcrotche, $2.25).
aThe Federal Radiaton Couned has recommended that the radiaton doses from all sources of radiaton other than natural background and medecal exposures should be hated to 5.000 mdluem per year IN andmduals as a result of occupatonal expo-sure and should be hmited to 500 milrem per year for andmduals an the general pop;iaton. The dose to indmduals due to average natural background radeten is about 130 rndirem per year.
' Man-rem is an expression for the summaton of whole body doses to indmduals in a group. Thus, if each member of a populaton group of 1,000 people were to receeve a dose of 0 001 rem (1 mdirem), or if 2 people were to receive a dose of 0.5 rem (500 mdhrem) each, the total man-rem dose en each case would be 1 man-rem
' Although the epvronmental nsk of radological effects stemang from transportahon accidents as currently ancapable of being numercalty quantified, the nsk remains small regardless of whether et is being apphed to a sangle reactor or a multreactor site
I Table 5.3. Radiological Environmental Monitoring Program - Operational Phase 1 a - o.e raibueri C.n-o. i.canese _s_.orieawa_ m ne-rieu es n ed Con ~uee erecedes _t er en amainees seees Airborne 8adioledice eed S E. M. E Sectors witbis less e Caettemens sampitag 9 appressestely Bedieledlee cartsiege; Webly for I-131 To deteselee alsberes radiomeclade Ferticolate 3 sectes 2 3 g I cle with weekly cellecties. Particolate filters Crees beta weebly, concentsettee et the psedicted 8 Sector 14-24.g Samyte size appresiastely 205 e l. samma isotopte quartesty se mesteen locattee, blebest papelaties Jl campeeltes by locaties. weighted localles and ambient conces-tratien eeteide of Fleet infleeece. 9 s, EE, E, SE, tisW, IN Sectors teette ees dose accommlettee by too Comme dose gearterly. To determine direct radiaties dose 7lSirert 9 Site Beendary (or more) therselanteescent deoi- free atmospheric releases. N Sectee 2-3 mi meters per localles. S. SW Sectees 18-20 mi hteo berse 2 Tatabaeassee Sever opetream and Ceeposite of weekly greb samples Gamma asetetic analysis seatbly. To determine radiesectide conces-our a ese-eeeth period. Tsitime analysis geesterly, lQI Serface deweatseam of the discharge trettees seselting free Fleet disebesges. 7l esseum. 2 nuiend .ee s.y Cit, te, Co-meeste ea-en e e er e see-eenth c e.e beta eed saaea saet.,ic T. deiermine dose c.etributi.e f,ee supplies Pessed. seeably. Tritism esalysie questerly. water coe yales. Ly1 9 gges,t ,6 { G e 9 l s,di.,es 2 yinen, of antase and dia.ba,ge s,e eemai c.n. coon .e ibe di.- s e. s..te,ic a.ai,st. s.ei- T. detect af .ey bande, of charge side of the river. asemally disebarged radioactive metestal is accere ses le sediment. l*S'.e8 l.*e 3 K Quadrant e 3 el Collectise of broadleaf vege- Camma teetepec see I-831 en edible To determine if any accometa-7 l leed Producta naties meetbly during the third perties sely. ties of dischassed radioactive I S Sector 84-20 mi quester, as available. eaterial to occerring to edible vegetaties. Fish 2 Tettsbawassee hiver opstreae and seeisme.at collectiae as Caama teeterte se edible porties To determine if any concestration de==stsene of discharge available. only. of discharged radioactive mate-real is eccorring in fish. From the ER-OL (Table 6.2A-3-9).
l l 5-70 Table 5.4. Activity of Radionuclides in a Midland Reactor Plant at 2552 MWt l Radioactive Inventory l Group /Radionuclide in Millions of Curies Half-Life (Days) A. NOBLE GASES Krypton-85 0.45 3,950 Krypton-85m 19 0.183 Krypton-87 37 0.0528 Krypton-88 54 0.117 Xenon-133 140 5.28 Xenon-135 27 0.384 B. 10 DINES Iodine-131 68 8.05 Iodine-132 96 0.0958 Iodine-133 140 0.875 Iodine-134 150 0.0366 Iodine-135 120 0.280 C. ALKALI METALS Rubidium-86 0.021 18.7 Cesium-134 6.0 750 Cesium-136 2.4 13.0 Cesium-137 3.7 11,000 D. TELLURIUM-ANTIMONY Tellurium-127 4.7 0.391 Tellurium-127m 0.88 109 Tellurium-129 25 0.048 ! Tellurium-129m 4.2 34.0 Tellurium-131m 10 1.25 l Tellurium-132 96 3.25 l Antimony-127 4.9 3.88 Antimony-129 26 0.179 E. AKALINE EARTHS Strontium-89 75 52.1 Strontium-90 3.0 11,030 Strontium-91 88 0.403 Barium-140 130 12.8 F. COBALT AND NOBLE METALS Cobalt-58 0.62 71.0 Cobalt-60 0.23 1,920 Molybdenum-99 130 2.8 Technetium-99m 110 0.25 Ruthenium-103 88 39.5 Ruthenium-105 57 0.185 Ruthenium-106 20 366 Rhodium-105 39 1.50
5-71 Table 5.4. (Continued) Radioactive Inventory l Group /Radionuclide in Millions of Curies Half-Life (Days) G. RARE EARTHS, REFRACTORY OXIDES AND TRAN5URANICS Yttrium-90 3.1 2.67 Yttrium-91 96 59.0 Zirconium-95 120 65.2 Zirconium-97 120 0.71 Niobium-95 120 35.0
, Lanthanum-140 130 1.67 Cerium-141 120 32.3 Cerium-143 100 1.38 Cerium-144 68 284 Praseodymium-143 100 13.7 Neodymium-147 48 11.1 Neptunium-239 1300 2.35 Plut' onium-238 0.045 32,500 Plutonium-239 0.017 8.9 x 106 Plutonium-240 0.017 2.4 x 106 Plutonium-241 2.7 5,350 Americium-241 0.0014 1.5 x 105 Curium-242 0.40 163 Curium-244 0.018 6,630 , Note: The above grouping of radionuclides corresponds to that in Table 5.6.
4 I l i
5-72 Table 5.5. Approximate 2-Hour Radiation Doses From Desigo Basis Accidents at Exclusion Area Boundary Dose (rem) at 519 meters' Infrequent Accidents Whole Body Waste Gas Tank Failure 0.50 b Small-Break LOCA 0.21 SteamGgnerator, Tube Rupture 0.13 Fuel-Handling Accident 0.063 Limiting Faults Main Steam Line Break 0.0013 Control Rod Ejection 0.16 Large-Break LOCA 1.4 a Plant Exclusion Area Boundary Distance. b LOCA-Loss of Coolant Accident; the TMI-2 accident was one kind of a small-break LOCA. C 5ee NUREG-0651 (Ref. 53) for descriptions of three steam generator tube rupture accidents that have occurred in the United States.
Table 5.6 Summary of Atmospheric Releases in Hypothetical Accident Sequences in a PWR (Rebaselined) Accident en e or Probability a j Fraction of Core Inventory Released Group reactor yr Xe-Kr I Cs-Rb Te-Sb Ba-Sr Ru La Event V 2.0 x 10 8 1.0 0.64 0.82 0.41 0.1 0.04 0.006 TMLB' 3.0 x 10 8 1. 0 0.31 0.39 0.15 0.044 0.018 0.002 PWR3 3.0 x 10 s 0.8 0.2 0.2 0.3 0.02 0.03 0.003 PWR7 4.0 x 10 s 6 x 10 3 2 x 10 5 1 x 10 5 2 x 10 s 1 x 10 8 1 x 10 8 2 x 10 7 T a Background on the isotope groups and release mechanisms is presented in Appendix VII, WASH 1400 (Ref. 57). See Appendix E for description of the accident sequences and Release Categories. c Includes Ru, Rh, Co, Mo, Tc. d Includes Y, La, Zr, Nb, Ce, Pr, Nd, Np, Pu, Am, Cm. ! Note: Please refer to Section 5.9.4.5(7) for a discussion of uncertainties in risk estimates. I 1 l
Table 5.7. Summary of Environmental Impacts and Probabilities Cost of Population Offsite Persons Persons Exposure Latent
- Mitigating Probability Exposed Exposed Millions of Cancers Actions of Impact Per over over Early person-rem 50 mi/ Millions Reactor-Year 200 res 25 rem Fatalities 50 mi/ Total Total of Dollars 10 4 0 0 0 0/0 0/0 0 10 5 0 0 0 0.009/0.0093 0/0 12 5 x 10 8 0 4,600 0 1.1/3.8 130/310 230 10 s 0 34,000 0 6.4/36 740/2,600 1,000 10 7 2,500 105,000 T
9 17/100 2,200/6,900 3,300 % 10 8 7,000 600,000 380 24/140 4,500/12,000 5,900 Related Figure 5.4 5.4 5.6 5.5 5.7 5.8 a Includes cancers of all organs. Genetic effects would be approximately twice the number of latent cancers. Note: Please refer to Section 5.9.4.5(7) for a discussion of uncertainties in risk estimates.
5-75 Table 5.8 Average Values of Environmental Risks Due to Accidents per Reactor-Year Environmental risk Average value Population exposure Person-rems within 50 miles 26 Total Person-rems 130 Early fatalities (resident population) 0.000015 j (weighted transients) 0.000017 - Latent cancer, fatalities (resident population) l All organs excluding thyroid 0.0072 ' Thyroid only 0.0018 Latent cancer, fatalities (weighted transients) All organs excluding thyroid 0.000058 Thyroid only 0.000026 Cost of protective actions and decontamination $4,800*
- 1980 dollars NOTE: Please see Section 5.9.4.5(7) for discussions of uncertainties in risk estimates.
l l 5-76 l Table 5.9. (Table S-3) Uranium-Fuel Cycle Environmental Datal ) (Normehred to rnodel LWR annual fuel requrement (WASH-1248] or re;erence reactor year (NUREG-0116)) Maarnum effect per annual fuel l Envronmental conasderatons Total requrement or reference reactor year of model 1,000 MWe LWR NATunAL RESOURCES USE Land (acres). Temporanty commtted 8 . 100 Undsturt>ed area. . 79 Dsturt>ed aree.. 22 Equrvalent to a 110 MWe coal-fred power plant. Permanently cometted 13 Overt)urden moved (rnelkons of MT). 2.8 Equivalent to 95 MWe coal-fired power plant. Water (othons of gallons): Dscharged to er- 160 =2 percent of model 1,000 MWe LWR wim cookng tower. Dscharged to water bodes 11,090 Dscharged to ground. 127 Total . 11.377 <4 percent of model 1,000 MWe LWR wrth once-through coohng Fossd fuel. Electncal energy (thousands of MW-hour) 323 <5 percent of model 1,000 MWe LWR output. Equrvaient coal (thousands of MT) 118 Equrvalent to the consumpton of a 45 MWe coal-fred power plant. Natural gas (milions of scf). 135 <0.4 percent of rnodel 1,000 MWe energy output EFFLUENTS-CHEMICAL (MT) Gases (inclu6ng entrainment):
- SO .. 4,400 NO, ' .. 1,190 Equrvaient to enssons from 45 MWe coal-I fred plant for a year.
Hydrocart)ons 14 CO .. . . . _ 29.6 Partculates. 1.154 Other gases. F.. . . . . . 67 Pnncipally from UF. producton, ennchment, and reprocesseng. Concentraton withen range of state standards-below level that has effects on human health. HC1. ..- . .014 Liquids-SO". .. 99 From ennchment. fuel fabreaton, and repro-NO . ...
- 25 8 cessing steps. Cornponents that constitute Fluonde . ... - 12.9 a potentral for adverse envronmental effect Ca'* 5.4 are present in elute concentratons and re-C1 8.5 cerve ad6tional dilutson by rocerving bodes Na' 12.1 of water to levels below permssable stand-NH ..- .. . . . .
. 10 0 ards. The constituents that reques eluton Fe .. . . . . . .4 and the flow of eluton water are.
NH. 8iOO cfs. NO.-20 cfs. Fluonde-70 cfs. Ta hngs solutens (thousands of MT).. ... 240 From rnills only-no segnifcant effluents to envronment. j Sotids .. . . . . . . 91,000 Pnncipally from mils-no signifcant effluents to envronment
5-77 , Table 5.9. Continued (Normahred to model LWR annual fuel requwerrer,t (WASH-1248) or reference reactor yoar (NUREG-0116)) Maximum effect per annual fuel Envvonmental considerations Total requwement or reference reactor year of modet 1.000 MWe LWR / _ EFFlu(NTs-RADtOloGsCAL (CURif s) Gases (meluding entramment). Rn-222.. Presentty under reconsideration by the Com-mssson. Ra-226.. 02 Th-230 .02 Ureruum .. 034 Tntium (thousands) ., 18.1 C-14.. 24 Kr-85 (thousands) .. 400 Ru-106. .14 Pnneipally from fuel reprocesemg plants. 1-129.. 1.3 1-131.. - . . . . .83 Tc-99.- Presently under cons deration by the Com-mssion. Fission products and transurance.. .203 Liquids Uraneum and daughters .. 2.1 Pnncipatty from mihng-encluded todogs hquor and returned to ground-no ef-fluents, therefore, no effect on envvon-rnent. Ra-226... . . . . . . . . . . . . . . . . . . .0034 From UF. production. Th-230.. .0015 Th-234.. . . . . . . ~ . . .
.01 From fuel fabreation plants-concentration 10 percent of 10 CFR 20 for total process-eng 26 annual fuel requwements for model LWR.
Frssion and actrva:,on products.. .. 5 9 x 10-
- Sohds (buted on site).
Other than high level (shallow).. . . _ . . 11,300 9,100 0 comes from low level reactor wastes and 1.500 0 comes from reactor decon-terrunation and decommesaoneg-buried at land bunal facdotes. 600 O comes from rndis-mcluded a tadings retumed to ground. Apprournately 60 O comes from conversson and spent fuel storage. No sig. rufcant effluent to the envvonment. TRU and HLW (doop).. 1.1 x to ' Buned at Federal Reposstory. Effluents-thermal (bdhons of Bntish thermal units)._ 4.063 (5 percent of model 1,000 MWe LWR. Transportation (person rem) Esposure of workers and general pubhc .. 2.5 Occupational exposure (person-rom) ... 22 6 From reprocessmg and waste management.
'In some cases where no entry appears it rs clear from the background documents that the matter was addressed and that, vi ettect, the Table should be read as if a specife zero entry had been made. However, there are other areas that are not addressed at all an the Table Table S-3 does not velude health effects from the effluents desenbod m the Table, or estwnstes of releases of Redon-222 from the uransum fuel cycle or estimates of Technetsum-99 released from waste management or reprocesseng actrvities. These issues enay be the subtect of litigation m the endnndual heenseg proceedings Data supportog thrs table are given o the "Enywonmental Survey of the Uransum Fuel Cycle." WASH-1248, Aprd 1974, the "Envvonmental Survey of the Reprocessmg and Waste Management Portion of the LWR Fuel Cycle," NUREG-0116 (Supp.1 to
( WASH-1248), the "Pubhc Comments and Task Force Responses Regardog the Envvonmental Survey of the Reprocessmg and Weste Management Portions of the LWR Fuel Cycle." NUREG-0216 (Supp. 2 to WASH-1248), and m the record of the final rulemphng perteerung to Urarnum Fuel Cycle impacts from Spent Fuel Reprocessmg and Radioactive Waste Management, Docket RM-50-3 The contnbutions from reprocessing. waste management and transportatson of wastes are maxwrured for either of the two fuel cycles (uranium only and no recycle). The contnbution from transportation excludes transportation of cold fuel to a reactor and of wrediated fuel and radioactrve wastes from a reactor whch are conssdered m Table S-4 of 5 51.20(g). The contnbutions from the other steps of the fuel cycle are grven en columns A-E of Table S-3A of WASH-1248.
'The contnbutions to temporardy comrrutted land from reprocessmg are not prorated over 30 years, sece the complete temporary impact accrues regardless of whether the plant servces one reactor for one year or $7 reactors for 30 years.
'Fstimated effluents based upon combustion of equrvalent coal for power generahon.
- 12 percent from natural gas usa and process.
l L. .___-_.___. _
- 6. EVALUATION OF THE PROPOSED ACTION 6.1 UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS The staff has reassessed the physical, social, and economic impacts that can be attributed to operation of the Midland Plant. Such impacts, beneficial or adverse, are summarized in Table 6.1 of this environmental statement. Inasmuch as the plant is currently under construction, many of the expected adverse 1 impacts of the construction phase are evident. The applicant is committed to '
an ongoing program of restoration and redress of the plant site, which will be completed after the termination of the construction period. At the ) resent time the staff foresees no impacts of a magnitude requiring mitigating actions except possibly those of fogging, as discussed in Sec-tion 5.4.1. However, In addition to this, the applicant is required to adhere to the following conditions for protection of the environment:
- a. Before engaging in additional construction or operational activities that may result in a significant adverse environmental impact that was not evaluated or that is significantly greater than that evaluated in this statement, the applicant shall provide written notification of such activities to the Director of the Office of Nuclear Reactor Regulation and shall receive written approval from that office before proceeding with such activities,
- b. The applicant shall carry out the environmental monitoring programs outlined in Section 5 of this statement as modified and approved by the staff and implemented in the Appendix B Environmental Protection Plan (nonradiological) and Appendix A Technical Specifications (radiological) that will be incorporated in the operating licenses for Midland Units 1 and 2.
- c. If adverse environmental effects or evidence of irreversible environ-mental damage are detected during the operating life of the plant, the applicant shall provide the staff with an analysis of the problem and a proposed course of action to alleviate it.
6.2 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES There has been no change in the staff's assessment of this impact since the earlier review except that the continuing escalation of costs has increased the dollar values of the materials used for constructing and fueling the plant. 1 1 6-1 l 1
6-2 6.3 RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY There have been no signficant changes in the staff's preconstruction evalua-tion of the relationship between environmental effects of short-term uses (construction and operation of the plant) and long-term productivity (FES-CP, Sec. VIII). The conclusion that the dedication of resources for a nuclear generating plant at the Midland site is consistent with the balancing of short- and long-term objectives for use of the environment is still valid. 6.4 BENEFIT-COST
SUMMARY
The benefits and costs of operating the plant are summarized in Table 6.1, which provides the staff's assessments of degrees of benefit or cost, as well as magnitudes of impact where they are quantifiable. References that contain further information are indicated. 6.4.1 Benefits A major benefit to be derived from the operation of the Midland Plant is the approximately 8 billion kWh of baseload electrical energy that will be produced annually (for this projection the staff assumed that Midland Units 1 & 2 will operate at an annual average capacity factor of 66% for the lifetime of the plant). The addition of the plant will also improve the applicant's (and Detroit Edison's) ability to reliably supply system load requirements by contributing 1357 MWe of generating capacity to the interconnected bulk power supply for the East Central Area Reliability Power Pool (ECAR) and the Mid-America Interpool Network (MAIN). Another benefit to be derived is the savings in overall system production costs that will accrue from operation of the plant. A production-cost analysis i was submitted by the applicant (Consumers Power Co. comment letter, April 2, 1982) in which system costs were projected for the years 1984 through 1988, both with and without Midland Units 1 & 2 in service. The average annual saving for the period was projected to be $279 million. The applicant estimates that these savings will increase as the cost of replacement energy increases and as improvement in the capacity factor of the two units is realized. i Secondary or indirect benefits arising from operation of the Midland Plant include wages paid to about 700 operating personnel (projected at about $20 million per year in 1984 dollars) and taxes paid to state and local subdivi-sions (Sec. 5.8.3). The applicant paid $11 million in property taxes on the Midland Plant ($7 million to the City of Midland) in 1980, and projects an annual property tax payment to the city of $67.8 million (1984 dollars) during operation (Sec. 5.8.3). Total annual taxes paid to state and local subdivi-sions during operation are estimated at about $71 million. The local bodies receiving a majority of these funds would be Midland public schools, Midland County operating budget, ambulance service, Delta College and County Inter-mediate School District (Section 5.8.3). Retail purchases by plant operating personnel are estimated at about $7.5 million annually (Sec. 5.8.2). An additional secondary or indirect benefit is that the provision of process steam to the Dow Chemical Company by the Midland Plant will enable Dow to comply with area and regional air quality requirements.
6-3 6.4.2 Costs 6.4.2.1 Economic The economic costs associated with plant operation include fuel costs and O&M costs, which are expected to average 15 and 6 mills per kWh, respectively (in 1984 dollars) (based on a capacity factor of 56% in 1984). The staff estimates the decommissioning costs for Midland Units 1 & 2 to be $235 million in 1984 dollars. 6.4.2.2 Environmental and Socioeconomic Changes in plant design, operating procedures, and environmental data that were taken into consideration in this operating-license review have not led to significant increases in the environmental or socioeconomic costs over the corresponding costs that were estimated during the construction permit review. The costs considered include those attributable to the uranium fuel cycle and to plant accidents. Such costs are either negligible or range from small to moderate. 6.4.3 Conclusions As a result of the analysis and review of potential environmental, technical, economic, and esocial impacts, the staff has prepared an updated forecast of the effects of operation of the Midland Plant. No new information has been obtained that alters the overall balancing of the benefits versus the environ-mental costs of plant operation. Consequently, the staff has determined that the plant will most likely operate with only minimal environmental impact. The staff finds that the primary benefits of minimizing system production costs and increasing baseload generating capacity by 1357 MWe greatly outweigh the environmental, social, and economic costs.
6-4 Table 6.1. Benefit-Cost Summary for the Midhnd Plant Magnitude Staff Assessment I Benefit or Cost (Reference)t3 or Referencets of Benefit or Costt8 ] BENEFITS l Direct I Electrical energy 8 billion kWh/yr Moderate Additional generating capacity 1357 MWe (nameplate rating) Moderate Reduced generating costs $279 million/yr Large Indirect Local property taxes (Sec. 5.8) $67.8 million/yr (1984$) Large Employment (Sec. 5.8) 700 employees Small Payroll (Sec. 5.8) $20 million/yr (19845) Small Local retail purchases by $7.5 million/yr (19845) Small employees (Sec. 5.8) , Local service and merchandise $6.0 million/yr (19845) Small ! purchases by utility (Sec. 5.8) Improvement in air quality due to (Sec. 5.4) Small reduction of area gaseous emissions COSTS Economic Fuel 15 mill /kWh (1984) Small Operation and maintenance 6 mill /kWh (1984) Small Decommissioning $235 million (19845) Small Environmental and Socioeconomic Resources committed: Land (Sec. 4.2) 500 ha Small 2 Water (Sec. 5.3) 1.55 x 107 m Moderate l Uranium - U 0s 3 (NUREG-0480) About 8000 t Small ! Other materials and supplies (FES-CP, Sec. IX) Small Damages suffered by other water users due to: Surface-water consumption (Sec. 4.2) 0.8 m8 /s Small Surface-water contamination (chemical) (Sec. 5.3) Small to Mcderate Surface-water contamination (thermal) 159 x 10' J/ min Small Groundwater consumption (FES-CP, Sec. V.B) 0 None Damage to river aquatic biota due to: Impingement and entrainment (Sec. 5.5) Small Thermal effects (Sec. 5.5) Small Chemical discharges (Sec. 5.5) Small Damage to terrestrial resources due to: Fog and ice (Sec. 5.5) Small Transmission line maintenaxe (Sec. 5.5) Small
. Cooling pond (regional waterfowl) (Sec. 5.5) Small 4
6-5 Table 6.1. (Continued) Magnitude Staff Assessment Benefit or Cost (Reference) or Referencett of Benefit or Costt2 COSTS (Continued) Environmental and Socioeconomic (Continued) Adverse socioeconomic effects due to: Loss of historic or archeological resources (Sec. 5.7) Small Traffic s (Sec. 5.8) Small Fog and ice on roads (Sec. 5.4) Moderate Demands on public facilities and services (Sec. 5.8) Small Demands on private facilities and service 4 (Sec. 5.8) Small Crop losses (waterfowl) (Sec. 5.8) Small Adverse nonradiological health effects due to: Air-quality changes (Sec. 5.4) Small Adverse radiological health effects due to: Reactor operation on: r General population 1 (Sec. 5.9.3) Small (Sec. 5.9.3) Workers onsite (Sec. 5.9.3) Small (Sec. 5.9.3) 8alance of fuel cycle (Sec. 5.10) Small Accident risks (Sec. 5.9.4) Small (Sec. 5.9.4) 11 - Unreferenced economic values are derived from applicant's comment letter, dated April 2,1982 (see Appendix A). t8 - Where a particular unit of measure for a benefit / cost category has not been specified in the EIS, or where an estimate of the magnitude of the benefit / cost under consideration has not been made, the reader is directed to tha appropriate EIS section or other source fcr further information. ta . Subjective measure of costs and benefits are assigned by reviewers, where quantification is not possible: "Small - impacts that, in the reviewers' judgments, are of such minor nature, bases: on currently available information, that they do not warrant detailed investigations or. considerations of mitigative actions; " Moderate" - impacts that, in the reviewers' judgments,. are likely to be clearly evident (mitigation alternatives are usually considered for moderate impacts); "Large" - impacts that In the reviewers' judgments, represent either a severe penalty or a major benefit. Acceptance requires that large negative impacts should be more than offset by other overriding project considerations.
\
1
- 7. LIST OF CONTRIBUTORS The following personnel of the Office-of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission, Washington, DC, participated in preparation of t.his draft environmental statement: NAME TITLE REVIEW BRANCH Darl S. Hood Project Manager Licensing Branch #4 Ronald W. Hernan ~ Project Manager Licensing Branch #4 Maurice Messier Environmental Review Antitrust & Economic Coordinator Analysis W. Wayne Meinke Health Physicist Radiological Assessment David M. Rohrer Emerg. Prep. Analyst Emergency Preparedeness Licensing Raymond O. Gonzales Hydraulic Engineer Hydrol. & Geotechnical Richard B. Codell Sr. Hydraulic Engineer Hydrol. & Geotechnical Jocelyn A. Mitchell Nuclear Engineer Accident Evaluation Angela T. Chu Nuclear Chem. Engineer Accident Evaluation Steven Baker Nuclear Engineer Accident Evaluation Sarbeswar Acharya Environ./ Radiation Accident Evaluation Physicist David West Nuclear Engineer Accident Evaluation Millard L. Wohl Nuclear Engineer A aident Evaluation William G. Snell Meteorologist Accident Evaluation James Hauxhurst Meteorologist Accident Evaluation Sidney E. Feld Environmental Antitrust & Economic Economist Analysis Louis M. Bykoski Environmental Siting Analysis Economist Charles W. Billups Aquatic Scientist Environmental Engineering Gerry E. Gears- Sr. Land Use Analyst Environmental Engineering i i The following personnel of the Division of Environmental Impact Studies of J Argonne National Laboratory, Argonne, Ill., participated in the preparation of l this draft environmental statement: l 7-1 t
7-2 L.S. Busch Need for Action and Benefit-Cost; B.S. (Chemical Engineering) 1939, 42 years experience 4 J.E. Carson Air Quality; Ph.D. (Meteorology) 1960, 38 years experience J.D. DePue Technical Editor (ANL input); M.S. (Biology) 1974, 15 years experience V.A. Harris Chemistry: M.S. (Environmental Engineering) 1978, 5 years experience B.A. Payne Social Impact; Ph.D (Sociology) 1977, 7 years experience A.A. Siczek Chemistry; Ph.D (Physical Chemistry) 1974, 15 years experience Y.H. Tsai Thermal Hydraulics; Ph.D. (Civil Engineering) 1978, 5 years experience W.S. Vinikour Ecology; M.S. (Biology) 1977, 6 years experience R.A. Zussman Project Leader; Ph.D. (Microbiology) 1963, 18 years experience I 1 I i l
- 8. LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS ENVIRONMENTAL STATEMENT ARE SENT Advisory Council on Historic Preservation Department of Agriculture Department of the Army, Corps of Engineers Department of Commerce Department of Energy Department of Health and Human Services Department of Housing and Urban Development Department of the Interior Department of Transportation Environmental Protection Agency Office of the Governor of the State of Michigan Midland County Board of Supervisors East Central Michigan Planning and Development Region Michigan Office of Intergovernmental Relations 8-1
- 9. RESPONSES TO COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT Pursuant to 10 CFR Part 51, the " Draft Environmental Statement Related to the Operation of Midland Plant, Units 1 and 2" was transmitted, with a request for comments, to the agencies and organizations listed in Section 8.
In addition, the NRC requested comments on the draft environmental statement from interested persons by a notice published in the Federal Register on February 18, 1982 (47 FR 7351). In response to these request, comments were received from: U.S. Department of Agriculture, Economics and Statistics Service, February 16, 1982, Velmar W. Davis (DAES) Raymond M. Donahue, Midland, MI, February 24, 1982 (RMD) U.S. Department of Agriculture, Soil Conservation Service, February 26, 1982, Homer R. Hilner (DASCS) U.S. Departmer,t of Agriculture, Agricultural Research Service, March 2, 1982, Thomas J. Army (DAARS) Peggy E. Roth, Midland, MI, March 11, 1982 (PER) Marjorie Kruger, Freeland, MI, March 11, 1982 (MK) William A. Thibodeau, Saginaw, MI, March 23, 1982 (WAT) Vicente Castellanos, Freeland, MI, March 26, 1982 (VC) Diane Hebert, Midland, MI, March 24, 1982 (DH) Andrea K. Wilson, Midland, MI, March 24, 1982 (AKW1) U.S. Departmeat of Transportation, U.S. Coast Guard, March 26, 1982, James F. Veach (DTCG) Lucille M. Hallberg, Midland, MI, March 29, 1982 (LMH) Thomas Hearron, Saginaw, MI, March 31, 1982 (TH) State of Michigan, Department of Public Health, April 1, 1982, Bailus Walker, Jr. (MDPH) James F. Wilson, Midland, MI, April 1, 1982 (JFW) Consumers Power Company, April 2, 1982, Roy A. Wells (CPCo) 9-1
t I I 9-2 i Michigan United Conservation Clubs, Lansing, MI, April 2, 1982, Thomas L. Washington (MUCC) Debra K. Stempek, Midland, MI, April 2, 1982 (DKS) William A. Lochstet, University Park, PA, April 4, 1982 (WAL) A.B. Savage, Midland, MI, April 4, 1982 (ABS) i Sharon K. Warren, Midland, MI, April 4, 1982 (SKW) U.S. Environmental Protection Agency, Region V, April 5, 1982, Barbara Taylor Backley (EPA) Mark A. Handler and Christine K. Handler, Midland, MI, April 4, 1982 (MAH) Andrea K. Wilson, Midland, MI, April 12, 1982 (AKW2) U.S. Department of Health and Human Services, Public Health Service, April 12, 1982, John C. Villforth (PHS) U.S. Department of the Interior, Office of the Secretary, April 13, 1982, Bruce Blanchard (DIOS) Mary Sinclair, Midland, MI, April 17, 1982 (MS1) Barbara Stamiris, Freeland, MI, April 20, 1982 (BS) Mary Sinclair, Midland, MI, May 7, 1982 (supplement to April 27, 1982, letter) (MS2) Wendell H. Marshall, Mapleton Intervenors, Midland, MI, April 7, 1982 (WHM) State of Michigan, Office of the Governor, May 11, 1982, William G. Milliken, Governor (MOG) The comment letters are reproduced in Appendix A along with an index showing the locations in this document of the individual letters and the corresponding NRC responses. l The comments from DASCS, DAES, and DAARS did not require a staff response either l because these agencies or individuals had no comments or because their comments indicated agreement with the draft environmental statement. The EPA comments indicated that no objections to operation of the Midland Plant exist but reques-ted that additional information be provided in two areas. The remaining comments did require a staff response. The staff's consideration of these comments and its disposition of the issues involved are reflected in part by revised text in the pertinent sections of this final environmental statement and in part by the following discussion. The comments are referenced by use of the abbreviations indicated above, by the individual comment numbers noted in the margins of the
9-3 comment letters shown in Appendix A, and by the page numbers in Appendix A on which copies of the comments appear. Many of the comments dealt with requirements of the National Pollutant Discharge Elimination System (NPDES) permit which must be issued by the Michigan Depart-ment of Natural Resources (MDNR). The NRC staff, in a letter dated May 24, 1982, requested that the MDNR prepare responses to those comments dealing with the NPDES permit. Several of the staff responses to comments on the DES make reference to responses received from the MDNR. Therefore, for completeness, the MDNR response letter, dated June 25, 1982, is included with those responses at the end of this section. i A letter was received from the State of Michigan, Office of the Governor (see page A-116) after the end of the public comment period. This letter transmitted concerns of the Michigan Environmental Review Board (MERB). Since schedular conflicts prevented members of the NRC staff from attending the MERB meetings during the period that the Midland Plant NPDES permit was under consideration, the staff has elected to also include that letter in this report and has responded to the comments attached to that letter. Response to Comment of Raymond M. Donahue (RMD 2/24/82 A-3) The turbine generators for the Midland Plant were designed by General Electric and are sized appropriately for the use of hydrogen as the cooling medium for the generator. Hydrogen has been used for several decades as a cooling medium in generators and when handled properly it is a safe and reliable cooling medium. The hydrogen monitoring and control system is designed to prevent an explosive mixture from develop-ing within the generator. Furthermore, as a safeguard, the generator is structurally designed to remain intact in the unlikely event of an internal explosion. The staff considers that the recent hydrogen explosion at the Consumers Power Palisades Nuclear Power Plant was an isolated incident and is not a representative model of the operating experience regarding hydrogen as a generator cooling medium. This incident was the result of a very localized gas release from the generator and did not present a threat to the safety of the plant. The Midland generator will utilize hydrogen as the cooling medium, which is the state-of-the-art practice for safety and efficiency. Responses to Comments of Peggy E. Roth (PER 3/11/82/ A-6)
#1. The estimate of 12 chances in 100 refers to the probability of one cancer death over the lifetime of the entire workforce due to one year of operations at the Midland Plant (Sec. 5.9.3.1.1). Persons exposed to radiation as a part of their occupations are permitted under federal regulations to receive higher doses than are members of the general
9-4 public, and consequently the risks to these occupationally exposed personnel may be somewhat larger than are the risks to members of the general public. The risk estimators used by the NRC are consistent with the recommendations of the ICRP, the NCRP, UNSCEAR, and the BEIR committee (see references 36-39 of Sec. 5 in the DES /FES). No assumption was made regarding a " safe" level of radiation. While no health effects have been detected which can be directly attributed to the low levels of radioactive effluents released from operating nuclear power plants, it is prudent to assume that the rate of incidence of such effects observed at much higher doses will also prevail at the lower, environmental levels. Regarding the long-term effects of radiation on living systems, Section 5.9.3.2 states:
".....the effects of radiation on living systems have for decades been subject to intensive investigation and consider-ation by individual scientists as well as by select committees, occasionally constituted to objectively and independently assess radiation dose effects. Although, as in the case of chemical contaminants, there is debate about the exact extent of the effects of very low levels of radiation that result from nuclear power plant effluents, upper bound limits of deleterious effects are well established and amenable to standard methods of risk analysis."
#2. This comment is rhetorical in nature and will not be specifically addressed.
#3. It is true that plans can not guarantee that an evacuation wili work with 100% efficiency; however, one of the purposes of evacuation plans is to detect and resolve potential problem areas before an evacuation is necessary. Routine heavy traffic at any specific time (e.g., 4:30 p.m.)
cannot be compared to movement of traffic during an evacuation because traffic control measures would be in effect during an evacuation which are not used on a daily basis.
#4. The Commission has amended its regulations effective April 26, 1982, to provide that need-for power issues and issues related to alternative energy sources will not be considered in ongoing and future operating license proceedings for nuclear plants unless a showing of "special circumstances" is made under 10 CFR Section 2.758 or the Commission otherwise so requires.
The Commission has determined that the need for power is fully considered at the construction permit (CP) stage of the regulatory review where a finding of insufficient need could factor into denial of issuance of a CP. At the operating license (0L) review stage, the proposed plant is substantially constructed and a finding of insufficient need would not, in itself, result in denial of the operating license. The Commission was further influenced by the substantial information which supports the conclusion that nuclear plants are lower in operating costs than conven-tional fossil plants. If conservation, or other factors, lowers antici-pated demand, utilities remove generating facilities from service according
9-5 to their costs of operation, with the most expensive facilities removed first. Thus, a completed nuclear plant would serve to substitute for less economical generating capacity. (See Section 2.) The Commission has also noted that alternative-energy-source issues are resolved at the CP stage, and the CP is granted only after a finding that, on balance, no obviously superior alternative to the proposed l nuclear facility exists. The Commission concluded that this determina- I tion is unlikely to change even if an alternative is shown to be marginally environmentally superior in comparison to operation of the nuclear facility because of the economic advantage which operation of the nuclear
- plant would have over available alternative sources. (See Sections 3 and 6.)
See text changes in Sections 2, 3, and 6.
#5. The NRC is currently conducting a generic rulemaking which will develop a more explicit overall policy for decommissioning commercial nuclear facilities. Specific licensing requirements are being considered that include the development of decommissioning plans and financial arrange-ments for decommissioning nuclear facilities.
Although no large commercial reactor has undergone decommissioning to date, the broad base of experience gained from smaller facilities is generally relevant to the decommissioning of any type of nuclear facility. Since 1960, 68 nuclear reactors, including 5 licensed reactors that had been used for the generation of electricity, have been or are in the process of being decommissioned. Estimates of the economic cost of decommissioning are provided in Section 6.4.2.1 of this statement. (See Section 5.11.) Responses to Comments of Marjorie Kruger (MK 3/11/82 A-7,8)
#1. The DES points out in Sections 5.9.3 and 5.9.4, respectively, that the radiation doses to the most exposed individual as a result of normal plant operation will be a small fraction of the dose from naturally occurring background radiation, and that the risk from accidental radiation exposure is very low. Consequently, even if it is assumed that combined chemical and radiation effects could occur, the staff concludes that any such effects produced as a result of plant operation will be much smaller than those produced naturally from background radiation at the present time.
#2. The staff has concluded that the Midland site meets the requirements of the NRC's reactor site criteria, 10 CFR Part 100. The pcipulation density within 3 to 5 miles of the site, which is largely affected by the presence of the City of Midland, is among the highest of all power reactor sites, although it is not beyond the range of the highest population density sites licensed to date. At distances of about 10 miles and beyond, which reflects the presence of the cities of Bay City and Saginaw, the
9-6 Midland site is considered to be close to average in population density when compared to other power reactors.
#3. As stated in Sec. 5.9.3.1.2 and Appendices C and D, assessments of radiological dose to individuals and to the population were performed using models described in U.S. NRC Regulatory Guide 1.109. Each of these models having to do with ingestion of water, milk, meat, vege-tables and other produce, fish and invertebrates, includes a factor which accounts for bioaccumulation, or concentration, of radionuclides as they move from one environmental medium to another; e.g., from lake or river water to fish, crops (via irrigation), etc. These factors account for the " build-up" of radioactivity in vegetation and animals, and are used in determining the maximum limits of radionuclide effluents from nuclear power plants consistent with the health and safety of the public. #4. Releases of airborne radioactive materials under normal operating con-ditions (including anticipated operational occurrences) are required to be at or below limits specified in Appendix I to 10 CFR Part 50, as noted in Section 5.9 of the DES. The goal of these regulations is to maintain exposure to the member of the public subject to maximum exposure to a very small fraction of the natural background dose or the dose limits specified in 10 CFR Part 20 as consistent with considerations of the health and safety of the public. Implementation of these regulations requires that calculations of potential doses to humans be performed, and in so doing, the bioaccumulation, or concentration, of radionuclides in farm products is taken into consideration. At the extremely low levels of radioactivity specified as design objectives by the 10 CFR 50 regulations (actual Midland releases are projected to result in doses well below these limits, as described in Appendix C), the effects on l farm produce and animals is negligible. These products are monitored, as described in Section 5.9.3.4 of the FES, to ascertain the levels of l radioactivity which may accumulate in them, and to ensure that these levels are consistent with values obtained in the radioactive effluent monitoring program of the plant. Experience at operating facilities has
' shown that measured levels of radioactivity in these media are generally not distinguishable from background radiation levels due to natural radiation in the environment.
#5. The staff agrees that the flow rate of the Tittabawassee River is low during dry periods. However, wastewater discharges to the river from the Midland Plant will be controlled to meet limitations given in the NPDES permit. These limitations will include concentrations of dissolved and suspended substances in the river which may not be exceeded at any flow rate. Thus, during periods of low flow when ambient concentrations meet or exceed NPDES limitations, the applicant will not be able to discharge into the river. See Appendix B for limitations giver in the draft (proposed) NPDES permit. #6. The discussion in Section 5.4.1 relative to the potential for pond-related fog formation has been updated, and a discussion concerning potential fog impacts on transportation has been added to Sections 5.4.1 and 5.8.5.
9-7
#7. When the conditions are favorable for the formation of fog from the cooling pond to interact with the radioactive effluent from the plant, the iodines and particulates will be deposited out at a greater rate.
(See responses to Lucille E. Hallberg comments 1 and 2 and response to Michigan United Conservation Clubs comment 8). This increased deoosi-tion rate dose will leave fewer iodines and particulates to be dep cited farther downwind. Yearly average deposition rates, upon which dose estimates are based, will change very little. Overall these changes will have a negligible effect on the dose estimates presented in the DES /FES.
, #8. Potential doses to life forms other than persons in the vicinity of the Midland Plant are discussed in Section 5.9.3.3 of the DES /FES. To summarize, there is no evidence to date to indicate that any other living organisms are very mucn ... ore susceptible to injury from radiation than are humans. Dosage received by hunters eating game would be less than the values for meat consumption given in Table C.6 of the DES, which already are very small. #9. This comment is rhetorical in nature and will not be specifically addressed.
Response to Comment of William A. Thibodeau (WAT 3/23/82 A-9)
.There is no data to support the $4 billion figure quoted by the commenter for decommissioning the Midland Plant. The NRC staff's estimate is $235 million in 1984 dollars. See Section 6.4.2.1 of this report and Section 5.8 of the ER-OL for the Midland Plant.
See response to Peggy E. Roth comment 5. Responses to Comments of Vicente Castellanos (VC 3/26/82 A A-12)
#1. The bases for the references to ' foreign material removed with the salt" and "the very large chemical storage caverns" are not clear to the NRC staff. The staff is not aware of any existing large chemical storage caverns in close proximity to the nuclear plant. Furthermore, the PSAR and its amendments, including the reports " Investigation of Possible Surface Subsidence at Midland, Michigan," July 1969, by Woodward-Clyde and Associates; and " Evaluation of Subsidence, Consumers Power Company, Midland Nuclear Power Plant, Units 1 & 2," March 1970, by General Analytics, Inc; together with the Safety Evaluation Report for the Midland construction permit written by the U.S. Atomic Energy Com-mission staff provide extensive analyses'and discussion of the solution cavaties.
Section 2.5.3.6 of the NRC Safety Evaluation Report, Operating License stage, for the Midland plant reports no evidence of subsidence as of . December 1981.
9-8
#2. The staff agrees that steam fog could reduce visibility on other nearby roads. The staff believes that the applicant's fog monitoring program should include such highways. See response to U.S. Department of Trans-portation (Coast Guard) Comment 1 and the final paragraph of Section 5.4.1. #3. See response to U.S. Department of Transportation (Coast Guard) comment 1. #4. If the meteorological conditions were favorable for the formation of a dense fog from the cooling pond and the necessary wind direction was favorable, there could be interaction of the fog with effluents from Dow Chemical or Dow Corning. However, the staff believes the extent of this interaction will be negligible compared to effluent interaction with naturally occurring fog. #5. Because of the very low density and friable nature of rime ice deposited from freezing fog (as compared to glaze ice deposited by freezing rain and drizzle), the staff expects'no icing damage to power lines as a result of operation of the plant's cooling pond. #6. The applicant does not expect " power outages due to icing of power lines." Areas affected by fogging or icing will be minimal. In the highly unlikely event of an outage attributable to fog or ice, the liability of the Consumers Power Company would be controlled by the Company's Standard Rules and Regulations, which are approved by the Michigan Public Service Commission. Generally, the rules require individual customers to take necessary and appropriate steps to protect their property. If damage occurs due to the negligence of the company, the company can be held responsible. #7. While isotope tagging of chemicals used in consumer products can and probably will occur at the Dow facilities, this process will not make these products unacceptable for the applications cited. The small quantities of radioisotopes that are released from the Midland Plant under normal operating conditions will be in extremely low concentrations in the environment, particularly after their dilution in air and water (as described in Sec. 5.9.3.1.2 of the DES /FES). The natural environment contains radioactive materials at concentration levels many times those due to emissions from Midland, so that any tagging of consumer products during manufacture would occur whether or not the Midland Plant were operating.
Furthermore, among possible routes of exposure due to nuclear power plant effluents, the potentially most significant have been shown to result from ingestion and inhalation. The greatest degree of concen-tration of a particular radionuclide is that of iodine-131 in the thyroid gland. However, these concentrations are not projected to reach levels high enough to result in more than a small fraction of the Appendix I Design Objectives (see Table C.7 of the DES /FES). By comparison, other routes of exposure and other radionuclides are known to be of lesser significance. With regard to the Salzburg landfill, there are no pathways that occur at this location that have not been evaluated at closer locations; hence, l
i 9-9 evaluation of potential doses at this specific location would not alter the l conclusions of the DES.
#8. Information available to the staff indicates that property values are l
l not affected by the presence of a nuclear power station. [See H.B. Gamble, l et al. , Effects of Nuclear Power Plants on Community Growth and Residential Property Values (NUREG/CR-0454), Prepared for U.S. Nuclear Regulatory l l Commission, April 1979.] Subsequent to the accident at TMI, the real estate market in the vicinity of the station collapsed for a period of time (less than 3 months). However, by the end of 1979 no effect of the l accident on property values could be determined. The staff is not aware of any published studies which link nuclear generating stations to ! declines in property values. [See H.B. Gamble and R.H. Downing, Effects of the Accident at Three Mile Island on Residential Property Values and l Sales (NUREG/CR-2063), Prepared for U.S. Nuclear Regulatory Commission, April 1981. See also John P. Nelson, "Three Mile Island and Residential Property Values: Empirical Analysis and Policy Implications," Land Economics, Vol. 57, No. 3, August 1981.] l
#9. The ER-CP, FES-CP, ER-OL, and DES-OL contain analyses' which indicate that the Midland Plant discharge will have small to negligible impacts on fish and waterfowl populations. The Michigan Water Resources Commis-l sion Act, as well as the Michigan Water Quality Standards, require that fish and game be protected. Such requirements are to be viewed at the animal population level; not for individual animals. It should be realized that virtually no development of any kind could proceed if consideration were to be given to preventing the possible injury or
~
death of individual animals. The analyses conducted by the staff and applicant to determine potential effects of the Midland Plant discharge on fish and waterfowl included a consideration of the relationship of impact on individual animals versus impact on populations of resident species. These analyses were based upon scientific data and technical l reports, including results from operational experiences at other power i plants. Using such analyses, the staff and applicant independently l concluded that the fish and waterfowl populations in the site vicinity j would experience minimal adverse impacts from plant discharges. This l level of impact is interpreted by the staff to be within acceptable l levels set forth in the requirements of both the Michigan Water Resources Commission Act and the Michigan Water Quality Standards. Also see State of Michigan Department of Natural Resources response No. 8 at the end of this section. l l #10. The purpose of the DES is to provide an assessment of the impact of the Midland nuclear plant by itself upon the environment in order to deter-mine whether an operating license should be granted. The staff has l concluded that the impact of the nuclear plant will be sufficiently low that an operating license should be granted. Although other environ-mental risks may be present, the staff notes that (1) such risks would be present even if the nuclear plant did not operate, and (2) the addi-tional risk of the nuclear plant is judged to be sufficiently small that the incremental changes in risk are not significant.
9-10 Responses to Comments of Diane Hebert (DH 3/24/82 A A-1Sa)
#1. See response to Peggy E. Roth comment 4. #2. The three areas of concern listed in this comment were addressed in the Safety Evaluation Report issued by the NRC for the Midland Plant in May 1982.
Responses to Comments of Andrea K. Wir .3 (AKW1 3/24/82 A A-1< In a July 3, 1981, letter to Science,1 Loewe and Mendelsohn have expressed their disagreement with the interpretation of their Hiroshima and Nagasaki dosimetry studies, reported earlier in Science.2 The opinion of Edward Radford of the University of Pittsburgh is based on his interpretation of the aforementioned studies, and represents a viewpoint that is not supported by many scientists working in this field. By way of contrast, one journal article has appeared that stated the possibility that the risk estimates for low doses of gamma radiation may actually be lower than previously thought.3 Another letter to Science has expressed the opinion that it is too early to draw any conclusions.4 It should be noted that the risk estimates for whole-body exposure used in the FES were based on the linear, non-threshold model of BEIR I. Consequently, the range for risk estimators for whole-body exposure used in the FES is consistent with the views of many members of the scientific community and even with the more conservative views of some members such as Dr. Radford. References
- 1. " Radiation Estimates," Letters, Science, Vol. 213, July 3, 1981.
- 2. "New A-Bomb Studies Alter Radiation Estimates," Science, Vol. 212, May 22, 1981.
- 3. T. Straume and R. Dobson, " Implications of New Hiroshima and Nagasaki Dose Estimates; Cancer Risks and Neutron RBE," Health Physics, Vol. 41, October, 1981.
- 4. " Radiation Estimates," Letters, Science, Vol. 213, July 3, 1981.
Response to Comments of U.S. Department of Transportation, U.S. Coast Guard (DTCG 3/26/82 A-19)
#1. The staff agrees with the comment that steam fog could reach Saginaw and Salzburg Roads, east of the cooling pond. However, the staff expects that the fog density will decrease rapidly with distance, and under such '
conditions there would be little hazard to highway traffic on these roads. The staff does agree that the applicant's fog monitoring activities
9-11 should include these sections of the public highways and that the appli-cant should be ready to take mitigative measures if required. The staff i recommends that the applicant closely coordinate its monitoring and l mitigation activities with local highway officials. The applicant has held meetings with the Midland County Road Commission for the purpose of discussing mitigative action in the event of excessive fog. The County Road Commission has authority over the actions such as installing road 1 signs, lights, etc. Responses to Comments of Lucille M. Hallberg (LMH 3/29/82 A-20,21)
#1. The staff's assessment of the potential for fogging from the cooling
& pond indicates that: (1) the frequency with which the fog will extend
#2. beyond 1.6 km (1 mi) from the pond is small; (2) the density of the fog will decrease rapidly with distance; (3) the fog will be buoyant and tend to become elevated with distance; (4) only about 30% of the time will the wind directions be favorable for radioactive effluents from the Midland Nuclear Plant or Dow to interact with fog from the cooling pond; (5) conditions favorable for the formation of dense fog will occur very t
much less than this 30% and, (6) routine effluent releases from the Midland Plant will under most conditions be elevated. Considering the above, the staff expects that any interactions of the fog with effluents from either the Midland Plant or Dow will be infrequent and probably elevated when they do occur. The staff believes that the frequency and extent of this interaction will be negligible compared to any interaction with naturally occurring fog. However, for those times when the fog does interact with the radioactive effluents, the following can be expected. The noble gases will have little or no affinity for the fog droplets, while some of the iodines (e.g., elemental) will be readily adsorbed by the fog. Radioactive particulates may act as condensation nuclei to induce coalescence between the fog and particulates. Iodines and particulates that combine with fog will be more readily deposited onto surfaces. This will result in an increase in the deposition rate of the iodines and particulates during those periods when the meteorological conditions are favorable for the radioactive effluents to interact with the fog. Based on the fact that no significant impact from radioactive effluents interacting with natural or man-made fog has been observed from other existing nuclear plants, and effluent interaction with fog from the Midland cooling pond is expected to be small compared to naturally occurring fog, any impact from this interaction is expected to be negligible. 4
#3. See responses to Mary Sinclair comment 9, U.S. Department of Transporta-
& tion comment 1, and Vicente Castellanos comments 2 and 5. The staff's
- #4. analysis of impact of fogging and icing on highway traffic is presented in Section 5.4.1 of this statement.-
9-12 No impact on air traffic at the Tri-City Airport is expected, because the airport is about 11 km (7 mi) from the plant. During its transit of this distance, pond fog will either completely evaporate or become a small cloud aloft.
#5. Because of the very low density and friable nature of rime ice, no damage to the biota of the area is expected. Such ice is easily dislodged by wind. The staff expects only very small amounts of snow to be generated by the cooling pond fog plume during operation. #6. The text of Section 5.4.1 has been revised to more clearly describe the & applicant's commitments to implement a fog-monitoring program and to #7. take mitigative actions if necessary. #8. Although fogging can occur near the cooling pond, it is not anticipated that it will have much of an adverse impact on either evacuation or on travel by emergency workers. As is stated on page 5-8 of the DES, if traffic hazards are observed as a result of the pond operation, mitiga-tive measures could be required, such as erection of traffic signs, road centerline and edge lights, and planting of trees as a fog barrier.
With these aids, movement of traffic should not require much more time than normal to traverse the short distances involved (on the order of a mile or two). Further, during an evacuation there would be additional help available in the way of traffic control personnel to help prevent accidents and to keep traffic moving. Adverse weather is one of the conditions which must be considered in any evacua-tion time estimate study, and it is not considered likely that fogging is any worse than the 25% reductions in travel times assumed for these purposes. Rcsponses to Comments of Thomas Hearron (TH 3/31/82 A-22)
#1. See response to Peggy E. Roth comment 4. #2. The comment does not indicate what studies might "suggest that present allowable radiation limits are too high to bring about the safety desired."
The DES /FES cites several references that discuss risks of exposure to radiation (e.g., Sec. 5.9.3.1.1), including BEIR I, BEIR III, ICRP, j NCRP, and UNSCEAR (references 35-39 of Sec. 5 in the DES /FES). These studies remain widely accepted among scientists working with health i effects of radiation; no studies have provided evidence for altering the l conclusions reached in the DES /FES. See also the response to comments l by Andrea K. Wilson (3/24/82), Mark A. Handler (4/4/82) and Mary Sinclair (4/17/82), regarding revised dose estimates based on the work of Loewe and Mendelsohn at Lawrence Livermore Laboratory. 1
#3. The staff has concluded that plant chemical discharges may adversely affect future downstream water users (Sec. 5.3.1). Maintenance of Tittabawassee River water quality is a regulatory responsibility of the
9-13 State of Michigan; the NPDES permit to be issued by the state will limit plant discharges when warranted by poor river-water quality. Also see State of Michigan Department of Natural Resources response No. 10 at the end of this section.
#4. See response to Department of the Interior comment 4.
#5. The staff does not agree with the conraent, and believes that the potential traffic hazard that could be caused by fogging has been correctly empha-sized. However, the text of Section 5.4.1 has been revised to more clearly describe the applicant's commitments to implement a fog-monitoring program and to take mitigative actions if necessary.
Responses to Comments of Michigan Department of Health (MDPH 4/1/82 A A-25)
#1. Soils-related problems at the Midland Plant have been the topic of extensive public hearings. These hearings were the appropriate forum for all the issues raised in the comment. The design and construction details of the remedial measures at the Midland Plant are well developed and are receiving appropriate NRC review prior to full implementation of the associated construction.
The soils settlement problem is considered to be a safety issue rather than an environmental issue and, as such, was extensively addressed in the Safety Evaluation Report (SER) issued in May 1982 by the NRC on the l Midland Plant. A supplement to the SER will be issued by the NRC follow- ! ing the staff's assessment of issues related to the soils issue. There-fore, the NRC does not consider discussion of this issue in this Final Environmental Statement to be appropriate.
#2. The process steam radiation monitoring program consists of not only continuous on-line gamma radiation monitoring, but also an off-line radiation monitoring program. The off-line radiation monitoring program includes the periodic collection of specific samples and the laboratory analysis of these samples for gross-bata activity, gross gamma activity, and tritium content with the highest sensitivity possible under controlled laboratory conditions. The samples to be analyzed in the laboratorp, and the frequency for measurements, are presented in Table 11.6-3 of the Midland FSAR. The staff considers that the off-line radiation monitoring will provide a reliable monitoring and sampling program to assure that the steam delivered to Dow does not exceed naturally occurring radio-activity levels within reasonable limits of detection. The on-line monitoring system provides the capability for prompt detection of signi-ficant radioactivity that may leak into the process steam system. In addition, the staff considers that the periodic sampling will be more
( sensitive in detecting leakage from the secondary system to the tertiary l system. A sampling system based on continuously composited samples would tend to delay and desensitize off-line results. This is due to the dilution
9-14 inherent with compositing. Desensitizing would occur should conditions be degrading at the end of the compositing period or if the tertiary activity is asymptotically increasing, as would be expected in a secondary-to-tertiary leak. Since the levels of radioactivity being monitored are essentially background, dilution due to compositing can very readily desensitize results to within background fluctuations (uncertainty). Grab sampling, on the other hand, provides the undiluted conditions as sampled. Grab samples of the evaporator blowdown provide a time-integrated sample which is equivalent to a concentrated, continuously composited sample for any radioparticulates or radiohalogens which potentially_may be present. This is due to the substantial partioning of these radioisot, pes with respect to the water in the evaporator hotwell and the process steam. In as much as the blowdown sample provides this feature, composite sampling is provided within the process steam conitoring program scheme. The concerns for real-time assessment with detailed confirmation was the basis for developing the existing compre-hensive monitoring program for the process steam system.
#3. Dow has stated that all chemical processes can be shut down safely within one hour, although some personnel may have to re enter for short periods of time if the emergency is extended. Consumers Power Company has committed to training Dow health physicists (Dow has a research reactor at its complex) and these health physicists will provide basic radiation training to Dow emergency workers, including training on radiation exposure control and survey procedures. The emergency workers will also be provided with radiation protection equipment as appropriate, such as protective clothing, respiratory equipment, and personnel dosimetry. #4. The components of the sewage system within the Midland Plant exclusion area necessary to continuity of system operation during a Midland inci-dent are, for the most part, passive tanks and clarifiers. Additionally, there are some valves and controls. The system operates for the most part by gravity flow.
Should personnel have to enter the area where the sewage system components are located during a Midland incident, both Consumers' Power Company and Dow have qualified health physics personnel to do so. They would be in full mobile radio contact with the Consumers' Emergency Operations [ Facility while so doing.
#5. See response to Lucille M. Hallberg comment 8. #6. The DES /FES does not attempt to review risk assessment models; rather it presents an assessment of risks resulting from exposure to low levels of ionizing radiation in the environment based on data accumulated and analyzed by various committees and organizations, including BEIR (I and III), ICRP, NCRP, and UNSCEAR (see references 35-37, 39 in Sec. 5 of the DES /FES). These organizations, along with the NCRP, represent the views of the overwhelming majority of the scientific community. The risk estimators used in the DES /FES are consistent with the values from these sources of information.
9-15
#7. The term " worst case" assumptions is intended to apply in the context of implementing the provisions of 10 CFR Part 100, " Reactor Site Criteria" (DES page 5-43, last paragraph). Accidents classified as severe, with potential consequences worse than those of design-basis type, are analyzed in the DES. Safety system malfunctions are considered in these scenarios.
Response to Comment of James F. Wilson (JFW 4/1/82 A-26) On October 25, 1979, the Commission began a proceeding to determine: (1) whether the Commission continues to have confidence that safe off-site , disposal of radioactive wastes from licensed facilities will be available; l (2) when safe disposal or off-site storage of radioactive wastes from ' licensed facilities will be available; and (3) whether radioactive wastes can be safely stored on site past the expiration of existing facility licenses until off-site disposal or storage is available. 44 FR 61372, 61373. In the notice commencing the proceeding the Commission said:
"During this proceeding the issues being considered in the rulemaking should not be addressed in individual licensing proceedings. These issues are most appropriately addressed in a generic proceeding of the character here envisaged .... However, all licensing proceedings now underway will be subject to whatever final determinations are reached in this proceeding." Thus, pursuant to the Commission's direction, the issue of the availability of permanent disposal of nuclear wastes from reactors currently in the licensing process, including the Midland Plant, Units 1 & 2, will be addressed in the generic rulemaking now underway. The Commission has completed the proceedings in this rule-making and has the record before it for decision. A decision is expected , later this year.
Responses to Consumers Power Company Comments (CPCo 4/2/82 A A-50)
#1. The staff does not agree with the applicant's position that, since Michigan Water Quality Standards for total dissolved solids (TDS) will not be exceeded in the river due to plant discharge, Midland Plant TDS dis-charges will have little effect on present or potential new users down-stream. The staff believes that the effect on present or potential water users downstream on the Tittabawassee River is dependent on type of use. In instances when the TDS concentration exceeds'500 milligrams per liter (mg/L), the concentration will meet Michigan standards for state waters, but not Michigan standards for public water supplies or National Secondary Drinking Water Standards. River water with TDS concentrations in excess of 500 mg/L would be acceptable for protection of aquatic life, recreational and agricultural use, and most industrial use; however, it would not be acceptable for use as a public water supply or for food processing without extensive treatment. As a result, river water which meets Michigan standards for state waters, but exceeds the standards for public water supplies, may have an impact on potential users for public supply or food processing.
Also see State of Michigan Department of Natural Resources response l No. 26-a at the end of this section.
9-16
#2. The text of Section 5.4.1 has been revised to include the applicant's commitment to monitor fogging and icing near the cooling pond (ER-OL, Sec. 6.1.3.1.8 [preoperation] and ER-OL, Sec. 6.2.3.1.2 [ operational]),
and its commitment to take whatever actions are needed to mitigate potential hazards to traffic caused by steam fog from the cooling pond (ER-OL, Sec. 5.1.4.2).
#3. See response to Peggy E. Roth camment 4.
#4. See response to Consumers Power Co. comment 1.
#5. See response to Consumers Power Co. comment 1.
#6. An appropriate text change has been made in Item 4.e in the Summary and Conclusions.
#7. Based on the information considered in Section 5.4.1, the staff expects that fog from the cooling pond will impact traffic on Gordonville Road.
#8. An appropriate text change has been made in paragraph 4.h of the Summary and Conclusions.
#9. An appropriate text change has been made in paragraph 4.i of the Summary and Conclusions.
#10. An appropriate text change has been made in Section 1.
#11. An appropriate text change has been made in Section 1.1.
#12. An appropriate text change has been made in Section 1.2.
#13. thru
#24. See response to Peggy E. Roth Comment 4.
#25 j & Appropriate text changes haye been made in Section 4.1.
l #26. i
#27. An appropriate text change has been made in Section 4.2.3.
#28.
& Appropriate text changes have been made in Section 4.2.4.1.
#29.
#30. An appropriate text change has been made in Section 4.2.4.4.
#31. An appropriate addition has been made to the text in Section 4.2.4.4.
#32. The staff acknowledges that the wastewater streams discharged to the cooling pond are the iron removal sump effluents, spent circulating and
9-17 service water treatment chemicals, and wastes from the hypochlorite generation system; and that the cooling pond will routinely receive these waste streams prior to their discharge to the Tittabawasee River. These wastes are generated during makeup-water treatment, cooling-water treatment, biocide generation, and demineralizer regeneration, as des-cribed in Section 4.2.6.1 of the DES.
#33. Appropriate text changes have been made in Section 4.2.6.1.
thru #42.
#43. Appropriate text changes have been made in Section 4.2.6.2.
thru #45.
#46. It is stated in the ER-OL, Table 5.1-1, that the Dow discharge flow excess temperatures used in the cooling pond blowdown study ranged from 4.6F to 5.1F , with an average of about 4.9F . #47. It is stated in the ER-OL, Table 5.1-1, that the minimum river flow used in the physical model study of cooling pond blowdown was 26.0 m3/s (920 cfs), not 27.5 m3/s (970 cfs). #48. There are no values calculated and presented by the applicant to indicate the sizes of the river cross-sectional area enclosed by the various isotherms. An appropriate text change has been made in Section 4.2.6.2. #49. & Appropriate text changes have been made in Section 4.2.6.2. #50. #51. The draft NPDES permit specifies that at no time shall the water i temperature at the edge of the mixing zone be greater than the monthly maximum temperatures (Sec. 5.3.2.2). An appropriate text change has been made in Section 4.2.6.2 to reflect this limitation. #52. Comment does not exist (part of 51). #53. The text of Section 4.2.6.3 has been changed to reflect additions to plant systems and changes in plant operating conditions that will increase annual gaseous emission rates. #54. & The text of Section 4.3.3.1 has been revised. #55. #56. The information on atmospheric dispersion factors is contained in Table C.2 of this FES. #57. Comment does not exist. #58. The text of Section 4.3.3.2 has been revised to include air quality data for 1980 for the Midland area from the report " Air Quality Report 1980,"
published by the Air Quality Division, Michigan Department of Natural Resources, Lansing, MI.
9-18
#59. An appropriate text change has been made in Section 4.3.4.1. #60. An appropriate text change has been made in Section 4.3.4.2. #61. An appropriate addition has been made to the text in Section 4.3.4.2. #62. An appropriate addition has been made to the text of Section 4.3.5.1. #63. No alteration of the information presented in Section 4.3.5.1 is necessary; however, an error in paragraph 2, sentence 1, has been corrected. #64. A spelling correction has been made in the references of Section 4. #65. An appropriate text change has been made in Section 5.1. #66. An appropriate text change has been made to Section 5.2.2. #67. An appropriate text change has been made to Section 5.2.2. #68. An appropriate text change has been made in Section 5.3.1; also see response to Consumers Power Co. comment 1. #69. The staff is aware that the NPDES permit does not regulate sulfate, sodium, or phosphate. However, these anions make up a portion of the constituents considered under the category of total dissolved solids.
The information given in the footnote on page 5-3 of this statement provides information required for assessment of impacts from plant discharges. An appropriate text change has been made in Section 5.3.2.1 concerning phosphate as phosphorous.
#70. & Appropriate text changes have been made in Section 5.3.2.1. #71. #72.
. & Appropriate text changes have been made in Section 5.3.2.2. ! #73.
#74. An appropriate text change has been made in Section 5.3.2.2 to specify the situations under which the cooling pond blowdown would have to be temporarily withheld in order to meet both the TDS and water temperature standards. #75. An appropriate text change has been made in Section 5.3.2.2. Also see response to Consumers Power Co. comment 48. #76. & Appropriate text changes have been made in Section 5.3.2.2. #77. #78. The staff's conclusion that there will be frequent periods of dense fog over Gordonville Road is not based on any model, but instead is based
9-19 primarily on observations of steam fog near the cooling pond for the Dresden Nuclear Power Plant in Illinois. Fog will form over the lake and be advected inland at air temperatures much higher than the -18 C (O F) or lower assumed in the applicant's comment. If the technique developed by Hicks (Ref. 3 for Sec. 5 of the DES) is used with an average winter pond temperature of 18*C (64.4 F) (Table 4.3 of DES), steam fog will be present over the cooling pond at air temperatures as warm as O C (32 F). The observations made at Dresden and elsewhere indicate that as the air temperature decreases, the steam fog will become more opaque (more dense) and last longer before evaporating. Thus, the critical air temperature for the onset of steam fog over the pond is much higher t.han the value cited by the applicant in his comment. Also, the applicant's calculations assume, incorrectly, that wind direction and air temperature at the site are not correlated. The heat load (heat loss per unit area of water surface) on the Midland cooling pond will be about 21% greater than that at Dresden. Because the spray canals at Dresden are about one mile north and northwest of the cooling pond, these units are upwind of the cooling pond whenever the wind carries fog over Lorenzo Road. Thus the sprays add very little to fogging conditions over that highway. The limited number of fogging observations that are available from cooling ponds, and the uncertainty associated with the staff's analysis, are indicated in Section 5.4.1. See also the staff's response to Consumer Powers Co. comment 2.
#79. The text of Section 5.4.1 has been revised.
#80. The text of the last paragraph of Section 5.4.1 has been changed to indicate that the extent of pond-induced steam fog will be monitored.
#81. The text of Section 5.4.2.1 has been revised to reflect the change in the number of diesel engines and boilers at the site.
#82. An appropriate text addition has been made to Section 5.5.1.2.
#83. This comment is a presentation of additional information for which no
~
response is necessary.
#84. An appropriate text change has been made in Section 5.5.1.2. #85. An appropriate text change has been made in Section 5.5.1.3. #86. See staff's response to Department of the Interior Comment 4. #87. An appropriate addition has been made to Section 5.5.2.4. #88. An appropriate text change has been made in Section 5.5.2.4. #89. Appropriate changes have been made in Sections 5.8.1, 5.8.2.2, 5.8.4, 5.8.5, 5.8.7.1, 6.4.1, and in Table 6.1.
l l l i 9-20
#90. Appropriate changes have been made in Sections 5.8.2.1 and 6.4.1, and in Table 6.1. l 1
#91. An appropriate change has been made in the text of Section 5.8.2.1. i l
#92. Appropriate changes have been made in Sections 5.8.3 and 6.4.1, and in Table 6.1.
#93. An appropriate text change has been made in Section 5.9.3.1.1.
#94. An appropriate text change has been made in Section 5.9.3.4.1.
#95. An appropriate change has been made to Table 5.3, which has been replaced with a copy of Table 6.2A-3-9 of the ER-OL.
#96.
& Appropriate text changes have been made in Section 5.9.4.5(6).
#97. i
#98. No credit in the Safety Analysis for the features indicated has been requested by the applicant. Because of this, they do not qualify as "special mitigation features" in the context of the referenced paragraph.
#99-
#101. Section 6 has been revised appropriately.
#102. The staff agrees that the water resources impact due to the consumptive water use of 0.8 m3/s (28 cfs) through evaporation is not significant, as indicated by the assessment of "small" in Table 6.1. The assessment of " moderate" pertains to the cost of committing 1.55 x 10 7 3m of river water to the cooling pond, particularly in light of the relatively small size of the river.
t
#103. The staff agrees that the judgment is subjective, but believes that the assessment of " moderate" is the proper one to use.
#104-
#107. Section 6 has been revised appropriately.
#108. The applicant's calculations assume that during containment purging there will be no air mixing between the air room and the rest of the containment, while the staff's calculations assume that there will be some air mixing due to leakage between the air room and the rest of the ,
containment. In addition, the staff elected not to quantify leakage l between the air room and the rest of the containment and assumed that air between the air room and the rest of the containment would be freely mixed. The above assumption is conservative. The staff-calculated releases and corresponding doses are well below the requirements of the applicable regulations.
#109. The table cited in this document has been superseded by Table 2.1-10, Revision 11 of the ER-OL, dated September 1980, which contains the data for the locations of milk cow and milk goat used in the DES /FES.
9-21
#110. & Appropriate changes have been made in Appendix H, Table H.2.
i-
#111.
Responses to Michigan United Conservation Clubs Comments (MUCC 4/2/82 A A-55)
#1. A contemporary copy of the Draft NPDES now appears in Appendix B.
& Also see State of Michigan Department of Natural Resources response
#2. No. 12 at the end of this section.
#3. The staff maintains its position that negligible impact to Tittabawassee River biota, particularly fish, will occur from the Midland Plant thermal discharge. A substantial amount of literature (see references cited in Sec. 5.5.2.2) exists to support the conclusions that the fish species that dominate tne Tittabawassee River can (1) selectively avoid excessive thermal conditions and/or (2) tolerate such conditions that will occur within most of the Midland Plant thermal discharge plume.
The literature indicates that fish are generally attracted to heated waters in cooler months (when elevated temperatures have the least potential to approach upper lethal levels) and are repelled during hotter months (as thermal tolerance levels may be reached). Additionally, fish do not necessarily stay in heated waters, but often move into them, perhaps to feed, and then move back to cooler (ambient) adjacent areas. Fish species can readily tolerate temperature differentials of 2.8C (5F ) for extended period of time. Temperatures differentials in excess of 2.8C will occupy a maximum of only about 8% of the entire river cross-section in the discharge area (Sec. 4.2.6.2). The references cited in Section 5.5.2.2 contain fish-capture data showing that healthy fish have been collected at temperatures in excess of 35 C (95*F). To provide additional assurance that thermal effects on fish are minimized, the Michigan Department of Natural Resources (MDNR), subsequent to the March 22, 1982, meeting of the Michigan Environmental Review Board, added effluent temperature limitations to the NPDES permit. See State of Michigan Department of Natural Resources response No. 12-b at the end of this section.
#4. The staff acknowledges that there is no discussion in the DES of the relationship between increased water temperature and increased chemical reactions from other pollutants that will be discharged from the Midland Plant and from the Dow Chemical Company. As described in Sections 4.2.6.1 and 5.3.2.1 of the DES, the primary pollutants that will be discharged from the Midland Plant are total dissolved solids (TDS). These wastes will be inorganic chemicals; therefore, reactions or chemical changes of the inorganic chemicals contained in the TDS at a water temperature of up to 38 C (100 F) are not expected to occur to a substantial degree.
As discussed in the FES-CP, Section V.C.2, the harmful effects of TDS on aquatic organisms are limited to osmotic effects which occur at very
- 9-22 a
' high concentrations, i.e. , generally above 5000 mg/L, about an order of
; magnitude higher than expected at the Midland Plant.
p 1 The staff does agree that there might be a potential for impact due to i the. increased temperature of water that will be discharged from the Midland Plant and organic chemicals discharged from the Dow Chemical
-Company, and has relayed this comment to the Michigan Department of '
Natural Resources so that it may be included in their review of dis-charge permits.
'Also see State of Michigan Department of Natural Resources response No. 12-c at the end of this section.
#5. If synergism does in fact occur at low levels of radiation, it is presently occurring between the existing environmental pollutants and the existing natural background radiation. Indeed, the present cancer incidence statistics for the area surrounding the Midland Plant must necessarily reflect any synergistic interaction between the environ-mental carcinogens in Michigan and natural background radiation of i' about 108 mrems per year. The Midland Plant will add of less than O.01 mrem per year to the average exposed individual residing within 50 miles of the plant- an exceedingly small fraction of the existing natural background radiation. Such a minute addition to the existing radiation. levels could have only a correspondingly minute additional effect and will not' measurably increase the synergistic interactions that, by hypothe' sis, may already be occurring in the environment.
Furthermore, the radiation released by Midland will even be smaller i than the variation in natural background radiation from place to place in the areas at or near the site boundary and beyond. As a result, any additional synergistic effects caused by radiation released from the Midland Plant will be correspondingly even smaller than those i induced by such local variations in natural background radiation and j would be completely undetectable, if they' occur at all. Although lack of detectability does not necessarily translate into no _ effect, the fact that naturally occurring var _iables alone are sufficient
-to mask any effect that occurs is indicative of negligible impact. The ,
staff knows of no studies that demonstrate synergism at any doses within several orders of magnitude of Midland's very low levels. Moreover, all studies of chemical carcinogenesis in animals or cells are necessarily carried out in the presence of natural background radiation. Thus, the results.obtained in all these experiments (which purport to measure effects of chemical carcinogens alone) already include any synergistic effects of the carcinogenic chemicals with low-level radiation at a dose rate due to natural background radiation (and far exceeding the dose
'that will result from Midland's releases).
The evidence on synergism is as follows: (1) Both radiation and chemical l
. carcinogens need to be present in individuals to cause a synergistic effect to occur between them; (2) the types and amounts of chemical carcinogens in the Midland area are not well defined, and while existing cancer rates may be attributat'le to . environmental pollutants, including
9-23 carcinogens, it is not clear that chemical carcinogens are present in sufficient amounts to support synergism with radiation from Midland; (3) synergism has been observed in laboratory studies where the amounts of radiation and the amounts of chemical carcinogens have been controlled; in all reported instances of observed synergistic reactions, the amount of radiation involved was millions of times greater and the dose rate of { exposure billions of times greater than the average doses calculated to i result from Midland Plant releases; (4) there is not evidence of synergism , between chemical carcinogens and radiation at, or even approaching, the 1 very low le"els of radiation to be emitted from the Midland Plant; and finally, (5) no studies seem clearly to suggest a curve for extrapolating the effects from the very high radiation levels where effects have been observed to the extremely low levels of radiation at issue here. Under these circumstances, we are unable to conclude with assurance that synergistic effects will result between existing chemical carcinogens in the area of the Midland Plant and the low levels of radiation that will be released during the plant's normal operation. In all likelihood, synergism will not occur, but the staff doubts that this can be proven with great assurance based on current scientific knowledge and evaluative techniques. The inability to define with precision whether synergism occurs at very low levels of radiation and to quantify it does not preclude our ability to place an upper bound on the effect and, assuming it occurs, characterize the impact. In view of the very iow levels of releases anticipated from the Midland Plant, particularly when viewed in relation to the existing natural background and the variations in natural background, synergistic effects, if any occur, will be truly miniscule, We note that in a prior NRC case, another licensing board on the evidence before it found no synergistic effects between radiation and pollutants at the levels near those projected for the dose rates due to that plant's releases. [See Duquesne Light Co., et al. (Beaver Valley Power Station, Unit No. 2), LBP-74-25, 7 A.E.C. 711, 730-31 (1974).]
#6. An appropriate text change has been made in Section 5.5.2.4 to clarify why dissolved oxygen levels will not be of concern.
Also see State of Michigan Department of Natural Resources response No. 12-d at the end of this section.
#7. Section 5.3.1 does not state that seepage from the cooling pond to groundwaters is occurring. What section 5.3.1 does state is as follows:
"The level of the perched water table beneath the station has risen to an elevation of about 191 m (627 ft) mean sea level (MSL) due to seepage from the cooling pond."
As described in the ER-0L, Sections 2.4.7.2.7 and 3.4.3, and the FES-CP, Section V.B, naturally occurring impermeable clays underlying the cooling pond are expected to prevent possible downward seepage of cooling pond liquids from reaching the confined drift and bedrock aquifers. In addition, the relatively thin surface sand deposits along the cooling pond dike were removed and backfilled with impervious clay to prevent any seepage from the cooling pond into the surface sand outside the
I
' 9-24 reservoir boundaries. In areas where the surficial sand was too thick ,
, to remove, a bentonite slurry trench cut-off wall was installed. 1 Pumping tests conducted in the plant fill area have shown that as expected, there is very little seepage occurring through the dike.between the ;
cooling pond and the plant fill area except in the vicinity of the ' Circulating Water Intake Structure and tae Service Water Pump Structure where the dike is absent. Seepage in this area is occurring through the natural and backfill sands which surround these structures. This seepage
.has resulted in the level of the perched water table beneath the plant rising to an elevation of about 627 ft MSL. This level, however, has 2 been lowered in certain areas of the plant fill by dewatering. During plant operatic " . a permanent dewatering system will maintain-groundwater levels, unde- the Diesel Generator Building and the Railroad Bay Area of the . .ary Building, below elevation 610 f t MSL. This dewatering system will return groundwater from the plant fill area to the cooling pond.
2 Figure 6.1-4 in the ER-OL shows that the plant fill area is also
' surrounded by a dike which is similar in construction to the cooling pond dikes. Thus it is expected that the high perched water table beneath the station will be confined. The plant fill area is also underlain by a thick clay layer which will prevent downward seepage to the drift and bedrock aquifers.
#8. See response i.o' Lucille M. Hallberg comments 1 and 2 and State of Michigan
~^
Department of Natural Resources response No. 12.e.,
- #9. As described in Section 5.9.4.4(2) of the DES, portions of the Tittaba-wassee River and Bullock Creek lie within the exclosion area. The DES- O also states that local and State agencies will evacuate and limit access to the exclusion area should the need arise. The authority for such p action is delegated by the Michigan Emergency Preparedness Act. There l~ will be no routine exclusion of the public from the surface waters of
! the Tittabawassee or Bullock Creek. Consumers Power, with aid of the p police / sheriff', will only evacuate the area during an emergency that l necessitates such an evacuation. -
#10. See response to Peggy E. Roth comment 4 and State of Michigan Departm'ent .
of Natural Resources respon'se Nos. 12.f and 12.g. Response-to Comment of Debra K. Stempek (DKS 4/2/82 A A-58)' See response to James I.. Wilson comment. Responses to Comments of William A. Lochstet j (WAL 4/4/82 A A-65)
~
#.1. Dr. .Lochstet contends "the health consequences of radon-222, emissions
- -x from'the uranium fuel cycle are improperly evaluated" because tha. staff
9-25 evaluated the impacts of radon-222 releases from the wastes generated in the fuei cycle for 1000 years or less, rather than for the entire toxic life of the wastes. Lochstet estimates that radon-222 emissions from the wastes from each annual fuel requirement will cause about 600,000 deaths over a period of more than 1 billion years. The major difference between the staff's estimated number of health effects from radon-222 emissions and Lochstet's estimated values is the issue of the time period over which dose commitments and health effects from long-lived radioactive effluents should be evaluated. Lochstet has integrated dose commitments and health effects over what amounts to an infinite time interval, whereas the staff has integrated dose commitments from radon-222 releases over a 100 year period, a 500 year period, and a 1000 year period. The staff has not estimated health effects from radon-222 emissions beyond 1000 years for the following reasons: Predictions'over time periods greater than 100 years are subject to great uncertainties. These uncertainties result from, but are not limited to, political and social considerations, population size, health characteristics, and, for time periods on the order of thousands of years, geologic and climatologic effects. In contrast to Lochstet's conclusion, some~ authors (see B.L. Cohen, " Radon: Characteristics, Natural Occurrence, Technological ; Enhancement, and Health Effects," Vol. 4, Progress in Nuclear Energy, l 1979) estimate that the long-term (thousands of years) impacts from the uranium used in reactors will be less than the long-term impacts from an i equivalent amount of uranium left undisturbed in the ground. Consequently, I the staff has limited its period of consideration to 1000 years or less for decision-making and impact-calculational purposes.
#2. A sentence has been added to Section 5.9.4.5(2) clarifying that the U.S.
average population was used beyond 350 miles from the site. The calcula-tion is actually an extended one in that the last spatial mesh (beyond 350 miles) is elongated and washout is implemented to deplete the plume of any non gaseous material that still might remain in the plume.
#3. . A map showing the location of the Midland Plant site, the Dow Plant, and the City of Midland has been added to Section 4 (Fig. 4.1).
Responses to Comments of A.B. Savage (ABS 4/4/82 A A-68)
#1. The production costs of the environmental statement are paid for in part by the licensing fees paid by the applicant. By law (National Environ-mental Policy Act of 1969), the NRC is required to issue an environmental impact statement for nuclear power plant applications, not the applicant.
The purpose of this report is to assess the environmental impact of operation of the Midland Plant and is considered by the NRC to meet the NEPA requirements for such a report.
#2. See response to Peggy E. Roth comment 4.
9-26
#3. This comment is largely the opinion of the commenter and lacks technical specificity. The subject of heat exchanger tube materials is one of ongoing research by the NRC ar.d the nuclear industry. However, no evidence exists that the materials selected for the Midland Plant design fail to meet NRC safety standards. The design and administrative pro-visions for and consequences of steam generator tube leakage are addressed in the Safety Evaluation Report issued by the NRC on the Midland Plant in May 1982.
#4. See Michigan Department of Natural Resources response No. 14-a at the end of this section.
In determining a flood-level elevation for the Tittabawassee River at the Midland Plant, the applicant not only assumed that all four upstream dams on the Tittabawassee River would fail but also assumed that these failures ~would occur coincident with the Probable Maximum Flood (PMF) in the river.' The applicant analyzed the effects of overtopping on the cooling pond dikes during a PMF. It was determined that there could be slight over-topping of the dike in the vicinity of the ultimate heat sink during a PMF. The applicant stated that because the dike is at least 60 ft wide at this locaticn and has a railroad track with a top rail clevation of
'about 633.8 ft MSL, overtopping would be minimal and would not remove an amount of dike material that could affect the operability of the ultimate heat sink.
. The staff reviewed the information presented by the applicant and performed independent analysis. The staff concluded that the potential for over-topping of the dike in the vicinity of the ultimate heat sink was small, and any overtopping that did occur would not affect the safe operation of the plant. Potential erosion of the caoling pond dike was also considered by the applicant. To resist the erosive effects of flood waters in the Tittaba-wassee River, the outer slopes of the cooling pond dikes are protected with riprap (stone) to the 100 year flood level of 614 ft MSL. Seeded i turf is provided between this elevation and the top of the dike, elevation l 632 ft MSL. The applicant stated that the velocity of a PMF against the cooling pond dikes would be about 4.5 ft/sec or less. The seeded turf (Kentucky blue grass) is considered to provide protection against velocities of at least 5 ft/sec. The staff has reviewed the applicant's submittals and performed independent analyses. The staff's estimate of PMF velocities against the cooling pond dike is 4.7 ft/sec. Thus, the staff agrees that erosion of the cooling pond dikes due to extreme flood events will be minimal and will not affect the safe operation of the plant.
#5. The Midland Plant proposed to use a 30% to 38% by weight aqueous solution of hydrazine for containment spray. Under normal conditions, such a solution is not flammable and will not decompose with explosive violence.
Under design basis accident conditions, the hydrazine in the aqueous solution could decompose into nitrogen and ammonia gases. Ammonia gas is readily dissolved in water, forming ammonium ions (NH +). Nitrogen
9-27 gas at atmospheric pressure and ammonium ions are neither combustible, nor flammable, nor explosive. Thus, the decomposition of hydrazine in an aqueous solution under design basis accident conditions will r.ot produce combustion. To our knowledge, hydrazine sulfate will not be used at the Midland Plant. In a postulated accidental spill of the hydrazine solution, the liquid will evaporate and some of the hydrazine vapor could enter the control room through the air intakes. The air intakes of the control room at the Midland Plant are equipped with redundant toxic vapor detectors. These detectors are connected to a mass spectrographic analysis system which is seismically qualified and safety grade. The staff has determined that this mass spectrographic analysis system provides protection against those chemicals, including hydrazine, believed to be stored or produced in the proximity of the Midland Plant Site (Section 6.4, Control Room Habitability, NUREG-0793, Safety Evaluation Report Related to the Opera-tion of Midland Plant, Units 1 and 2, May 1982). Upon detection of a toxic gas in the air intakes, the control room will be isolated and no further toxic gas will enter the control room. Makeup air is initially provided by a 3-hour supply of bottled air. After the supply is exhausted, the control room operators have self-contained breathing apparatus for protection against toxic vapors. A 6-hour supply of air for the breathing apparatus is maintained. In addition, the local supply of compressed breathing air is capable of providing uninterrupted service to the plant site for extended periods of time. The staff concludes that the control room habitability system is adequate to provide safe and habitable conditions under normal and accident conditions. Thus, the toxicity and carcinogenicity of hydrazine vapor will pose no significant safety concern to the Midland plant operators. For use in various plant systems besides containment spray, such as in the secondary water chemistry control, the aqueous solution of hydrazine is first diluted with water to 3% by weight. This 3% hydrazine solution will be further diluted after being injected into the various plant systems. The resulting hydrazine concentration will be in the order of 0.1 parts per million. The staff determined that the hydrazine solution at this concentration level will pose no significant safety concern to the Midland Plant.
- 6. The staff agrees that hydrazine is toxic and carcinogenic. Based on toxicity information, the estimated permissible concentration (EPC) in water has been set at 18 mg/L for hydrazine (Cleland, J.G. and G.L.
Kingsbury, " Multimedia Environmental Goals for Environmental Assessment," U.S. Environmental Protection Agency, EPA-600/7-77-136, 1977). The staff has calculated that the hydrazine concentration from the plant is expected to be about 10 mg/L following discharge into the Tittabawasee River; this is below tha EPC. Thus, the staff considers this concentra-tion in the river to be acceptable.
9-28 Also see State of Michigan Department of Natural Resources response No. 14-b at the end of this section.
#7. See the response to Michigan United Conservation Clubs comment 8 for discussion on the interaction of fog with radioactive effluents.
The staff believes an adequate assessment of fogging and icing resulting from plant operation is contained in Section 5.9.1 of the text. See also the responses to comment 5 by Vicente Castellanos, comment 5 by Thomas Hearron, and comment 9 by A.B. Savage.
#8. The staff does not agree that fog dispersal equipment should be installed.
The fog mitigation discussed in Section 5.4.1 would be adequate to protect motorists using Gordonville Road and other highways in the area.
#9. The only nonradioactive materials to be discharged to the atmosphere from the Midland Plant are sulfur dioxide and nitrogen dioxide, as described in the DES, Section 4.2.6.3. Emissions will occur infrequently and in quantities too small to be hazardous, whether absorbed in fog droplets or not. Thus, the potential health effects are negligible.
Also see response to A.B. Savage comment 7.
- 9a. The staff does not agree with the fog and ice analysis prepared by A.B. Savage. The staff believes that the analyses presented in Sec-tion 5.4.1 of this document fairly represent the extent of severity of steam fog and icing expected at the cooling pond.
- 10. This comment is subjective and is considered to be a safety issue, not an environmental issue. Overpressure protection devices are fully addressed in the Safety Evaluation Report issued by the NRC on the Midland Plant in May 1982.
- 11. This comment is rhetorical in nature and will not be specifically addressed.
- 12. The effects of exposure to low levels of radiation are fully discussed in Section 5.9.3 of this report.
- 13. The radiological consequences of accidents estimated by the staff are stated at the plant exclusion area boundary (EAB) as well as at larger distances. Thus, risks to local residents, as well as those living at distances of 50 miles and greater from the site, are estimated in a manner that the staff considers to be fair.
The Price-Anderson Act includes residents of Midland in its coverage for compensation in the event of an accident. The act provides for total compensation to an upper limit of $560 million. Congress has stated its intent to consider total claims in excess of this amount should such a situation arise.
- 14. The NRC staff's analysis of core melt accident liquid pathway consequences, Section 5.9.4.5(5), concluded that contamination of the regional aquifer
9-29 1 would be highly unlikely because of the presence of an essentially impervious layer of clay about 150 feet thick which lies between the I plant and the aqui 4r. Response to Comment of Sharon K. Warren (SKW 4/4/82 A-69,70) Although specific mention of these safety-related issues is not made in the DES, they are appropriately discussed in the Safety Evaluation Report [NUREG-0793, Midland Safety Evaluation Report, (May 1982); Sub-section 5.3.] The issues of reactor vessel fracture toughness and pressurized thermal shock are generic safety issues which are currently under active review and resolution by the NRC. In the case of reactor vessel fracture toughness, draft NUREG-0744 has been issued for public comment as a proposed resolution of this issue [NUREG-0744, " Resolution of Reactor Vessel Materials Toughness Safety Issue," Draft Version (September 1981)]. Given the generic nature of this issue and the SER review, and the enveloping of radiological consequences in the DES, speci-fic omission of this issue from the DES is not significant. Responses to Comments of U.S. Environmental Protection Agency (EPA 4/5/82 A A-73)
#1. See State of Michigan Department of Natural Resources response No.16-a at the end of this section. #2. Monitoring experience at operating pressurized water reactors is summarized in the annual Radiological Environmental Monitoring Report required from each facility. These reports are available for viewing at the NRC Public Document Room in Washington, D.C. These reports support the statement cited in this comment. #3. See response to Peggy E. Roth comment 5. #4. See response to James F. Wilson comment. #5. See response to Peggy E. Roth comment 5. #6. The leaks in the steam pressure lines referred to in this comment are considered under " anticipated operational occurrences." The quantities of radionuclides that escape from the primary cooling system resulting from these leaks are included in the source term calculations that describe plant effluents. Therefore, the radionuclides that ultimately I enter into unrestricted areas via this route are already accounted for l in the calculation of potential radiological impacts to members of the l public offsite. l #7. The primary source of ice on highways near the plant will be rime ice falling from trees, vegetation, and wires over and near the roadbed, not from direct deposition of moisture. Since the staff expects that the amount of ice resulting from operation of the plant will be small compared
9-30 . to the amount resulting from natural sources, and since the density of rime ice is very low, only a small increase in the amount of salt would be needed to maintain the road. Thus, no significant degradation of water quality is expected due to the small additional quantity of salt that might be used. The NRC was informed that the Midland County Road Commission presently applies an average of about 1 ton / mile of salt mixture (in winter) and about 1700 gal / mile of a brine solution (summer and winter) on approximately 400 miles of roads to control winter icing and summer dust problems. Also see State of Michigan Department of Natural Resources response No. 16-b at the end of this section. Response to Comment of Mark A. Handler / Christine K. Handler (MAH 4/4/82 A-74) The risk estimators for exposure to radioactive materials that were used in the DES /FES are consistent with values that can be derived from the BEIR I report, BEIR III report, ICRP, and UNSCEAR (References 35-37, 39 in Sec. 5 of the DES). They are also consistent with the recommendations of the NCRP (REF 38). These organizations represent the views of the overwhelming majority of the members of the scientific community. Given the margins of uncertainty associated with the health risk estimates of each of these organizations, the actual health risks may be more or less than the average values used in the DES /FES. Due to the extremely low doses calculated for the operation of the Midland facility in comparison to doses resulting from natural background radiation, any l' health risks associated with the operation of Midland will be a very small fraction of the possible incidence of ill-health and death resulting from natural background radiation. Regarding the research conducted at Lawrence Livermore Laboratory, see the response to the comment of Andrea K. Wilson, dated March 24, 1982. i Responses to Comments of Andrea K. Wilson (AKW2 4/12/82 A-75,76)
#1. The Michigan Air Pollution Control Commission approved an amendment to Dow Chemical's incineration license on May 18, 1982. This amendment authorizes incineration of wastes with atomic numbers between 1 and 83 plus americium-241 and polonium-210. These are the same isotopes authorized by the NRC.
#2. See response to Michigan United Conservation Clubs comment 5.
Responses to Comments of the U.S. Dept. of Health and Human Services, Public Health Service (PHS 4/12/82 A-77,78)
#1. .This comment endorses the DES; therefore no response is required.
,--yn w --
9-31
- 2. This comment endorses the DES; therefore no response is required.
- 3. The results of the probabilistic assessment which are presented as probability distributions of consequences do indeed depend on the modeling of the evacuation in the computer code. As detailed in Appendix F, the parameters are based in part on evaluations by the applicant of their emergency plans. Since the effectiveness of an actual evacuation might be greater or less than that characterized in the model (as noted in the referenced section), the results of a much more pessimistic evacuation response in a calculation of early fatalities were included in the DES in Appendix F. The model used in the probabilistic assessment studies is not a realistic representation of two-dimensional movement of the cloud and the evacuating persons. It is characterized by average para-meters which are applied to all evacuating persons, as detailed in Appendix F. Since it is not a realistic model, it has not been verified.
At the present time there are no studies being made or planned to verify the evacuation model presented in Appendix F.1. Evacuation models by themselves do not " demonstrate" that evacuation is or is not feasible at a specific facility. The models provide information to the protective action decisionmaker and aid in deciding on the types of protective actions to recommend during an emergency and to identify in advance particular problems that could be alleviated by traffic controls.
#4. The final operational monitoring program proposed by the applicant will be reviewed in detail by the NRC staff in relation to the Radiological Assessment Branch Technical Position, "An Acceptable Radiological Environ-mental Monitoring Program," Revision I, November 1979. This document includes requirements for appropriate monitoring of ingestion pathways by milk and/or broad leaf vegetation samples. Also included are require-ments for monitoring direct radiation from noble gases and airborne contaminants, including radioiodine. As stated in Section 5.9.3.4.2, the specifics of the required monitoring program will be incorporated into the Operating License Radiological Effluent Technical Specifi-cations.
Verification that instrument systems perform as expected and meet the Technical Specifications is provided by participation in the U.S. Environ-mental Protection Agency's Inter-Laboratory Comparison Program or another approved intercomparison program. Each licensee is required under their Technical Specifications to participate in such a program, which ensures that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid.
#5. This comment endorses the DES; therafore no response is required.
l
9-32 Responses to Comments of U.S. Department of the Interior, Office of the Secretary (DIOS 4/13/82 A-79,80)
#1. Potential impacts of chemical discharges from the Midland Plant were discussed in the FES-CP, Section V.C.2; it was concluded that such impacts would be negligible. Because these conclusions remain valid, a discussion of this subject area has not been included in the present document. Adherence to the discharge limitations set forth in the NPDES permit will ensure that chemical discharges will have negligible effects. #2. Paragraphs two and four of Section 5.5.2.2 were not meant to be contra-dictory. Paragraph two was meant to provide general background informa-tion on the types of impacts that can occur to fish from thermal dis-charges, including cold shock. An appropriate text clarification has been made in Section 5.5.2.2.
As discussed in Section 5.5.2.2, the thermal plume will be small and narrow [i.e., the 2.8C (5F ) mixing zone will occupy less than one-quarter of the river cross-sectional area and will extend only up to about 515 m (1700 ft) downstream]. Integration of this information with information relative to fish avoidance behavior and thermal tolerance (see response to Michigan United Conservation Clubs Comment 3) clearly indicates that thermal impacts on Tittabawassee River Fish will be negli-gible. For this reason, a detailed analysis is not provided. Similarly, emphasis has not been placed on potential cold shock impacts because of (1) the unlikelihood of occurrence and (2) the small number of fish that could be affected if a problem were to occur. The staff agrees with the applicant that the expected intermittent nature of thermal discharges to the Tittabawassee River will tend to lessen the attractive nature of warm water in the discharge vicinity (ER-0L, Sec. 5.1.3.3). In addition, fish occupying the discharge area during a plant shutdown are likely to disperse downstream with the plume as it gradually reurns to ambient temperature by mixing with cooler river water (ER-OL, Sec. 5.1.3.3). Furthermore, the references cited in Section 5.5.2.2 indicate that fish can tolerate a rapid decrease in temperature of greater than 10C (18F ) without undue harm. This is ' more than could occur at the Midland Plant, because at Midland there only will be an excess 4C (7F ) plume extending less than 30 m (100 ft) from the discharge (ER-OL, Fig. 5.1-2). For this reason alone, the staff would expect a negligible cold shock impact, even during an abrupt plant shutdown, if such should occur. l l Additionally, since the excess 4C (7F ) plume will extend less than 30 m (100 f t) downstream of the point of discharge, the number of fish able to occupy such a small area will be very small compared to the total fish population in the vicinity of the plant. Therefore, in the unlikely event that some fish in this plume would be affected by an abrupt shutdown, the impact in terms of the fish population would be negligible.
9-33 Also see State of Michigan Department of Natural Resources response No. 20-a at the end of this section.
#3. The presentation in the DES is somewhat misleading in that it implies that the landscaping program was designed for wildlife mitigative purposes.
The applicant's landscaping program was designed to improve esthetics and to provide screening, naturalization, and fog barriers. In addition, the landscaping was designed to meet zoning commitments (ER-OL, Sec. 3.1.2.3). It was not designed to mitigate construction phase impacts on wildlife, although as a secondary result of the program, a minor amount of wildlife habitat was created. The landscaping plan has been approved by the Midland Township Zoning Board of Appeals. The loss of onsite terrestrial habitat is a construction phase impact, and measures to mitigate these losses were considered during the staff's construction phase assessment. The site's total acreage is about 494 ha (1235 acres). The cooling pond's acreage is about 352 ha (880 acres). When the power block, parking lots, support buildings, lawns, and access roads are subtracted from the terrestrial portion of the site, less than half (perhaps 100-125 acres) might reasonably be considered wildlife habitat. A text change has been made to Section 5.5.1.1, second paragraph, to clarify the purpose of the landscaping program.
#4. 'The NRC staff is not aware of any studies that have demonstrated excessive bird mortality due to starvation from over-wintering at power plant cooling ponds, nor is the staff aware of any reports that have demonstrated detrimental effects on waterfowl migration due to the cumulative influence of artificially created open-water habitats. Therefore, the staff did not initiate a lengthy analysis of potential cooling pond impacts on waterfowl in Section 5.5.1.2. However, the staff did not dismiss the potential for other adverse impacts on waterfowl, and stated that miti-gative measures would be needed if such effects are observed. As a part 4
of tnis mitigative program, the applicant has contacted a Michigan Department of Natural Resources wildlife veterinarian *.o discuss the roles of State, Federal, and company representatives snould a disease incident require the implementation of the Federal Waterfowl Disease Contingency Plan. The staff believes, as does the Department of the Interior, that a waterfowl monitoring program should be made part of the Environmental Protection Plans. An appropriate text change has been made to Section 5.5.1.4. Also see State of Michigan Department of Natural Resources response No. 20-b at the end of this section.
#5. As stated in Section 5.9.4.5(5), the Midland reactor mats are founded in a clay layer which is approximately 46 m (150 f t) thick. In the event of a core-melt accident, the core-soil mass would move in a downward.
direction through this clay layer so it would be highly unlikely that contaminants would reach the surficial sands and travel to the Tittaba-wassee River. The staff, however, postulated a situation whereby the i
9-34 radioactivity released from the bottom of the reactor somehow reached the surficial sand layer and traveled to the Tittabawassee River. The cooling pond dikes extend completely around the plant site. These dikes have a continuous inspection trench / impervious cutoff that extends a minimum of two feet into the underlying impervious material except in areas where the depth to the underlying impervious material made installa-tion of a cutoff impractical. In these areas, a slurry trench cutoff was substituted. If contaminants were to reach the surficial sands as has been postulated, the dikes which surround the plant would act as a barrier and prevent contaminants from affecting the Tittabawassee River. The staff in its analysis conservatively disregarded the effects of the surrounding dikes and assumed that the contaminants from a core-melt accident would reach the river. Using a hydraulic conductivity of 1050 feet per year, an effective porosity of 0.25, and a hydraulic gradient of 0.007, a groundwater travel time of 59 years was determined from the Darcy equation. As explained in Section 5.9.4.5(5), the nuclides which would contribute practically all of the population dose from the liquid pathway in an assumed core-melt accident are Sr-90 amd Cs-137. These nuclides, however, would travel through the groundwater pathway at a much slower rate than the groundwater because of the process of sorption. To determine nuclide travel time, the staff used a distribution coefficient for 2 for Sr-90, a bulk density of 2.5, and a porosity of 0.4. The distribution coefficient used is conservative because it is much smaller than values shown in reference 68 of FES Section 5. Using these parameters, the staff determined a retardation factor of 13.5. However, as an added conservatism, the staff used a retardation factor of 9.3 from the LPGS (Ref. 61 of Sec. 5) to compute a travel time to the river for Sr-90 of 547 years. Using this travel time, the staff determined that less than 3 v 10-6 of any Sr-90 released to the ground in a core-melt accident would escape the site, as compared to 0.87 for the LPGS generic site (Ref. 61). Even less of the Cs-137 would escape because it usually has a much larger distribution coefficient than Sr-90. Responses to Comments of Mary Sinclair (MS1 4/17/82 A A-94)
#1. While it is acknowledged that final costs of construction will appreciably exceed original projections, the staff views these costs to be " Sunk Costs" which will, subject to decisions by the Public Utilities Commission or other appropriate authorities, be borne by one or more segments of the population whether or not the facility is granted an operating license. For this reason, does not consider that discussion of capital investment at the OL stage is required.
See response to Peggy E. Roth comment 4 for recent changes in NRC policy relative to items considered at the OL stage.
#2. The Commission has amended its regulations in 10 CFR 51 to exclude from consideration, at the OL stage of the licensing process, issues related to alternative sites (46 FR 28630, May 28, 1981) except under special circumstances as discussed in 10 CFR 2.758.
9-35 See Chapter 3.
- 3. See responses to Vicente Castellanos comment 8 and Mary Sinclair comment 2.
- 4. During the construction permit stage, the staff concluded that, under normal operating conditions, the small dose increment contributed by the plant to normal background radiation will be "unmeasurable and will constitute no demonstrable, meaningful risk to be balanced against the benefits of the plant" (Midland FES/CP Chapter V, March 1982). No information has surfaced, at this stage of review, that would alter the staff's conclusion drawn at the CP stage.
All contemplated radiation releases during normal operation fall within the dose design objectives of 10 CFR Part 50, Appendix I. As a result, any attempt to monetarily quantify these releases for inclusion in the cost / benefit balance would be of little value.
- 5. The term " cogeneration" is used because a portion of the excess heat produced by the Midland Plant will be used to provide process steam for the Dow Chemical Company.
- 6. All but a small fraction of the waste heat produced by the plant will be dissipated to the atmosphere by the cooling pond (see FES-CP, Sec. III);
little will be discharged to the river (see Secs. 4.2.6.2 and 5.3.2.2).
- 7. The rate of groundwater movement is extremely slow, and the movement of radionuclides in this medium is even slower due to adsorption-desorption of minerals in soil, rocks, and clay. By contrast, the drinking water pathway evaluated in the DES /FES involves release of plant liquid efflu9nts into the Tittabawassee River and ingestion of this water via the nearest drinking water intake at Bay City (as stated in Table C.5).
This is a much more direct pathway than one involving transport of radionuclides via groundwater. Thus, potential doses to individuals and to the population in the vicinity of the Midland Plant due to the groundwater pathway would be much smaller than the values listed in Table C.6 for the nearest drinking water supply. Also see response to Michigan United Conservation Clubs comment 7.
- 8. As indicated in the text change made in Section 4.2.6.1 in response to Consumers Power Co. comment 40, laundry wastes will be discharged directly to the Tittabawassee River, not to the cooling pond. Radioactive laundry wastes will not be discharged, but will be handled as other radioactive wastes (ER-OL, Sec. 3.5).
#9. Page 1: The data in DES Tables 4.1 and 4.2 (FES Tables 4.2 and 4.3) are based on Bechtel's cooling pond performance model (DES-OL, Ref. 4 of Sec. 4), not Bechtel's cooling pond fog model (Ref. 2 of Sec. 5). The Bechtel fog model is based on data from cooling ponds in Arizona and Illinois.
Paragraphs 2, 3, and 4: The statements are correct. The applicant did use the same Bechtel fog model and input data for both the CP and OL
9-36 stages. However, comment in paragraph 4 implies that the NRC did not use the DResden data it had, when, in fact, the NRC analysis in the DES-OL was based mostly on data collected at Dresden, not the Bechtel report. Paragraph 5 is not an accurate quote of Dr. Carson's remarks on Sep-tember 14, 1978. There will be some, not much, additional snow. He now expects the density and frequency of fogging near the pond (and over Gordonville Road) to be greater than was predicted in the FES-CP, for reasons given in Section 5.4.1. Icing impacts on animals, especially ducks, was discussed at the CP hearing by Dr. Lawrence Holcomb, a witness for the intervenors, not Dr. Carson. Paragraphs 6 and 7 are essentially true, except that the long plumes observed at Dresden are plumes aloft, not surface fog. Also see responses to Consumers Power Company comments 2 and 78 and Michigan Department of Natural Resources response No. 31.c to this comment.
#10. See response to Marjorie Kruger comment 7.
#11. See response to Michigan United Conservation Clubs comment 5.
#12. The Federal Register notice to which re'arence is made in this comment (45 FR 18023) discusses proposed channe to the Standards for Protection Against Radiation in 10 CFR Part 20. ,.s stated in Section 5.9.1 of the DES /FES, license requirements are specified in 10 CFR Part 50.36a that are imposed on licensees in the form of Technical Specifications on Effluents from Nuclear Power Reactors to keep releases of radioactive materials to unrestricted areas during normal operations, including expected operational occurrences, a low as is reasonably achievable (ALARA). Appendix I of 10 CFR Part 50 provides numerical guidance on dose-design objectives for LWRs to meet this ALARA requirement. The design objectives for total-body dose for all pathways of exposure are less than 1/50 of the limits specified in 10 CFR Part 20 as consistent with considerations of the health and safety of the public. The design objectives are also less than 1/10 the average background dose in the State of Michigan (108 mrems/ year), which includes internal (about 20 mrems/ year) as well as external dose contributions from natural radiation in the environment. Staff calculations of maximum individual l doses are made using data that tend to overestimate the quantities of food and water ingested by individuals, as well as inhalation rates and
,. time spent in various activities, so that the calculated doses are l larger than would actually be expected to occur. In addition, these
! calculations take into account differences among various age groups, as ! noted in Appendix C of the DES /FES. Table C.6 lists maximum calculated doses, and the member of the population (age group) to which these doses apply. The calculated doses for each unit of the Midland Plant are listed and compared to the Appendix I design objectives in Table C.7 of the DES /FES. These calculated doses are a small fraction of the allowable limits. Taking these considerations into account, the staff's position is that
9-37 it is not necessary to discuss variations in sensitivity to radioactivity by segments of the population. The risks to all individuals due to opera-tion of the Midland Plant are extremely low, as is discussed in Section 5.9.3.2 of the DES /FES.
#13. See response to Andrea K. Wilson comment letter dated March 24, 1982. #14. The contribution of tritium (H-3) to dose was taken into consideration in the calculations that were made for the DES. The amount of H-3 that is estimated to be released from a typical year of operation in liquid effluents from each Midland reactor is 440 curies (Table C.4). The dose estimates for the DES indicated that tritium resulted in a small fraction of the total dose to the whole-body and to specific organs.
It is true that H-3 behaves differently from other isotopes in that it becomes distributed in the body in a manner that is proportional to the water content for each organ. As a result, except for bone the dose that each type of organ tissue receives is about the same for a given amount of activity taken in by the body. Other isotopes generally have varying affinit:es for the different body organs. Regarding its effect on tissues, tritium is a weak (18 kev) beta emitter, therefore, its effect will be fairly local and inter-organ effects are small to negli-gible. Tritium can often be a problem from the engineering standpoint because it is chemically indistinguishable from the hydrogen in water. Therefore, it is not removed in filtering or ion-exchange systems. For this reason it is usually given special consideration, rather than because of any special behavior within the body. Except for its uniform distribution within the body, it is not expected to behave any differently from the standpoint of dose effects than any other beta emitter. Plutonium radionuclides in the plant effluents are included in the category "All others" in Table C.4. Their contribution to doses listed in Tables C.6 through C.9 is negligible.
#15 &' See response to Michigan United Conservation Clubs comment 5. #16. #17. As indicated in the text change made in response to Consumers Power Co. & comment 40, laundry wastes will be discharged to the Tittabawassee River #18. (not to the cooling pond). No radioactive wastes of any origin will be discharged to the pond (see ER-OL, Sec. 3.5). The only toxic chemical to be discharged will be hydrazine; however, as discussed in the response to A.B. Savage comment 6, the low concentration of this substance will be acceptable. Although, as indicated in the staff response to Michigan United Conservation Clubs comment 7, little contamination of groundwater under the cooling pond is expected, whatever dilution of pond-water seepage with groundwater that did occur would serve to decrease hydrazine concentrations to even lower levels.
Also see responses to Mary Sinclair comments 7 and 8.
9-38
- 19. The only pond water parameters to be controlled for operational purposes are pH in the water entering the condensers, free-chlorine content in the water leaving the condensers, and total disolved solids (TDS).
These parameters are controlled for the purpose of minimizing scaling and biological fouling of the condensers and service water system heat exchanger surfaces. Cooling of the reactor has no direct bearing on the parameters maintained as part of the cooling pond chemistry control program. While pond chemistry control requires frequent attention, the Consumers Power Company neither considers it to be a difficult task nor the raquire-ments to be rigid. All parameters have fairly wide ranges within which they can vary and still maintain river water quality when discharged. The NPDES Permit defines the discharge parameters which must be met, and by its issuance the applicant is committed to operating the Midland Plant in compliance with these limits. The DES-OL recognizes this fact in Section 4.2.6.1 by indicating that the chemicals in the cooling pond blowdown will be regulated to meet the discharge limitations of the NPDES Permit.
#20. See response to William A. Lochstet comment 1. #21. The DES /FES states that there will be no significant radioactive releases to the environment for low-level waste disposal at land-burial facilities.
No releases resulting in measurable radiological impacts to members of the public nave occurred, nor are any expected. The statement that high-level and transuranic wastes will be buried and will not be released to the biosphere is supported by Table S-3 of the Uranium Fuel Cycle Rule, 10 CFR Part 51.20 (44 FR 45362), reproduced as Table 5.9 in the FES. Data supporting the information in this table are in turn derived from NUREG-0116, " Environmental Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle." Section 5.10 of this report reflects the current status of Table S-3 to the Midland Plant licensing process. See the response to the James F. Wilson comment for additional staff position on radioactive waste disposal policy. Responses to Comments of Barbara Stamiris (BS 4/20/82 A A-101)
#1. The soils settlement issue at the Midland Plant is indeed of concern to the NRC as evidenced by the actions taken thus far in resolving the issue. This subject was discussed in the Safety Evaluation Report issued by the NRC on the Midland Plant in May 1982. Following the conclusion of the staff's review on the matter, the NRC staff intends to issue a supplement to the SER which will address resolution of the issues. The soils settlement issue is considered to be one of safety, rather than one of that environmental impact of operation of the Midland Plant, and is therefore not appropriately addressed in this report. #2. See response to Peggy E. Roth comment 4.
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#3. See response to Peggy E. Roth comment 5. #4. See response to A.B. Savage comment 4. #5. The underlying artesian aquifer, discussed in Appendix D to the 1970 SER-CP, lies approximately 200 feet below the Midland Plant and is separated from the groundwater in the shallow surficial sands by a thick clay layer. During the OM-OL hearings (pages 4291-4296 of the 8/12/81 transcript), there was some discussion concerning artesian pressure in groundwater which was found in a boring located in the surficial sands.
The essentially impervious clay layer isolates the regional aquifer from l the surficial groundwater. Therefore, artesian water pressure in the l surficial sands will not affect the regional aquifer.
#6. The staff is aware of the existing poor waste-assimilation and processing qualities of Tittabawassee River water in the vicinity of the plant and did conclude in the DES that plant chemical discharges might adversely affect future downstream water use. This conclusion of potential, unavoidable adverse impact is presented in the Abstract and Summary and Conclusions (item 4.d) and was considered in the Benefit-Cost Summary provided in Section 6. The related staff assessment is presented in Section 5.3 and draws on information discussed in Section 4.2.6.
The staff has evaluated the elimination of the cooling pond-blowdown cooling tower from the original plant design and has concluded that (1) the applicant will be able to operate the Midland Plant within the thermal limitations of the NPDES permit [see limitations in the draft NPDES permit, Appendix B], and that (2) thermal wastes discharged into the river will be assimilated rapidly, with no thermal impact on down-stream water users. See Section 5.3.2 for a discussion of these topics. See Michigan Department of Natural Resources response No. 32-a to this comment at the end of this section.
- 7. This general area is considered by the staff to be primarily a safety issue.
Buried stainless steel piping at the Midland site is not coated on the outside but is protected from corrosion by the site-wide galvanic pro-tection system. Discussions were held in 1979 between the applicant and the NRC staff on corrosion of buried piping from the condensate storage tank. The utility's consultants examined this piping, and concluded that this corrosion is a highly localized pitting present on only one side of the piping. In view of the good soil chemistry at the Midland site, it seems unlikely to the NRC staff that this pitting would have been caused by interaction between the piping and the soil prior to the activation of the galvanic protection system. Subsequently, the utility's consultants have suggested that these corrosion pits were caused by stray currents resulting from improper grounding during field welding of other components at the Midland site. The staff concurs that this is a likely explanation for the pitting attack cited. The staff is advised by the utility that selected lengths of buried stainless steel piping in the borated water storage tank injection lines will be excavated
9-40 and examined to determine the condition of the external surface of this piping before the start of operation of the plant. Portions of the condensate storage lines have already been examined during the investi-gation described in the cited exhibit. The staff concurs that this proposed inspection followed by replacement of any defective piping will ensure the integrity of these systems. The staff also concurs that the system-wide galvanic protection system now in effect will prevent any future external corrosion by the groundwater. The utility has also advised the NRC that proper grounding of field welding equipment is now in practice at the Midland site. The settling stresses should not have an effect on the corrosion behav-ior of stainless steel piping, both because of the galvanic protection system and because stainless steels are inherently resistant to stress corrosion cracking in pH 8.5 to 9 water that is low in chlorides at ambient temperatures. Should the site-wide galvanic protection system become inoperative, corrosion at hypothetical flaws in the coating on the carbon steel pipes should not be serious for periods up to at least six months, in that pitting depths should not exceed half the 1/16-inch corrosion allowance in this period of time. As noted above, the NRC staff also would not anticipate significant corrosion of Type 304 stainless steel to occur in backfill material used at Midland in the same six-month period. Also, during any period the galvanic protection system is inoperative, some protection would continue to be provided by the buried zinc anodes.
#8. The Dow pond is located about 1130 ft west of the Midland Plant. The maximum depth of water in this pond is about 11 ft. The bottom of the pond is at an elevation of about 603 ft MSL. Any seepage from this pond in an easterly direction toward the plant will be intercepted by Bullock Creek, which has a channel invert of about 593 ft MSL. This is 10 ft lower than the bottom of the Dow pond. In addition, the plant fill area is surrounded by a dike which has an impervious cutoff which extends into the underlying impervious material. Consequently, even if Bullock l Creek did not intercept seepage from the Dow pond, the dike would prevent j any seepage from moving into the plant fill area.
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#9. This comment expresses concern that the NRC does not systematically address the combined and inter related effects of a number of problems which have been identified by the applicant and the NRC during construc-tion of the Midland Plant. In addition to the actual problems encountered, the commenter states that the generic problems of B&W reactor sensitivity and TMI problems add to the total effect. The NRC has addressed these concerns in the Safety Evaluation Report issued in May 1982 on the Midland Plant and considers that document as the proper vehicle to discuss these concerns. The applicant has been required to take measures which specifically address each of the problems cited, as well as assess overall generic concerns such as the B&W sensitivity and TMI items. It is acknowledged that this comment was submitted to the NRC prior to issuance of the SER by the NRC and that the commenter therefore did not have the benefit of having read the SER at the time the comment was made.
9-41 The defects described in this comment are examples of manufacturing or construction defects that are dealt with by the NRC's Inspection anc.' Enforcement programs. Before a license to operate the plant is issued, the defects that are mentioned and others that come to light later will either be repaired or the system will be shown, by analysis, to have at least the capability (and hence the level of safety) that was assumed in the safety analyses.
#10. The staff concludes that the Midland site meets the requirements of the NRC's reactor site criteria, 10 CFR Part 100. In determining the distance from a reactor to the nearest population center, the regulation, in section 100.11(a), clearly states that: "In applying this guide, the boundary of the population center shall be determined upon consideration of population distribution. Political boundaries are not controlling in the application of this guide." The section on Site Characteristics reflected these considerations.
Response to Comment of Mary Sinclair (MS2 4/17/82 A-102) Future action relative to the S-3 Table is presently before the Commission. Pending a Commission decision on this matter, the staff does not consider it appropriate to withhold issuance of this report at this time. Responses to Comments of Wendell H. Marshall (WHM 4/7/82 A-103 - A-115)
#1. The rate of heat discharged into the cooling pond, in 8tu/hr for various plant operating conditions, is given in Tables 4.2 and 4.3. All of this heat, except about 1% or 2% discharged into the Tittabawassee River in the blowdown, will be dissipated into the atmosphere. #2. The plant consumptive water use is discussed in Section 4.2.3. The restrictions on makeup water withdrawal from Tittabwassee River for various river flow conditions are presented in Section D-1 of the FES-CP and in Table 3.4-6 of the ER-OL. Following these restrictions, it is expected that the plant makeup would not have a major effect on the river flow. #3. The cooling pond performance for various plant operating conditions is presented in Section 4.2.6.2. #4. The State of Michigan is responsible for ensuring that discharge permit monitoring provisions will be met and that plant discharges will be in compliance with applicable regulations.
See NPDES Permit in Appendix B.
#5. The temperature of the cooling pond will be monitored prior to the release of pond blowdown to the river.
See NPDES Permit in Appendix B.
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#6. See Sections 4.2.6.2 and 5.3.2.2; also see response to Wendell H. Marshall comment 4.
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#7. It is indicated in Section 1.1 that a Final Environmental Statement--
Construction Phase was issued in March 1972.
#8. The NPDES establishes limits only for nonradioactive effluents. #9. The status of certification is discussed in Section 1.2. #10. See responses to Peggy E. Roth comments 4 and 5. #11. Unresolved safety issues, as well as those issues related to the Midland Plant soils settlement problem (which is Midland-specific and not generic in nature) have been discussed in the NRC's Safety Evaluation Report issued in May 1982. Since these are safety issues and not environmental issues, they are not addressed in this report. #12. The original cooling tower design is understood to have been eliminated by the applicant because it was determined that the discharge could meet water quality standards without the additional cooling that would have been provided by the tower. #13. The comment is irrelevant since the initially proposed cooling tower will not be constructed. #14. The Code of Federal Regulations is available for use in public document rooms, including those of the Grace Dow Memorial Library in Midland and the NRC Public Document Room in Washington, D.C. See the Foreword for addresses of those facilities.
The requirements of 10 CFR 50.34a pertaining to an application for a license to operate a nuclear power reactor are summarized in the following paragraph: Each application shall include: (1) a description of the equipment and procedures for the control of gaseous and liquid effluents and for the maintenance and use of equip-ment installed in radioactive waste systems, (2) an esti-mate of the quantity of each of the principal radionuclides expected to be released annually to unrestricted areas (3) a general des ription of the provisions for packaging, storage, and ship.aent offsite of solid waste containing radioactive materials.
#15. This information is presented in Tables C.1 and C.4 of this report (as well as the DES). #16. The SER was issued on schedule in May, 1982 as NUREG-0739. Historically, the staff's Appendix I evaluation of the radwaste system which is sum-marized in the DES has relied heavily on operating experience with the i types of systems proposed for use in the plant under consideration.
9-43 Design details are generally not available at the time the DES is being prepared to permit a firm assessment of the capability of specific systems to meet the requirements of Appendix I. Consequently, it has been our practice to include the detailed evaluation of the radwaste i systems in the Safety Evaluation Report (SER).
- 17. The staff requires, and the applicant has stated in the FSAR, that the solid radioactive wastes will be transported to a licensed burial facility.
- 18. The cost of disposal is determined by the licensed operator of each burial site and the staff does not consider the cost of burial in the evaluation for the Midland DES.
- 19. See response to Michigan United Conservation Clubs comment 5.
- 20. The radiation dose design objectives of Appendix I and the calculated doses from the operation of the Midland Plant are provided in Table C.7 of this report.
- 21. The references containing the requested information are cited in Sec-tion 4.2.6.1, and are available at the public facilities discussed in the response to Wendell H. Marshall comment 14.
- 22. No significant radioactive wastes will be discharged to the cooling pond. See response to Wendell H. Marshall comment 21 regarding non-radioactive wastes.
- 23. See the subsection Cooling Water Treatment in Section 4.2.6.1.
- 24. See response to Wendell H. Marshall comment 1.
- 25. The discharge temperature of the cooling pond blowdown is discussed in detail in Section 4.2.6.2.
- 26. The Michigan water quality standards relative to thermal discharges and the staff's evaluation of thermal impact are presented in detail in Section 5.3.2.2
- 27. See response to Wendell H. Marshall comment 4.
- 28. See response to Wendell H. Marshall comment 21.
- 29. See State of Michigan Department of Natural Resources response No. 12-c.
- 30. See State of Michigan Department of Natural Resources response No. 12-d.
- 31. See State of Michigan Department of Natural Resources response No. 12-d.
- 32. Midland Plant discharges will be required to meet NPDES permit limita-tions and Michigan water quality standards. Therefore, plant operations will not significantly affect downstream water quality or biota regard-less of river-level fluctuations. The river banks currently support a
9-44 depauperate biotic community because of water-level fluctuations from upstream hydroelectric facilities, as well as because of the generally poor water quality conditions of the river. Thus, the biota inhabiting the river bank areas consist principally of species that can tolerate or adjust to fluctuating river levels. Because of this, plant operation will not significantly affect the biota along the river banks. Also see State of Michigan Department of Natural Resources response No. 12 g.
#33. The pH of the cooling pond wastewater will be controlled prior to dis-charge into the Tittabawassee River tc meet limitations specified in the NPDES permit (see Appendix B). No pH impacts are expected by the staff. #34. See response to Wendell H. Marshall comment 33. #35. As stated in Section 4.2.6.1, the staff believes that the cooling pond blowdown discharge will contain no detectable free residual chlorine.
Thus, there is little potential for formation of toxic organo-chlorines, particularly polychlorinated-biphenyls.
#36. The annual release of 135 metric tons of sodium into the ccoling pond will increase the TDS levels in the blowdown. However, as stated in Section 5.3.2.1, the plant will be operated to meet NPDES limitations such that blowdown will be permitted until the TDS limit is reached, but not beyond. Thus, the staff expects negligible impact.
Also see State of Michigan Department of Natural Resources response No. 10.
#37. See response to Wendell H. Marshall comment 21. #38. The basis for the statement indicating full vertical mixing in the Tittabawassee River is presented in Reference 5 of Section 4. #39. The Midland Plant blowdown discharge would achieve full vertical mixing at different transects in the Tittabawassee River depending upon the river flow rate and the blowdown discharge rate and temperature. See Reference 5 of Section 4 for a discussion of these interactions. #40. The river flow depth below the point of discharge varies according to the river flow conditions. Field survey data indicates that in 1977, the depth at the point of discharge was about 1.9 ft for a river flow rate of 360 cfs.
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#41. See Section 4.2.6.2. #42- #44. See response to Wendell H. Marshall comment 29. #45. As indicated in Sections 4 and 5, it will be the cooling pond blowdown discharge frequency and rate that will be regulated according to the changes in river flow, temperature, and TDS levels. The Midland Plant
9-45 is not expected to be shut down because of low river flow conditions or cooling pond temperatures. Also see State of Michigan Department of Natural Resources response No. 12 g.
- 46. Measures to control fugitive dust during construction of large industrial facilities, such as the Midland Plant, include watering, chemical treat-ment, and paving of surfaces, and restricting vehicle speed. As discussed in Sections 4.2.6.3 and 5.4.2.2, the staff expects little impact from fugitive dust during plant operation.
- 47. The radioactive elements being referred to in Section 4.3.3.1 are noble gases, iodines, particulates, carbon-14, and tritium.
- 48. See Section 4.3.4.1. The staff is unaware of applicant plans for this type of terrestrial monitoring, and does not require it because no significant terrestrial impact is expected. See Section 5.5.1.4.
- 49. The staff addressed the potential environmental impacts resulting from the use cf 345 Kv lines in Section 5.5.1.3. The staff has recently revieweu new data concerning electric field effects on human health from 345-Kv systems and presented its findings again in the Seabrook Draft Environmental Statement (NUREG-0895, May 1932). The staff con-cluded in its z.nalysis that there is no evidence to date that operation of 345 Kv systems will have adverse biological health effects on humans.
- 50. The right-of-way width varies along the transmission corridor. The width along the entire route is given in the ER-OL, Figures 3.9-2 and 3.9-3A through 3.9-3H.
- 51. Information on the clearing and proposed maintenance of the right-of-way is presented in the ER-OL, Sections 4.2 and 5.B.3.
- 52. The nearest human resident will be 200 feet from the line. The nearest expected members of the public will be persons standing directly under the lowest points of the conductor spans. Certain bird species may use parts of the transmission line towers for roosting activities.
- 53. The biotic composition along the right-of-way is described in the report
" Terrestrial Ecological Survey for the Midland Nuclear Plant, Tittaba-wassee Substation, Gary Road Substation 345 kV Transmission Right of-Way for' Consumers Power Company," by Asplundh Environmental Services, November 1979. Also see the FES-CP, Section II.F.2.
- 54. See Section 4.3.4.2. Seasonal sampling information is presented in the report " Aquatic Assessment of the Tittabawassee River in the Vicinity of Midland Michigan" prepared for Consumers Power Company by Lawler, Matusky and Skelly Engineers, May 1980.
9-46
#55. See response to Wendell H. Marshall comment 54. The biotic composition of the cooling pond will vary depending upon season, plant operating conditions, and other factors. Generally, the cooling pond will contain the more thermally and chemically tolerant species that enter from the Tittabawassee River. #56. Based on an evaluation of biological oxygen demand levels, the staff expects that there will be little potential for odor problems near the cooling pond. #57. See response to Wendell H. Marshall comment 54, and Section 4.3.4.2. #58. & See response to Wendell H. Marshall comment 29. #59. #60. The staff believes that it is unlikely that the prime farmland inundated by the cooling pond can or will be returned to its original use after plant operation ceases. See response to Peggy E. Roth comment 5. #61. See response to Wendell H. Marshall comment 50. #62. The State of Michigan has water quality regulations. See response to Wendell H. Marshall comment 4. Also see NPDES Permit in Appendix 8. #63. & See response to Wendell H. Marshall comment 29. #64. #65. The requested information is presented in detail in Section 5.3.2.2.
l Also, see response to Wendell H. Marshall comment 4.
#66. See response to Wendell H. Marshall comment 46. #67. The biota referred to are all the terrestrial biota discussed in the FES-CP, Section II.F.2. The staff related the operating characteristics of the plant to the remaining site biota in order to arrive at its assessment of no significant adverse impact. A major consideration is that once construction is completed, no major additional habitat distur-bance will occur. Experience has shown that nuclear plant operation generally has negligible impact on site terrestrial biota. #68. See response to Peggy E. Roth comment 5. #69. The applicant's monitoring program is designed to meet NRC requirements for protection of the environment (see Sec. 6.1).
9-47
#70. Thermal death of fishes follows a time / temperature relationship and is dependent on a multitude of factors, including species, size, age, and condition. The information presented in the paragraph in question does not specifically relate to the death of fishes, but to their upper pre-ferred temperatures. #71. See respons to Wendell H. Marshall comment 3. #72. See responses to Wendell H. Marshall comments 30 and 31. #73. See response to Wendell 11. Marshall comment 53. #74. The results of the staff evaluations are presented in paragraphs 2, 3, and 4 of Section 5.6.1.2. #75. See response to Wendell H. Marshall comment 54. #76. Only minor effects on the agricultural economy may sporadically occur.
The staff is unaware of any plans to provide monetary compensation to farmers experiencing losses.
#77. In its evaluation of the Midland Nuclear Plant, the staff used two years of onsite meteorological data to assess the consequences of routine and postulated accidental releases. These data were used in conservative atmospheric dispersion models that take into consideration diffusion conditions (as a function of direction) that produce high effluent con-centrations, such as temperature inversions and stable conditions accom-panied by low wind speeds. The staff believes its evaluation was suf-ficiently conservative. See Section 2.3 of the Midland SER and Appendix C of the DES for a more detailed discussion of the dispersion models. #78. Section 5.9.3.4.1 discusses preoperational radiological monitoring, and Table 5.3 summarizes the types of samples analyzed. This table has been revised for the FES.
Also see responses to U.S. Public Health Service comment 4.
#79. See response to Mark A. Handler comment. #80. The section containing the cited paragraph discussed radiological impacts on biota other than humans. As stated in this section, no cases of exposure that can be considered significant in terms of harm to biota have been detected. Preoperational radiological monitoring (Sec. 5.9.3.4.1) is performed to establish a baseline by which it will be possible to identify any changes in environmental radioactivity concentrations following the beginning of plant operation. #81. Environmental sampling was conducted at Three Mile Island, Unit 2 during the actual periods of release. See, for example, NUREG-0558, "Popula-tion Dose and Health Impact of the Accident at the Three Mile Island Nuclear Station." Sections 3.C, 5.0, and Appendix B discuss the various types of samples taken, which included gamma radiation measurements i using TLDs, airborna measurements of plume exposure, analyses of milk
9-48 samples for I-131, and collection and analyses of environmental soil, grass, surface water, and air samples in the path taken by airborne discharge.
#82. The Department of Energy (00E) has the legislative responsibility for siting, building, and operating high-level waste repositories. The DOE currently is performing field studies in several locations throughout the United States to determine potential sites for a high-level waste repository, e.g., in salt domes in Louisiana and Mississippi, in basalt formations in Hanford, Washington, in bedded salt in New Mexico, and/or in tuff formations at the Nevada test site. Based on current plans, it is expected that Final Environmental Statements will be completed for potential repository for salt domes, basalt formations, and for the Nevada test site tuff formations in the near future. Following a review of the characteristics of the potential sites in various media, a site will be selected for the first repository. The current schedules include availability of the first repository for commercial high-level wastes between 1997 and 2006.
Onsite or offsite storage would be required for high level wastes until
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such a facility becomes available. Storage facilities for high-level wastes would be designed to minimize environmental impacts over a 20-to 30 year storage period to account for possible delays in repository operation. Currently, spent fuel from nuclear power plants is stored in fuel pools. This spent fuel also requires continued storage until a high-level repository is sited, constructed, and licensed. Therefore, the spent fuel at Midland will be disposed of in a similar manner to the spent fuel which exists at other nuclear power plants. Section 5.10 of the DES discusses high- and low-level wastes. Table 5.9 provides estimated environmental effects. WASH-1248 and NUREG-0116 give further detail on radioactive waste disposal.
#83. See response to Peggy E. Roth comment 5.
Responses to Comments of the State of Michigan, Office of the Governor , (MOG 5/11/82 A-116 - A-118) ! #1. See response to Consumers Power Company comment 1 for the NRC staff's l position. Although the Michigan Department of Natural Resources (MDNR) was not asked specifically to respond to this comment, a presentation
. was made to the Michigan Environmental Review Board in their April 26, 1982, meeting by the MDNR staff.
The following points were made by the MDNR:
- a. Plant TDS mass loading represents about 2% of total river load.
9-49
- b. River concentration of TDS as measured at Freeland Bridge will not exceed Water Quality Standards of 500 mg/l average and 750 mg/l maximum as a result of TDS input from the cooling pond discharge at the Midland Plant.
- c. The " designated use" for the Tittabawassee River per R323.1100(1) of Part 5 of the Water Resources Commission (WRC) General Rules is "As a minimum, all waters of the State shall be protected for agricultural uses, navigation, industrial water supply, public water supply at the point of water intake, warm-water fish and partial body contact recreation" (emphasis added).
- d. The water quality standards of 500 mg/l average and 750 mg/l maximum for TDS were designed to protect for the most restrictive designated uses which are public and industrial water supply.
- e. Per EPA's Quality Criteria for water (Red Book), freshwater fish can tolerate TDS concentrations from 5,000 to 10,000 mg/1.
#2. References 24 and 25 in Section 5 of this report represent two Michigan State University annual reports regarding recent waterfowl use of the Midland Plant cooling pond and vicinity. While the results of these preoperational studies do not allow the prediction of future impacts with complete certainty, they do provide base data for future assessment.
The current studies on waterfowl use of the cooling pond are being conducted while the pond remains unheated. Under these circumstances, waterfowl are more likely to leave the area (continue migration) before food supplies become limited due to the onset of inclement weather. However, when the plant becomes operational and the cooling pond heated, an undetermined number of waterfowl may remain for an extended period of , time before continuing their migration. The applicant will be required to continue preoperational waterfowl monitoring and to continue a monitoring (and mitigative, if necessary) program following the start of plant operation. Also see response to Department of the Interior comment 4.
#3. See response to Michigan United Conservation Clubs comment 3. In addition, as indicated in Michigan Department of Natural Resources response No. 12-b (Table I) at the end of this section, discharge temperatures in excess of 95 F (35 C) ordinarily will not be permitted under the terms of the NPDES permit, regardless of river flow conditions.
Under some conditions, small releases (5 cfs) of water heated up to 100"F (38 C) will be permitted.
#4. See responses to Michigan United Conservation Clubs comment 3 and State of Michigan, Office of the Governor, comment 3. Taking the maximum permissible discharge temperature and fish thermal tolerance temperatures into consideration, the staff concludes that the possibility of lethal conditions for fish will be very small. #5. Appropriate text changes have been made to Section 5.4.1.
9-50 l l l
#6. See responses to Michigan United Conservation Clubs comment 3 and State of Michigan, Office of the Governor, comment 4. #7. See response to Michigan United Conservation Clubs comment 9. #8. The comment cited represents a conclusion on the part of the NRC staff relative to exposures resulting from design-basis accidents as compared to exposure resulting from normal plant operation. The sections that precede this conclusion develop the data that support this conclusion. #9. The preparation of an evacuation plan is the responsibility of State and local authorities and is normally included in the local emergency plans, not in the Environmental Statement or in the site emergency plan.
Evacuation is triggered by exceeding protective action guides which are described in the site emergency plan and in Annex Q to the Michigan Emergency Preparedness Plan. Sensitivity of the consequences of acci-dents, to various evacuation times including no evacuation, are given in Section 5.9.4.5 and Appendix F of this report. With respect to Dow Chemical Company, Dow states that it can safely shut down all of its plant processes in about one hour. Consumers Power Company is also providing training to Dow health physicists who will in turn provide basic radiation training to Dow emergency workers. The staff's preliminary assessment of the Midland Emergency Plan is given in Supplement No. 1 to the Midland SER, issued in June 1982. Also see the responses to U.S. Public Health Service comment 3 and Michigan Department of Public Health comment 3. MICHIGAN DNR RESPONSES G0 HERE
I i l l 9-51 STATE OF MICHIGAN M
#tLIAM G MILLIKEN Governor l Z"'. 'ff,, DEPARTMENT OF NATURAL RESOURCES
=ana w = a. orate, SilvtNs t ua$oN SuiLDiNG Joa= t wotre Box 30028 caaates a vcunotove LAN$iNG us 44909 Mo*ARDA TANNER Director June 25, 1982 Elinor Adensam, Chief Licensing ' ranch No. 4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
)
Re: Consumers Power Company Jackson, Michigan Midland Nuclear Power Plant NPDES Permit No. MI 0042668
Dear Ms. Adensam:
In response to your letter of May 24, 1982, attached is the Michigan Department of Natural Resources' (Departcent) responses on comments relating to NPDES permit matters received by the Nuclear Regulatory Commission (NRC) on the draft environmental statement. These responses address the comments in the ten com-ment letters transmitted to the D6partment by the NRC. The proposed NPDES permit effluent limitations are adequate to protect the desig-nated uses of the Tittabawassee River which include recreation-partial body contact; fish, wildlife, and aquatic life-intolerant fish, warmwater species; agriculture; cocaercial; water supply-industrial; and other uses. The permittees i compliance with requirements of the proposed NPDES pe mit will assure all waste-water discharges resulting from the power plant's operation will comply with Part 4, Water Quality Standards of the Michigan Water R. sources Commission's General Rules. Thank you for the opportunity to respond to these coc:ments. Sincerely, W'TER QUALITY DIVISION r A ~ C*C , Robert J. C urchaine Division Chief RJC/CMB/ REB /pla cc: R. Fobes Environmental Protection Agency T. Newell C. Bek D. Inman R. Basch WQD file
, , , , Biology file
4 9-52 4 e VINCENTE CASTELLANOS (3/26/82)
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3 .' Item 7: Violation of Michigan Water Resources Comis'sion Act The DES states that some fish and waterfowl will die as a result of cooling " pond and radioactive discharges from^ the nuclear piant into the Tittabawassee River. This is a clear violation of the Michigan Water Resources Consnission, , Act.(Seeenclosure) The DES does not state this. .
RESPONSE
The proposed temperature and chemical limitations on the cooling pond aischarge should not result in lethal effects to fish and waterfowl in or on the Tittabawassee River. The limitations on'the total combined discharge from the Midland Nuclear Power Plant are adequate: to protect the designated uses of the Tittabawassee River which ' include recreation - partial body contact. fish, wildlife, and aquatic life - intolerant fish, warm-water species; Agriculture; commercial; Water Supply - industrial; and othes uses. All wastewater discharges resulting from the power plant operr.tions will comply with Part 4. Water Quality Standards,- of the Water Resources Comission's General Rules. Therefore, the Michigan Water Resources Commission Act will not be' violated. Radioactive discharges are regulated by the U. S. Nu: lear Regulatory Commission nottheMichiganWaterResourcesCommisiion. I u
9-53 THOMAS HEARR0N (3/31/81)~
- 10. Impact on Downstream River Users Further, the degradation of water quality in the Tittabawassee River foreseen in the report is quickly glossed over. However, users of water downstream from the plant (e.g., the City of Bay City, Michigan) will be saddled with additional costs for purification, while such costs would stultify the growth and development of new industry.
RESPONSE
The State Water Quality Standards of 500 mg/l average and 750 mg/l maximum for total dissolved solids (TDS) will not be exceeded at Freeland Bridge as a result of discharge from the Midland Nuclear Power Plant. The State Water Quality Standards of 500 mg/l average and 750 mg/l maximum for TDS are designed to protect the most restrictive designated uses which are public and industrial water supply. At the 500 - 750 mg/l concentration range, intake water would not require treatment for TDS reduction; therefore, no additional water purification cost will be incurred by downstream water users. No water intakes were identified between the Midland Plant discharge and Freeland Road during the public hearing on the permit. In addition MDNR staff will be doing field studies during 1982 to define the areal extent of the TDS plume. Thus, future uses will be able to optimally locate water intakes relative to-the TDS plumes. In summary, Midland Nuclear Power Plant discharges of TDS will not impair the designated uses of the river. Therefore, future downstream users will be able to locate intakes in the river downstream of Midland.
9-54 THOMAS L. WASHINGTON (4/2/82)
- 12. State Laws In addition to our coments on the adequacy of the DES pursuant to NEPA, we have attached coments directed to the State of Michigan Department of Natural Resources (MDNR) concerning the adequacy of this document to satisfy state laws and our questions and objections relating to issuance of the draft NPDES permit.
Contrary to the statement in the DES (5.3.2.2), the Michigan Water Resources Comission (MWRC) has not " issued" a draft NPDES permit, but has merely placed such a proposed draft on public notice. Further, the DES (1.2) states:
"the staff is not aware of any potential non-NRC licensing difficulties that would significantly delay or preclude the proposed operation of the plant". I can assure you, on behalf of the MUCC, that such a sanguine observation is inaccurate. Resolution of objections to the proposed degradation of the Tittabawassee River through public review of NPDES permits may very well "significantly delay" the proposed operation of the plant.
RESPONSE
MUCC is correct: The MWRC has not " issued" a draft pennit. The draft permit was public noticed in accordance with Part 21. Wastewater Discharge Permits, of the General Rules of the Michigan Water Resources Comission. The draft permit i has undergone thorough review by the public in the form of written coments and public hearing. Compliance with the proposed NPDES permit requirements will assure that the Midland Plant discharges comply with water quality standards. The MDNR staff is not aware l of any potential non-URC water quality related issues which would significantly delay l or preclude the proposed operation of the pl'snt. l
9-55 THOMAS WASHINGTON (4/2/82) 12-b: THERMAL CHEMICAL DISCHARGE TO TITTABAWASSEE RIVER , The DES (5.5.2.2) concludes that the thermal dischar2e to the Tittabawassee River will result in " negligible impact". This is contradicted by statements by MONR fisheries biologists in review of the DES before the Michigan Environmental Review Board (3/27/82). They claim the high discharge temperatures will " kill fish" and have clear negative impact on the river.
RESPONSE
The MDNR has, subsequent to the March 22, 1982 meeting of the Michigan Environmental Revier, Board, revised the permit by including effluent temperature limitations (see Table I attached). Consumers Power Company has agreed to the revised limitations for inclusion in the NPDES permit. This table is included in the NPDES Dermit as part of the special conditions regulating thermal discharges. MDNR staff, because of .these effluent temperature limits and the temperature limits applicable after mixing in the river, are now satisfied that t;1e thennal discharge from the Midland Nuclear Power Plant will not result in lethal effects to fish in the Tittabawassee River and will comply with the State %sur Quality Standards.
9-56 ALLOWASLE DISCHARGE TEMPERATURES MIDLAt;D PLANT COOLING FC;:0 BLOUDOWN mperature stonth Ifo December 75(1)(2) January 7s(1)(2) February 75(1)(2) March 80(1)(2) April 85 I3I May 95(3)(4) June 95(3)(4) July 95 I3}I4) August 95(3)(4) September- 95(3)(4) October go(3) November 85 I3) (1) Maximum weekly average ten.:perature. (2)3n the event of a Plant shutdown, sudden termination of the discharge will not occur. Rather, the normal pond discharge criter:a will be followed until the discharge reaches 5 cfs at which time discharge may be terminated. ! 13) Maximum temperature, except as provided in Footnote 4. I*} Discharges of up to 5 cfs are permitted when discharge temperatures are greater than 950F but not greater than 1000F. No discharge is allowed when the cooling pond blowdown discharge temperature is greater than 1000F. l TABLE I j
9-57 THOMAS WASHINGTON (4/2/82) 12-c: SYNERGISTIC EFFECTS There is no discussion in the DES of the relationship between increased w'ater temperature and increased chemical reactions from other pollutants discharged by Consumers or by Dow Chemical Company. The Dow NPDES permit is being reviewed at this time by the MWRC and consideration of additive or synergistic effects of the two federal permits is an obvious omission in the DES. Dow is currently discharging, based on our estimates, over 200,000 pounds of chlorinated organic i chemicals directly into the proposed Consumers mixing zone. This includes thousands of pounds of highly toxic substances and carcinogenic chemicals.
RESPONSE
The relationship between increased discharge water temperature and increased chemical reactions due to other pollutants discharged by Consumers Power Company or Dow Chemical Company has been addressed. The MDNR utilized the data provided by Consumers Power Company (Amendment 1 to the State Discharge Permit Application dated October 20. 1978 and " Effects of Selected Toxicants and Thermal Disc 5arge Interactions on Aquatic Biota") and thermal discharge restrictions to analyze the possible synergistic effects. The MDNR concluded that the interaction of the Dow Chemical Company and Consumers Power Company discharges should not adversely affect the aquatic life in the Tittabawassee River bas'ed on the current state of knowledge on synergistic effects under these conditions; the conc'entrations of pollutants expected in the river; and the temperature requirements imposed o the Midland Nuclear Plant discharge. t
9-58 i l THOMAS WASHINGTON (4/2/82) l 12-d: RIVER BIOTA The DES (5.2.2) concludes thet. "no adverse impact on river biota is expected" due to reduced dissolved oxygen in the river. No substantiation for this conclusion is provided. I
RESPONSE
Effects of the Midland Nuclear Power Plant discharge on dissolved oxygen levels in the Tittabawassee River have been assessed by the MDNR staff. This assessment concluded that Tittabawassee River dissolved oxygen levels will remain well above the Water Quality Standard for dissolved oxygen, i.e. 5 mg/l as a daily average and no single value less than 4 mg/1. Therefore, no adverse impact on river biota in the river is anticipated from reduced dissolved oxygen. i i l
9-59 l THOMAS WASHINGTON (4/2/82) l' 12-g: MAKE-UP/ RETURN FROM LAKE HURON No mention is made of the alternative of obtaining cooling pond make-up water from Lake Huron, nor of resulting positive and negative impacts nich would ensue. No mention is made of the alternative of returning such Lake Huron waters to W Lake Huron for discharge.
RESPONSE
Based on the cooling pond operation study of 41 years of daily river flow data, Consumers Power Company can operate successfully with make-up from the Tittabawassee River without securing pond make-up water from Lake Huron. There is no need for alternative sources of pond make-up during the . life of NPDES permit. The discharges of cooling and condensing water and treated low volume wastewater to the Tittabawassee River will be restricted as necessary to comply with the State Water Quality Standards. Therefore, there is no need for constructing
-pipelines to Lake Huron to convey the treated wastewaters from the Midland Nuclear Power Plant.
4
i 9-60 l i A.B. SAVAGE (4/4/82) 14-a: UPSTREAM DAM FAILURE The Michigan State Department of Natural Resources recently reported a "high danger" of failure of the upstream dams on the Tittabawassee River at Sanford and Beaverton. Such failure of earthen dams could result in sudden flooding with damage to installations and leave the unit with inadequate cooling water.
RESPONSE
The Michigan Department of Natural Resources classified Sanford and Beaverton dams as "high hazard potential" indicating there would be a high hazard potential to riparians should the dams fail. The Michigan Department of Natural Resources did not rate these dams as structurally unsafe. In fact, these dams should withstand a 200 year flood with a low probability of failure. Therefore, there is no "high danger" of failure of dams as implied by the commenter. The dikes at the Midland Nuclear Power Plant are at elevations above the probable maximum flood combined peak flow of 262,000 cfs. Therefore, failure of Secord, e Smallwood, Edenville and Sanford dams is expected to cause no flood damage to the plant installations or affect the supply of cooling water. l
9-61 THOMAS WASHINGTON (4/2/82) 12-e: FOGGING IMPACTS FROM COOLING POND The DES (5.4.1) discuss the predicted dense fog from the cooling pond which is expected to be "quite common" in the area. However, no discussion is included of possible air and water quality impacts from interaction with radioactive gases from the plant or with chemical discharges from Dow. Will fog entrap pollutants? Will such possible concentrations fall out and increase water quality impacts in the 1ccal watershed?
RESPONSE
The MDNR will not comment on fog entrapment or fall out of airborne radioactive gasses and resultant water quality impacts in the local watershed since releases of radioactive substances are regulated by NRC. Relative to non-radiological substances, the Air Quality Division staff of MDNR analyzed the interaction of the airborne plume from the Dow hazardous waste incinerator with the fog from the Midland plant cooling pond. This analysis used conservative assumption and indicated that in the worst-case the interaction could result in a five percent increase in the airborne concentrations of the Dow incinerator emissions. Even though this analysis did not address the fallout or depositional impacts of these pollutants in the watershed. It is unlikely that the interaction of these airborne plumes would increase the water quality impacts in this watershed. In addition if water quality impacts were to occur these impacts would be expressed in changes in the river's aquatic life. These impacts therefore would likely be detected in the ecological monitoring program being conducted by the Company.
9-62 i THOMAS WASHINGTON (4/2/82) 12-f: ALTERNATIVESTOMINIMIZEWdTERQUALITYIMPACTS The DES (3.2) concludes that consideration of alternatives is not required for the operating-license stage. However, a major change from the, proposed outline in the construction permit final environmental statement, is elimination of a cooling tower.
RESPONSE
In 1976, Consumers Power Company proposed elimination of cooling towers for condenser cooling water blowdown. Consumers Power Company demonstrated to the MDNR staff that the State Water Quality Standards could be met without the blowdown cooling towers. The MDNR subsequently concurred in the elicination of blowdown cooling towers because they were not needed to meet the State Water Quality Standards. The temperature limitations in the draft permit will assure that the Water Quality Standards will be met. l i
9-63 A.B. SAVAGE (4/2/82) 14-b: HYDRAZINE l 0 Hydrazine is to be used as a scavenger. It decomposes at 329 F into ammonia and nitrogen with explosive violence. Hydrazine sulfate also decomposes explosively at 482'F into gas and sulfur. Hydrazine, like aumenia, is flammable. It boils at 235"F and freezes at 0 C (32 F). It is toxic and carcinogenic.
RESPONSE
Neither anhydrous (98% minimum concentration) hydrazine nor dihydrazine sulfate will be used at the Midland Nuclear Power Plant. Consumers Power Company proposes to use a 31 aqueous hydrazine solution which has no flash point or fire point. It it neither explosive nor flannable at this concentration. Therefore, hydrazine to be used by the Midland Plant is not explosive or flannable. Hydrazine is not expected to be discharged at concentrations that would pose
~
an unacceptable risk to human health or to the environment. The Company has been granted approval by the MDNR to use hydrazine at levels specified in the Conpany's application dated November .11,1981.
9-64 A.B. SAVAGE (4/4/82) 14-c: MUNICIPAL WATER SUPPLY There is danger of pollution of the water supply.
RESPONSE
Since release of radioactive substances to the environment is regulated by NRC, the Michigan Department of Natural Resources will not comment on " danger of pollution of the water supply" 1 by radioactive substances. i f I I
~9-65 U.S. ENVIRONMENTAL PROTECTION AGENCY (4/15/82) 16-a: WATER QUALITY IMPACTS Makeup water for the cooling system will be withdrawn from the Tittabawassee River. The intake structure design includes trash-racks and travelling screens with a 3/8 inch mesh to prevent debris from entering the cooling system.
Since the construction license was issued, newer design for intake structures have been developed. One of these designs is a fine mesh wedge-wire screen tnat is bulkhead mounted. The final EIS should discuss whether or not this design could still be installed at the site to minimize fish impingement and reduce maintenance costs at the site.
RESPONSE
Consumers Power Company installed the 3/8 inch mesh travelling screens at the river intake structure and river water was withdrawn through these screens for initial filling of the cooling pond in 1978-1979. The Company monitored fish losses curing this period and will do further; post-operational monitoring. The Michigan Water Resources Comission has tentatively determined that the location, design, construction and capacity of the Midland Plant intake structure reflects the best technology available for minimizing adverse environmental impact in accordance with Section 316(b) of the Act. During the period beginning 60 days following the start of consnercial operation of the second unit and for a period of one year, the company will be required to conduct a study to measure the numbers and species of fish impinged and entrained at the river intake structure to determine if the intake structure does comply with the requirements of Section 316(b) of the Act. One hundred twenty (120) days following completion of such study, the company will be required to submit the findings of the stpdy to the Chief of the Water Quality Division. Such study will be conducted in accordance with an approved study plan. 1
9.-@@ l l U.S. Environmental Protection Agency i 16-a: Water Quality Impacts (Response continued) I If, on the basis of the study report and applicable standards established pursuant to Section 316(b) of Public Law 92-500, the Commission determines that the intake structure does not reflect the best technology available for minimizing adverse environmental impact, it will so notify the company, specifying the reason (s) for its determination, and the company shall submit to the Chief ni the Water Quality Division, within 90 days of such notification, its plan and construction time schedule for minimizing the environmental impact of the intake structure. The Company, as part of the 316(b) report, will be requested to analyz,e the wedge-wire alternative suggested by EPA as well as other feasible new technologies that develop prior to completion of the report. The WRC will determine the best technology available pursuant to Section 316(b). t
9-67 U.S. ENVIRONMENTAL PROTECTION AGENCY (4/15/82) 16-b: ROAD SALTING Icing of the roads near the cooling pond may occur during winter months at 4 the Midland Plant. The final EIS should discuss whether or not additional salting of the roads will be required and what the resulting water quality impacts will be.
RESPONSE
Impacts of additional road salting on water quality of the receiving stream are expected to be minimal. The discharge permit;No. MI 0042668, public noticed on February 5,1982 restricts the discharge of total dissolved solids as necessary to meet the state water quality standards. The on-line computerized discharge control system will regulate the discharge of TDS to assure standards compliance at Freeland Road. Therefore, additional TDS from road salting will be accounted for and the discharges in the plant restricted such that the water quality standards are not violated.
l 9-68' 1 MICHIGAN DEPARTMENT OF PUBLIC HEALTH (4/1/82) 18: PLANT EMERGENCY PLAN 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 unfa~vorable conditions, maintenance of the sewage system could only be performed by travelling directly into the radioactive plume from the rdactors, 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,o maintenance.
.7ESPONSE The Michigan Department of Natural Resources intends to allow the use of Dow's sanitary sewage treatment system by the Midland Nuclear Power Plant so long as the limitations and conditions of the Dow NPDES permit are met. In an emergency situation with significant radioactive releases the MDNR would allow Consumers Power Company to use alternate sewage disposal methods -(pump and haul).
l l
9-69 U.S. DEPARTMEtlT OF IffTERIOR (4/13/82) 20-a: TITTABAWASSEE RIVER - Thennal Plume l Additional data should be presented in the final statement concerning the impacts from plant discharges in the river, as well as an approximation of l the actual effects to be caused by the plume in the river. More important, however, we believe the discussions about the effects of the thermal plume in the river, and to fishery resources including fish migration are unclear and fragmented. (RefertoSections 4.2.6.2. 5.3.2.2 and 5.5.2.2.) For example, paragraph's one and three on page 5-12 are contradictory in their conclusion as to whether the fisheries in the Tittabawassee River will be subjected to cold shock. Furthermore, the discussion on the subject of intermittent heated discharge into the Tittabawassee River and its effect on the fisheries during the winter season is not adequate. The following additional infonnation would be helpful in describing the effects of the thermal discharge on the fi'sheries of the Tittabawassee River: the space occupied by the plume in the temperature range which would be detrimental to fish by sudden temperature drops; the species affected, and how; and the tendency for thermal discharges to attract and concentrate fish in the plume areas during winter months.. A discussion on the percent of time the average and worst case plume sizes will occur for the coldest and warmest months indicated should also be presated along with the confidence limits for the analysis 'of pitsus configurations. RESP 0flSE As for cold shock, the pennit requires that in the event of a sudden plant / shut-down during the months of December through March the discharge will continue under normal operating procedures. The discharge may be terminated if less than 5 cfs. This limitation along with the effluent temperature limits should prevent cold shock l l
9-70 1 U.S. Department of thterior (4/13/82) l Response (continued) l problems for aquatic life. With respect to plume dimensions the largest plume (to the + 5'F isothem) will not exceed 1/4 of the surface area for a distance of 1700 feet. This plume requirement will be met by use of the on-line computerized discharge control system. The MONR believes that this is a reasonable mixing zone which along with the effluent temperature limits should adequately protect aquatic life. In addition, the permit requires the company to conduct an ecological monitoring program and plume maps to detemine the impact of plant discharges on the aquatic ecosystem of the Tittabawassee River. If, on the basis of the ecological monitoring program reports and plume maps the MDNR detemines that the discharge from the Midland Plant is adversely impacting the aquatic ecosystem, the Company wl.ll be required to reduce the adverse impacts to levels acceptable to the MWRC.
9-71 U.S. DEPARTMENT OF INTERIOR (4/13/82) 20-b: As the Midland Electric Generating Plant becomes operational, its large heated cooling pond, which supports fish, aquatic plants and possibly other forage organisms of waterfowl, could attract and hold hundreds or even thousands of birds. If these migratory birds remain after mid-January, they probably will be too weak to continue their migration, would overwinter in the pond, and be subjected to the harsh winter conditions prevalent. As a result, large numbers could succumb to starvation, disease or pond freeze-up due to plant shut-down. For the protection of this important resource, it is strongly suggested that waterfowl use and mortality be monitored at this large open water area during the winter months and made a condition in the license.
RESPONSE
The above coment is not directly NPDES pennit related. The Wildlife Division of MDNR has evaluated the potential effects of the cooling pond on waterfowl and other water related birds and animals. The primary concern of the MONR Wildlife Division is that waterfowl disease outbreak be monitored. In this regard, the Company has autopsied sick or dying waterfowl during the preoperational period as part of an Avifauna Monitoring Program and they intend to continue this program after the Plant goes on-line.
9-72 CONSUMERS POWER COMPANY (4/2/82) 26-a: The DES concludes that plant total dissolved solid (TDS) discharges may produce a small to moderate impact on existing and potential new water users. It is the CP Co. position that since Michigan Water Quality Standards for TDS will not be exceeded in the river due to plant discharges (i.e., cooling pond blowdown). Midland Plant TDS discharges have little effect on present or potential new water users downstream. The Michigan Water Qualitj Standards are established to "... protect the quality of waters for recreational purposes, public and industrial water supplies, agriculture uses, navigation and propagation of fish, other aquatic life and wildlife." In addition, the Midland Plant cooling pond blowdown discharge is controlled by an en-line, real-time computer control system designed to match pond blowdown discharges with ambient river conditions to meet Water Quality Standards.
RESPONSE
The Michigan Department of Natural Resources agrees with the commenter that the discharge limitations are adequate to protect the designated uses of the receiving stream, including public and industrial water supplies. The TDS discharge from the Midland Plant should have little effect 'on present and future water users downstream.
9-73 CONSUMERS POWER COMPANY (4/2/82) 26-b: SPECIFIC COMMENTS
RESPONSE
The Michigan Department of Natural Resources recomends that these changes be incorporated into the FES. l l l 1 1
9-74 i. l. MARY SINCLAIR (4/17/82) 31-a: SYNERGISTIC EFFECTS Failure to discuss the combination of the overlapping chemical, thermal and radioactive environments of the Dow Chemical Co. and the nuclear plants-- and the synergistic effects this will produce --a con'dition that is unique and requires special study at this site.
RESPONSE
Refer to the Michigan Department of Natural Resources response to 12-c: Synergistic Effects. 31-b: GROUN0 WATER Nhtte the DEIS states that no groundwater will be used for plant operations, (DEIS 4-2) the water that is seeping from the cooling pond will be contaminated and can affect the groundwater.
RESPONSE
An impervious clay liner under the cooling pond and the plant site and the natural soils in the area provide a protective liner which would prevent contamination of groundwater.
9-75 MARYSINCLAIR(4/17/82) 31-c: COOLING POND EFFECT The amount of water available for cooling in the pond will be lost at a l I greater rate than these data in the DEIS indicate and other resources of I cooling water may need to be provided.
RESPONSE
Refer to the MDNR response to 12-g. 31-d: BALANCING OPERATIONAL AND ENVIRONMENTAL REQUIREMENTS The DEIS also states that the water in the cooling pond will have to be maintained at a carefully controlled chemical content in order to use this water for cooling the reactors. It is not clear from the DEIS how the rigid requirements for the cooling pond water can be maintained as well as maintaining the limits of what goes into the Tittabawassee River as defined by the requested water permit.
RESPONSE
Plant circulating water will be treated with sulfuric acid and sodium hypochlorite, passed through the Units 1 and 2 condensers and returned to the cooling pond. Residual chlorine is not expected to be in the cooling pond discharge; however, to assure that residual chlorir'e will not adversely impact the aquatic environment, limitations of 0.2 mg/l average and 0.3 mg/l mafimum are specified in the permit. To. regulate sulfuric acid additions to'the cooling pond the pH of the pond discharge is limited to the range 6.0-9.0.
9-76 BARBARA STAMIRIS (undated) 32-a: WATER REQUIREMENTS "The Water Resources Commission, State of. Michigan (1960) has stated that the water requirements 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 fails to consider this finding and in fact accepts the elimination of the additional cooling capacity offered by the orginal cooling tower design.
RESPONSE
Refer to the MDNR response to 12-f and 12-g. t l
APPENDIX A. COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT CONTENTS Comment NRC Commenter Letter Response U.S. Department of Agriculture, Economics cnd Statistics Service, February 16, 1982 . . . . . . . . . . . . . . . A-2 N/A Raymond M. Donahue, Midland, MI, February 24, 1982 .... A-3 9-3 U.S. Department of Agriculture, Soil Conservation Service, February 26, 1982 . .................. A-4 N/A U.S. Department of Agriculture, Agricultural Research Service, March 2, 1982 . . . . . . . . . . . . . . . . . A-5 N/A Peggy E. Roth, Midland, MI, March 11, 1982 ...... .. A-6 9-3 Marjorie Kruger, Freeland, MI, March 11, 1982 . . . . . . . A-7 9-5 William A. Thibodeau, Saginaw, MI, March 23, 1982 . . . . . A-9 9-7 Vicente Castellanos, Freeland, MI, March 26, 1982 . . . . . A-10 9-7 Diane Hebert, Midland, MI, March 24, 1982 . . . . . . . . . A-13 9-10 Andrea K. Wilson, Midland, MI, March 24, 1982 . ...... A-16 9-10 U.S. Department of Transportation, U.S. Coast Guard, March 26, 1982 . . A-19
. .................. 9-10 Lucille M. Hallberg, Midland, MI, March 29, 1982 ..... A-20 9-11 Thomas Hearron, Saginaw, MI, March 31, 1982 . . . . . . . . A-22 9-12 State of Michigan, Department of Public Health, April 1, 1982 A-23
.. .... ............... 9-13 James F. Wilson, Midland, MI, April 1, 1982 . ....... A-26 9-15 Consumers Power Company, April 2, 1982 .......... A-27 9-15 Michigan United Conservation Clubs, Lansing, MI, April 2, 1982 A-51
.................. 9-21 Debra K. Stempek, Midland, MI, April 2, 1982 ....... A-56 9-24 William A. Lochstet, University Park, PA, April 4, 1982 . . A-59 9-24 A.B. Savage, Midland, MI, April 4, 1982 . . . . . . . . . . A-66 9-25 Sharon K. Warren, Midland, MI, April 4, 1982 ....... A-69 9-29 U.S. Environmental Protection Agency, Region V, April 5, 1982 .. .
.................. A-71 9-29 Mark A. Handler and Christine K. Handler, Midland, MI, April 4, 1982 A-74
.................. 9-30 Andrea K. Wilson, Midland, MI, April 12, 1982 . . . . . . . A-75 9-30 U.S. Department of Health and Human Services, Public Health Service, April 12, 1982 ............. A-77 9-30 U.S. Department of the Interior, Office of the Secretary, April 13, 1982 . . . . . . . . . . . . . . . . . . . . . A-79 9-32 Mary Sinclair, Midland, MI, April 17, 1982 ........ A-81 9-34 Barbara Stamiris, Freeland, MI, April 20, 1982 ...... A-95 9-38 Mary Sinclair, Midland, MI, May 7, 1982 (supplement to April 17, 1982, letter) ..~.............. A-102 9-41 Wendell H. Marshall, Mapleton Intervenors, Midland, MI, April 7, 1982 . . .
.................. A-103 9-41 State of Michigan, Office.of the Governor, May 11, 1982 . . A-116 9-48 A-1
A-2 W States Economics Washwgon. O'C' 9 Agnamare Department of and Stadsdes SeMce 20250 February 16, 1982
.1#9 9
Ms. Elinor G. Adensam, Chief s Licensing Branch No. 4 *E'Oi'. 3D C Division of Licensing 8' U.S. Nuclear Regulatory Commission 2 ' O d 'O i982emII Washington, D. C. 20555 {"Q Deer Ms. Adensas: 4,. Thank you for forwarding the material concerning the N' proposed 'iseuance of operating licenses to the Constuners Power Company for the startup and operation of the Midland Plant, Units 1 and 2, located in Midland County, Michigan. We have reviewed Docket Nos. 50-329 and 50-330 and have no comments. Sincerely, w - v et VELVAR W. DAVIS As ciate Director N ural Resource Economics Division l (0 h0 A 0
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l eg v4 Ronald W. Hernan Office of Nuclear Reactor Regulation - U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dear Sirs I wish to make the following recommendation related to the CRAFT ENVIRONMENTAL STATEMENT concerning the Midland nuclear plant license. I think that helium gas should be used for cooling the tur-bine in place of hydrogen. The practice of using hydrogen has been due to the high thermal conductivity of tne gas (7 13 as compared to air at 1). The explosive hazard of
#1 this use is exemplified by the recent hydrogen explosion at the Consumers Power Pallisades Nuclear Plant. The hydrogen there was used to cool the turbine.
Helium which has a thermal conductivity of 6.23 is an inert gas and non-flammable. Helium has long ago replaced hydrogen as the carrier gas in thermal conductivity detect- _ ors in gas chromatographs. I would appreciate your considering this suggestion. l Yours traly, ,
*W l
f uok f k Raymond M. Donahue dgf[jg iff4 RAYMOND M. DONAHUE
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A-4 Soil I A ) Unitec States Copartrnent of Conservation 1405 South Harnson Road, Room 101 l Agriculture Service East Lansing, Micnigan 48823 l I February 26, 1982 i 1
. ~ , A Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, D.C. 20555 kan Draft Environmental Statement Related to the Operation of Midland Planc, Units 1 and 2 Dear Sirst j
We have reviewed the Draft Environmental Statement related to the Operation of Midland Plant, Units 1 and 2 and we have no comment. Items concerning prime agricultural land, flooding and erosion control were discussed and reviewed in the Environmental Impact Statement for Construction, dated March,1972. Sincerely, =
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Homer R. Hilner 2 40g 1-State Conservationist g h HRH:rpc geh 28695 % N
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A-5 l United States Agricultural National Beltsville, Maryland i Department of Research Program 20705 Agriculture Service Staff p+ 8 ' , ,g March 2, 1982 , I'ECEy;gy Mr. Harold R. Denton, Director a N IS$2 m Office of Nuclear Reactor Regulation muus, g4 U.S. Nuclear Regulatory Comission 1 % Washington, D.C. 20555 m /s O
Dear Mr. Denton:
We recently received a copy of the Draft Environmental Statement related to the operation of Midland Plant, Units 1 and 2--Docket Nos. 50-329 and 50-330. Researchable problems of an agricultural nature that may arise from installation and operation of a nuclear powe;* plant would most likely be detected by the Soil Conservation Service (SCS). We are in constant comunication with the SCS and will be informed by them if we need to become involved. We request, therefore, that cur name be removed frcm the list of reviewing agencies. The following name should be deleted from the list: Carl W. Carlson Assistant Administrator Soil, Water, and Air Sciences Room 330-A U. S. Department of Agriculture Washington, D.C. 20250 Sincerely. THOMAS J. A Deputy Administrator
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A-6 1200 Sylvan Lane Midland, Mi 48640 March 11,1982 O Ronald W. Hernan, L.P. Manager 8 . y'b Office of Nuclear Reactor Reg. a .:;.p% H U.S.N.R.C. ,2*I? ,, ;.D f~n Washington D.C. 20555 r P.e : D.E.S. Midland Plant.t* nits 1 & 2. February 1982 t, 4g%g,I ,,
Dear Mr. Hernan:
< f,g,g 4 I am writing you to comment on the above as was requested in order to advise you en how some of us feel about the Nuclear Plant in Midland, Michigan:
~ The report states that the radiation risks are acceptable or that 12 chances in 100 are acceptable. My co==ent on this issue is W that many prominent health physisists and scientists report that no amounts of radiation is safe-how do,you and "only engineers",
know what will happen in our cody systems after 20 years exposure
,, even in small amounts?
For reference, please read articles by Gofman, Bertell, Caldicott.
~
It is interesting that before the current administration in gI Washington, the N.R.C. was really watching things at the Midland site, I feel you have done an about face, are you really looking out for the protection of the people, or are you a partner in 1
,, ths utility business?
y
- Evacuation: The plan is a joce. It is good only on paper, would
, you try just getting out Eastman, Saginaw or Route 10 at 4:30 daily?
~
The economic value of the com= unity..certainly business men and et tax base are aided, but the investors of the plant are to be the ones to gain most, we as ratepayers challenge you to prove to us that
; this plant will not cost us all more in the long run than coal.
" Decommissioning: Why build a plant that you have to put a fence
; pg arcund in 30 years and say, its hot den t go near it, and the ccer again charged to the rate payers, of course we could be
, dead frem cancer before the 30 years pass for me.
Please N.R.C. stop subsidi::ing nuclear power plants, maybe 7ou can calance the budget then when the utilities can go it alene then we will indeed have somecne in Washingtcn to represent us, the pecple of this country. Thank you for your eff;rts and concern. Sincerely,
, y -, i Peggy E. Rcth / e' s:031bCc70$oN23 PDR A PC 78 ',
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A-9 0%f susw Marek 23,1982
% Of Mr. Ronald w. Hernan 4
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Liscensing Plant Manager Office of Nuclear Reactor Regulation 6 u c; ..EMO UJ. Nuclear Regulatory Commission .,
-2 washington, D.C. -
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Dear Mr. Hernan,
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I as writing to question the contents of Section 511, "D ' 11 ioning", of the NRC's Preliminary Draf t Re port on the Environmenta Impact of the Midland (Michigan) .'1 ant. The statement, "The technology for decommissioning nuclear facilities is well in hand and, although technical improvements in decommissioning techniques Are to be expected, at the present time decommissioning can be performed safely and at re-seasonable cost...", is a particularly bothersome comment. what principles of syllogistic reasoning and scientific analys ts were used in determining the cost of decommissioning this facility .a " reasonable" 7 Is the public, and especially the Consumers Power ratepayer, to assume snat the cost of decammissioning equal to, and in all likelihool, in far excess of the original construction costs, is " reasonable' 7 Is the reviewer of the Preliminary Draft Report expected to endorse the assumption that "... Decommissioning costs for reactors are a small I f raction of the present-worth commissioning costs..." af ter being referred to NUREG-0586, "urart Generic Environmental Impact S tatement on Decommiss-ioning of Nuclear FacilitieW', which indicates that the Elk River, Minn-esota of plant cost 12 million more that the original construction cost 16 milliont Using the formula suggested in NUREG-0586, one can easily estimate an approximate cost of decomissioning the Midland nuclear facility as well beyond 34 billionL Construction costs to date are 43.39 billion and will undoubtedly exceed 14 billion by the time the plant goes on line in 1983 or 1984. Did the NRC factor in the impact of inflation in their estimate? Was the fact that the Midland plant is much larger that ioningthe Elk River facility and therefore will require greater decommiss-costs, included in the analysis t If so, how 13 it possible the NRC could refer to these exhorbitant costs as " reasonable" 7 as an agency of the U .S. Federal Government, the NRC is responsible to tne American people for any evidence of environmental impact saat may cause physical nuclear or economic power plant. It amrm.wnen considering the liscensing of a appears those who prepared the preliminary environmentel to carry out thisimpact draf t for the Midland nuclear facility nave failed charge. Sincerely, , w h d. A Ed w coa AILLIAM A. THIBODEAU 3245 weigi. Road h/
//O saginaw, Michigra 8203300244 820323 PDR ADOCK 0500032 D
A-10 i l March 26.1982 egi e Mr. Ronald W. Hernan ( Licensine Pro. lect Manaaer _ _, m gq3 Office of Nuclear Reactor Regulation 9
4* D U.S. Nuclear Requlators Connission Washineton. D.C. 20555
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Dear Sir:
/
wa ico In reviewine the Draft Environmental Statener.t. I have found that some vers critical areas have not been discussed. ITEM 1: Subterranean Caverns These caverns new be within 1/4 mile of the Nuclear Plant. The FSAR 2.5.1.2.5.4.1 does discuss these caverns but it left nans unanswered questions. Since there has not been specific calculations of the "foreien" natorial removed with the salt that was removed. it is possible that the caverns are 4{ { sienificant19 lareer than estinated. Also never discussed. was the vers laroe chemical storace cavern which is northWant of the nuclear plant- and , is utilized bw Dow Chemical Companw. Mr. Jeff I Kinball. a seismolonist for the NRC. was unable to j answer several questions about these caverns at the OM hearine on Julw 10.1981 in Midland. Mr. Kimball admitted to not knowine the exact location of the caverns. He did saw that the caverns were beine further investiested. Where are the results
~ of this investication? Whw hasn't remote-sensino l been used to evaluate these caverns?
ITEM 2: Fooeine of Roads Dense foe new be so severe durine the months ~ of ' November through March that visibilitw wil1 be l sienificantlw reduced to create traffic hazards. ) gg The DES on1w mentions Gordonville Road. Whw were the parallel roads (Saeinaw and Posewville) not considered. Our children in school busses and I hundreds of Dow emploween travel these roads in a j one hour time span. Who is responsible for their )
-- safetw as thew travel throveh this nuclear plant 1 created hazard? Will the dense foe crest a l vehicular hazard for the hazardous waste trucks from the Dow Chenical Companw. These trucks will df3 be turnine at Saeinaw and Salzbure road 1 82040b0469820326n POR A 05000329 (
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A-11 l l intersection at the rate of one ever 8 to 10 minutes. This will occur when full operation of Dow Chemical's 152 acre hazardous waste landfill beeins operation. ITEM 3: Foamine of Airborne Effluents Will dense foeoine phwsicalls and/or chemicallw saturate toxic effluent from the Dow Chemical gsf Compans and Dow Cornine causino then to have a short airborne fliaht? The results will be a hieher concentration of toxicitw in the Midland area. ITEM 4t Icina and Insurance Liabilitw 4t$ Should power outace occur due to icine of power __. lines. home owner insurance companies will NOT cover losses such as flooded basements. loss of perishable acods in freezers and gg refrieerators.etc. This danaae is not considered an Act of God but a man-created (nuclear plant)
, hazard. The DES does not discuss this liabilitw.
ITEM 5: Radiation Taeeine Radio-isotopes nas taa products produced at the Dow Chemical and Dow Cornine plants makina these products unacceptable for certain applications: 47 such as contact lenses (Freeland). ear. nose and breast protheses (Henlock) or elues (used for NASA pro.iects). No evaluation of the radioactive impact on the 152 acre Salzbura hazardous landfill has been addressed bw the DES. ITEM 6: Propertw Devaluation It is recoenized that the nuclear plant will impact propertw value in the area resultina in the loss of
#6b thousands of dollars for individual residences near the nuclear plant. The DES nealects this impact complete 19.
ITEM 7: Violation of Michiaan Water Resource Connission Act The DES states that some fish and waterfowl will die as a result of coolina pond and radioactive discharaes from the nuclear plant into the 49 Tittabawasssee River. This is a clear violation of the Michiean Water Resource Connission Act. (See enclosure) The DES does not discuss this.
A-12 1 ITEM 8: Risk Assesnent ! The DES fails to make a cunviative risk assessment of the nuclear plant with the followine established environmental risks: qf/(> Two chemical companies Four hazardous waste landfills Numerous chemical and brine disposal wells Three chemical storace caverns Open hazardous waste storace area (inside Dow complex) Two recoenized earth favits In conclusion. I stronelw uree the NRC and the Michioan DNR to connence. immediatelw. hearines on the Draft Enviornmental Statement. I also would appreciate wour response to nw questions. neerelw. D\ 9. Vicente aste11anos Hazardous Waste Spokesman Ineersoll Township-Midland Countu 4823 S. Saeinaw Freeland. MI 48623
I i A-13
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g iN, To: Ronald '4 Hernan j2 z' .W$ Licensing Project Manazer . 'l 3 Office of Nucles: ?.ezulate:-r Cc=13si0n
;c, g" ylr; 4ashington, D.C. ra" z ,
N . x ,, J/ This letter is a response to the NBC's Draf t Environmen Statement (DES), that attempts to show cost effectiveness for the Midland Nuclear Plant. It is a clear example of lobbying for the utility industry, by an organization that was originally set-up to protect the interests of the public. This report shows us that we can no longer rely on the NRC to protect our safety or our economic well-being. Any citi,in with the smallest amount of knowledge of the Midland Nuclear P. tnt, and Michigan's energy needs, will immediately see that the DES comes very,close to being a fairy tale. First of all Consumers Pcwer's electric demand has been dras-tically reduced, mostly due to the effectiveness of conservation efforts. Mr. Gordon Heins, of Consumers Power Co. , testified under oath in 1977 that his company had 37% excess electrical capacity at that time. Residential growth declined to 1.9% during the 1973-79 period. i, This was down from 7.3% (1965-73). Commercial sales declined to 2.9% (1973-79) down from 9 55 (1965-73). Industrial demand declined to 2.3% (1973-79) down from 5.15 (1965-73).1 These figures are fairly representative of electric demand throughout the country. As a result many utilities have scrapped plans, or cancelled construction, of nuclear plants. Nationwide, the utility industry has twice as much generating capacity in reserve as thg back-up of 15-20% that is deemed a pmdent margin of safety. The cost effectiveness figures shown for opemting the Midland Nuclear Plant, in the DES, are absurd. Firstly, the 58% per-romance capacity for a five year period is unrealistic, con-sidering the background of Consumers Power Co. Their Palasades (00%
- 1. Long Term Electric Forecast, Consumers Power Co. 1981-1998.
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- 2. New York Times, b 6-80 ! O 8204060026 820324 PDR ADOCK 05000329 D PDR f
A-14 Nuclear Plant in South Haven has consistently operated below aversge. James Keppler, region III NHC director, also stated that: "It (Palasades) ranks below average in ter-us of compl-12nce snd pr0blems that car. te attributed to people. " ?.a t sane inept reanagement group will be operating the Midland clant.
'"~ Already the NRC has found the Midland plant to be weak in three g different areas:
- 1. Quality assurance, including managsment and training;
- 2. Substructures and foundations; 3 Safety related components.
"The DES report has also chosen to ignore constmetion costs.
Can we seriously ignore 3 39 billion dollars, that we, as ratepayers, will be held financially responsible for? Also, a report by the Energy Dept., shows that if the massive pl government subsidies were included in the cost of nuclear energy, it would operate at 4.7 cents per Kilowatt hour, making (COMg' it even more costly than oil-fired electricity, the most expensive power available, which currently runs 3 75 cents per Kilcwatt hour.3 A report by Charles Komanoff, Komanoff Energy Associates, i clearly outlines the manipulation of facts and figuMs by the nuclear industry, designed to show cost effectiveness for nuclear energy. Step by step, Mr. Komanoff is able to show how the Atomic Industrial Forum (AIF) was able to come up with its totally unrealistic cost figures in their 1979 survey. The AIF survey,
- 1. failed to make sufficient allowance for waste and decommissioning;
- 2. excluded lower cost coal plants operated by the country's two largest coal-burning utilities (American Electric Power and TVA);
3 penalized other coal-fired plants for being used below their potential capacity, due to excess genersting capacity. Moreover, the AIF omitted the r aclear plants eith the highest construction costs (21 omitted tactors) . The 21 omitted reactors cost an average of 60% more to construct, and produced 19% less electricity per unit of capacity than the 39 reactors included in the AIF survey. 3 Midland Daily News (12-26-80) l _. _ _ _ _ _ _ . __ ._. . _ . ._. .. __ . _ _
A-15
-3 Are we supposed to si: back and accept this kind of manipulative study?
Komanoff concludes in his 1979 report, " Nuclear Power Costs; Past, Present, Future" that;
- 1. The capital costs of nuclear pltnts completed 00 day avarsgs approximately 13-2 -imes enose of new ecal planta, causing total generating costs to be slightly higher for new nuclear plants enan for coal;
- 2. Based on trends prior to the Three Mile Island accident capital costs for plants undertaken today will be twice as high for nuclear as for coal with scrubbers, so that nuclear generating costs will average 60%
more than coal. By the end of 1978 the " typical" new nuclear plant was 49% gl more ex and 90%costlier pensive than to build thanplant a coal a new coal plant, without with a scrubber, a scrubber. i ho Michigan's economy cannot stand the burden of the rate increases I that will be necessary for the construction and operation of the Midland Nuclear Plant. (o.+- last so psrcent) Many Michigan companies have already cited high energy costs in our state as a reason for not expanding,and perhaps leaving Michigan altogether. We surely cannot believe that with another large rate increase on the horizon, we will ennence the business clinate of Michigan. A strong program of conservation in our state is the only sane way of keeping the business we have now, and eventually attmet-ing new business. Geneml Public Utilities (cwners of Three Mile Island) recently scrapped plans for three large power plants. By this action, they hope to save customers 1.2 billion dollars over the next 30 years. They have instead proposed an electricity ccuservation and allocation plan, putting their energy costs at $250.00 per Kilowatt , as opposed to 81,750.00 per Kilowatt, it they had proceeded with the plants. l This plan will also save an estimated 200 million barrels of l imported oil, cut projteted load growth in half, and of course I greatly benefit the mte payer. The bunien of cost for the Midland plant is on the ratepayer. Therefore the decisions being made about it's future should in part, also rest with us.
A-15n.
.u.
Consumers Power Company will profit, unile we pay, even if tne a Midland plant does not provide a reliable source of electricity. Fl The self interest of this company has been apparent for many yea rs. It could be the final blow to Michigan's sagging economy. (Con $.) ! Ot'se: stron:17 13 1 :iti.:an if "iiland, 2nd Michi.pn, '.c the continsied const:vction of the ver/ costly and unnecessarf Midland Oiucles? Plant. Sincerely, lj t.r fi.c Jd64 LG Diane Hebert 2505 E. Sugnet Midland, MI 48640
A-16 MMcK 2+,M4L
.In respc.gse tc the Draft 2:viron= ental Statement related -
the gperaticn cf Midland Plant, Unitz 1 and 2, issued Fe' . , 1982. Specifically, R diologic21 I= pacts: p',
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.. - c Page 3-1 of the Draft nviron= ental State =ent (3 a _e -ol rel ted to the eparation of tidland Fl:nt, Units-1 an. I, **,,
- - . . a issued February 1982 states that ir, the abc.ence of anyvisnifi-cant environ ental cr E22ety cbjection, che decisics (th-I,ermit operation of the Eidland Flant) is an ecencnic cne. -
There is new evidence that car inv2111 ate the cenclatiens-
'of the radiologic 21 inpact sectics o'f the 325. "The risk estinates and r:liation tcxicity levelt ,ay be underctated and there cay be, af ter all, significant environment;l and, safety objections.'
The NRC staff used se:2 tic (cancer) 2nd senetic risk esti=ators b2 sci en wilely acceptel scientific infor ation. Specifically, the staff's esti: tes are based on infer:ation co: piled by the Niticnal Acale=y cf Science'c Advicery Oc=mittee en the 31clogical 3'ffectc of Ionizins Radiation (33IR I, 1972)' (325 ;. 5-237 The values used for risk ectinators are said to be consistent'with the reco: endatiens cf coveral other recogni:ed , ridiction protection organi: tiens; specifically, the Inter-2.ational Cc::itsien cf Radiological Frctection (IORI), the National Council en Radiation Frotection and Eeasureuent (I.CRF), the 'Hational Academy of Sciences 22IR III,1960 Repcrt (an update on BEIR I), and the United Nations Scientific Co==ittee on the Effects of Ato:ic Radiation (UI;5CEAR). The cancer scrtality data from Hiroshi:n are considered the =ost valuable in the world. In an attempt to define radiation risks these data have been the basis for the nidely recognized 3EIR III report however, there is recent evidence frc= research beins initiated by phycicicts William Locre ar.d Idgar %endelsohn at the Lawrence Liver =cre National Laboratory in 0:11fornia and frc: work at the 02k Ridge national Laboratory in Tennessee that previcus calculatiens on radiation data frc= the atocic blasts at Hiroshina and , CLO O . Nagasaki are in error.
' c B203290360 820324 PDR ADOCM 05000329 D ppg
A-17 2
',Until recent conths it was thou3ht that the Siroshi=a blast produced a high LET (neutron)' radiation. New evidence :
now indicates that nost of the cancer caused by these do=bs
- .came from low L7t., (gamma) radiction, considered less dan.i;ercus than the high L3T forn. Since the effects on 5" an. health fron the blast renain the c
- =e, one cuct cenclude that the gr.nna rays were more toxic than had been thcucht. ,,
tost signific:.nt is that those studies will have a direct bearing on the conclusions.of health ef(gets frc: nuclear reactors, which are gn=ca ray en-itters. , Edward Radford, an epideniologist at the universiti of Pittsburgh and the committee chairman for the BEIR III report considers the 3EIR 1980 report obsolete and expects that the probabilities it gives for the risk of dying of cancer after expceure to ga--a radiation will be Scubled. Likewise, he thinks the probabilities for contracting any forn of, cancer after irrad,iaticn will be quadrupled'(S,cience, ray 22, 1981). The credibility of 3 IR report is in serica jeopardy and 120 scientists who cet last Septe ber 1951 have greed that dose estimates should be revised in lig'qt of men research done at Liversore, two other national laboratorios(,and two private censulting fir =s (Science, Octcber 2, 1981). .It should also be ncted that several radiation prctection organications cited as references in the D25 are also re-evaluating their assesssents based on these current findings. Sheuld the Liver:cre revision be fcund correct, the modified version of the BEIR III report would nc longer be valid (3ulletin of Atomic Scientists, June-July 1981). Hence, the basis of the public health assess =ents as stated in the DES wculd also be considered invalid. In light of this new informatien, the issuance cf an operating license should be suspenled. A re-appraisal of all radiation data conpiled in the 33S seems only a'; pre;riste, fcr public health concerns should be -arc cunt to granting a nuclear reacter operating license.
i A-13 l 3 Ccnsidering the continued updates and revisient an
" accepted radiation deze standards" it seens illogical to ,
continue, at the current rate, developnent cf an industry that I cannot keep pace riith all the updating. l c Andrea K. Wilson b l A' d d it- [h/f W 3/C 6 blueen 4&ULnd :. ~~M9aufj& @b@. li 1
A-19
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1.15069.m in r&rd Commencant wasnmoton. OC 20593 g7 unded States Coast Gwara Staff Symoot: G-WS/ll
- 202-426-2262 UnNed States Coast Guard MN x r
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i~, . Ms. Elinor G. Adenssa Chief f Licensing Branch #4 -( .' Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -
Dear Ms. Adensas:
This is in response to your letter of 12 February 1982 concerning the Draft Environmental Statement related to the operation of Midland Plant Units 1 and 2. The concerned operating administrations and staff of the Department of Transportation have reviewed the material submitted. The Federal Righway Administration had the following comments to offer:
"The proposed plant is located on the immediate west side of the Tittabawassee River opposite Saginaw Road which generally parallels the east side of the river in the vicinity of the plant. Saginaw Road is on the Federal-sid Urban System. Salzburg Road, also on the east side of the river and on the Federal-aid Urban System, intersects Saginaw Road immediately southeast of the railroad bridge crossing the river from the plan t.
From the information provided on page 5-6, 7 and 8 the area immediately east of the river could be affected by dense fog or ice from the operation of the cooling ponds. We recommend the applicant coordinate with the local road authority on the proposed mitigation and fog monitoring prog' ram addressed on page 5-8. It may be desirable to install some of these measures in advance of plant operations to reduce anticipated hazards (signs, centerline or edge lights) until the results of monitoring are known." The opportunity to review the draft statement is appreciated. l Sincerely, (CO} JAMES F. VEATCH l Acting Chief, Ports and Waterways l Planning Staff /O By direction i
A-20
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.icensing ?roject l'anager Cffi:2 f Nue13 r 2enet:r T.a- thti:n '
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c.0. ..uclear Ee: alnte:/ C0=13sien P 7.esnin-ten, M . 2C G J u V-
Dear W. Uernan:
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(2 I risu to rescond to tne D aft Environcental Statement. ::: ' dr
- J In Snorn testi=eny before he Atomic Energr Co=cission Iicens 'f3 oar . Tard Epstein, world renown reteorologist from tne University of Micnifunrtestified JW/ tnat routine releases of radienctivity f.va tne tidland nuclear riants would be entra ped in tne for;ging frem tue cooling pond and would rain cutand i:e out in the im=ediate area predicing far nightr levels of concentrations of radio-traclidss.
Uany of tnese radio-rniclices are long-lind. 7ne7 rill enter tne rater sned and,
# 2. tuersfore, tne Tittabanassee River and Bulloc'c Creek, in =uen nigner concentrations tnan Consumer's Power nas indicated, die to his ;iahway of concentr: tion of effluents.
In a st-te=enf, to tne :lew 'ork Times, a number of medical doctor's associated nita tne Pn7sicians for Social Reseensibility nave ra:ned about -tat they call dangerous cyks about nuclear tower. Their statement includes tue following co==ents: 31 clear plants routinely release radioactive effluents into tue air and water. Tnese may contain elements hat concentrate in tue bones, r:1seles, tuyroid and otner organs. The magnitude of tne healta ris:q is inesti=able since it =ay take ti=e for tue seterial to circulate broup tne food I enain before nu=an exposurs reacnes significant levels. Ianke=ias :ould not tuen appear for at least five :. ore years; other cancers,15 to 30 years, and latent genetic hage =ignt only becoce manifest generations hence.
" Fog plumes un to five siles long nave been observed at the D esden pend, rib =crse predictions for 1:idland.
In Sentember 1978, James Carson, reteorologist from tue Argocne Natienal Iaboratories, met witu local tidland officials.to specifically warn tues of tne far = ore severe fogging and icing free tue cooling nond tuat could be anticipated tuan was origional17 M3 described in be idland Envirorn= ental Impact Statement of tarea 1972. His information indicated tuat tue fogging and icing from tne nend and he subsequent entrancent of radio-nuclides would be even greater tuan n. Epstein indicated. Ja=es Car:en stated tuat tue pecole in tue area of tue !:idind conling nond would be h subjected to uundreds of nours of stea= fog every winter. Dica additional snow will be generated in the area and icing would occur on ucces, trses and sni=als.
~
(C>O) his observations ere based en dat from tne 2esden ecoling tend in Illinois. (3eentel nad used data co--iled at an irisona cooling pond). Tuat 1.fo:rztion was not acclicable to a cooling tend in tue : lid:sst, according to Carsen. /O 8204060021 0329 PDR ADOCM O 0329 D pgg
A-21 Carson inricated ? r2ch reater entant Of the severity of the fon-in:: -roblen in the vicinity of the :lidland cooling pend then an7ene had anticipated.
~ha 2reeden end cove c 1,275 acres a .d ::ns 90 decrees hotter than the .anbient te:rcrature. The l'icland pond cov4rs "iC acres and willde even hotter than at Tesden. Ihnse fog dL be 72ite t.cc cn over and near the :*idland tend d:rin:; '
M _ the cooler eart of the year. (Noveder through !! arch).
- (,#Ii*) Ihring these fogc7 teriods, visibility could be sufficiently redaced to create traffic hazzards. Frequent eeriods of dense fog will ree,uire roads in the vicinity of, and esrecian7 Cordenville Road to be very well narked. Ocrdenville F.oad nay hLve to be widened to allon core caneuverability, flashing licts rxt have to be gg installed to wam notorists that they are entering a heavy for; area where zero visibility was -casible.
Pon Cook. resident insnecter at the l'icland clant said he had visited the 2ssden _ area daring fogging .:nd the residents called the road near the pend,"suicit's road.**
#6[, This eccessive evacuatica fo -ine and precadares, icing as well as,coneitica the renoval could have an and deliver 7 ofaererse effect radicactive en energency rastas.
Creps could be con += hated. g { Tne o.sr:**rn Of Tri-City Air : ort eculd be affected. In ::;7 c-inion, this problem area has not been properly addreseed as yet even thou;;h F the IRC has recognized the ecoling mend situatien as an adverse conditien in the gg g IES. The !30 doesn't even plan to neniter Censumer's preposed solutien. It is hard to believe that tha :30 is takin; this restensilility so lichtl7 in vier of the fact that they are rescensible for the health and safety of the residents of Saginaw, Jay City,1:idh nd and the surrcunding areas. I reuld think that the ID.C wculd be nest concerned about these matters and vrould folicw un on Consumer's action. I then:;ht the !SC was in the erecess . ef getting it's act together. I neuld ap reciate cur rescense to these nai,ters. Sinecrely, Incille ::. Hallber-
A-22 4579 S. Washington Saginaw MI 48601 March 31, 1983 Ronald W. Me: nan
*icensing Plant 3anager !
Office of Nuclear Reacor Regulation U.S. Nuclear Regulatory Consission Wasnington D.C. 2c555 Oear Mr. Hernan! I have read the NRC staff's Draft Environmental Statement on the Midland Nuclear Plant. I am shocked and appalled at the report's questionable methodology, its narrow focus and its minimizing of the enviromental consequences of a nuclear plant in Midized. I make reference to the following areas Economics: the report considers only generating costs, ignoring the enozzous construction costs which ratepayers such as I will have to be responsible for. Using such a methodology, one would also conclude that buying a diesel-powered Mercedes is cheaper than huying a Chevette because the Mercedes gets better gas mileage. Further, the report con; ares the cost of nuclear-generated electricity with that of purchased g( power--normally the most expensive electricity--while specifically not considering the economics of converting the plant to coal or other fuels. Finally, the NRC staff apparently accepts Consumers Power's assertion that an excess generating capacity of 23 per cent is necessary. On the other hand, Standarti and Poor recently downgraded Consumer's bond rating, precisely because of a fear that Consumers was building too much i generating capacity. ! Environmental inpactst. the report's section on radiological impacts is based on data which is questionsble at best and outdated at worst
#2 more recent studies suggest that the present allowable radiation limits tre too high to bring about the saf sty desired. Further, the degradation
~
of water quality in the Tittabawassee River foreseen in the report is uickly glossed ober. However, users of water downstrean from the plant e.g. , the city of Bay City, Michigan) will be edled with additional b costs for purification, idtile such costs could stultify the growth and development of new industry. Finally, the findings on effects to pg waterfowl are tased on pure speculation, while the section on anticipated fogging from the plant's cobling pond underestimates the seriousness of g the matters area school buses and trucks carrying hazardous wastes from
,Dow Chemical Company will be nainsf the roads affected.
All in all, the report is shoddy and inadequate. I sak, as a concerned citizen living downwind and downstrana from the plant, that the NEC reconsider the position presented in the report. To this end, I ask for public hearings in Midland, so that those citizens most directly affected by the plant may more aanily participate. '
- - (, , Sincerely yours, N,
, A
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R -m E32:-.j\ H - H Q%dm- ,a p Jn '.;.gy? r @l Thomas Hearron
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9204060092 820331 / PDR ADOCK 05000329 D PDR hN '.'n N
A-23 STATE OF MICHIGAN w
&' l WILUAM G. MILLIKEN. Governor DEPARTMENT OF PUBLIC HEALTH g, 3500 N. LOGAN [I' P O. 80X 30035. LANSihG. MouGAN 40000 /., r -
Bailus Walker, Jr. , Ph.D., M.P.H. '
./ .f Director
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s-- y> + -- April 1, 1982 6 e< 7 U. S. Nuclear Regulatory Comission 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 Comission Safety Evaluation Report (SER), scheduled for completion in May 1982, and we will review those aspects of the plant when the SER is received. Coments 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.
M 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 nomally 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 l cool C6 i 8204120137 820401 DR ADOCK Oscoo3;9 PCR
A-24 U. S. Nuclear Regulatory Conrnission April 1, 1982 Page 2 system as the heat source. Since Dow produces aspirin and other chemical products which are consumed by the public, it is imperative 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. M 3. Plant Sitino and Plant Emeroency plan - According to the JES 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 dirsctly 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 2 choice of , i (1) evacuation of the entire Dow property with loss of equipment and, possibly, with loss of control of plant processcs that could be dangerous, or (2) evacuation of all Dow personnel except those essential for Isafe shutdown. In the latter case radiation exposures could be excessive. Dow has pledged to evacuate upon 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 hours after the initiation of evacuation. Although Dow has had an evacuation plan for years, it is being revised especially for a ruclear 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 perfonned by traveling directly into the rattoactive plume from the Reactors, less than 1/3 mile away. We celieve that' this sewage system should not be used during a major Midland Plant emergency, unless it can be accomplished with no maintenance.
A-25 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 g 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.
N& 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, i leaking only at the regulatory leakage rate, in spite of the fact that the containment could be breeched and ntanerous valve leakage problems have been experienced by operating plants. Thank you for the opportunity for consnent. Sincerely, qhtAl t Bailus Walker, Jr. , Ph.D. , M.P.H. Director l l l I i
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A-27 C0aStim8f3 FP0vver C.: Campany Generea OMises: 184s weet Parassa l'Ioas, Jackson, MI 492ot * (81717sto463 Jernes W cook v,. ~,s,. , - ~,,,,o.,. s.4 cessr.uctie. April 2, 1982 Darrell G Eisenhut, Director Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND PROJECT MIDLAND DOCKET NOS 50-329, 50-330 DES-OL COMMENTS FILE: 0505.5 SERIAL: 16594 In response to the February 8,1982 letter from Robert L Tedesco, Assistant Director for Licensing, pursuant to IC CFR 51.25, attached is one copy of Consumers Power Company comments on: Draft Environmental Statement (NUREG-0537), l Related to the Operation of Midland Plant Units 1 and 2 Docket Nos 50-329 and 50-330 February 1982. These comments are being submitted within the specified comment period which expires on April 5, 1982. We believe the Draft Environmental Statement (DES) adequately supports the Staff's position that "...af ter weighing the environmental, economic, technical, and other benefits against environmental and economic costs and af ter considering available alternatives at the operating license stage ...the action called for under NEPA and 10 CFR Part 21 is the issuance of operating licenses for Midland Plant Units 1 and 2... ." We do, however, have comments which we believe clarify certain points contained in the DES and generally further support the overwhelming benefita of the Midland Plant. The following major comments concerning the DES are presented for your consideration. Corresponding specific revisions to the DES text as well as additional detailed comments on the document are provided by attachment for KRC consideration.
- 1. The DES concludes that plant total dissolved solid (TDS) discharges may produce a small to moderate impact on existing and potential new water gg users. It is the CP Co position that since Michigan Water Quality Standards for TDS will not b'e exceeded in the river due to plant discharges (ie, cooling pond blowdown), Midland Plant TDS discharges will have little effect on present or potential new water users downstream.
oc0382-0833a131 1
l l l A-28 I 2 i
-The Michigan Water Quality Standards are established to "... protect the quality of waters for recreational purposes, public and industrial water , supplies, agriculture uses, navigation and propagation of fish, other
!- aquatic life and wildlife." In addition, the Midland Plant cooling pond blowdown discharge is controlled by an on-line, real-time computer control systes designed to match pond blowdown discharges with ambient river _ conditions to meet Water Quality Standards.
~ 2. The DES concludes that cooling pond operation will result in a moderate adverse impact on road traffic adjacent to the pond due to fog and icing.
j The DES also states that the existing state-of-the-art does not permit a i more precise assessment than the comparative assessment provided within the DES. Furthermore, it is recommended that the Applicant initiate a fog i monitoring program for the roads in the immediate area of the pond. CP Co concurs that actual frequency, duration, and extent of fog and icing due-to pond operation cannot be accurately predicted by present models _although su'ch models are useful for general prediction of such factors.
- 42. To better define actual conditions and to supplement model studies, CP Co^
initiated (in 1979) a two year preoperational fog and ice monitoring program to establish a baseline for determining actual operational effects of the pond. This monitoring commitment was made in Section 6.1.3.1.8 of the Environmental Report (ER). A two-year operational fog and ice 1 ' monitoring program will be initiated after commercial operation of Unit 2 to assess the actual effects of cooling pond operation. This socitoring commitment was made in Section 6.2.3.1.2 of the ER. Additionally, CP Co , has committed in ER Section 5.1.4.2 to take actions to mitigate the effects of increased incidence of fogging and icing due to plant l operation. r-
~ 3. CP Co has recently revised plant and production cost data based on latest y cost forecasts. This information is provided in the attached detailed comments on the cost-benefit analysis.
' Please consider these comments and the attached detailed comments for l incorporation into the Final Environmental Statement.
If you have any questions on these comments, please contact David A Sommers at ] (517) 788-1128. [1 o l / fy ll 7 ;;< Zw &
! JWC/RFG/fas i
i CC RJCook, Midland Resident Inspector i
- DBMiller, Midland Construction (3)
RWHuston, Washington l7 I l 1 oc0382-0833a131 2 h a __,__,4 __ _ _ . . - . . , . _ - . . , _ _ - _ . _ . ,
A-29 CONSUMERS P0WER COMPANY COMMENTS ON MIDLAND DES NUREG-0537 The following specific comments are provided for NRC consideration. These comments are presented by Chapter and Section of the DES-OL with designation of paragraph within the Section, sentence, table, and page number as appropriate. The basis for each of these comments is provided as necessary or appropriate. The bases for comments on the ABSTRACT and
SUMMARY
and CONSLUSIONS sections are provided within the associated detailed comments on the main body of the DES. SPECIFIC COMMENTS ABSTRACT
' Pora 1, Sentence 5, (p iii)
Delete " Chemical discharges. . . .of the plant's NPDES permit." M Insert - Wastewater discharges should have a negligible effect on Tittabawassee River water quality since Michigan Water Quality Standards and NPDES Permit limits will not be exceeded as a result of Plant discharges.
SUMMARY
AND CONCLUSIONS Para 4.d, Sentence 1 (p vi) Delete ..."to moderate impacts on existing and potential new"... gy Insert - effects on new (if any) Para 4.e, Sentence 1 (p vi) Delete " Thermal wastes discharged"... 4y Insert - The elevated temperature in the cooling pond blowdown Para 4.g, Sentence 2 (p vi)
~
Delete "... fogging is likely to have an adverse impact"... d7 Insert - fogging may have an effect Para 4.h, Sentence 1 (p vii) Change to- The cooling pond will attract WATERF0WL; HOWEVER, THE IMPACTS Wb ON WATERF0WL WILL BE SMALL IN TERMS OF POPULATION EFFECTS. Para 4.1, Sentence 1 (p vii)
~
Delete - ..."are expected to"... Insert - will miO382-0808a131 l l l
i A.30 2
- 1. INTRODUCTION Para 3. Sentence 2 (p 1-1)
- # fg) Change to- 505 MWe
<- Basis - gross nameplate rating i
, Section 1.1 ADMINISTRATIVE HISTORY Para 2, Sentence 2 (p 1-1) - The footnote for this sentence also should 4F/f indicate that the ER-OL has been updated and revised 13 times through December 1981.
~
Section 1.2 PERMITS AND LICENSES
, Para 1, Sentence 1 (p 1-2) gj Delete - ... "as of March 1978", ...
Insert - as amended through Revision 10, November 1979
- 2. PURPOSE AND NEED FOR ACTION
~
All Sections in this Chapter The Nuclear Regulatory Commission has approved a rulemaking (47 FR i s'/y 12940, March 26, 1982) which removes consideration of need for power issues and alternative energy issues from operating license proceedings. Therefore, all data and discussion in the DES on these issues should be removed and replaced by a reference to the Commission's Rulemaking action. Section 2.1 RESUME Para 1, Sentence 2 (p 2-1)
<!4 Change to - 505 MWe Section 2.2 PRODUCTION COSTS Para 2, Sentence 4 (p 2-11 # ff Comment - Based on a recent change in Dow low pressure steam reservation to 1800 Mlb/hr and the gross nameplate rating of 1357 MWe, an average annual capacity factor of 54% should be used from 1984 through 1988. See note (a) to revised Table 2.1.
miO382-0808a131
A-31 3 Para 2, Sentence 7 (p 2-2) Comment - Based on the Dow change in low presure steam reservation Y/dp and the Applicant's December 14, 1981 load forecast revision, Applicant now estimates that replacement energy for Midland Units would cost 4.9C/kWh in 1984 Table 2.1 (p 2-3) Applicant has revised its estimates of production costs for Midland 1
& 2 and for replacement power. These new estimates are provided on
,, I7 the attached revised Table 2.1 as a comparison to DES Table 2.1.
Para 3, Sentence 1 (p 2-5)
- Change to - ..." average capacity factor of 56%)--to be $190 million"...
II Basis - revised Table 2.1
, Para 4 (p 2-5)
Comment - Applicant estimates average lifetime capacity factor is 66% which would provide apprcximately 8 billion kWh/yr. 40/9 Basis - Applicant's current estimate of capacity factory, gross nameplate rating of 1357 MWe, and recent change in Dow low pressure steam reservation. to 1800 Mlb/hr. Section 2.3 DIVERSITY OF SUPPLY
~
Para 1, Sentence 4 and 6 (p 2-5) l qF10 Comment - Currently 76% of Applicant's generation is coal-fired. In
. 1985 this dependence on coal is reduced to 62%.
. Para 1. Sentence 5 (p 2-5)
Change to - ..."(Palisades 740 MWe, and Big Rock Point, 63 8I*25 MWe)"... IW Basis - ER-OL, Revision 12, Table 1.1-12 Section 2.5 C0 GENERATION CAPABILITY I Para 1, Sentence 1 (p 2-7) Delete - ..."1,400,000"... Insert - 1,800,000 Basis - Recent change in Dow low pressure steam reservation. miO382-0808a131
Table 2.1 Appaleant's Project!as of Ammust Production Coets and Cost Savinas Per fear Prom Operettom of Midlead Units 1 & 2.1994-1988Ie) (je dollars of the year speelfled) 1984 1985 1986 1987 1988 Categorr $ a 10 mil /kWh $ s 10 mil /kWh $ a 10 at t /htAn $ a 10 all/kWh $ e 10 mil /htAn Productics Costs for Nidland I & 2 Puel 97 15 73 15 90 13 81 13 91 13 den bl 6 68 12 67 10 73 II 80 In Total 138 21 IW 27 157* 23 19 24 til 2b Productica Coets for Replacement knergy ld) 3M b9 272 % b4b 6b b89 75 618 85 Savlage With Midl 1 & 2 Operettos
- 190 138 281 335 bbi Productics coste
'3m 2b 8 With Midland I & 2 Without Midlead 1 & 2 21 49 27 23 6b TS 2%
85 lg
- .s I*IA cepeelty factor of %5. b25, 585. 555 and 615 for 1984.1985,1986,1987 and 1988, respectleely. As assumed based on the plant's gross .umsplate rating of 3.351 IN.
(b)Dased on change la Duu now preneure steen reservettom to I.800 W1b/hr mad an ammuel fuel cycle, lutades both fised and verlebte portions of OaM. ( IBased es load forecast of 12/lb/81. Includes feet and OaN costs. Table below shove proportions of replacement energy and price. Date that these values have been rounded. I*IAverese sevlage of $279 million per year. 1984-1988. Price Oil Price coal Price Purchased g S 081 (all/kWh) 5 Coat (mil /kW1h 5 Purchased (all/k'dh) 1984 3 9% 21 A T6 51 1985 2 305 33 39 65 61 1966 E 118 28 bb TO Tl 1981 3 t13 25 48 72 82 1988 b 151 25 % 11 91 Eacelettom rate /yr 14.15 c~
A-33 5 ! Section
2.6 CONCLUSION
S Para 3 (p 2-8) Comment - Staff may want to recalculate decommissioning cost as a Yd3 percentage of projected lifetime production cost savings.
~
Basis - Applicant provided revisions of 1984-1988 production cost savings. Also refer to the comment on DES Section 6.4.1.
- 3. ALTERNATIVES TO THE PROPOSED ACTION Section 3.2 ALTERNATIVES Para 3, Sentence 5 (p 3-1)
$14 Comment - Applicant estimates an average savings of $279 million/ year for the first five years of operation.
Basis - Applicant's revised Table 2.1.
- 4. PROJECT DESCRIPTION AND AITECTED ENVIRONMENT Section 4.1 RESUME, Line 5 t
Para 1, Sentence 1 (p 4-1)
.g g Delete - "...and dewatering wells... pond seepage (Sec 5.3.1)."
Insert - dewatering wells used to control groundwater levels in the
, power block area discharge to the cooling pond (Sec 4.2.3):
Para 3 Sentence 1 (p 4-1) { Delete - ..." thermal discharges to the river"... l YO Insert - elevated temperature in the pond blowdown to the river. Basis - Pond blowdown prevents excessive TDS concentration in the l pond. Although there will be a thermal component to that l blowdown (FES-CP, Section III.D.1), these discharges are l for TDS control, not thermal considerations. Section 4.2.3 WATER USE l Para 2, Sentence 1 (p 4-2) Change to -No groundwater will be used for NORMAL ONSITE plant l operation. t miO382-0808a131
i A-34 6 1 l Add - The offsite visitor / training center will use 4875 GPD and 4 the outage building will use 7500 GPD when this facility I is in use (NPDES Permit Application (page 2 of 15). Groundwater collected from the power block dewatering system is routed to the cooling pond (NPDES Permit Application, Fig 1). Section 4.2.4.1 Intake Structure Para 1 Sentence 1 (p 4-2) Delete - ..."will be"... M Insert - has been
- Basis - Intake structure was completed in 1978.
Para 1, Sentence 2 (p 4-2) Delete - " Makeup water... diameter pipe." Insert - River water is supplied from the river intake structure to the makeup pump structure through a single 96-inch (244 cm) diameter pipe. The makeup water is pumped from the pusy structure into the cooling pond through a 72-inch (183 cm) diameter concrete pipe (ER-OL, Rev 10, November 1979, Section 3.4.4). Section 4.2.4.4 Discharge Structure
~
Para 2, Sentence 1 (p 4-3) Delete - ... " concrete pipes of 80 ca...in the Tittabawassee River." 430 Insert - ... pipes of 90-cm (36-in) diameter originating in the coolest portion of the cooling pond (ER-OL, Sec 3.4.5) which combine into a single pipe. The river discharge
structure consists of three valved 80-cm (30-inch) diameter discharge pipes to the River.*
~
Para 2, Additional last sentence (p 4-3) g Insert - A concrete apron with riprap around the edges also protects the river bed from erosion (ER-OLS Rev 9, June 1979, Section 3.4.5).
-Section 4.2.6.1 Chemical (Coolina Pond Blowdown) g Para 1, Sentence 1.and 2 (p 4-4)
Delete - "The cooling pond...desineralizer regeneration wastes." miO382-0808a131 l
A-35 7 Insert - The cooling pond will routinely receive several plant wastewater streams prior to their discharge to the Tittabawassee River. These wastewater streams are the iron removal sump effluents, Unit I and 2 clean waste sump effluents, spent circulating and service water treatment chemicals, and wastes from the hypochlorite generation
- system.
Para 2, Sentence 2 (p 4-4) Delete - "The applicant has stated ... when makeup water is drawn (ER-OL, Sec 5.1.2);" b Insert - The cooling pond generally is kept full when possible and therefore blowdown may be withheld when makeup cannot keep up with pond water losses caused by evaporation and seepage; blowdown can occur without makeup if pond level is high enough (ER-OL, Rev 12, June 1981, Section 5.1.2): Para 3, Sentence 1 (p 4-4) Delete - " Blowdown will be ... highest river flow;" Insert - Blowdown is likely to be discharged on a nearly continuous l g basis (except when radwaste dilution flow is used) but at variable rates in March, April and Pfay of each year of operation during periods of high river flow, consistent l with Water Quality Standards and NPEES Permit limits; t l Basis - (ER-OL, Rev 12, June 1981, Section 5.1.2) and (ER-OL, Rev
% 9, June 1979, Section 3.4-5)
~
Para 4, Add final sentence (p 4-4) Qf Insert - However, Michigan Water Quality Standards for dissolved oxygen concentration of 5 mg/l will be maintained in the river. Section 4.2.6.1 Chemical (Process Water Demineralizer Regeneration) Para 1, Sentence 3 and 4 (p 4-4) gg Delete - ... "there will be discharges of... . Such wastes are" ! Insert - demineralizer regeneration wastes normally will be
" discharged directly to the Tittabawassee River. This wastewater stream is
~
Para 1, Sentence 5 (p 4-5)
#3[ Delete - "These wastes... pond blowdown operation"...
miO382-0808a131
A..36 8 i l 1 l Insert - This wastewater stream discharge will be regulated ! l Section 4.2.6.1 Chemical (Coolina Water Treatment) Para 1, sentence 1 (p 4-5)
#hh5 Change to - Sulfuric acid will be added to the recirculating cooling water BEFORE PASSING THROUGH THE CONDENSER to control scaling ...
. Para 1, Sentence 3 (p 4-5)
Delete - ... "and will be regulated to meet the limitations of the
#j( NPDES Permit."
Basis - The Permit only regulates sulfates indirectly via the TDS limit. Section 4.2.6.1 Chemical (Miscellaneous Waste Streams) After Para 1 (p 4-5), Insert new paragraph p(q), The effluent from the oily waste treatment system and the laundry waste effluent are discharged directly to the Tittabawassee River through the river discharge structure.
~~
Para 4, Sentences 1 and 2 (p 4-5) Delete - "Several minor waste streams... oily waste processing system;"... Insert - The Unit 1 and 2 neutralizing sumps and the evaporator building neutralizing sump are routinely dischaTged to the river but these waste streams can be discharged to the
'~
cooling pond under certain circumstances if necessary; Para 4, Sentence 3 (p 4-5) Delete - "The discharged wastes will be regulated to meet the conditions of" ...
#4.2.
Insert - The waste streams will be regulas d to maintain limits in... Section 4.2.6.2 Thermal (River Discharse)
~
Para 1, Sentence 3 (p 4-6) Delete - ... "100 m (330 ft)" ... l #M l Insert - 90 m (300 ft)
,. em a
miO382-0808a.11 3 1 1
$ k
A-37 9 Para 1, Sentonce 5 (p 4-6) Atpqp Delete - ... "are required" ... Insert - were taken into consideration in the model Move - make this the last sentence in Para 1
- Para 3, Sentence 1 (p 4-9)
AL(jp Delete - ... "60 m (200 ft)" ...
-- Insert - 610 m (2000 ft)
., Para 3, Sentence 3 (p 4-9)
Delete - ... "2.7'C (4.98F)." Insert - 2.8'C (5.0*F). Para 3, Sentence 4 (p 4-9) 3 Delete - ... "26.0 to 103.3 m /s (920 to 3650 cfs)." 3 Insert - 27.5 to 103 m /s (970 to 3650 cfs). Para 3, Sentence 8 (p 4-9) Delete - "However, no specific data...by various isotherms." Basis - Specific data referred to in the next sentence of this dagg paragraph, " field observation of full vertical mixing" and examples of surface extent of thermal plumes were provided in the references mentioned in the second paragraph of this DES-OL section. Additionally, App A of the Alden
-~
hydraulic modeling study (DES-OL, Ref 5, Sec 4) shows cross sections of several thermal plumes.
~~
Para 5, Sentence 1, Item (6) (p 4-11) M ,, Change to - ...(6) cooling pond discharge temperature AND TDS,...
, Para 6, Sentence 2 (p 4-11) gf,g() Change to - For the remaining months, the SIMULATION RESULTS
_, INDICATE THAT THE blowdown... _, Para 6, Sentence 2 (p 4-11) jgI Delete - ... "(2) ambient river temperatures will be within 2.8'C (5*F) of the anximum allowable," ... m10382-0808a131
A-38 10 il65b Renumber - (3) ..., (4)... Basis - Item (2) was an assumption in the simulation study. In operation, blowdown discharge will be proportionately reduced within SF of the maximum allowable river
== temperatures.
Section 4.2.6.3 Other (Gaseous Emissions) Para 1 (p 4-11) Comment - The ER-OL (Section 3.7.1) provided preliminary data on nonradioactive gaseous emissions. The Applicant now has applied (or will apply as necessary) to the Michigan Air Pollution Control Commission (MAPCC) for Permits to Install the following systems: l Emergency Security Diesel Fire Water System Auxiliary Temporary System Generators Diesel Pump Diesel Boilers Boilers Purpose Plant Fire water Security Steam during Testing of emergency pump lighting, startup & process steam power etc outages evaporators 4 1 2 3 Number of 1 Units , Operating Testing Testing Testing Startup=S
- Testing Mode Outage =0 Evaluated for Emissions Duty Cycle 4 hr/mo/ unit 30 min / week 30 min /mo S=270-993 Continuous Evaluated MMcf/yr for preop testing 0=0-231 MMcf/yr Fuel Type No 2 Fuel No 2 Fuel No 2 Fuel Natural Gas Natural Gas oil Oil Oil Total Annual 13,600 kg 125 kg 95 kg S=88,000 kg 511,000 kg 0=20,900 kg NO Emissions ToEal Annual 1,390 kg 7 kg 6 kg --- ---
SO "I"I "" 2 miO382-0808a131 l
i l 1 A-39 l 11 l Section 4.3.3.1 Climatology (Severe Weather) Para 1, Sentence 5 (p 4-13)
. Change to- 26,000-km (10,000-mi2 )
Para 2, Sentence 2 (p 4-13) b Change to- 13 mm (0.5 in) Section 4.3.3.1 Climatology (Atmospheric Dispersion) Comment It appears that a summary paragraph with estimates of
. projected concentration levels and dispersion
! - characteristics may have been omitted inadvertently. W57M _ Section 4.3.3.2 Air Quality Para 1 (p 4-15) Delete - Entire paragraph Insert - " Air quality data for Midland area have become available since the FES-CP was issued. Data for total suspended particulates (TSP) and for sulfur dioxide (S0 ) have been 2 l collected in Midland County. Carbon monoxide (CO), gg nitrogen dioxide (N0 2), and ozone data are available from saginaw County. The data for calendar year 1980 show that Midland County is in compliance with National Ambient Air Quality Standards (NAAQS) for TSP and SO 2
. In Saginaw County, the 8-hour NAAQS for CO was exceeded four times during the year; the 1-hour C0 standard was achieved. The I annual NAAQS for NO and ozone were met in Sagini.w County 2
in 1980." Basis - " Air Quality Report, 1980. Air Quality Division, Michigan Department of Natural Resources." Six copies are enclosed. Section 4.3.4.1 Terrestrial
=
r Para 3 (p 4-15) pgg Comment - Shorebird and waterfowl fauna using the cooling pond, as described in DES-OL references 19 and 20, represent three times as many species as listed in Appendix B of the FES-CP.
A-40 12 Section 4.3.4.2 Aquatic Para 1, Sentence 2 (p 4-15) h Change to - ...that this MAY BE related to sampling methodologies
, AND FREQUENCY.
w Para 1 (p 4-15) Add new last sentence - However, recent biological monitoring indicates low biological productivity are more likely the result of sediment instability, particle size and organic g content rather than existing discharges Basis - ER-OL, Rev 12, June 1981, Section 2.2.2.3 which references
" Aquatic Assessment of the Tittabawassee River in the l Vicinity of Midland, Michigan. Lawler, Matusky and Skelly Engineers, May 1980."
Six copies of appropriate excerpts are enclosed.
,Section 4.3.5.1 Terrestrial Para 1, Sentence 4 (p 4-16)
, Change to - . . .has been found ON THE PLANT SITE.
1 Para 3 and 4 (p 4-16) M Comment - NRC may want to consider slight alteration to these paragraphs in light of Applicant comments on Appendix H2 of the DES-OL.
" Section 4 References (p 4-21), Ref 3 Change to - R L FOBES
- 5. ENVIRONMEN1'AL CONSEQUENCES AND MITIGATING ACTIONS Section 5.1 RESUME Para 1, Sentence 3, line 9 (p 5-1)
Mh Delete - ... " impacts on future downstream water users are likely due to plant discharges" ... Insert - future downstream water users, if any, may be affected
. only slightly by the combination of effluent discharges from all sources miO382-0808a131 A
I A-41 13 l 1 Section 5.2.2 Transmission Lines Para 1, Sentence 3 (p 5-2) h49 Delete - ... " maintenance clearing."
., Insert - right of way maintenance to control vegetation.
-- Para 2, Sentence 1 (p 5-2)
Delete - . . " maintenance clearing" .. Insert - vegetation control Section 5.3.1 Use Para 2 (p 5-2) Delete - entire paragraph-Insert - As concluded in Section 5.3.2, plant chemical discharges will be within regulatory limits. Plant operation may produce small, intermittent effects on potential new (if any) water users in terms of additional water-treatment costs. There are no present downstream water users that 8bh8 will be affected by Plant TDS discharges (ER-OL, Rev 12, Section 2.1.3.4.1). The TDS concentration in the river is controlled by regulatory limits of 500 mg/l as a monthly l average and 750 mg/l as an instantaneous maximum to protect water quality for all uses. Dissolved solids will be a f actor in regulating Midland Plant discharges. The combination of effluent discharges from all sources in I this area may at times increase the river TDS levels to the regulatory limit which might occasionally preclude downstream discharges of TDS, thus unavoidably impacting future (if any) water users below the Plant area. Plant cooling pond. blowdown is controlled continuously to protect against Plant discharges which would cause the w river TDS to exceed regulatory limits, Section 5.3.2.1 Chemical Para 1. Sentence 1 (p 5-3) 2 Change to . . ."(including TDS, chlorine, PHOSPHATE AS ' HOSPHORUS,". P . Delete - Footnote at bottom of p 5-3
,, Basis - NPDES permit does not regulate sulfate, sodium or phosphate.
miO382-0808a131
A-4_2 14
~
Para 2, Sentence 1 (p 5-3) Delete - "The regulatory limit...see Sec 4.3.2)." Basis - ER-OL, Rev 12, Table 3.6-3 has average '[VS = 395 mg/l (1978) versus the 500 mg/l average limit for Water Quality Standards.
- Para 2, Sentence 3 (p 5-3)
Change to - This plant will be operated IN COMPLIANCE WITH PERM 1r g 77 REQUIREMEhTS TO MAIhTAIN COMPLIANCE WITH MICHIGAN VATER
% QUALITY STANDARDS FOR TDS.
Section 5.3.2.2 Thermal Para 2 Sentence 1 (p 5-3) Af 71 Change to - ...at the point of discharge of the cooling pond blowdown, AND AT THE EDGE OF A DEFINED MIXING ZONE,
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RESPECTIVELY, require that: Para 2, Sentence 1, Ites (2) (p 5-3)
'- Change to - 2.8'C (5'F) ABOVE AMBIENT RIVER TEMPERA'IURE; Para 4 (p 5-4)
Delete - . entire paragraph Basis - Ites (1) is a restriction on makeup withdrawal not a limit on blowdown. Items (2) and (3) were assumptions in the cooling pond simulation study (NPDES Permit Application,
- Appendix C) not operational limitations.
Para 5 Sentence 4 (p 5-4) Delete - "However, no specific... staff to evaluate." Basis - See comment on Sec 4.2.6.2, Para 3 which discusses the
- data submitted.
- Para 6, Eentence 4 (p 5-5)
Delete - "On an average basis...will occur"... Insert - The modeling studies indicate that plant discharge would have occurred... Para 6, Sentence 5 (p 5-5)
#77 Change to ..."the thermal plume AND TDS limitations". .
5 miO382-0808a131 I
A-43 15
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Section 5.4.1 For and Ice Para 1-8 (p 5-7, 8) Comment - The Applicant is currently implementing a Fog and Ice Monitoring Program as defined in the ER-OL Sections 6.1.3.1.8 and 6.2.3.1.2. The Applicant's monitoring program will establish preoperational conditions as well as measure conditions after the plant is in operation. . The DES-OL fails to mention the existence of this ongoing monitoring program. The establishment of the monitoring program was based on the recognition that on-site field data are needed because there are no mathematical models capable of reliably predicting fogging conditions during operations. The Staff conclusion that frequent periods of dense fog will 417 6 occur on Gordonville Road seems premature and is based on modeling results which appear to be very conservative. As noted in the DES-OL, very dense fog is only expected during the coldest part of the year when the differential temperature between the air and pond water is 70*F to 80*F. For example, during the period of December 1, 1980 through March 31, 1981 there were only 34 hours (approximately 1 percent of the time) in which a l differential temperature of 70*F or more would have i existed between the predicted monthly average pond temperature and the actual air temperature. Not only must this differential temperature exist, but the winds must also be from a northerly direction for fog to be carried over Gordonville Road. Based on meteorological data available from instruments located as the Midland Plant, northerly winds occur approximately 24 percent of the time during the December 1, 1980 to March 31, 1981 period. Thus, the joint probability of occurrence of the two conditions required for fogging at Gordonville Road would be 0.24 percent or approximately 7 hours per winter season based on the 1981 meteorological data. This probability assumes that both conditions (differential temperature and wind direction) occur simultaneously which is not always the case. Finally, the Staff's predicted impacts are based on very limited observations at other locations which may not be representative of conditions at Midland and the conclu-sions appear to represent a pessimistic interpretation of these limited observations. The two units at Dresden produce about 1618 MWe with heat dissipation via a 1275 acre cooling pond. Midland Plant produces 1357 MWe with heat dissipation via a 880 acre cooling pond. The ratios of pond area to electrical output are similar for these two plants and pond temperatures would be only slightly miO382-0808a131
.A-44 16 higher at Midland. The Dresden Station also uses spray modules for additional cooling which increases the water vapor emissions and increases fog and ice potential.
For the above reasons this Section of the DES-OL should be rewritten to fairly characterize the state of knowledge, the uncertainty associated with the predictions and a mere representative impact prediction made.
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Para 7, Sentence 2 (p 5-8) 4l}q Delete - ..." lake." Insert - pond. Para 8, Sentence 2 (p 5-8) jlg() Delete - .. " density"... Insert - extent
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Section 5.4.2.1 Emissions g Para 1, Sentence 1 (p 5-8) Add - one security system diesel and three temporary high pressure boilers for testing. Section 5.5.1.2 Cooling Pond Para 1 (p 5-9) Comment - Applicant does not believe that winter starvation is a jgg;g concern because similar overwintering situations in Michigan shew that waterfowl leave to obtain food elsewhere before starvation becomes a probles. fig 3 Comment - Significant gull overwintering seems probable (References
,, 24, 25 for DES-OL, Section 5).
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Comment - Heated water itself would contribute little to waterfowl WIS4 disease. Section 5.5.1.3 Transmission Corridors Para 1 Sentence 1 (p 5-10)
- 3) gyp Delete - ..." maintenance clearing". .
Insert - vegetation control i miO382-0808a131 i
A-45 17 Section 5.5.1.4 Monitorias "rogram
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Para 1 (p 5-10) Commsnt - CP Co presented a proposed terrestrial operational monitoring program to comply with expected environmental technical specifications which would be part of the NRC operating license. Staff's conclusion indicates that the proposed monitoring plan will indicate impacts but it will not be made a condition of the operating license (and hence the enviromental protection plan). Staff should
== confirm that this monitoring program is not required.
Section 5.5.2.4 Dissolved Oxygen Effects Para 1, Sentence 1 (p 5-13) JIgg Add new sentence af ter sentence 1 - However, pond blowdown will be terminated if Michigan Water Quality Standards for
,, dissolved oxygen concentration.of minimum 5 mg/l are not met.
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Para 1 Sentence 2 (p 5-13) Ob6 Delete - "Nevertheless"... Insert - Additionally Section 5.8.1 Population Para 1, Sentence 1 (p 5-14) gg Change to- 700 persons Basis - New Applicant estimate of operation work force size. Also
, requires other changes by NRC Staff in Section 5.8 of DES-OL.
Section 5.8.2.1 Local Economy Para 1. Sentence 3 (p 5-14) digp Change to - $20 million; $7.5 million; $9 million Basis - New Applicant estimate of work force increases the estimates of payroll, retail sales, and bank deposits
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Para 2, Sentence 2 Delete - "These unavoidable... arrived in the area." ff9/ l miO382-0808a131
.A-46}}