ML20056B561

Forwards Info Re Util Objections to Portions of Plant Permit for Consideration & Early Resolution of Differences

ML20056B561
Person / Time
Site:	Monticello
Issue date:	10/30/1969
From:	Engels R NORTHERN STATES POWER CO.
To:	Tuveson R MINNESOTA, STATE OF
References
NUDOCS 9102070482
Download: ML20056B561 (24)

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-( i NORTHERN STATCS POWER CCMPANY j

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PatenpfWt October 30, 1969 , j i

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1 Mr Robert Tuveson, C'lirman Minnesota Pollution C ntrol Agency Albert Lea, Minnesott 56fd7 i I

Dear Mr Tuveson  !

I With the hope tha. It will clarify our objections to portions of the Monticello -l plant permit and lead to early resolution of differences, we submit the attached I material for cons izration by the Minnesota Pollution Control Agency.

All will agree the .ibject of radioactive waste is an extremely technical one.

Our reluctance to put our permit objections in writing has not been based on any unwillingness to share facts with the Agency. Rather, we have found it most dif-ficult to state these in a way that the information would not be misconstrued and would be genuinely useful to you and to the other members of the Agency. We had therefore advocated continued face-to-face communication and discussion with your staff and consultant in an effort to find solutions. I But perhaps this written report will help to focus on the issues and clear the way for meaningful discussion. Your agency and our conpany have common objectives, j We both are committed to safeguard the health and wcIl-being of the public. At l issue only is the difference in opinion of how to achieve these objectives.

We are confident the vaste treatment and handling facilities at Monticello are entireJy adequate for the intcnded purpose, which is the protection of public health and safety. The addition of more waste control equipment, we believe, is unnecessary; but we are willing to explore this subject further with your staff and your consultant. It is our wish to share and discuss facts and to engage in mutual problem solving.

Though we have filed suit, we have previously stated and now reaffirm our desire to continue discussions with the MPCA. We do not consider litigation a barrier to reaching an agreement. There is no reason we can see why the MPCA and NSP, working together, cannot find a solution for safeguarding the environment, and we wish to continue our discussions to resolve the differencese 3437 9102070482 691030 y CF ADOCK 05000263

. N O RT. ;RN GTATES POWER COf- 'ANY 4,

Mr Robert Tuveson Page 2' '

October 30, 1969 We hope the attached consentary on Permit No 5633 will be a constructive step in that direction. We look forward to hearing from you at your earliest convenience.

Very truly yours r' / J

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Robert 11 Engels l President l

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NOR . c4ERN STATES POWER C' 1PANY i

e f Attacdrient to Ictter Ihted October 30, 1969 frm R. H. L'ngels, President, Northern States Pcuer O:Inpany, to Ibbert Tuveson, Chanrmn, Minnesota Pol- 4 lution Control Iqcncy.

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MINNESCTIA POLIMION OCNTPOL IECY PERMIT 10. 5633 DATED MAY 20, 1969 '

y In its review of the waste disposal pemit issued by the Pollution ~ ~~ j 7

Control Agency for Northern States Pwer Cmpany's Ibaticello Naclear Gen-erating Plant, NSP has no significant difficulties with the sections of the permit entitled "Ganeral Conditions" and "Special Conditions Relating to Con-ventional Wastes". Ikwever, the section e}1 titled "Special Conclitions Pelat-ing to Radioactive Wastes" contains aribiguities and unworki.ble features which will be str:marized later in this menorandum.

l The Special Conditions Relating to Radioactive Wastes are not limited ]

I to a specification of levels of pemissible waste release, bat also contain i

canditions governing plant operating facilities and operating methods. A .

carparison on an isotope-by-isotope basis of the permitted levels of radio-active waste release as listed in the PCA parmit indicates that there is no consistent relationship between the PCA levels and those pemitted by Federal standards pImulgated by the Atomic Energy Ccantission in Title 10, Code of Federal IL%tions, Part 20. Berefore, it is inaccurate to say that the -

PCA permit is fifty times (or any other nu::ber) nore restrictive thea AEC

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standards or any other widely recognized standards. %e only statement which can be mde in this regard is that the PCA permit establishes waste release limits l

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Wich are very substantially nore restrictive than those pennitted by

• Federal law.

j A su:rary of NSP's analysis of the PCA permit gives the following gen-eral conclusions with regard to the Special Carditims Relating to Radio-active Wastes:

1.

As presently designed, the Fbnticello Plant probably can (nply with Conditions 1, 2 (a) , 2 (d) , 2 (e) , 3, 9, 10, 11, 12, 13, 14, ,

and 15. Compliance with these canditions depends upon clarifi-cation of portions of the permit language.

2.

With tle addition of a substantial anount of waste treatment equip-ment ar.d with the consequent expense and delay, the plant could be f

.rodified to permit probable empliance with Conditions 2(b), 2(c),

4, and 5.

Clarificatian of permit language, especially regardirx3 s

technigms of neasurcrent, will be requi. red.

3.

With the addition of a substantial amount of waste treatment equip-ment and with consequent expense and delay, the plant could be nodified to permit possible cmpliance with Conditions 6, 7. arvi R, but its availability as a reliable power production facility could -

be empromised seriously.

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Even i.f the substantial expenditures for additional waste treatment

' equipnent and the corresponding delays in in-servioe operation are ,

undertaken, the enforcernent of the PCA permit will not result in ll u

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, any significant additional protection of the public health and safety. Ch the contrary, the permit will result in significant 4

additional radiological exposure of plant personnel, in the handl-ing of larger quantities of radioactive westes, in an overall deg-radation of safety factors in plant equipcent, and in unpredictable and undependable operation of the plant as a pwer-production fa- ,

cility.

'Ihe follcwing is a paragraph-by paragraph cmmentary on the fifteen conditions in the PCA pernit. 'lhe ntnbers in the follming text refer to =

the ntrabered Special Conditions Relating to Radioactive Wastes beginning on; Page 4 of Permit !b. 5633: ,

1. NSP is in emplete accord with the general policies stated in Con-dition 1. IEP has stated publicly that its goals are the same as those stated in the PCA pennit, namely that the actual levels of radiation exposure of m=bers of the public shall be kept as far below recognized safety limits as possible, consistent with tech-nological feasibility and reasonableness of cost.

2. 'Ihe seccad condition of the PCA permit deals specifically with operating (qui Iraent and procedures. 'Ihis is 2.nappropriate because the permit not only specifies the limits for waste releases, but also attenpts to dictate the equi ment l which nust be used to achieve these limits. Specific conm2nts relating to the five parts of Cbndition 2 are as follows:

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8 i (a) 'Ihis provision requires that isP treat liquid ard gaseous wastes in the nnnner prcposed in 1EP's Final Safety Analysis Report submitted to the Atanic Diergy Ca: mission. NSP ob-viously will co:: ply with this requnu:ent. -

(b) his provision requires the rcmoval of certain gaseous radio-isotcpes to the extent obtainable "by effective activated charcoal filtration of the entire air ejector off-gas floa".

e Capliance with this part of the State permit would require NSP to install substantial additional gaseous waste treatrent -

equignent in the plant, with the attendant additional cost and delays. It is NSP's position' that this is an unnecessary re-quire ent, because envircreental monitoring in the vicinity of boiling water reacters similar to 1bnticello has indicated that releases of these gases (radicio5ine and other halogens) are so Icw that they are negligible when related to recognized f standards. %erefore, installation of the filtration equipnent would not effect any inprove, ent in public health and safety.

- I Be 1bnticello stack emission and environ:: ental nonitoring pro- f grams will serve as a control on halogen releases.  ;

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(c) Wis condition requires routine ion-exchange treatment of floor- g.

drain and chemical wastes. As written, this is an unreasonable requircr:ent, because dcmaneralization is not an effective form of treatrent for such wastes. Me present treaInent system in- "

stalled in the plant provides for filtration of these wastes.

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Idditicnal evaporation cquipment could be installed, with oon-sequent expense aml delays, to treat chemical wastes further, g y

but there is no evidence that this would effect any inprove:nent

• i of public health and safety. NSP is considering the use of disposable clothing to minunize lidaid laundry wastes.

(d) This condition requires that fuel rods be inspected for "de-tectable or significant anounts of uranium on their external surfaces" and that the results of the inspection be reported

. m "in detail" to the Agency. Application of this prcnision re- F quires the definition of what constitutes " detectable or sig-nificant a'munts" of uranium. 'Ihe fuel fabricator has developed asscmbly techniques which mtnimize the anount of radioactivity on the extemal surfaces of the fuel rods, and NSP will conduct additional quality assurance inspect _ ions at the fabricator's plant to detennine that these procedures are follcued.

(c) 'Ihis condition requires, anong other things, the develognent i

and application, "to the full extent possible", of the nethods l' I

and techniques for locating and identifying leaking fuel rods -

after operation of the reactor begins. 'Ihere are no inspection techniques knom at the present tire which are adequate to ident-ify all fuel rods which might develop leaks. NSP obviously will not install any fuel rods in the reactor which dre knam to be e defective, and NSP will use the best techniques available in

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the industry to identify leaking fuel elemnts. NSP will use these techniques during refueling outages and at other times when it is necessary to identify leaking fuel elenents in the core.

3. 'lhis condition limits the gross beta-gama radioactivity of liquid effluents in the discharge canal to an annual average of 10-7 micro-curies par milliliter above natural background. As is custcrrary, NSP assums that tritium is not included in the measure::ent of grcus bata-ganna radioactivity. NSP has indicated publicly it is prepared to meet the limitation in PCA Permit Condition 3.

4. 'Ihis ccndition lists pemitted concentrations in the discharge canal for nineteen specified radioisotopes, with limits given for canal flows of 645 cubic feet per second and of 36 cubic feet per second. ' l

'Ihese pemissible concentraticns are indicated as applying an an j annual average basis, but there is a confusing reference to average 1

daily concentration. In addition, the condition specifies that the '

average daily discharge canal concentration of any other radioisotopes not listed shall not exceed 1/3000 of the ICEP limits or 1/300 of the l l

I ABC lbnits. Apart fm2 tin samntic problem intrcxhced by the muang  !!

l of annual and of daily levels, NSP is concerned because the discharge ql

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levels listed in the permit are in nost cases so low that it is not  ;

s - t-technically feasible to meas t entratians.* In all cases, it k would be impossible to ncasure the icw levels of cancentration in the Nj discharge canal itself, so reasuremnts would have to be made in the ji e

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waste sample tank prior to waste release. Even at the expected levels in the tank, the limit of detection sensitivity for nost l

of the isotopes is greater than the expected concentraticn in the >

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• I waste tank. For these reasons, NSP believes that it will'be im-possible to insure carpliance with Condition 4.

5. 'Ihe first part of condition 5 permits a seven-day average gross -

beta gam.a activity release in the discharge canal of 5 ti2res 10-7 microcuries per milliliter, in excess of existing background radio-activity and presmably disregarding tritium. IEP expects to corply ,

A with this part of Condition 5. The second part of Condition 5 per-

. i mits an average concentration, assmed to be weekly, of any specific . i radioisotope to reach five times the value given in Cbndition 4. 7he i

problems of neasurrent listed in the coments in Condition 4 also pertain to Cbndition 5.

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6. 'Ihis condition limits the gross beta-gama activity of the gaseous effluent to an annual average of 0.01 curies per second. The radio- l

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activity in the gaseous effluent is related to the arount of fuel leaks in the reactor core. If the fml performs in an unrealistically ,

ideal renner, it is conceivable that the limit of 0.01 curies per -

second might be net by the plant as presently designed, but the prob-ability of this circumstance occurring over a long-term basis is so small that this condition in the PCA permit alloos no operating mar- ,

. gin in the event that fml performance is less than ideal. Operat-ing experience from existing nuclear power plants forces IEP to the

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-B-I conclusion that the Ibnticello Plant rest likely could.not p rate for any substantial period of time under Candition 6 without being forced to shut do.m for the detection and replacanent of leaking i fuel. 'Ihese frequent start-ups and shutdwns of the reactor would expose operating personnel to additional in plant radiation, would require the handling of additio".al quantities of radioactive waste, and would degrade the overall safety factors of the plant equiptent.

In an attempt to maet the extramly restrictive waste release limi-tation of Condition 6, :3P could install substantial additional gasecu: waste treatment equignent, with the corresponding heavy expenditures and construction ddlays, U[Jp :ven with the installation of this equiprnt, cmpliancewithCond5ifn6couldnctbeguaran-trod in a nunner which would be consistenhwith the need for reliable

.pwer pInduction from the Ftnticello Plant.

7. his condition lists permissible concentrations of fifteen radio-isotopes to be reasured in the plant gaseous effluant stack before release to the atnesphere. 'Ihe condition also has an overall lirri-tation on other radioisotopes not listed. It is 15P's position that it is impracticable to identify and easure these isotopes in the stack in the manner rquired by the PCA permit. Tne approach of the PCA pennit in establishing an effluent standard in the plant' stack differs fundamentally from the AEC approach to health and safety, which establishes lirits at off-site locations, where the public is present. We isotopic levels indicated

in the PCA permit to be reasured in the stack are about one million tines more restrictive than the equivalent of air requirements at -

the site boundary. Because of the restrictive levels in the PCA 1 permit, it is probable that the plant will be able to operate only for a limited period of tire before requiring shutdNn to search for ard to renove leaking fuel. he installation of the additional gaseous waste treatnent equ(rraent mentioned in the discussicn of e

Condition 6 would permit a closer approach to the limits listed in Condition 7, but the problem of nuasurment of the very law levels of activity specified in the PCA permit would renain.

8. Wis condition nodifies Condition 7 by allowing a weekly gaseous release rate of 0.05 curies per second. %is value corresponds to a nore reasonable long-term release rate based upon expected fuel l

perfornance, but it is likely that this rate of activity release 1 could prevail for several weeks, rather than for simply one week.  !

l Under the terms of the PCA permit, the plant, as presently designed '

and constructed, would have to shut dom frequently for work on the core, with the previously rentioned disadvantages of radiological exposure to the workers, handhng of additional wastes, and over-all degradation of plant safety. he installation of the additional I waste treatrent equipmnt rentioned in the discussion of Cbndition 6 could be nede, but the difficulties of measurment discussed with Conditions 6 and 7 also apply to Condition 8. \ \

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9. Bis prwision of the PCA permi.t establishes a maxinum gaseous waste 1

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release rate of 0.30 curies per second for any fifteen-minute period and establishes a limit on the radioisotopes given in condition 7. IEP expects to be able to neet the overall limit of 0.30 curies per second, although such a limit removes nest of the operating nargin which should be available to the plant oper-i ators for short-term crergencies. 'lhe portion of Condition 9 which refers to neasurcnent of stack concentrations of specific isotopes l l e

cannot be conplied with because of the technological difficulties .

! of neasurencnt mentioned for Conditions 6, 7, and 8.

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10. Condition 10 requires routine effluent nonitoring "to identify . {

I and quantitatively account for all specific radioisotopes that are released in significant quantities". IEP's regular plant cperating procedures provide for quantitative identification of l

radionuclides which have a significant relationship to public health. Hcuever, the language of the PCA permit, and its reference l

to statenentsin the Tsivoglou Report of January 31, 1969, leave l i

l considerable uncertainty as to the arount of identification which would be required by PCA. It appears that the PCA permit contem-plates identification of the increcental addition by the plant of isotopes in quantities which are so minute as to be unidentifiable  !

by presently feasible techniques of analysis. I i

11. 'lhis condition requires that an environnental nonitoring program ,

J as described in the Tsivoglou Repart of January 31, 1969 must be l

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conducted. ISP ins inaugurated such a program, even though nost ruthorities who have reviewed the program regard it as un-a

! warrar.tedly extensive.

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12. This condition rcquires that the results of effluent neasuremnts.

and of the env:Lronnental nonitoring program be reported nonthly to the Pollution Control Agency. This provision can be met, al-

, though custmarily cIrarorrental nonitoring programs provide for collection of data over a longer period of time, usually six nonths or a year, and the submission of this data in a semi-annual or an-nual report.

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13. This condition requires cooperation with the Pollution Control Agency and with the Minnesota State Board of Health in the de-

, velopment of cTergency plans to be follcwed in case of plant accident. NSP's crergency plans conterplate full cocperation with all Federal, State, and local health and safety agencies, and these plans will beccre a part of the AEC operating license for the Ibnticello Plant. Condition 13 of the PCA permit is written broadly and refers to language in the Tsivoglou Peport of January 31, 1969, which seems to indicate that State agencies should be allcwed to take control of plant operations during eTergencies. IGP will cooperate with State agencies to the naxinum practicable extent, ,

but NSP must naintain full control of plant operations at all times,

. including energency conditions.

14. This condition limits the PCA permit to the first year of plant

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, 1 , - operation and provides for changes to the permit at any tima and for annual renewal by the Igency. NSP recognizes the desirability 1 i

1 of frug rant revis of the plant operatirg data by the Pollution j l

Control Agency. NSP will keep the Agency fully informed of the plant operating results. In vis of the limited nuclear pwer-plant expertise on the staff of the Pollution Control Agency, it j appears that the requirement for annual ren mal of the operating pemit could introduce serious procedural problems for both NSP

and the Agency. A nore workable provision would be the issuance of a long-term permit, with provisions that the permit limits be ,

1 l l nodified by the Agency if required after a revis of actual oper- l 1

j ating experience of the waste-treatmnt equipnent.

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15. 'Ihis condition seems to confirm state:Tentsmade by NSP and bf l

! recognized authorities in the field of reactor health and safety

] to the effect that the very 1m levels of radioactive releases per-mitted in the PCA permit are considerably nore stringent than are rcquired for health and safety.

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STATE OF MINNESOTA .

i POLLUTION CONTROL AGENCY ' 9  !

717 oELAWARE STREET S E" (OAK AND oELAWARE STREETS s E.) \ .f a N f MINNEAPOLtS. MINNESOTA 8 I[( f j (

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May 28, 1969 3 u. n:gn g, 3 -

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. Mr. Donald E. Nelson

- General Counsel ~

Northern States Power Company 414 Nicollet Mall a Minneapolis, Minnesota 55401

Dear Mr. Nelson:

'i The application for a waste disposal permit for the Monticello Nuclear Generating Plant in Wright County

, , which was submitted to the Agency has been approved, ,,

j and a copy of permit no. 5633 is enclosed.

Please review the permit carefully and let ue know if you have any questions concerning it.

i Yours very truly, i 9 -] 1 l

John P. Badalich, PE w

Executive Director l

JPB/GRM:bk1 -

Enclosure cc: Mr. Arthur V. Dienhart, Chief Engineer, Northern States Power Company Mr. George Hickler, Chairman, Monticello Township Board Chairman, County Board of Commissioners, c/o Auditor 4

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. o go STATE OF MINNESOTA l POLLUTION CONTROL AGENCY  !

717 DELAWARE STREET s E. '

(OAK AND DELAWARE STREETS s.E.)

. MINNEAPOLIS. MINNESOTA '*

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es44o s l WASTE DISPDSAL PERMIT ~

Monticello Nuclear Generating Plant, Northern States Power Company, .

Monticello Township, Wright County Pursuant to authorization by the Minnesota Pollution Control Agency, and in accordance with the provisions of Minnesota Statutes,1967, Chapters 115 and 116, a permit is hereby granted to Northern States Power Company, '

Minneapolis, for disposal of waste from a steam electric generating plant being constructed by the company in the west half of Section 33, Township 122 N, Range 25 W. Wright County, including the discharge of effluents, as  ;

herein conditionsbelow specified given below. therefrom to the Mississippi River, subject to the '

rGeneral Conditions '

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This permit shall not release the permittee from any liability or obligation imposed by Minnesota statutes or local ordinances and shall remain  !

in force by law. subject to all conditions and limitations now or hereafter imposed The permit shall be permissive only and shall not be construed as estopping or limiting any claims egainst the permittee for demage or injury to person or property, or any waters of the state, resulting from any acts, j operations, or omissions of the permittee, its agents, contractors or essigns,  ;

nor as estopping or limiting any legal claim of the state against the per- -

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mittee, its agents, contractors or assigns, for damage to state property,  !

or for any violation of subsequent regulations or conditions of this permit. {

2. I No assignment of this permit shall be effective until it is executed j in writing Agency. and signed by the parties thereto and thereafter approved by the l 1

3.

No major alterations or additions to the disposal system shall be-made without the written consent of the Agency.

4 The use of the disposal system shall be limited to the treatment or disposal of the waste materials or substances described in the permit application dated July ll, 1967, and associated material filed with the Agency.

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5. The permit is subject to modification or revocation, and may be

• ' susponded et any time for failure to comply with the terms stated he sin or the provisions of any other applicable regulations or standards at the i

' Agency or its predecessors, and is l'aued with tha understanding that it does not estop subsequent establishment of further requirements for treat-ment or 03ntrol at any time by insertion of appropriate additional clauses 4

herein at the discretion of the Agency in crder to prevent or reduce possible pollution of the environment. -

6. The permittee or assigns shall defend, indemnify and hold harmless the State of Minnesota, its officers, egents and employees, officially or i personally, against any and all actions, claims or demands whatsoever which may arise from or on account of the issuance of this permit, or the construction lj j or maintenance of any facilities hereunder.

?. Certification of completton of the project shall be made immediately af ter construction is finished, reports on effluent quality and operational practices shall be submitted ragularly every month, and the permit holder

shall certify that he is in all respects in conformance with the conditions given in the Agency policy statement of August 22, 1967 entitled, " Policy Regarding Operation Permits er Sewage and Industrial Waste Treatment Works.

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I Special Conditions Relatinn to Conventional Wastes 1

" 1. No raw sewage'of treated sewage effluent shall be discharged to surface waters of the state from the plant site. i l

2. Any additional conctruction plans and design data which mey be  ;

requ. red for all disposel systems needed for collection, treatment and dis-i posal of sewage, industrial westes and other westes originating at this site, and for effective containment of stored liquids or other pollutional materials, for the prevedion of water pollution to conform with the requirements of this i'

pernit, shcll be submitted together with any other information requested for review by the Agency. All such plans shall meet wim the approval of the Agency and the systems be completed before operation of the plant is started.

3. The following standards of quality and purity applicable to the effluent of the holding pond shall not be exceeded at the point of discharge from the pond:

pH value 6.5 -iB.5

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Turbidity value 25 5-day biochemical oxygen demand 25 milligrems/ liter i

Total suspended solids 30 milligrants/ liter

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' 4. Cooling f acilities shall b2 provid d and cperatcd to in ure that the <

heat content of the cooling water efter reasonable dilution and mixing in the

• river does not raise the temperature of the river above the limits specified

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Maximum Temperature  !

July and August, inclusive 86*F (or 5'F above the June and September, inclusive 80*F embient temperature  ;

May and October, inclusive 67'F of the river, which-April and November, inclusive 55'F ever is greater., ex-l March and December, inclusive 43'F cept that in ne case January and February, inclusive 37'F shall the riveu tem-perature be raised

{ above 90*F by the dis-i -

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, charge of thir, affluent i i

The design of treatment works for compliance with the stream standards,  :

unless otherwise specified, shall be based on the seven consecutive dty low i flow of the river which is equal to nr exceeded by 90% of such seven-day minimum average flows of record (the lowest seven-day flow with a once in ten 2

year recurrence interval) for the critical month. The extent of the mixing zone to be permitted will be determined by the Agency at a later date after i revicuing the date made available on the characteristics of the river and the '

effluent and other pertinent considerations. s

, e 5. No industrial' waste, or other. wastes, treated cr untreated, shall be discharged into the waters so as to cause any nuisence conditions, including, without limitation, the presence of substantial amounts of floating solids, scum, oil, susnended solids, discoloration, obnoxious odors, sludge deposits, l slimes, or fungus growths, or other offensive effects; or so as to cause any i material increase in any other chemical constituents; or cause any substantial change in any characteristius which may impair the quality of the water so as to render it objectioncble or unsuitable for fish and wildlife or as e source of water for municipal, industrial or agricultural purposes; or other-

] wise impair the qualty of'the waters for any other uses. .

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6. The company shall measure the quantity and characteristics of and sample and analyze the industrial wastes, other wastes and stored liquids at the site as may be requested by the Agtacy, and shall provide the Agency every month with a complete report on such measurements, camples and analyses, to-gather with any other information relating to waste disposal or pollution control which may be requested, l

7.  !

Facilities for monitoring the quality of the receiving waters shall  !

be provided and used as requasted by the Agency. Results er the monitoring

chall be reported to the Agency at monthly intervals.

8.

The company shall cause to be made without cost to the state, tech-  !

nical studies and investigations of the biota and quality and related matters I pertaining to the waters of the state which receive the plant effluents, or Agency.are in the immediate vicinity of the plant, as may be requested by the which Complete reports shall be submitted annumily, or more frequently upon request. I f

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9. Continuous operation of all of the treatment works et their maximum

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capability consistent with practical limitations and maintenance needn of such  ;

works shall be mainteined et all times when the plant is in operation and hhen necsesary to provide adequate treatment of the ecuege, industrial westes or ather westes by the terms of this permit. l

10. . The company shall expediticusly make any changen in weste disposal monitoring, and reporting practices, and provide any additionel treatment l

, works or disposal systems or other safeguards for the prevention of pollution i of the environment upon the request of the Agency.

11. Uquid substences which could constitute a source of pollution of the waters of the state shall be stored in accordence with regulation WPC 4 Other westes as defined by Minnesota statutes, section 115.01, subdivision 4, shall not be deposited in any menner such that the same may be likely to gain entry into these waters. In any case where such substances, either liquid or solid, as a result of eccident or natural ceteatrophe should gain entry into any waters of the state, it shell be the responsibility and duty of the company to inform the Agency in the quickest time possible and immediately remove and recover all such pollutional substances to the fullest extent reasonably possible under existing conditions.

12. The industrial or other weste effluents as discherged shall comply with any and all applicable requirements of effluent stenderds or river classifications and etandards which may be adopted by the Agency for this type,of source and/or for these waters in the future.

Soecial Conditions Relatino to Radioactive Westes

1. It is the policy of the Agency that all radioactive pollution of the environment shall be held to the lowest level that is attainable within the limitations imposed by technological feasibility and economic reasonable-nets. In no case shall rnembers of the public be exposed to radiation be'yonc the limits recommended by the Internetional Commission on Radiologica). Pro-tection. In additica, the actuel levels of radiation exposure of members of the public shall be kept es f ar below those limits es possible, consistent with technological feesibility and reasonableness of cost.

2. In keeping with the above policy of the Agency, all practical  ;

measures for treatment, control and containment of radioactive westes from j the Monticello nuclear generating plant of the Northern States Power Compeny l shall be employed for the purpose of preventing the release of radioactivity i to the environment. Such measures shall include et least, but not be limited  ;

to:

)

(a) all meseures for the trestrrent, control and containment

{

of liquid end geseous radioactive effluents that are indicated in  !

the Final Safety Analysis Report of the Northern States Power Company, Unit 1, Monticello nuclear generating plent; and h

O

( b")

rdutine removal of radiciodine andwns halan from the

.s - gaseous effluents to the full extent feasible, the degree of treatment and removal being at least the equivalent of that pro-vided by effective ectivated charcoal filtration of the entire air ejector offges flow; and (c) routine ion exchenge treatment (Powdex demineralization or equivalent) of the combined low purity wastes (primarily from floor drains) and the neutralized chemical usstes (primarily from laboratory drains and shop decontamination solution drains). The combined estimated flow is 8,000 gal / day; and (d) initial inspection of ael rods for surface contamina-tion with urenium before use in the reactor, and decontamination or replacement of fuel rods that have detectable or significant amounts of uranium on their external surfaces, so as to prevent the use of such fuel rods in the reactor. The plant operator shall report in detail to the Agency the measures teken in this regard before startup of the reactor; and (e) initial thorough inspecition a fuel rods to identify those that might develop fission produc+ leaks, and rejection

} of such rods for use in the reactor; tre the full extent possible, development and application of methods and techniques for locating

' and identifying leaking fuel rods after operation of the reactor begins, so that such rods may be removed during usual fuel replace-ment operations or,. at other times, to prevent excessive release of

' radioactivity to the env.'ronment. The operator shall report in detail to the Agency the actual measures taken in both of these regards before startup of the reactor. If necessary, he shall initiate research and development activities designed to develop the needed effective procedures.

3.

The gross beta-gamma radioactivity of liquid effluents released to the plant discharge canal shall be limited to the extent that the annual aver-age gross cenal shall beta-gamma not exceed 10-7 radioactivity concentration of the water in the discharge pc/ml (100 pc/1) plus the background radioactivity.

4 As an integral part of Special Conditions 3 ebove, the concen h ations of specific radioisotopes in the discharge canal shall not exceed, on an annual average basis, the following limits:

Averece Deily Concentrations, ve/ml Radicisotope Normal (a) Lou River Flow River Flow (1) (2)

(3)

H-3 2 x 10~0 4 x 10 -7 F-18 8 x 10~I 1 x 10 -11 Na-24 2 x 10-12 -11 3 x 10

_ _ _ _ . _ _ _ . _ _ _ _ _ _ . _ _ . . . _ - - ~ -

--~"-- - - - - - - ' '

~

. . O o Average Deily Concen~tration, pc/ml Radioisotope flormal a)

Low River Flow River Flow (1) (2) (3)

Cr-51 9 x 10-1 1 x 10-11 Mn*S6 5 x 10-12 4 x 10-11 Co-58 -12 9 x 10 1 x 10-10 Co-60 ,

9 x 10~I3 1 x 10~11 Sr-90 4 x 10~I 8 x 10~I2

-11

^

^

Sr-91 2 x 10 4 x 10-10 Sr-92 -12 4 x 10 8 x 10~11 Tc-99, Mo-99 -10 1 x 10 4 x 10~

I-131 -11 8 x 10-1D 4 x 10 I-133 2 x 10-10 4 x ID'9

,I-135 -11

. r, 6 x 10 1 x 10~9 Te-132 6x D~I3 1 x 10~11 Cs-136 6 x 10~I' 1 x 10

-12 Cs-137 2 x ID~I3 4 x 10~I3 Ba-139 ~I3 4 x lO 6 x 10-12 88-140 4x10 -12 6 x 10~11 -

(a) Open cycle - 93 percent of days; no use af cooling towers; discharge canal flas 645 cfs.

(b) Closed cycle - 7 percent of days; full use of cooling touers, discharge ca1al flow 36 cfs.

In addition to the specific radioisotop concentration limits given in the above table, and on an interim basis until plant operation provides more definite linformation, the average daily discharge canal concentration of any other radioisotope shall not excced one three thousandth (1/3,000) of the specific ICRP limit for continuous occupational exposure or one three-hundredth (1/300) of the numerical limit for that radioisotope as specified in Appendix B, Table II, Title 10, Part 20 of the USAEC Standards for Protection Against Radiation. In case these two limits differ for any specific radioisotope, the lower limit shall epply.

7

~

In e'ddi, tion to a 1 of the foregoing liquid ef

5. ent radioactivity l concentration limits, for eny seven consecutive day period the average gross I ta-gamma radioactivity concentration of the water in the discharge canal s all not exceed 5 x 10~ pc/ml (500 pc/1) plus the background radioactivity, and the average concentration of any specific radioisotope in the discharge canal shall not exceed a limit of five times the value given in the above table.

6. The gross beta-gemma radioactivity of the gaseous effluent released I

via the plant stack shall not exceed, on an annual average basis, a release

) rate of D.01 curie per second. This refers to a total stack cir flow of 4,000 {

4 j cfm, and thereby also specifics the limiting concentration of gross beta-gamma l radioactivity in,the stack effluent before dilution in the atmosphere.

7. As an integral part of Special Condition 6 above, the concentrations

of specific radioisotopes in the stack before release to the atmosphere shall i not exceed, or en annual average basis, the following limits

Radioisotoon Stack Concentration (")

pc/ml H-3 4 x 10

Ar-41 3 x 10

-6

Kr-83m 1 x 10-0 l

' ~

i Mr-85m '

3 x 10~

Kr-85 2 x 10~

1 Mr-87 1 x 10-3 Kr-88 1 x 10-3 Kr-89 2 x 10-5 Xe-131m 1 x 10-6 1

Xe-133m 1 x 10-5 i Xe-133 3 x 10-'

i 1 Xe-135m 4x10 a Xe-135 6 x 10~

i l Xe-137 5 x 10

-5 Xe-138 2 x 10-3 (a) At a total stack air flow of 4,000 cfm.

i

. In additi'on to the s ific radioisotope limite gi in the table immediately -ebove, and on an interim basis until plant operation provides more definite information, the average daily stack concentration of any 3 o.t.her radioicotope before release to the atmosphere shall not exceed 10 '

times the specific ICRP limit for continuous occupational exposure, or 100 times the numerical limit for that radioisotope as specified in Appendix 8, Table II, Title 10, Part 2D, of the USAEC Standards for Protection Against Radiation.

8. In addition to all of the foregoing gaseous (stack) effluent con-centration limits, the gross beta-gamma radioactivity of the gaseous effluent i

released via the plant stack shall not exceed a release rate of 0.05 curie per second for any seven consecutive day period. During such a period, the stack concentrations cf specific radioisotopes shall not exceed five times the numerical limits given in Special Condition 7.

A stack release rate of 0.05 curie per second shall automatically sound a plant alarm to warn the plant operator that the weekly release rate limit has been reached.

9. In addition to all of the foregoing gaseous (stack) effluent con-centration limits, the gross beta-gamma radioa;:tivity of the gaseous effluent released via the plant steck shall not exceed a release rate of 0.30 curie per second for any 15 minute period. During such a period, the stack con-a centrations of specific radioisotopes shall not exceed 3D times the numerical limits given in Special Condition 7.

o A stack release rate 'of 0.3D curie per second shall eutomatically sound 4

I a second and different alarm to war the plent operator that the ' instantaneous' release rate limit has been reached. After a 15-minute delay, the air ejector I offgess isolation valve shall automatically close, shutting dow the reactor, if the redicactivity release rate has not been successfully reduced to the weekly release rate limit, or less.

10.

During the first year of operation of the nuclear generating plant  !

i st Monticello, the routine effluent monitoring program of the Northern States Power Comptny shall be designed to identify and quantitatively eccount for all specific radioisotopes that are released in significant quantities. This effluent monitoring program shall provide for and include at least the kinds of samples, frequencies, radioassay procedures, etc., described in the MPCA Final Report entitled Radiosctive Pollution Control in Minnesota, and dated

January 31, 1969 (see especially pp. 139-143).

11.

During the first year of operation of the nuclear generating plant at Monticello, the routine environmental radiological monitoring and sur-veillance program of the Northern States Power Company shall be designed to detect and evaluate all significant radioactive releases from the plant.

This environmental monitoring program shall prov$de for and include at least the kinds of samples, frequencies, radicarsay procedures, etc., cescribed in the MPCA Final Report on Radioective Pollution Control in Minnesota, dated January included31, 1969 (see especially Table IV, pp. 135 and 136, and the section in pp. 114-139).

1

. 12, n All. effluent evenvironmental monitoring pr results shall be t

reported month 1; by the Northern States Power Company t the Agency. All monitoring" program results shsll also be available for inspection by the g., Agency at the plant Site at any time.

13. The Northern States Pouer Company shall cooperate to the full extent necessary with the MPCA and with the Minnesota State Board of Health (MSBH) for purposes of development by those agencies of an adequate and effecitye emergency protection plan designed to immediately control and )

minimize the effects of any accidental release of unexpectedly large quanities '

of radioactivity from the Monticello nuclear generating plant. In particular, the Northern States Power Company shall immediately notify both the MPCA end ,

the MSBH of any uncontrolled release of unexpectedly large quantities of radioactivity to the offsite air and/or uater environment due to operational failure of any of the power plant systems. Also, the Northern States Power Company shall cooperate in this regard to the full extent outlined in the MPCA Final Report on Radioactive Pollution Control in Minnesota (see pp. 90-97), and in any other manner requested by the MSBH.

14. The "Special Conditions Relating to Radioactive Wastes part of this l permit is limited to the first year of operation of the Monticello nuclear '

generating plant. During this period that part of the permit may be modified by the Agency in any manner and to any extent deemed necessary by the Agency.

A new permit relative to radioactive wastes, modified end changed to the ex-tent deemed necessary by the Agency, and based upon the results of the first year of power plant operation, will be issued by the Agency for the second  !

year of operation. '

' 15. It is emphasized that public and environmental radiation protection practice is based upon a concept of very long term protection, rather than only immediate or momentary protection. The generally accepted I.C.R.P. limits  :

are designed to restrict radiation exposure, on a continuous basis and over  ;

a lifetime, to levels that will not produce detectable or significant sometic l or genetic harm. Th e annuel average release rate limits contained in this Permit also refer to continuous lifetime radiation exposure, rather than to l momentery' levels, and are considerably more stringent than could be permitted l according to the I.R.C.P. recommendations. Hence, the slight transitory (E.G., daily) variations around these limits that are to be normally expected should not result in overexposure to radiation of eny member of the public, and should therefore not be viewed as cause for great alarm or for hasty and unrecsoned action. I Ak

( John P. bedalich, FE 1 Executive Secretary and Chief Executive Officer Permit No. 5633 Dated May 20, 1969 l