ML20058L211
| ML20058L211 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/30/1972 |
| From: | Hatling R MINNESOTA ENVIRONMENTAL CONTROL CITIZENS ASSOCIATION |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 9105130399 | |
| Download: ML20058L211 (3) | |
Text
50-263 Ji/ilE(::(::;ot MINNESOTA EN VIRONM ENT A L CONTROL CITIZENS ASSOCI ATION CENTRAL MANOR e
. Saint Paul, Minnesota 55101. Phone: (612) 222-2998 26 East Exchange
"} W June 30, 1972 Directorate of Licensing 4
f,g ggtF ff U.S. Atonic Energy Comnission We shincton, D.C.
~1 Re: Draft Environnental Statement by the U.S. Atomic Energy sk Commission, Directorate of Licensing, Monticello Nuclear Generating Plant, Northerns States Power Company, Docket db No. 50-263 Gentlenen:
We have reviewed the Draft Environmental Statenent for Konti-cello with conc ern, if not elarn, because of its inadecuecy in definine inenct of the Monticello Nuclear Plant.
Nowhere in this Statement is thene reference to the notential effects on the oublic in terns of deaths or illnesses.or Renetic effects wh!ch could result fron dev-to-dev radioactive emissions th ouchout the life of the plant -- or can be nostulsted in the event o' s severe accident et the Blent.
Since risks to the -ublic, now and in fu ture renerati ons. have been the enuse for creetest c~ncern anone many inforred, know-ledgeable scientists srd lav ne rsons, it seens incredible to us thst no consideration has been civen to the decree of risks in terms of,;blic hesith ef fects) involved in the operation of this plant.
We c annot s e e how an y s ta teme nt on environmental innect can icnore such critien1 considirstions.
In addition to the unanswered ouestions regarding the environ-nental innset of radioactive emissions is the question of thernel collution to the Kississinpi River.
The Stetenent totelly ignores the temperature criteria recon-mendations for this zone of the Mississippi River established by the Environnental Protection Acency on the basis of the St. Louis Conference.
Not only does the Statement igore these temperature criteria reconnendations -- it soeculates on the basis of state tamper-ature standards which do not exist because no mixine zone has ever been defined for the hot water diachsrees.
To neet the nexinun tercerature limits es recuired by the State's cernit in the forr it presentiv evists, the Concenv nev neasure tencers-ture es fer ownv as New Orleens.
The Statenent accents thin 1sek of deinition and furtber confuses the issue by saying (v. III-7). "Althourh it w,"id not be necerserv to onernte the con 11nc tavers in order tm nae t the no rnit terne rn tu re li-! t e dur' ac noch of the vaer, NSV hes made e co~n$trent to the FPCA to onernte the e,ol!nc tnwe s to the noximum extent nrectic al."
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-2 The Statement rakes no attenot to define or question "the marinum extent cosctical" chrase desnite its meaningless implications.
We find nsn7 octinistic conclusions throuchout this Statement which areasr to be based on assumrtion, often totsily unfounded.
Por examnle:
P. VI-6: "In cese of an accident, procedures which carriers are recuired.
to follow will reduce the consecuences of en accident in nany cases.
The pro-cedures include secrecation of denaged and leaking neckeces from people, and notification of the shioper and the Departrent of Transportation."
There appears to be no answer to cuestion of the driver being killed or injured in the secident.
P. VI-7: "Lenkage of centsninsted coolent resulting from inproper closing of the essk is possible as a re-i sult of human error, even though the shipper is renuired to follow specific procedures which include tests and
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examination of the ' closed container prior to each ship-ment.
Such en accident is unlikely during the h0-year life of the plant."
Question: Is it realistic to assume no human error in h0 veers?
P. VI-8: "It is unlikelv thet a shirment of solid radio-active weste will be involved in a severe accident during the h0-yesr life of the clant."
Another unfounded assurp-tion.
Yany other such unfounded conclus4.cns exist throuchtut this Statement.
Vany cuestions also exist which this State-ent does not cover.
For exam"le:
Whet he-ens to the radioisotore tritium nroduced by the nient?
Whet is its effect on the envi ronmen t ?
The Statement nentions the production o' nlutonium.
How is this extrenelv toxic substance controlled?
What he pens if it is releesed to the env ironne nt ?
through clant operations.
or s~cident.
A statement on Pece IX-1 reads, "After decomiissioning of the reactor, the mejor portion of the site could be redleimed for other purooses if desireable.
If it is decided that the eres occuoied by the reactor facility should be pieced on permanent restrictive access, thnt area would be irretrievably lost."
Such leek of provision for renovel of this reactor after it has been deco nissinned would sn e ar to be a violation of many of the ends of the National Environnental Policy Act outlined in the Statement's Forward (Peges xii-xiii).
We have been inforred by the Minnesots Pollution Control Acency that the Atomic Enerev Connission will hold public hearing on j
l the Leeft Environrental Statement for Monticello.
It is cur further understanding the t the AEC staff carsonnel will be v
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available for testimony and cross examination.
The Finnesota Environmental Control Citizens Association intends to appear and pa rticipate as a party in that hearing.
It is our intention that the above comments, as well as other considerations impossible to cover here, will be fully explored in the course of that hearing.
We reserve he richt to make additional comments on the environne1tal inract statement based on the record of that hearing, i
Yours truly,f wAfb
- Russell Hetling, Chairnan Vower 1eneration Ts s'< Force I
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