ML20091A199

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Discussion & Findings Re Consideration of Suspension Pending NEPA Environ Review of License DPR-22
ML20091A199
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 11/18/1971
From:
NORTHERN STATES POWER CO.
To:
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ML20091A175 List:
References
NUDOCS 9105140440
Download: ML20091A199 (34)


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DISCUSSION AND FINDINGS BY THE DIVISION OF REACTOR LICENSING U.S. ATOMIC ENERGY COMMISSION RELATING TO CONSIDERATION OF SUSPENSION PEhDING NEPA ENVIRONMENTAL REVIE_W OF THE PROVISIONAL OPERATING LICENSE DPR-22 FOR THE MONTICELLO NUCLEAR CENERATING PLANT E-5979 AEC DOCKET NO. 50-263 November 18, 1971 9105140440 711119 PDR ADOCK 05000263 P PDR

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1.0 INTRODUCTION

1 j On September 9, 1971, the Atomic Energy Commission (AEC) j published in tric Fe eral Register a revised Appendix D to 10 CFR Part 50, setting forth AEC's implementation of the National i

j Environmental Policy Act of 1969 (NEPA). Paragraph E(3) of revised Appendix D generally requires a holder of an operating 1970 but before September 9,1971,

) license issued af ter January 1, i

to furnish to the AEC within 40 days of September 9,1971, a written statement of any reasons, with supporting f actual submission, why with reference to the criteria in paragraph E(2)

! of revised Appendix D the permit should not be suspended, in whole

or in part, pending completion of the NEPA environmental review 4

specified In Appendix D.

s On January 19, 1971, after a public hearing.,the AEC issued Provisional Operating License DPR-22 to the Northern States Power Company (NSP) for the Monticello Nuclear Generating Plant E-5979, on October 15, 1971, NSP filed with the AEC the statement required by paragraph E(3) of Appendix D.

i 1.1 De t e rmin a ti on In accordance with the requirements of Section E of Appendix D, we have determined that Provisional Operating License DPR-22 for the Monticello Nuclear Generating Plant E-5979 should not be suspended, f r. whole or in part during the review period, pending completion of the NEPA environmental review specified in Appendix D.

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A formal " Determination" to this ef fect is being forwarded to t'se Federn1 Register for publication. In reaching this deter-i i mination, we have considered and balanced the factors in I Paragraph r.(2) of Appendix D.

1.2 Background

in July 1966. NSP filed an application for a construction permit for the Monticello Nuclear Generating Plant with the AEC.

An extensive review of the application was made by the AEC's 4

regulatory staf f and by the Advisory Committee on Reactor Safe-guards. A public hearing was held before a three-member Atomic

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Safety and Licensing Board at Buffalo,tiinnesota on May 25 and 26, 1967. On June 19, 1967, Construction Permit CPPR-31 was

. issued, to build a boiling water reactor with a power 1cvel up to

1670 MWt. In November 1968, NSP submitted an application to the AEC for an operating license and submitted the Final Safety Analysis Report (FSAR). Again an extensive review of the application was made by the AEC's regulatory staff and by the Advisory Committee on Reactor Safeguards. At the Commission's initiative, another public hearing was held before an Atomic Safety and Licensing Board (ASLB) beginning in April 1970 and continuing intermittently until November 19, 1971. Interes ted l members of the Public were admitted as parties. On August 25, 1970, the ASLB authorized issuance of an interim provisional operating I

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1 q license allowing fuel loading and operation of the reactor at j power levels not in excess of 5 MWt, providing the reactor head

was not installed, and on September 8, 1970, the AEC issued a i

provisional operating license permitting such operation. NSP 1

started fuel loading of the reactor soon af ter and initial crit-

icality was achieved on December 10, 1970. Following the ASLB's j favorable decision issued on January 15, 1971, the AEC issued a full power provisional operating license on January 19, 1971, I

but included a restriction limiting power to 5 MWt until acceptable performance of the feedwater pumps was verified by the AEC. On February 18, 1971, the AEC approved operation of the reactor at power levels up to 1670 MWt. On June 30, 1971, testing of the plant was completed and the plant was considered te be in service.

Concurrent with the application to the AEC for an operating license, NSp made applications to the Minnesota Water Pollution Control Commission (now Minnesota Pollution Control Agency - MPCA) for permission to discharge heated wc'er and other plant waters to the Mississippi River, and to the Minnesota Department of Conservation (now Minnesota Department ti Natural Resources - MDNR)

for permission to approprit __ sling water from the Mississippi River and to construct intake and discharge structures. In May, 1969 MPCA approved the temperature limit on water discharge l

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I restricting the temperature rise to 5'T over the ambient river temperature after mixing.1!

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) In August 1968, MPCA decided to establish State standards i

f for release of radioactive wastes from the Monticello Plant.

1 j In June 1969, MPCA issued permits covering both water discharge and radioactive waste releases. NSP filed suit in the United l

States District Court, maintaining that MPCA did not have juris-diction to set limits on radioactive waste releases. On December 22, 1970, the Court ruled that the Federal Government (AEC) has the exclusive right to regulate nuclear generating facilities. In January 1971, the State of Minnesota appealed; 4

however, in September 7,1971, the U.S. Eighth Circuit Court of I

Appeals sustained (2-1) the ruling of the District Court of December 1970. The State of Minnesota is reported to be seeking U.S. Supreme Court review of the Eighth Circuit's decision.

While litigation was proceeding between NSP and MPCA on the I issue of jurisdiction over nuclear power plants and radioactive discharges, NSP and MPCA agreed to proceed with the possible l installation of additional means to reduce off gas releases from the plant, as had been recommended by MPCA. On April 1, 1971, A Exhibit 5, Monticello show cause statement filed October 15, 1971.

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] NSP submitted a request for approval of the proposed gas storage system to the AEC.E This request was further amended on October 15, 1971 and is currently under review.2!

1 j 2.0 COMPLETION OF NEPA REVIEW s

In accordance with revised Section B of Appendix D to 10 CFR 1

Part 50, NSP expects to file an environmental report on November 8, 1971. The time necessary for the completion of the NEPA review for j

the Monticello Plant is estimated to be 12 months. The criteria set forth in Section E of Appendix D have been evaluated with this approximate time period in mind. That is, the environmental impact of continuing operation, the foreclosure of alternatives of the type that might be required as a result of the full NEPA review, and the effects of suspending operation for 12 months I

have been considered. Should the actual NEPA review of the case exceed 12 months, such a longer time period would not add i

significantly to the environmental impact which operation of the j plant has caused to date, but would substantially increase the cost

. of suspended operation if the plant were shutdown. We have taken these considerations into account in balancing the factors l

specified in Paragraph E of Appendix D to 10 CFR Part 50, and l have concluded that if a significantly longer time period i l

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, Monticello Technical Specifications Change No. 2 filed April 1, 1971.

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Monticello Technical Specifications Amendment Change No. 2 filed {

October 15, 1971.

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6-i sere required to entp!ctc d., NC1'A review, it would not affect i our determinat ion that the operatint license of the Monticello Plant should not he suspended at this time.

3.0 ENVIRONMI:NTAl. EFFF. CTS 3.1 Radiological Effects NSP has submitted the first six-month operating report covering the period from December 10,1970 (initial criticalf ty date) to June 30, 1971.b This report lists the radioactive vastes released during the operating period. The Division of

! Compliance has selectively audited these reported releases and

, found them to be accurate.

3.1.1 Caseous Effluents i

l Gaseous ef fluents may originate f rom the steam air ejectors, plant startup, steam turbine gland seal leakage, con t ainme n t purging, liigh Pressure Core injection turbine testing and plant ventilat ion systems. For normal operation, we have calculated

. that the contribution to the dose at the site boundary f rom l

these sources, excluding the air ejector, is less than 5 mrem /yr; which is consistent with the Commission's " low-as-practicable" requirements and with the numerical guides given in the proposed Appendix I to 10 CFR Part 50. I

. l The air ejector is by far the greatest source of radioactive gaseous effluent. The gaseous radwaste system provides a delay 4/

l Monticello Six-Month Operating Report No. 1, filed Augus t 5,19 71.

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1 time of 30 minutes for decay of the radioactive fission and activa-tion gases prior to release. These gases are then released through a 100-meter stack af ter passing through high efficiency filters.

During the first six months of operation of this plant, the releases were small f ractions of the releases permitted by the Technical 1

Specifications; 0.028% for the noble gases and 0.12% for iodines and particulates. However, commencing in Augus t , the source of

! activity has increased considerably. The reason for this increase is deterioration in the performance of the fuel. Based on experi-ence to date at other reactors, this activity will probably continue to increase. At present, the gaseous release is at approximately 4% of the limit specified in the Technical Specifications.

As noted above, on April 1,1971, NSP submitted to the AEC for review the design of a proposed gaseous radwaste system, which by the addition of holdup tanks and other related equipment, the func-tion of which would be to reduce substantially the stack activity release rate. Because of the time required for review by the AEC l compared to time for equipment delivery and for cons truction, it is unlikely that this off-gas system modificoiica can be implemented during the NEPA review period.

On July 14, 1971 an unexpected gaseous release occurred at a rate of about 25,000 uC1/see through the main stack and about

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i 2,000 pC1/see through the reactor building vent.5/ This release

.! lasted for approximately 30 minutes. Our analysis has shown that l 1

l the integrated dcse at the site boundary was negligible. We have i

informed NSP that means should be provided to mitigate such un-

] controlled releases. NSP has agreed to review the system design with the objective that the incident will not recur, and to provide means to control releases frou. the reactor building vent.

Based on the amount of gaseous radioactivity that the Monti-cello plant is expected to emit during the NEPA review period, the proposal by NSP to install a waste gas handling system, NSP's plans to mitigate uncontrolled releases, and the f act that plant operation will not foreclose incorporation of cther necessary

, additions or modifications that may be dictated es a result of a complete NEPA review, we conclude that the incremental effect of i

gaseous releases on the environment during the period NEPA review

! is acceptabic.

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3.1.2 Liquid Effluents The liquid radwaste system is designed to provide the maximum i

practical capability for recycling process wastes to the reactor I

5/ Letter from NSP to P. A. Morris of the AEC, Reporting of Unusual Occurrence, dated July 23, 1971.

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system and thereby reduce the need to discharge radioactive liquids to the environment, hiquid wastes are processed on a batch basis.

The radioactive and chemical contaminants are removed from the liquid waste streams either by filtration, or by filtration followed by mixed deep bed demineralizers before the liquid is returned to the primary system. Certain low level liquid radwastes are pumped to the discharge canal where the wastes are diluted with the circula-ting cooling water before discharge to the river.

Except for one occurrence, the radiation level of liquid efflu-ents has been close to background, and therefore negligibic. On July 15, 1971, as a result of an incident involving an uncontrolled release of gaseous radioactivity (see Section 3.1.1), the existing meteorological conditions were such that the released radioactive gas came into contact with the water in the cooling towers. Radio-active gases were dissolved in the water raising the activity of s the water in the discharge canal to as high as 2.5 x 10 pC1/cc for a short period of time.

However, the amount of radioactivity discharged during that short period of time was negligible.

During the first six months of operation, the liquid releases

-6 arc.ounted to 4.5 x 10 % of Technical Specifications limits. With continued plant operation, we expect an increase in the amounts of f

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j radioactivity to be released. However, based on the history of the 5 operation of this plant and other similar plants, we conclude that the total activity to be released with liquid effluents during the period of the NEPA review will be acceptably small .

I 3.1.3 Solid Radvaste The solid radwaste system relics on shipments of solids from the plant to AEC licensed of f-site disposal facilities. For the

! first six months of operation, Monticello has shipped 7.6 curies t

] of solid waste to Sheffield Nuclear Center, Sheffield, Illinois, i -

, The amount of solid wastes that will be generated and will require l shipment during the NEPA review period are not expected to be a

significant.

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3.1.4 Transportation of Irradiated Fuel Elements NSP states that shipment of irradiated fuel from the Monticello plant during the NEPA review period is not expected.b l

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! 3.1.5 ConcJusions l

Based on plant operating data and data from the environmental monitoring programs, we conclude that radioactive releases from

Monticello are not causing any significant adverse impact on the 6/ Monticello show cause statement filed October 15,19 71, page 10.

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! environment. In-plant monitoring and continuation of the f

l environmental monitoring prograns by NSP and the State of Minnesota i

will assure detection of incipient adverse environmental effects from continued operation of the plant. Even if reduction in these i .

Iow levels is deemed desirable as the result of the NEPA review, the added increment of radiation during the NEPA review period will i

be within the technicci specification limits which are designed to j prevent undue impact on safety or the environment and therefore 4

a are acceptable.

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. Water Use 4

3.2.1 Cooling Water Requirements Cooling water for the plant comes from the Mississippi River.

On March 12, 1970, the MDNR issued a permit authorizing NSP to appropriate water from the Mississippi River tor use in the operation 7

of the Monticello plant. / The authorization is for continuously j pumping water from the Mississippi River at a variable rate from l

i 45 cfs to 645 cfs for a maximum total annual appropriation of about 467,000 acre feet. The permissible flow depends on river

flow, temperature and climatic conditions, and allows several modes 1

of operation of the recirculating water system. The recirculating 1 -

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water system includes two induced draft, cross flow cooling towers,

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Exhibit 4, Monticello show cause statement filed October 15, 1971.

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Each cooling tower is rated to remove 3.9 x 10' Btu /hr at a flow J

j of 645 cf s and a wet bulb temper ature of 73*F.

1 The cooling towers are not designed for operation during the 4

, winter months. We understand the MPCA has requested NSP to operate l

the cooling towers throughout the year, NSP is currently evaluating 5

this request. If, af ter the completion of the NEPA et vironmental review, year round operation of the cooling towers should be required, the present system can be modified to meet this requirement. In the interim period, continued operation of the plant will be within the ,

limits prescribed in the water use permit issued by MDNR.

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i The nearest public water supply using Mississippi River water j is the Minneapolis-St. Paul system, approximately 35 miles downs t ream from the plant. As discussed in Section 3.1.2, the liquid radwaste i

discharges to the Mississippi River have been small. Measurements b'y the Minnesota Department of Health and the St. Paul Water Depart-4 ment show no increase in radioactivity in the St. Paul water supply t

since the Monticello plant began operation. Since water releases to the river are centro 11ed on a batch basis, it is not expected 1

that the radioactivity level of discharges to the river will increase I

significantly during the NEPA review period.

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The Monticello plant also uses well water for plant donestic needs and river intake pump shaf t sealing. Two wells, each rated at 50 rpm vithdraw ground water f rom a depth of approximately 90 feet. MDNR has issued a permit to NSp allowing ground water appropriation at the rate of 100 gpm. We are in agreement with the opinion that continuation of thin withdrawal during the NEpA l

s review will not have noticeabic ef fectn on surrounding wells out- -

side the site.

3.2.2 Thernal Ef fec ts On May 20, 1969, the MpCA issued a waste disposal permit for .

the Monticello plant, khich includes thermal discharges to the river.8/ This permit requires that the maximum temperature of the discharged water not exceed limits specified for each month of the year or 5'r above the ambient temperature of the r'iver, whichever is greater, except that in no case shall the river temperature be raised above 90'F by the discharge of the ef fluent , af ter reasonable dilution and mixing in the river, e

i According to the licensee, thermal surveys of the discharges o

to the river are being conducted with the cooperation of the MPCA.a/

i p/ See Note 1, page 3. _

9/ Monticello show cause statement filed Oc tober 15, 1971, page 6. .

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g These surveys will continue until appropriate data are collected under various climatic and hydrologic operating conditions to establish the mixing zones provided for in the MPCA permit. The i

licensee reports that under summer conditions, when the full flow is directed to the cooling towers before the water is discharged to the river, that within about 100 f t , downs tream f rom the plant ,

the plume temperature is less than 5'F above ambient.9 / These 1 same studies show that by the time the flow reaches the community of Monticello, three miles downstream, the plume temperat ure profile cverage reaches a level within 2*F of ambient. In this three-1 mile reach, the heated water travels close to the right bank of the river, so that more than half of the stream profile is essentially unaf fected by the warm water discharge.

We conclude that any adverse ef f ects thet may arise due to thermal discharges over the period of the NEPA review period will probably be small. An environmental monitoring program is discussed in Section 3.2.3 which should permit detection of adverse trends and indicate the need Joe any remedial action.

3.2.3 Ecolery An environmental monitoring program has been in effect since May 1968 and will continue for the duration of the life of the 9/ Monticello show cause statement filed October 15,19 71, page 6.

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'lhe collection and Hampling frequencies of the environ-1 i

mental monitoring program are incorporated in the plant Technical 4

t Specifications.

l The licensee issues yearly reports of the data

{ co11ceted in the program. Three reports have been filed with the i I

} AEC, the latest one for the year 1970.11/ -

Since the plant did l

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not start operation until 1971, these reports can be considered a

1 to provide a base line for subsequent studies. Interim reports 1

also have been submitted by NSP consultants. Dr. Alan J. Brook, I Consulting Biologist, Department of Ecology and Behavioral Biology,  ;

University of Minnesota, compared analyses of algae samples obtained 1

from the Mississippi River at Monticello f rom January through August 1971, with samples obtained in 1970, prior to plant opera-l tion.12/ Dr. Alfred J. Hopwood, Department of Biology, St. Cloud i

State College made an assessment of the' impact of the Monticello plant on aquatic ecology in the first six months of operation.13/ -

The reported data show that there has been some effect on algae i

and aquatic life since start of operation, but because of the short period of plant operation, it is difficult to reach conclu-i 1

sions regarding whether the observations are related to the thermal i'

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Exhibit i 6. Monticello show cause statement dated October 15, 1971.

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Environmental Monitoring and Ecological Studies Program, '1970 Annual Report, July 1, 1971 12/

Exhibit 8, Monticello show cause statement dated October 15, 1971.

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Exhibit 7, Monticello shew cause statement dated October 15, 1971.

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) impact of discharges or possibly attributable to other factors.

1 We conclude that during the relatively short NEPA review period,

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continued operation of the plant within the limits for thermal dis-charges set by the MPCA will not cause significant adverse effects I

on the environment. Any incipient effects would be detected by

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f the existing monitoring program and corrective action taken.

1 3.3 Climatolorv a

i Monticello has two 9-cell, induced draft, cross flow cooling

towers as part of the circulating water system. The two adverse meteorological effects resulting from the operation of a wet cool-ing tower are fog and drif t.

A visible plume frequently is discharged from a wet cooling tower. This pluma consists of localized fog. Fog can exist when the air is saturated with water vapor and occurs under conditions of high humidity and low temperature. The concern with regard to t the operation of a wet cooling tower is that under unusual climatic i

conditions, the plume could touch the ground. This could occur under J

conditions of high humidity, low temperature and high atmospheric 1

stability. When temperatures are low enough, this fogging could contribute to local icing conditions. Usually, however, cooling tower plumes rise due to their initial velocity and buoyancy. Since i

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i the cooling towers are not expected to be used during the winter i

j months of this year, fogging f rom the cooling towers is not con-a 4 sidered to create a significant problem during the cold weather I l

months at the beginning of the NEPA review period.

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I Drift is the entrained water droplets that can be carried out i

. of a wet cooling tower. Recent surveys of cooling towers and  !

experience at Monticello have indicated only minor instances of i this effect. Drift from the cooling towers is not expected to j

, create any significant problems during the NEPA review. Any i

problems due to drift can be reduced by installing suitable drift i

i eliminators on the towers.

i We conclude that the continued operation of the plant and the i

required use of the cooling towers will not have a significant
effect on the climatology of the area during the NEPA review period.

1 f The incremental addition of moisture to the watershed is very small when considered in terms of additional rainfall. However , a

significant additional dollar cost would be incurred if a different J

cooling method were required as a result of the NEPA review.

i l 3. 4 Land Une

) The site is located about three miles northwest of the Village of Monticello, Minnesota, on the Mississippi River. Since the i

plant is in operation, changes to the land have already taken place.

The licensee states that except for recent small parcel acquisi-tions, NSP has owned the 1325-acre site since 1925, and that no additional land use is contemplated during the NEPA review period.14/ -

The applicant also states that areas used during construction for laying down equipment, parking, construction force offices and shop buildings have been graded and are being allowed to return to their original state.

All transmission facilities from the plant were completed by

, July 19 70. The licensee states that no additional facilities are planned for installation during the review period.15/ -

We conclude that suspension of operations during the NEPA review period would not affect the use of land.

3.5 Aes thet i es The Monticello plant was built as a commercial facility. No special treatrent was provided, except as the applicant states, "The facilities were given special architectural treatment in an 14/ Monticello show cause statement filed October 15,19 71, page 3.

15/ Monticello show cause statement filed October 15, 19 71, page 4.

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l attempt t o blend them into the surroundings."15/ We conclude that suspension of operation would not affect the appearanta of the plant with the exception of fogging as noted above.

I l 3,6 Noise Nuclear reactors do not prodoce undue noise levels during f

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! operation. The nearest residence to the Monticello plant is 2750

.eet and the nearest roadway (State liighway 152) is approximately 3000 fget from the reactor building. The licensee states that to l; date no complaints have been received regarding noise. Since no t'ajor modifications to the plant are anticipated during the NEPA i

rt view period, the level of noise is not expected to rise during this period.16/

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Based on the low noise level produced in a nuelcar power plant

, and the distances from the plant to the nearest residence or road-way, we conclude that the noise level at the Monticello plant is acceptable and that suspension of operation during the period of NEPA review would not provide a significant benefit.

3. 7 Non-Radiological Ef fluents 3.7.1 Chemical Releases Some discharge of water from the cooling towers is necessary to prevent fouling, because of the accumulation of solids during the 15/ Monticello show cause statement filed October 15, 1971, page 4.

M/ Ibid, page 12, i

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l evaporation process. Chemicals that are used to control fouling of the cooling towers are discharged, but in relatively small quantiti: . The MPCA wahte disposal petuit for the Monticello plant specifies limits on types and contene of chemicals that are al; owed in non-radiological releases to the Mississippi River.

We concur with the HPCA limits and have concluded that the impact on the river of releases of within these Ifmits will not be appreciable. At Monticello, chemical vastes are collected in a holdup pond for settlement or treatment, if required, prior to release to the Mississippi River. To date, these releases have been well within the prescribed limits.b ! There is no reason to believe that the prescribed limits will be exceeded during the NEPA review period. Alternative chemical agents or further treatment of the discharge vould not be precluded by continued operation of the plant.

3.7.2 Sanitary Seware According to the licensee, sanitary sewage from the plant is collected and treated in a system utilizing a 7000-gallen septic tank and a drain field approved by the Minnesota Department of Health.E The MPCA vaste disposal permit for Monticello states 17/

Monticello show cause scatement filed October 15, 1971, page 7.

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l that "No raw sewage or treated sewage ef fluent shall be discharged j to surf ace waters of the state f rom the plant site.19/ W9 conclude -

i j that the manitary sewage generated at Monticello will not have an g

impact on the environment.

I f 3.7.3 H,1,sge11ancoun Relenses_

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} , Normal operation of the Monticello plant will generate small i amounts of combustion products. Sources of these combustion products i

4 are f rom the plant heating boiler which utilizes light fuel oil; monthly testing of the emergency diesel generatorst and periodic i

i , testing of the diesel-engine-driven emergency and fire pumps.

1 The amount of eir pollutants generated from these sources is relatively small. The adverse impact on the environment f rom air l

pollutants generated from the operation of combustion equipment t  :

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at the Ibnticello plant during the period of the NEpA review would be insignificant.

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3. 8 Miscellaneous Environmental Ef fects I

3.8.1 Population 1

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The plant has an operating statf of approximately 70 people who live in ncighboring communities. We are of the opinion that the number of people scattered in these communities are not a 19/ Exhibit 5. Monticello show cause statement filed October 15, 1971, page 2.

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significant burden on the community facilities such as housing and webools. NSP states that no increase in the sfac of the Montice2)o staff is contemplated during the NETA review period.ES!

l 3.8.2 Intake Structure and Fish To reduce the possibility of fish being taken up by the intake flow, the plant river water intake facilities have been designed for a flow of about 0.5 fps, whereas the average river velocity is 4 to 5 fps. In the intake structure, the water passes through a t rash rack followed by two parallel automatically operated travel-4 ing screens. According to the licensee, prior to commercial opera-tion af the plant, certain changes were made to the intake system to reduce the potential for fish damage.21/ Also, as a result of an understanding between NSP, the MDNR, and the HPCA, wash water from the intake structure traveling screens is now returned directly to the river, so that the few fish that might be carried by the i traveling screens are returned to the river.21/ We conclude that

appropriate precautions to mitigate harm to fish have been taken i

l and considering the period of the NEPA review, these precautions i

are adequate.

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Monticello show cause statement filed October 15, 1971, page 12.

1 lbid, page 7.

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3. B. ) }u_ture TentA by EPA 1he appiteant states that in l'ebruary 1970. NSP entered into an agr ee rne n t with the Federal Water l'cIlution Cont rol Administration (now part of the Invironmental Protectior, Agency) to allow use of a small portion of the Monticello site for the purpose of conduct-ing field temperature studies on fish and biological organisms.22/ -

Using warrn wat er discharges f rom the Monticello plant, controlled water t emperat ure environments for the studies will be provided in a series of sn.all canals. Const ruction work by the federal agency will soon be underway on these f acilities and operation is expected to begin in 1972. We concur with the licensee that this facility will not interf ere with the environrnental protection features of the plant and will provide valuable scientific infor-matlon.

3.9 Foreclosure of Alt ernnt Ives DurinR the Prospective Review Period As discussed above, the incremental en"ironmental impact of continued operation of the plant during the full NEPA review would not be significant. The major adverse environmental iropact has already been rede. Alternatives that potentially could be af f ected by continued operation are those re'.ated to ef fluent control measures. These include the environmental impact of routine or 22/ lbid, page 4 f

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) accidental radiologleal releases, thermal and chemical effects of

' water releases and the environmental impact of water vapor from the l

coola nr. t owers. We have examined each of these areas to determine the alternatives that might be foreclosed as a result of continued opera-tion during the NEpA review period and concluded that further opera-i 1

I tion will not foreclose alternatives in this completed operating plant.

j Appendix D to 10 CTR Part 50 requires that a cost-benefit analysis of radiological, thermal and other environmental effects be performed by the AEC during the NEPA review and that a conclusion be reached on whether modification or termination of the license is i varranted. The radiological effects involve both anticipated low-level releases associated with operation of the plant and with j potential releases of radioactivity at somewhat higher levels that could result from an accident.

Routine gaseous and 11guld efficent releases are governed by the limits set forth in 10 CFR Part 20 and the technical specifications which are lacluded in the operating license. NSP is further required to keep radioactive effluents as far below these If mits as practicable..

This will include meeting numerical guidelines for routine relesses comparable to those proposed in Appendix I to 10 CTR Part 50. We l

l conclude that modifications to the radwaste system would not be '

precluded by continued operation.

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rhe probability of ecturrence of accidents and the spectrum of their ronwequences to be considered f rom an environmental cf fects st andpoint will be analyzed using bent estimates of probabilities and realistic fission product release and transport assumptions.

For site evaluation in our safety review extremely conservative assurptions were used f or the purpcse of comparing calculated doses resulting f rom a hypothetical release of fission products f rom the fuel, against the 10 CFR Part 100 siting guidelines. The computed doses that would be received by the population and environment from actual accidents would be significantly less than those presented in our Mont icello Safety Evaluation.i3/ Although the environmental ef fects of radiological accidents are anticipated to be small, if further reduction of postulated accidental releases is required as a result of the full NEPA review, additional engineered safety sys-tems could be added. For example, space is available for the inclusion of supplemental containment air cicanup systens.

Operating parameters also could be adjusted, at some extra dollar cost, to reduce further the environmental impact of postulated accidental releases. We conclude that alternatives related to mitigation of accident consequences would not be pre-cluded by the continuation of operation during the prospective NEPA review period.

- - -23/

Safety Evaluation by the Division of Reactor Licensing, U.S. Atomic Energy Commission in the mat ter of Northern States Power Company, Monticello Nuclear Generating Plant , Unit 1, Docket 50-263, March 18, 1970, page 44

l, ' .

i j  :

i l

4

1hermal effects on the Mississippi River ecology will be small bernuse of the u*.e of cooling towerr., small quantitles of chemicals 8

f rem the cooling towers will be discharged. Some environmental 4

1 effects will res91t from the water vapor released from the top of i

these cooling towers. A significant additional dollar cost would j be incurred if a different cooling method were required as a result of the NEPA review.

I i

j in cummary, no alternatives would be foreclosed by continued operation of the plant from the standpoint of technical feasibility, l

, but significant dollar costs could be incurred if rajor changes

+

in the plant design, such as a change in the method of cooling, were

} required at the end of the NEPA review.

t 4.0 ALTERNATIVES IF SUSPENSION ACTION WERE TAKEN 4.1 Power NSP and its subsidiary, Northern States Power Company (Wisconsin),

own and operate an interconnected system of electric transmission

) lines in Minnesota, Wisconsin, North Dakota and South Dakota, 1

r Electric power is produced in various generating stations or received through interconnections with other power suppliers. The present NSP generating capacity, including Monticello is 3436 MW, and an additional 313 MW of generating capacity from fossil plants is expected to be available in May 1972.24/ TI.a peak load 12, Monticello show cause statenent filed October 15, 1971, page 2.

f f

- i1 -

regis tered to date is 3301 MW, which occurred in 19 71. The projected peak load for i summer of 1972 is 3678 MW.E1 Monti-cello summer rat ing is ' - N' . The projected generating capacity of NSP equals the projected peak load, without any reserve. With no reserve, if the Monticello plant were to be made unavailable, at times of peak loads, power would have to be provided f rom other power generating companies or customers' power consumption would have to be curtailed. In the meantime, older, less efficient, fossil fuel burning plants would have to operate to make up the needed power.

If the Monticello plant is not available, the Upper Mississippi Valley Power Pool, of which NSP is a meuber, will have a reduction in the generating reserve from 12% to 4%.20- Since the contiguous areas also have new nuclear operating teactors c hicct to NEPA s

f review (Point Ileach and Dresden 3), the shortage of power in this i

section of the country could become acute, particularly if l

operation of these plants were suspended during the NEPA review period.

The unavailability of power would require NSP to attempt to replace some of the Monticello generated energy f rom its older, less efficient equipment. Accordir.g to NSP, to replace the energy/ Monticello show cause statement filed October 15, 1971, page 2. 21/ lbid, Appendix 9, page 2. i 16/ Monticello show cause statement filed October 15,19 71, page 15, i I i

i s

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generated at Monticello would require 1.8 million tons: of coal per year, which has not been purchased.2'7/ It is doubt f ul whether the additional supply and t ransport ation f acilitlen required to pro-vide t h i r. amount of coal or oil could be made available in time. Also, the burning of this additional coal in NSP's older generating equipment would release approximat ely 80,000 t ons of sulphur dioxide and 18,000 tons of part iculate mat ter, which would have a subs t ant t al itt. pac t on the environment.2 7/ According t o the licensee, in 19 72 new air pollution control

     ,                                    equipment is scheduled to be installed in several plants to meet       new ai r quali ty requi rement s.2'7/    -

Conceivably, the deferral of shutdowr. c' these plants for installation of antipollution equipment could be required if power were not available f rom the Monticello unit. 4.2 ,C9,tj; We have examined the Nfp estimate of costs that might be incurred through suspension of the Monticello operating license in whole or in part.'8/ If the lleense were to be suspended in its entirety pending completion of the NEPA review, NSP has stated

                ?_7 / Monticello show cause statement filed October 15, 19 71, page 16.

J,8 / lbid, page 17.

 -                    _ _ _ - _ _ _ _ _ _ _ - _ _ .                                                                          O

l . j under oath that the added expenses would amount to about j

                                                                $20,000,000 for the one-year period.24/ This es timat e and the j

i I I j other costs estimates discussed herein do not appear to be un-reasonabic. These costs are based on the asstnption that all ,

energy requirements would be furnished by NSP generation to the l

j extent possibic, and beyond this, purchases from outside sources j are ass umed. In addition, there will be an added cost due to i cont ract ual commitments f or nucicar fuel and reprocessing. This j penalty is estimated by the licensee to be $1,000,000 over the i i one year period.29/ - J

                                          $.0                 DETERMINATION AND llALANCING OF FACTORS I
;                                                                        Pursuant to Section E of Appendix D to 10 CTR Part 50, we have taken into consideration and balanced the following factors in 1

j making a determination whether to s'aspend the operating license for the Monticello plant pending completion of the NEPA environ-1 4 mental review. j $.1 It is not likely that continued operation during the period that the NEPA review will be completed will give rise to an ! incremental impact on the environment that is substantial and undully adverse. As discussed in Section 3.0 above, the 1 29 / Honticello show cause statement filed October 15,19 71, page 17. 4

l s l 1 I { environmental effects are those associated with the operation of the plant. The environmental costs of construction, i.e., those associated with the change of the site from its forner undeveloped state, already have been incurred. l

                   $.2                Continued operation during the prospectiva NEPA review period                 ;

vould not foreclose subsequent adoption of alternatives to plant I design features from the standpoint of technical feasibility if modifications were required at the end of the NEPA review. As dis- ' i cussed in Section 3.1 and 3.9 above, existing flexibility exists in '

   ,                         system performance specifications in the are.a of treatment of radio-                 i active wastes and installation of additional accident mitigating features should improvements in these areas prove necessary as a result of the NEPA review. As discussed in Section 3.2 and 3.7 above, additional reduction in temperature of the heated water from the cooling tooers would not be precluded, nor would a different type of chemical additive or additional treatment of these additives be precluded. A change in the type of cooling facility would be more

! costly, but would be technically feasible. We regard this eventu-i ality as unlikely in view of the absences of apparent substantial environmental impact and we are supported in this judgement by the d ] f avorable comments from other Federal and State agencies on the ex- , pected impacts of operation which are consistent with experience to date. A i 1 L ! I i l

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               ,.                 i l

As discussed in Section 3.1 above, continued operation of the plant will result in some gaseous, liquid and solid radioactive vaste generation. However, the added increment of radiation during the NEPA review period would be very small. 5.3 The ef fects of suspension of the operating license would be s ub s t ant i al . As discussed in Section 4.2 above, the cost of shutting down the plant for one year has been estimated at about $21,000,000. As discussed in Section 4.1 above, there would be increased environ-mental impact due to operation of old, coal burning plants. Continued operation of the plant will increase the level of activity in some equipment. However, as discussed in Section 3.1.1 above, NSP has proposed to modify the gaseous radwaste system which will ef fect a substantial reduction in the stack activity release rate. We conclude that the large cost of plant shutdown ! ($21,000,000) outweighs the possibility that the slight increase in radioactivity levels of some equipment during the period of l l continued operation would affect substantially a subsequent decision i j regarding me,dification of the facility to reduce environmental impact.~ i i l Af t0r balancing the factors described above as to environmental l impact of continued operation and the potential for foreclosure I I

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of alterns.t Ives an a result of further operation of the plant against the effects of shutdown costs, we conclude that the operating licci.ne for the Monticello Nuclear Generating Plant should not be suspended pending completion of the NEPA review. Pending completion of the full NEPA review, the holders of Provisional Operating License No. DPR-22 may proceed with the operation of the plant. The discussion and findings herein do not preclude the AEC an a result of its ongoing HEPA environ-mental review from conti ng, modifying, or terminating the , operating license or its appropriate conditioning to protect environmental values. I

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