ML20114E971
| ML20114E971 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 11/03/1969 |
| From: | David Nelson NORTHERN STATES POWER CO. |
| To: | Ramey J US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML093631134 | List:
|
| References | |
| NUDOCS 9210120325 | |
| Download: ML20114E971 (15) | |
Text
. -.
... ~,..
=-,
Q m
cm; ~3
(
m'%
- : s V
N O R T H E R'N STATCS POWCR C O M-P A N Y 9 3.... N# *
- G 414 NICOLLET M ALL p.,,"
M I N N C A Po b e s. M I N N E S. OT A 554o1-t LAW DEPARTMENT '
tetr. PHONE 3 30.e soo oo% a t.o.
m a t..ow ARCA C O C E 012
.,-o o~...,
..~..
.m.
J OS.o G. Mcfe A NNON Davi PM D Weltaho-sR.
9 november 3, 1969 The Honorable James T.
Ramey Commissioner U.
S. Atomic Energy Commission Washington, D. C.
20545'
Dear Mr. Ramey:
I am enclosing, for your information and file, a copy of a letter dated Octcber 30 from Robert H. Engels, President,.
Northern States Power Company, to Mr.-Robert Tuveson, Chair-i man, Minnesota Pollution Control Agency.
Attached to the letter are a ccpy of the Minnesota Pollution Control Agency permit issued for the Monticello Plant and the comments of Northern States Power Company with reference to the-terms of the permit.
As you may hncw, Governor LeVander has,.upon several occa-s ion s, publicly criticized the Company-for not submitting its comments with reference to the State permit.. The encicsures are an attempt by the Company to-respond to'the Governor's request.
My best personal regards.
Sincerely,
.,/.
L
/U s
.,y,, e,,,/ [.
M 4 > ev s-DONALD E. NELSON-Er, closures cc:
.Kr. Howard Shapar {w enc 1]
3..
,.'~~~ ~/(""5
. J. ~ t J,
[
9210120325 920520
~
" * " " ' " ' * * * " " ~ ~
m _
.. ~ _ _ -
e~
1.
i
(
- ka Q
NORTHCRN OTATCC POWCR C O FA P A N Y M 4 N N E A PO L8 0. MIN N E G OTA 5 5 4o1 i
1
..u.
e October 30, 1969 i
PJ Robert Tuveson, Chairman l
Minnesota Pollution Control Agency Albert Lea, Minnesota 56007 f
Dear Mr Tuveson With the hope that it vill clarify' cur objections to portions of the Monticello
}
plant permit and lead to early resolution of differences, we submit the attached l
caterial for consideration by the Minnesota Pollution Control Agency.
1 All will agree the subject of radioactive vaste is an extremely technical one.
Our reluctance to put our permit objectionb in writing has not been based on any unwillingness to share facts with the Agency.
Rather, we have found it cost dif-ficult to state these in a way that the information wo"ld not be misconstrued and i
vould be genuinely useful to you ard to 'the other acabers of the Agency. We had j
therefore advocated continued face co-face coctunication and discussion with your staff and consultant in an effort to find solutions.
i Eut perhaps this written report vill help to focus on the issues and clear the way 1
for scaningful discussion. Your agency and our cc pany have cocnon objectives.
We both are ce==itted to safeguard the health arJ well-being of the public.
At 1ssue only is the difference in opinion of how to achieve these objectives.
s
- We are confident the.vaste treateent and handling facilities at Monticello are
{
cntirely adequate for the intended purpose, which is the protection of public health and cafety. The addition of more waste; control equip =ent, we believe, is unnecessary; but we are villing to explore this subject further_vith your staff and your consultant.
It is our wish to share and discuss facts and to engage in cutual problem solving.
f Though we have filed suit, we have previously stated c:.d now recffir= our desire to continue discussions with the 12CA. We do not. consider litigation a barrier to reaching an agreement. There is no reason we caa see why the-M?CA and NSP, working together, cannot find a solution for safeguarding the environment, and we wish to continue our discussions to re. solve the differences.
6-f
pOE-jg(CBgc
,~
NORTHERN GTATES POWER COMPANY
+
Mr Robert Tuveson Page 2 October 30, 1969.-
a i,
e hope the attached corr.entary on Permit 50 5633 will be a constructive step in that direction.
'w'e look forward to hearing from you at.ycur earliest convenience.
Very truly yours
/
i nh
./f 4 4
e Robert H Engels President h
I a
ce John P Eadalich 4
4 t
k i
V J
en em
4 9
N.4THERN CTATZs POWCF1 bMPANY M
4
.y d
gu Attachreat to Iatter [hted Cetob2r 30,1969 frcm R. H. L'ngels, President, Northern States Paeer Corpany, to Ibbert Taveson, Cuim,an, Finnesota Pol-lution Control Agency.
MI1:NESOTA POLLUTICN CCmcL AGB'CY PIGMIT No. 5633 DATED FAY 20, 1969 In its review of the waste disposal pemit issued by the Pollution Control Agency for t orthern States Poaer Canpany's Fcnticello Ibclear Gan-ersting Plant, ISP has no significant difficulties with the sections of the pecit entitled "Gmeral Co.ditions" and "Special Conditions Palating to Cbn-ventional Wastes". Hwever, the section entitled "Special Conditions Palat-3 f
ing to Padioactive Waster," contains ambiguities and unworkable features which will be sumarir x1 later in this menorandum.
Se Special Conditions Palating to Padioactive Wastes are not lircited to a specification of levels of pemissible waste release, but also contain i
ec-ditions governing plant operating facilities and operating rethods. A
~
e canparison on an isotope-by-isotope basis of the pemitted levels of radio-i active waste release as listed in the PCA pemit indicates that there is no consistent relationship between tM PCA levels and those peritted by Federal standa:ds pronulgated by the Atomic Energy Comrission in Title 10, Code of
,i Federal Pegulations, Part 20. m erefore, it is inaccurate to say that the PCA pemit is fifty times (or any other nu:rber) nere restrictive than.Mr i
sta-dards or any other widely reccgnized standards.
Se only s a'e: art which can be :-
- in this regard is that the PCA pe=it establishes waste release liri
4
.r
_ 7~ -
l
{.
,,)
a 4-i f.
which are very substantially nore restrictive than those peritted by i
Federal law.
l A sumary _of lSP's analysis of the PCA pecit gives th3 -folicwing gen-t eral conclusicas with regri to the Special Conditiens Relcting to Radio-I i-active Wastes:
i l
1.
As presently designec, the }bnticello Plant probably can co ply i
with conditions 1, 2(a), 2(d), 2 (e), 3, 9,10,11,12,13,14, 8
S.
and 15. Cenpliance with these conditicas depends upon clarifi-i' cation cf portions of the pemit language.
i i
l-2.
With the additica of a substantial a==t of waste treacet equip-4 rent-and with the consequent e>: pense and delay, the plant could be' t
i nodified to pentit prcbable cmpliance with Ccnditions 2(b), 2(c),
.4, and 5.
Clarification of pemit lenguage, especially-regarding
?
)
techniques of reasur&mt, will be required.
i 3.
With the addition of a substantial arc =t of waste treat ent eo.f p-i rant and with consequent expense and delay, the plant' could be
+
l Rodified to #t_ pcssible cenpliance with Conditions 6,- 7,land 8,:
1 i
but its availability as a reliable pcuer-prcduction facility couli l
be c=pn=ised seriously.
Even if the substantial expanditures for additional waste treat =.ent 4.
l equiprmt ard the correspending delays 'in in-service _cperation are t-undertaken, the enfommt of the PCA pe=it will not. result in 9-E 4
4 I
, ~...
(
(
ct%h' w
anp significant additional protection of the public health and
~
safety. On the contrary, the penrit will result in significant additic".al radiological exposure of plant personnel, in the handl-ing of larger quantities of radioactive wastes, in an overall deg-radation of safety factors in p1>,nt equipment, and in unprdictable l
and undependable operatica of' the plant as a pcwer production fa-cility.
tu foi,'owirs is a paragraph-by paragraph cer:me:PAmy on the fifteen canditions in the PCA permit.
The nu:rben in the following text refer'to the nu:-bered Special cac.dittent Prlating to Padicactive Wastes beginning on Page 4 of Perrit To 5633:
1.
IsP is in ccrplete accord with the general policies stated in Con-dition 1.
NSP has stated publicly that its goals are the same as those stated in the PCA permit, namely that the actual levels of radiation exposure of Im bars of the public shall be kept as far below reccqnized safety 11 rits as possible, cc.sistent with tech-nolcgical feasibility and reasonableness of ecst.
l 2.
?.e second ecndition of the PCA permit deals specifically with operating equipent and procedares.- Tnis'is inappropriate because l
the perrit not only specifies the li:rits for waste releases, but also
(.
atte pts to dictate the equipmnt which r.ust be used to achievu l
these lirits. Specific c~,... cats relating to the five parts of i
conditica 2 are as follws:
wm.wm
(,'
{
05 A 9
l (a) mis provision requires that isP treat liquid and gaseous wastes in the manner proposed in NSP's Final Safety Analysis e
Report s'dxritted to the Atcmic Energy Can-ission. NSP ob-I viously will ocaply with this require ~ent.
(b) mis provision requires the renoval' of certain gaseccs radio '
isotopes to the extent obtainable "by effective activated -
i charcoal filtration of the entire air ejector off-gas flow".
l Cmpliance with this part of the State per:rit muld reqaire 8
l NSP to install substantial additional gaseous waste treatment
(
equipent in the plant, with the attendant additional cost and 4
i I
delays. It is NSP's position that this is an unnecessary re-i quirerent, because envirenrental monitoring in the vicinity 2
J of 1: oiling water reactors'similar to Ibnticello has indicated i
e i
that releases of these gases (radiciodine and other halogens) are so 1cw that they arq negligible when related to recognized f
standards. Serefore, installation of the filtration equipent t
would not effect any inprovenent in public health and safety.
Se Panticello stack e:rission and environrental renitoring pro-
+
grars will serve as a control on halogen releases.
Y 6
(c) mis condition requires routine ion-exdange treatment of ficer-drain and cherical wastes. As writtes, this is an unreasonable-i requirerent, because derine.ralization is no: an effective form 2
of treatrent for such wastes. Se present treatre.t system in-
.i stalled in the plant provides for filtratica of these wastes.
J.1 i
i
i
{[
(
l 1
1 4
l Additional evaporation cquipunt could be installed, with con-f sequent eye and delays, to treat chemical wastes further, but there is no evidence that this would effect any inprovcaent 4
?.
[
of public health and safety. NSP is considering the use of disposable clothing to minimize liquid laundry wastes.
1 i
t (d)
This condition requires that fuel rods be inspected for "de.
I-tectable or significant ancunts of uraniun on their external surfaces" and that the results of the inspection be reported i
a l
"in detail" to the Agencye Application of this provision re-1-
j quires the definition of what constitutes "detec*dle or.sig-4 nificant ancunts" of uranium. h e fuel fabricator has=develcoed assembly techiques which mini:rize the amount of radioactivity on the external surf' ces of the fuel rods, and NSP will conduct j
a t
i a.dditional quality assurance inspecticns at the-fabricator's d
plant to deter:rine that these procedures are follcwed.
1 i
(e)
This condition requires, anong other things, the develo;rnent 4,
and application, "to the full extent possible", of the nethods i
- ~
p and techniques for lccating and identifying leaking fuel cds i
{
after operaticn 'of the reactor begins. There are no-inspection techniques known at the present time which are adequate *w ident-ify all fuel rods which right develop leaks.. NSP cbviously will i
- j. _
not install any fuel rods in the reactor which are'kncWn to be defective, and NSP will use the best techniques available in 12 -
l 4
1
.a,.~
a
~,
-,a.
..,.....,. _... -. ~.
t
(;
gN N
?,
1
\\_i j
c.-
l the industry to idantify leaking fuel cicments'. NSP will use i.
j these techniques during refualing outages and at other tines -
t.
l -
when it is necessary to. identify leakmg fuel ele:ents in the 4
j core.
8 4
l 3.
mis aandition limits the gross beta samna radioactivity of ligaid effluents in the discharge canal to an annual average of 10-7.- ricro-7 J
j curies par milliliter above natural' background.- As is custcnary, i
. NSP asst =cs that tritium is not-included in the reasuremnt of.
j t
f i
gross beta-sa=a radioactivity. NSP has indicated publicly I
it is prepared to meet the 11ritation in PCA Pe=it Cccditicn 3.
4.
':his ccadition lists permitted concentrations in the discharge canal.
for nineteen specified radioisotcpes, with limits given for canal 4
ficws of 645 cubic feet per-second and of 36 cubic feet per seco.d.
i 4
-hese pemissible concentraticas are indicated as applying on an i
j annual average basis, but there is a confusing reference.to average-r daily c=centratica. In addition, the candition specifies that the j
average daily discharge c = al concentration of any other radioisotcpn not listed shall not exceed 1/3000 'of the ICEP limits or 1/300-of th<e i
i-j AEC lirits. Apart f.C tha semantic problers introduedby the rixing.
r.
l_
of annual and of daily levels, NSP is concerned because the discharge levels listed in the perit are in nest cases so 1cw that it-is not i
technically feasible to measure the concentraticas. In all cases, it would be i.p.ssible to reasure the icw levels of concentra-icn in de
~
discharge canal itse2f, so reasurements would have to be rade in the
}
13 _
1 1
f s
-w
+
a-s----c-r w...
4 xe m y av.yyg-aw
-ryg
.w n
_,,.w--
+gy. r e t,-yg--e-rWs--
, we sr y +-v1yw
0$y'h 9
waste sanple tank prior to wasta release. Even at the expected f
icvels in the tank, the limit of dotmetion sensitivity for nest of the isotopes is greater than the expected concentraticn in the
[
waste tank. For these reasons, NSP believes that it will be im-possible to insure cc pliance with Condition 4.
i 5.
':he first part of Condition 5 permits a seven-day average gross beta-gama activity release in the discharge canal of. 5 times 10-7 ricrecaries per rilliliter, in excess of existing background radio-i activity and presurably disregarding tritiu:n. MSP expects to ccuply
^
with this part of Condition 5.
The second part of Condition 5 per-mits an average concentration, assumed to be weekly, of a:ry specific radioisotcpe to reach five tires the value given in Condition 4. 'Ihe problems of reasurement listed in the ccnments in Condition 4 also i
pertain to Condition 5.
).
6.
':his condition lirits the ps beta-ga=a activity of the gaseous i
effluent to an annual average of 0.01 curies per second. The radio-activity in the gaseous effluent is related to the arount of fuel leaks in the reactor core.
If the fuel perfc=s in an umalisticall f
ideal ranner, it is conceivable that the lirit of 0.01 curies per j
second right be net by the plant as presently designed, but the prob-ability of this circumstance occurring over a long-*2nn basis is so srall that this condition in the PCA pe=it allcws no cperating rar-gin in the event that fuel perfomance is less than ideal. Operat-ing experience from existing nucle-p::wer plan *a fem NSP to the 4
h 14 -
g gg.
m-Ee es 4
ef P"-
S' N
gN p
4 j
conclusion that the Fbnticello Plant rest likely could not operate j
for any substantial period of time under Condition 6 without being j
forced to shut d wn for the detection and replacement of leaking fuel. t ese frequent start-ups and shutd xns of the reactor would 1
j expose operating personnel to additional in plant radiation, would r
require the handling of additional quantities of radioactive waste, f
and muld degrade the overall safety factors of the plant equipment.
}
In an attempt to reet the extrcrely restrictive waste release limi-
]
tation of Condition 6, NSP could install substantial additional l
gaseous waste treat:nent equipnent, with. the corresponding heavy i
j expenditures and ccast:nction delays, but even with the installation of this equipmnt, cerepliance with condition 6 could not be guaran-l teed in a manner which would be consistent with the need for reliable power production f:cm the Fbnticello Plant.
i l
7.
this condition lists permissible concentrations of fifteen radio-i isotqies to be reasured in the plant gaseous effluent stack before
?
j r21 ease to the atnesphere.
?a condition also has an.overall liri-tation on other radioisotopes not listed.
It is ISP's position thaf it is irpracticable~ to identify and reasure these isotopes in the stack in the ranner.@ed by the PCA peredt. - 'Ihe app:cach of the pCA perrit in establishing an effluent. standard in the plant stack differs funda. ntally from the AEC approach to health and i
w safety, which establishes lirits at off-site locaticns, where the a
public is present.
te isotopic levels indicated l
15 -
4 4
~~
e os~~-
n.
e s-..,.
-w4,, -,
.%m. - +. - --..->
f (fh 0'
99 in the PCA permit to be ncasured in the stack are about one villion tires nere restrictive than the equivalent of AT requiru:m:nts at the site boundary. Because of the restrictive levels in the PCA perrrit, it is probable that the plant will be able to cperato only for a lireited period of tine before requiring shutdoan to search for ard to renove leaking fuel. Se installation of the additional gasecus waste treatnent Mment mentioned in the diseassion of Condition 6 would permit a closer apprcach to the lirits listed in Condition 7, but the problem of neasurmt of the verf Icw levels of activity specified in the PCA permit wculd rmain.
8.
his condition noddies Condition 7 by allcwirq a weekly gaseous release rate of 0.05 curies per second. mis value corresponds to a nere reasonable long-term release rate based upon expected fuel perfonmnce, but'it is likely that this rate of activity release could prevail for several weeks, rather than for uinply one week.
Under the tems of the PCA pemit, the plant, as presently designed and constructed, would have to shut d wn frequently for work en the core, with the previously rx:ntioned disadvantages of r diological
+
e.xposure to the workers, handling of additional wasceo, and over-a all degradation of plant safety, m e installatica of the additional waste treatnent equipmem mentioned in the discussion of Condition 6 could be reads, but the difficulties of nessure:mnt discussed with i
Conditions 6 and 7 also apply to Cnndition 8.
9.
Bis previsien of the pCA pe=i.t establishes a naxi:.r gaseous waste 4-
~
_t 4
J release rate of 0.30 curies per second for any fifteen.minuta period and establishes a limit on the radioisotopes given in i
condition 7.
NSP expects to be able to ncet the overall limit 1
i of 0.30 curies per seccnd, although such a limit rcmes rest of
~
I the operating reargin which should be available to the plant oper -
ators for short-term cmegencies. 'Ihe portion of Condition 9 which d
refers to neasurement of stack concentrations of specific isotopes i
cannot be explied with because of the technolcgical difficulties of neasure ent nenticned for Conditices 6, 7, and 8.
4
- 10. Condition 10 requires routine effluent ncaitoring "to identify and quantitatively account for all specific radioisotopes that i
are released in significant quantities". NSP's regular plant 11 cperating procedures provide for quantitative identification of radionuclides which have a significant relationship to public i
health. Haaever, the language of the pCA permit, and its reference.
[
[
to state:entsin the Tsivoglou Report of January 31, 1969, leave I
- co.siderable uncertainty as to the arount of identification which 1-muld be reqaired by PCA. It appears that the PCA permit contem7 plates identification of the 'incremontal addition by the plant of i
isotopes in quantities which are so minute as to be unidentifiable by presently feasible techniques of analysis.
i
- 11. 'Ihis condition @es that an environ:nantal nenitoring prcgram as described in the Tsivoglou Prmm4 of January 31, 1969 nnst be 4
17 -
3 I
'1
-.~ ~ ~.
4 w
y-r,~..
w s
-,-n.--,
o m
,,e n ~
em
,p a.
,e
_. _. _. ~ _ _
e r ',.
1 g
c C h,.d p -
er 1
.j-
=
hI condacted. SSP his inaugurated such a program, even though l
most authorities who have revicaed the program regard it as un-l warrantedly extensive.
i 3
- 12. Tais condition recuires. that the results of effluent r.aasurcrents
~
l-j and of the enviro = ental :=nitoring program be reported ncnthly 4
ll-to the Pollution Control A;cncy.
'Ihis provision can be ret, al-i l=
though custmarily enviro =antal ronitoring progra s provide for; l
(i
- j collection of data over a longer period of thre, usually six nonths j
I'll or a year, and the submission of this data in a semi-annual or an-it nual report.
i i
- 13. This coadition rcqaires cooperation with the Pollution Cca. trol
Agency and with the Finnesota State Eoard of Health in the de-h,: veleprent of em?rgency plans to be folloaed in case of plant 1-t j accident. NSP's < ergency plans conte:rplate full cocperation i-i with all Fcderal,5 ate, and local health and safety agencies, and a
- i, these plans will beccre a part of the AEC operating license for i<
j .the hbnticello Plant. Ccndition 13 of the PCA c.errit is written g {; : broadly a.d refers to language in the Tsivoglou Feport of Janumy 31, 1969, which seers to indicate that State agencies should be alloaed { to take control of ple.nt operations durinJ emergencies. NSP will 4 - cooperats with State agencies to the raxint.ru practicable ex: cat, [ but NSP =st raintain fuu control of plant cperaticns at all ti es, i ~ i { including e.argency conditions. 1
- 14. This edition li-its the PCA carrit to the first year of pla.t-i-
l 4 ii .c ) a. E , - ~.. .m._.
6 ~.Q? y-operation and provides for changes to the pemit at any tire and for annual reneeal by the Agency. NSP reccgnizes the decirability of frequent review of the plant operating data by the Pollution Control Agency. NSP will keep the Agency fully infomed of the plant,cperating results. In view of the li:nited nuclear-poacr-plant expde on the staff of the Pollution Control Agency, it appears that the requirement,for annual reneaal of the operating ipemit could introduce serious procedural problems for both NSP '/ and the Agency. A recre workable provision would be the issuance ..y of a 1cag-term pemit, with provisions that the pe=it limits be , modified by the Ayncy if required after a review of actual oper-ating experience of the waste-treatment equipnent. i
- 15. 'Ihis condition see to confi:m state:nentsmade by NSP and by reccgnized authorities in the field of reactor health and safety to the effect that the vary. loa levels of radioactive releases per-ritted in the PCA penrit are considerably raore stringent than are required for health and safety.
8 AvD/lj _,p-
- _ee.>-i-
- ense'
- u
~ - _ _ - _ _ _ _ - _. _-}}