ML20125B394
| ML20125B394 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 07/28/1971 |
| From: | Morris P US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Dienhart A NORTHERN STATES POWER CO. |
| References | |
| NUDOCS 9212090341 | |
| Download: ML20125B394 (26) | |
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JUL 2 8 571 Docket No. 50 263 Northern States Power Company ATTN Mr. Arthur V. Dienhart Vice President, Engineering 414 Nicollet Hall Pinneapolis, Minnesota 55401 Gentlemen:
It has been of interest in the nuclear industry that in some reactors fueled with UO s Power changes may be followed by an increase in the 2
iodine content in the primary coolant.- Data taken at the Tsuruga power reactor from April to May 1970 indicate that-following shutdown ofthereactor,tgeI-131concentrationintheprimarycoolant-increased 3
by a factor of 10 to 10. We understand that the increase of iodine content af ter a scram has also been observed at Monticello. We do not-know the reason for this phenomenon.
In order to gain an understanding of this-anomaly, we would appreciate your taking some-data at the Monticello-reactor. The data would consist of taking primary coolant samples at a frequency consistent with changing operating ' para:neters, i.e., variation in power level and primary coolant' cleanup.
Samplea taken f rom just before shutdown until the iodine content in the pri-mary system levels off would also be important.
We would like to discuss this matter with you at your convenience to get your views on taking these data.
Sincerely, original siend by Peter A. Morns Peter A. Horris, Director
~ Division of Reactor Licensing cc:
Mr. Gerald Charnoff Shaw, Pittman, potts,
'Irowbridge 6 hadden 910 17th Street, N. W.
Washington, D. C, 20006 (See attached for-distribution)
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.......u October 30, 1969 Mr Robert Tuveson, Chairman Minnesota Pollution Control Agency Albert Lea, Minnesota 56007 Dear Mr Tuveson With the hope that it will clarify our objections to portions of the M material for consideration by the Minnesota Pollution Co onticello Our reluctance to put our permitAll will agree the subject of radioactive vaste one.
unwillingness to share facts with the Agency. objections in writing has not been based o to state these in a way that Rather, we have found it most dit--
j ficult would be genuinely useful to you and to the other members of the Ag
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therefore advocated continued face-to-face communication and discus We had j
staff and consultant in an effort to find solutions.
s on with your But perhaps this written report will help to focus on the issues and clear th for meaningful discussion.
Your agency and our company have common objectives.
e way We both are committed to safeguard the health and well-being of the publi issue only is the difference in opinion of how to achieve these objectives c.
At We are confident the waste treatment and handling facilities at Monticello health and safety. entirely adequate for the intended purpose, which is the protecti are unnecessary; but we are willing to explore this subject further w and your consultant.
mutual problem solving.It is our wish to share and discuss facts and to engage in Though we have filed suit, to continue discussions with the MPCA.we have previously stated and now reaffirm our desire i
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 we wish to continue our discussions to resolve the differences. find a solutio i
3417
4 Noh.HERN CTATE8 POWER Cs APANY Mr Robert Tuveson Page 2 October 30, 1969 We hope the attached commentary 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 p
m Robert 11 Engels President ec John P Badalich
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I THERN STATED POWER
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1 Attachment to Istter Dated October 30, 1969 fmm R. H. Engels, President, Northern States Power Ompany, to Ibbert 'Ammon, Omirman, Mimesota Pol-luticm control Agency.
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,J MINNE:90TA POLTETICH CCN1 POL 1GtCl PERMIT 10. 5633 DATED MAY 20_, 1969
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In its review of the waste disposal permit issued by the Pollution Otntrol Agency for Northern States Power Ccmpany's Manticello Nuclear Gen -
erating Plant, NSP has no significant difficulties with the sections of the permit entitled " General Conditions" and "Special Conditions Relating to Con-ventional Wastes". Ilawever, the section entitled "Special Conditions aelat-ing to Radioactive Wastes" cantains anbiguities and unworkable features which will be sumarized later in this nuorandum.
'Ihe Special Ccnditions iblating to-Radioactive Wastes are not limited to a specification of lewels of pennissible waste release, but also contain canditions governing plant operating facilities and operating methods. A emparison on an isotope-by-isotcpe basis of the permitted levels of radio-active waste release as listed in the PCA permit indicates that there is no consistent relationship between the PCA levels and those permitted by Federal standanis prmulgated by the Atomic Enon3y Comnission in Title 10, Code of Federal Begulations, Part 20. brefore, it is inacr2 rate to say thet the PCA permit is fifty tinos (or any other nunber) re.e restrictive than AEE standards or any other widely recognized standards. 'Ihe only stateent which can be mde in this regard is that the PCA permit establishes waste release limits 3417
t i which are very substantially nore restrictive than those pennitted by rederal law.
l 1
A sunnary of NSP's analysis of the PCA pennit gives the folicwing gen-eral conclusions with regard to the Special Corditicns Relating to Radio-active Wastes:
1.
As presently designed, the Fbnticello Plant probably can caply with conditions 1, 2 (a), 2 (d), 2 (e), 3, 9, 10, 11, 12, 13, 14, ard 15. Otmpliance with these conditicns depends upon clarifi-cation of portions of the permit language.
2.
With the additicn of a substantial amount of waste treatnent equip-ment and with the ecnsequent expense and delay, the plant could be nodified to permit probable conpliance with Cbaditions 2(b), 2(c),
4, and 5.
Clarification of pennit language, espacially regardiry techniqms of ncasurment, will be ruquired.
3.
With the additico of a substantial amount of waste treatmant equip-nent and with consequent expense and delay, the plant could be ntxiified to permit possible ccmpliance with Conditions 6, 7, and 8, but its availability as a reliable pcwcrTroducticn facility could be ccnprornised seriously.
4.
Even if the substantial expanditures for additional waste treatnent cquipnent ard the ccn responding delays in in-service operation are undertaken, the enforement of the PCA pennit will not result in
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. anf significant additional protection of the public health and safety. On the contrary, the pennit will result in significant riditional radiobgical exposure of plant personnel, in the handl-ing of lxver quantities of radioactive wastes, in an overall deg-1 radatAcn of colety factors in plant (quipant, and in unpredictable and t.n6tpendable operaticn of the plant as a power-production fa-cility.
The follcuire is a paragraph-by-paragraph comentary on the fifteen cmditions in the PG permit. The numbers in the following text refer to the numbered Special Ccoditions aclating to Radioactive Wastes beginning on Page 4 of Permit tb. 5633:
1.
!SP is in catplete 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 PG permit, namely t?at the actual levels of radiacion exposure of nutbers of the public shall be kept as far below recognized safety limits as possible, consistent with tech-nological. feasibility and reasonabicness of cost.
2.
The secxnd condition of the PCA pennit deals specifically with operating equipment and procedures, this is inappropriate because the permit not only specifies the limits for waste releases, but also attenpts to dictate the equipnent which must be used to achieve these limits. Specific cnmtnts relating to the five parts of Cbt.lition 2 are as follcust
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4 (a) 'Ihis provision ropires that tGP treat liquid and gaseous wastes in the manner proposed in !EP's Final Safety Analysis i
Report suhnitted to the Atomic Diergy Ctmnission. ISP ob-viously will cmply with this requixumnt.
(b) W is provision requires the ratoval of certain gaseous radio-isotopes to the extent obtainable "by effective activated charcoal filtration of the entire air ejector off sas fIm".
Carpliance with this part of the State permit would require NSP to install substantial additional gaseous waste treatumt equipnalt in the plant, with the attendant additional cost and d21ays. It is NSP's position that this is an unnecessary re-quiruTent, because envircnmental nonitoring in the vicinity of boiling water reactors similar to !bnticello has indicated that releases of these gases (radiciodine and other halogens) are so Icw that they are negligible when related to recognized standards. %erefore, installation of the filtratic.a equipnent would not effect any improvenunt in public health and safety.
'Ihe Ibnticello stack anission and environnental nunitoring pro-grans will serve as a control on halcgen releases..
(c)
'Ihis ocndition requires routime icn-exchange treatnent of floor-drain and chemical wastes. ~ As written, this is an unreasonable requiranent, because danineralization is not an effective form -
of treatncnt for such wastes. 'Ihe present treatnent systen in-l stalled in the plant provicbs for filtration of these wastes.
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Additicnal evaporation equipnent could be installed, with con
'f sequent expmse and delays, to treat chenical wastes further,
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but there is no evidence that this would effect any inprovanent of public health and safety. E P is considering the use of disposable clothing to minimize liquid laundry wastes.
(d) mis condition ra]uires that fuel rods be -inspected for '"de -
tectable or significant anounts of uraniun on their external surfaces" and that the 'results of the inspection be reported "in detail" to the Agency.. Application of this provision re-quires the definition of what constitutes " detectable or sig-nificant annunts" of uranium. Se fuel fabricator has developed asscubly techniques which mininize the' anount of radioactivity.
cn-the external surfaces of the fuel rods, and NSP will conduct adiitional quality assurance inspections at the fabricator's plant to detennine that these procedures are folicwed. -
(e) mis candition requires, anong other thiigs,' the'.develcpnent.
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ard application,. "to the full extent possible", of the methods and techniques for lcx:ating and identifying leaking fuel rods after operation 'of the reactor begins.- W ere are no: inspection:
techniques kncun at the present tine 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 'are-kncun to be -
defective, and NSP will use the best techniques available in m
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6-the industry to identify leaking fuel elemmts. NSP will use these technicpes during refuelirg outages and at other tines when it is necessary to identify leakirg fuel elenents in the Core.
3.
'Ihis condition limits the gross betaganma radioactivity of liquid effluents in the discharge canal to an annual average of 10-7 micro-curies per milliliter above natural background. As is custmary, NSP assumes that tritium is not included in the measuranunt of grcss betayama radioactivity. NSP has indicated publicly it is prepared to meet the limitation in PCA Permit Condition 3.
4.
his ccndition lists permitted concentrations in the discharge canal for nineteen specified radioisotcpes, with limits given for canal ficws of 645 cubic feet per second and of 36 cubic feet per seccnd.
mese permissible ocnccntraticns are indicated as applying cn an annual average basis, but there is a confusing reference to average daily ccncentraticn.
In addition, the condition specifies that the average daily discharge canal otncentration of any other radioisotcpes 1
not listed shall not exceed 1/3000 of the ICRP limits or 1/300 of the AEC limits. Apart frun tle semantic problems introcueed by the mixirs of annual and of daily 1cvels, NSP is concerned because the discharge-levels listed in the permit are in nost cases so 1cw that it is not technically feasible to measure the concentraticns. In all cases, it would be impossible to neasure the Icw 1cvels of concentration in the discharge canal itself, so measuremants would have to be made in the
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. waste sanple tank prior to waste release. Even at the expected levels in the tank, the limit of detection 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 cmpliance with Condition 4.
5.
The first part of Ccrdition 5 permits a sevm-day average gross beta ganma activity release in the discharge canal of 5 tines 10'7 microcuries per milliliter, in excess of existing background radio-activity and presunably disregarding tritium. tEP expects to cmply with this part of condition 5.
The second part of (bndition 5 per-mits an average concentration, assuraxi to be weekly, of any specific radioisotcpe to reach five tines the value givm in Cbndition 4. The problenn of neasurment listed in the ccnments in condition 4 also pertain to conditicn 5.
6.
7his condition limits the gross beta-ganma activity of the gaseous effluent to an annual average of 0.01 curies per scoand. The radicr-activity in the gaseous effluent is related to the anount of fuel Icaks in the reactor oore. If the fuel performs in an unrealistically _
ideal mnner, it is conceivable that the limit of 0.01 curies per second might be not by the plant as presently designed, but the prob-ability of this circunutance occurring over a long-term basis is so snnll that this condition in the PCA permit allows no operating mar-gin in the event that fuel performmcc is less than ideal. Operat-ing experience fran existing nuclear power plants forces IEP to the
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P conclusion that the Manticello Plant nost likely could not operate for any substantial period of time under ccndition 6 witicut being forced to shut doan for the detection and replacenant of leaking ftel. 'Ihese frequent start-ups and shutdoans of the reactor v,uld expose operating personnel to additional in plant radiation, would require the handling of additicnal quantities of radioactive waste, and would degrade the overall safety factors of the plant equipmnt.
In an attmpt to noet the extrumly restrictive waste release limi-tation of Condition 6, NSP could install substantial additional gaseous waste treatment equipnent, with the corresponding heavy expenditares and ccnstruction delays, but even with the installation of this equipnent, ocrupliance with Condition 6 could not be guaran-toed in a manner which would be consistent with the need for reliable
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power production frun the Mmticulo Plant.
7.
'1his conditi.on lists pennissible concentrations of fif teen radio-isotopes to be neasured in the plant gaseous effluent stack before release to the atnosphere. Se condition also has an overall limi-tation on other radioisotcpes not listed.
It is tEP's position that it is impracticable to identify and neasure these isotopes in the stack in the manner required by the PCA permit. W e approach of the PCA permit in establishing an effluent standard in the plant stack differs fundamentally from the Air approach to health and safety, which establishes limits at off-site locations, where the public is present.
'Ihe isotopic levels indicated
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. in the PCA pennit to be neasured in the stack are about coe millicn tines nere restrictive than the equivalent of ABC requirements at the site boundary. Because of the restrictive levels in the PCA permit, it is prob *,ble that the plant will be able to operate cnly for a limited period of the before requiring shutdown to search for and to renove leaking fuel. 'Ihe installation of the additional gasocus waste treatnent equ.tpnent mentioned in the discussicn of Condition 6 would permit a closer approach to the limits listed in Ccndition 7, but the problan of neasurment of the very Icw levels of activity specified in the KA permit would ranain.
8.
'Ihis conditicn nodifies Condition 7 by allowing a weekly gaseous release rate of 0.05 curies per second. 'Ihis value correspands to a nore reascnable long-tenn release rate based upon expectal fuel performance, but it is likely that this rate of activity release could prevail for several weeks, rather than for sinply one week.
Under the terms of the NA permit, the plant, as presently designed and constructed, would have to shut down frequently for work cn the core, with the previously nentioned disadvantages of radiological exposure to the workers, handling of additional wastes, and over-all degradation of plant safety. 'Ihe installaticn of the additional waste treatnent equipent nenticned in the discussion of (bndition 6 could be made, but the difficulties of measurement discussed with conditicns 6 and 7 also apply to (bnditicn 8.
9.
'Ihis prwisica of the PCA permi.t establishes a maximam gaseous waste
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(bndition 7.
NSP eq ects to be able to meet the overall limit of 0.30 curies per second, although stx:h a limit removes mcst of i
the cperating nargin which should be available to the plant oper-ators for short-term mergencies. 'Ihe portion of Condition 9 which refers to measurment of stack ocncentrations-of spr.ific isotopes cannot be canolied with because of the technological difficulties
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of measursent nonticned for Conditions 6, 7, and 8.
- 10. Ccodition 10 requires routine efflumt mtnitoring "to identify and quantitatively account for all specific radioisotopes that are released in significant quantities". NSP's regulat' plant operating procedures provide for quantitative identification of <
radionuclides which have a significant relationship to public health. However, the language of the PCA permit, ard itsL reference -
to statementsin the Tsivoglou Report of January 31, 1969,. leave considerable uncertainty as to the amount of identification which-would be required by PCA.. It appears that.the PCA permit contam-~
plates identification of the increental addition by-the plant of-isotopes in quantities which are so minute as to be unidentifiable by presently feasible techniques of' analysis,
- 11. Mis condition requires that an environnental nonitoring prtxJram -
as described in the Tsivoglou Report of January 31, 1969 must be 1
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- 12. 'Ihis ccndition requires that the results of effluent measurments and of the environmental mcnitoring program be reported rnonthly to the Pollution control Agency. 'Ihis provision can be met, al-though custcriarily environmental nonitoring prograns provide for collection of data over a 1cnger period of time, usually-six roonths or 'a year, and the submierten of utis data in a smi-annual or an-nual report.
- 13. This ccndition requires cocperaticn with the Pollution Ccntrol Agency and with the Minnesota State Board of Health in the de-velcpnent of emergency plans to be follcwed in case of plant-accident. - NSP's etergency plans ccntenplate full cocperation with all FWderal, State, and local health and_ safety agencies, and these plans will beccxte a part of the ABC cperating license for the Monticello Plant. Condition-13 of the PCA permit is written-broadly and refers to language in the _Tsivoglou Report of January 31,-
1969, which seems to indicate that State agencies should be allcwod to take control of plant operations during stergencies._ NSP will cooperate with State agencies to the naxinum practicable extent,-
but NSP nust maintain full control of plant operaticns at all~ times, incluiing emergency conditions.
- 14. 'Ihis condition limits the PCA permit to the first year of plant i
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operation and provides for changes to the pennit at any time and;.
_ for ' annual reewal by the Agency. -NSP recognizes the. desirability of frequent review of tb plant operatlig data by the Pollution ~
Control Agency. NSP will keep the Agency fully-informed of-the l
plant operating results.
In view of the limited nuclear pwer--
plant expertise on the staff of the Pollution Control Agency, it
.i appears that. the requirment 'for annual renewal of the~ aperating.
4 permit could intrcduce serious procedural problerts for both NSP; end the Agmcy. A nore workable provision would'be the issuance -
of a lcrg-term permit, with provisions that the permit limits be modified by the Agency if required after a review of actual oper-ating experience of the waste-treatment equipment. -
- 15. 'Ihis condition seens to confinn statementsmade by NSP and by recognized authorities in the. field of reactor health and safety to the effect that the very low levels of radioactive releases:per-mitted in the PCA permit are considerably nore stringent _than are -
required-for health and safety.
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STATE OF MINNESOTA Skb POLLUTION CONTROL AGENCY
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Mr. Donald E. Nelson General Counsel Northern States Power Company 414 Nicollet Mall Minneapolis, Minnosota 55401
Dear Mr. Nelson:
The application for a wante disposal permit for the Monticello Nuclear Generating Plant in Wright County which was submitted to the Agency has been approved, and a copy of permit no. 5633 is enclosed.
Please review the permit carefully and let us <<now if you have nny questions concerning it.
Yours very truly,
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John P. Badalich, PC Executive Director JPS/GRM:bkl Enclosure Mr. Arthur V. Dienhart, Chief Engineer, Northern cc:
States Power Company Mr. George Hickler, Chairman, Monticello Tcunehip Goerd Chairman, County Board of Commissioners, c/o Auditor 3417
STATE OF MINNESOTA POLLUTION CONTROL AGENCY 717 oELAWARE STREET S E.
(OAK AND DELAWARE STREETS S E.)
MINNEAPOLIS, MINNESOTA es44o WASTE DISPOSAL 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 in hereby granted to Northern States Power Company, Minneapolis, for disposal of weste from a steem 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 below specified therefrom to the Mississippi River, subject to the conditions given below.
General Conditions 1.
This permit shall not release the permittee from any liability or obligation imposed by Minnesota statutes or local ordinances and shall remain in force subject to all conditions end limitations now or hereafter imposed by law.
The permit shall be permissive only and shall not be construed as estopping or limiting any claims against the permittee for damage or injury to person or property, or any waters of the state, resulting from any acts, operations, or omissions of the permittee, its egents, contractors or esoigns, nor as estopping or limiting any legal claim of the state against the per-mittee, its agents, contractors or assigns, for damage to state property, or for any violation of subsequent regulations or conditions of this permit.
2.
No assignment of this permit shall be effective until it is executed in writing and signed by the parties thereto end-thereafter approved by the Agency..
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 weste materials or substances described in the permit application dated July 11, 1967, and associated material filed with the Agency.
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The permit is subject to modification or revocation, and may be suspended at any time for f ailure to comply with the terme stated herein or the provisions of any other applicable regulations or standards of the Agency or its predecessors, and is issued with the understanding that it does not estop subsequent establishment of further requirements for treet-ment or cantrol at any time by insertion of appropriate additional clauses herein et the discretion of the Agency in order _to prevent or reduce possible pollution of the environment.
6.
The permittee or assigne shall defend, indemnify and hold harmless the State of Minnesota, itu officers, egents and employees, officially or personally, against any and all actions, claims Or demands whatsoever which mey arise from or on account of the issuence of this permit, or the construction or maintenance of any facilities hereunder.
7.
Certification of compl-tion of the project shell be made immediately after construction is finished, reports on effluent quality and cperational practices shall be submitted regularly 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 Industriel Weste Treatment Works."
Special Conditions Relatino to Conventional Westes 1.
No rew sewage or treated sewage affluent shall be discharged to surface waters of the state from the plant site.
2.
Any additional construction plans and design data which may be required for all disposal systems needed for collection, treatment and dis-posal of sewage, industrial westes and other westes originating at this site, and for ef fective conteinment of stored liquide or other pollutional meteriale, for the preven; ion of water pollution to conform with the requirements of this permit, shall 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 follow'qg standards of quality and purity applicable to the affluent of the holoing pond shall not be exceeded at the point of discharge from the pond:
pH value 6.5 - 8.5 Turbidity value 25 5-day biochemical oxygen demand 25 milligrams / liter Total suspended solids 30 milligrame/ liter
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Cooling f acilities shall be provided and operated to insure that the heat content of the cooling water ef ter reasonable dilution and mixing in the river does not raise the temperature of the river above the -limits specified below:
Period 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-March and December, inclusive 43*F capt that in no case January and February, inclusive 37*F shall the river tem-parature be raised above 90*F by the die-charge of this affluent.) _
The oesign of treatment works for compliance with the stream standards, unless otherwise specified, shall be based on the seven consenutive day low flow of the river which is equal to or exceeded by 90% of such seven-day minimum average flows of record (the lowest seven-day flow with e onct in ten year recurrence intervel) for the critical month.
The extent of the mixing zone to be permitted will be determined by the Agency at a later date efter reviewing the date made available on the characteristics of the river and the effluent and other pertinent considerations.
5.
No industriel weste, or other wastes, treated or ut..reated.. shall be discharged into the waters so es to cause any nuisance conditions, including, without limitation, the presence of substantial amounts of floating solids, scum, oil, suspended solids, discoloration, obnoxious odors, sludge deposits, slimes, or fungus growths, or other offensiva effects; or so es to cause any material increase in any other chemical constituents; or cause any substantial change in any characteristics which may impair the quality of the water so as to render it objectionable or unsuitable for fish and wildlife or as e source of water for municipal, industrial or agriculturel purposes; or other-wise impair the qualty of 'the waters for any other uses.
6.
The company shall measure the quantity and characteristice of and sample and analyze the industrial wastes, other wastes and stored liquidu at the site as may be requested by the Agency, and shall provide the Agency every month with a complete report on such measurements, samples and analyses, to-gather with any other information relating to weste dispcDal or pollution control which may be requested.
7.
Facilities for monitoring the quality of the receiving waters shall be provided and used es requested by the Agency.
Results of the monitoring shall be reported to the Agency et' 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 pertaining to the waters of the state which receive the plant effluents, or which are in the immediate vicinity of the plant, as may be requested by the Agency.
Complete reports shell be submitted annually, or more frequently ~upon request.
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y 9.
Continuous-operation of all of the treatment works et their maximum -
capability consistent with practical limitatione and maintenance needs of such works shall be maintained-et all times when the plent is in operation and W1en necesesry to provide adequets treatment of the sewego, industrial westes or other westes by the terme _of this permit.
10.
The company shell expeditiously make any changes in weste disposal monitoring, and reporting practices, and provide any additional treatment works or disposal eyetems or other safeguards for the prevention of pollution.
of the environment upon the request of the Agency.
11.
Liquid substances which could constitute e 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 depoeited 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-e result of accident or natural catentrophe should gain entry into any waters of the state, it shall be the responsibility and duty of the company to inf orm the Agency in the quickest time possible end immediately remove end 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 etendards or river classifications and standards which may be adopted by the Agency for this type of source and/or for these waters in the future.
Speciel Conditione Relating to Redicactive Westes 1.
It is the policy of the Agency that all radioactive pollution of the environment shell be held to the lowest level that is atteinable within the limitations imposed by technological feasibility and economic reasonable-In no cese shall members of the public be exposed to.rediation beyond ness.
the limits recommended by the International Commission on Radiological Pro-tection.
In addition, the actuel levels of radiation exposure of members of the public shall be kept as f ar below those limite as possible, consistent with technol6gical feasibility 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 the Monticello nuclear-generating plant of the Northern States Power Company shell be employed for the purpose of preventing the release of radioactivity to the environment.
Such measures shall include et least, but not be limited to:
( e) ell measures for the treatment, control and conteinment of liquid and geseous radioactive effluents that are indicated in.
the Final Safety Analysis Report of the Northern States Power Company, I
Unit 1, Monticello nuclear generating plant; and l
l
,(.
/'
-5 (b) routine-removel-of radiciodine end helogens from the; gaseous effluents to the' full extent feasible, the degree of treatment and: removal being.at least<.the. equivalent of that pro-vided by effective tictivated charcoel_filtrationLof the entire air < ejector offgeei flow; and routine ion exchange treatment (Powdex'domineralization (c) or equivalent) of the combined low purity westesE(primarily from floor drains) and the neutralized chemical westes (primarily from laboratory drains and shop decontamination solution drains).- The combined estimated flow is 8,000 gel / day; and (d) inittel inspection of. fuel rods for surface contamine-tion with uranium before use in the reactor, and decontamination or replacement of fuel rods that have detectable-or_eignificant amounts of uranium on their external surfaces, so es ta prevent-the use of such fuel rods in the reactor. -The plant operator shell report in detail to the Agency the measures taken inLthis regard before startup of the reactor;'and (e) initial thorough inspecition of fuel rods to identify those that might develop fission product lenke, and rejection of such rods for use in the reactor; to 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, et other times, to prevent excessiveDreleens of radioactivity to the. environment.
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 shell-initiate research and development activities designed to develop-the:needed effective procedures.
3.
The gross' beta-gemme radioactivity of liquid effluents released to the plant discharge canal-shall be limited to the extent that the annualiever-age gross beta-gamme radioactivity _ concentration of the water in the1 discharge canal shall not exceed 10-7 pc/ml (100 pc/1) plus-the background radioactivity..
4 As en integral part of Special Conditions =3 above, the-concentrations of specific radioisotopes in the -dischargo canal shall not exceed on en annuel:
overage basis, the follouing limits:
l Averace Daily Concentrations. uc/ml Normal _(*
Low (D)
Radioisotope River Flow
-River Flow (1)
(2)
(3)-
2 x 10~0 -
4-x 10" H-3
~1
-11 l
F-18 8 x 10 1 x 10
~12
~
L Ne-24 2 x 10 3-x 10
n <
. ^ * :..
!^
g g.
, Average"Deily: Concentration,-pc/ml-Radioisotope Normal"(*)'
-Low l(b)-
River Flow
. River Flow-s (1)
(2)
(3)
Cr-51 9 x 10-13
'l-x 10-11 Mn-56
.5Lx 10-12
- p x g0"II Co-58 9 x'10-12 1 x'10-10
~
9 x 10-13 Il x 10~11 Co-60 4 x 10~13 8'x 10-12 Sr-90 Sr-91 2 x 10~11 4 x 10-10 4 x 10-12 8'x 10-11 Sr-92 Tc-99, Mo-99 1 x 10 4 x 10~9
-10 4 x 10~II 8 x 10-10 I-131 2'x 10-10 4 x 10~9-I-133 6 x 10~11 1 x 10-9 I-135 6 x 10~13 1 x-10~11 Te-132 Cs-136-6 x 10~
_1 x 10-12 4 x 10-13 2 x 10-13
~
~12 4 x 10~I3 6 x 10 8a-139 4 x 10~12 -
6 x 10~11 8a-140 (a)
Open cycle - 93 percent of days; no use of.: cooling towers; discharge, canal ritu 645 cfs.
?
(b)
Closed cycle percent of days; full _use of cooling-towers, discharge cen al 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 information, the average daily discharge canal ~ concentration :of _any other1 radioisotope shall not exceed lone three thousandth (1/3,000) of_the specific ICRP limit for continuous occupational exposure or one three-hundredthT (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; apply.
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.t.
- (.
_. 7 5.
In addition to all of the foregoing liquid effluent radioactivity-concentration limits, for any seven consecutive day period the. everage grose beta-gamme radioactivity concentration'of'the water'in the discharge canal
~
shell not exceed 5 x 10~7 pc/ml (500-pc/1) plus the.beckground radioactivity, and the1everage concentration of-any specific radioisotope in the discharge 1cenal ermil'not exceed a li.mit of five times the value_given in the above-table.
6.
The grnes bete-gamme radioactivity of-the gaseous' effluent relsesed vie the plant stack shall not exceed, on en annuel everage basis,'a-release rate of 0.01 curie per second.
This refers to-a total stack air flow of 4,000 cfm, and thereby also specifics the limiting concentration of gross bete-gemme radioectivity in the stack effluent-before' dilution _in the atmosphere..
7.
As en integral part of Special Condition'6 above, the concentrations-of specific radioisotopes in the eteck before release to the atmosphere shell not exceed, or en-ennual everage basis, the following limits:
Radioisotope Stack Concentration (e) pc/ml H-3 4 x 10-9 Ar-41 3 x 10 Kr-83m 1 x 10-'
Kr-85m 3 x 10~
- 2 x 10~7 Kr-87 1 x 10-3 Kr-88 1 x 10-3 Kr-89 2 x 10-5 Xe-131m 1 x 10 Xe-133m 1 x 10-5' Xe-133 3 x 10 '
Xe-135m 4 x 10~'
~
Xe-135 6 x 10
-0 Xe-137 5 x 10 Xe-138 2 x 10-3 (e)
At a total stack air flow of 4,000 cfm.
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--ev.i
-.,ie.rresem e.
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m
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i g
e'
-In addition to the specific radioisotope limite-given in the table immediately above, and on an=. interim basis until plant operation provides more definite information, the everage daily-stack concentration of,any-other radioisotope before relenes to the atmosphere shall:not exceed 10 times the specific ICRP limit for continuous occupational-exposure, or 100 timee the numerical limit for that radioisotope as specified in Appendix B, Table II, Title 10, Part 20, of the USACC Stenderde for Protection Against Radiation.
8.
In addition to all of the foregoing geseous (stack) effluent con-centration limits, the groes beta-gemma radioactivity of the geseous effluent released via the plant stock shall not exceed a release rete of 0.05 curie per second for any seven consecutive day period.
During such a period, the st eck concentrations of 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 gasoous (stack) effluent con-centration limits, the gross bete-gemma radioactivity of the gaseous effluent released via the plant stack shall not exceed a release rete of 0.30 curie per second for any 15 minute period.
During such a period, the stack con-
~
centrations of specific radioisotopes shall not exceed 30 times the numerical' limits given in Special Condition 7.
A stack release rate of 0.30 curie per second shall automatically sound a second and different elerm to warn the plant operator that the ' instantaneous' release rate limit has been reached.
Af ter a 15-minute delay, the air' ejector 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 at Monticello, the routine effluent monitoring program of the Northern States Power Company shall be designed to identify and quantitatively account for all specific radioisotopes that are released in significant quantities.
This effluent monitoring program shall provide for and include et least the kinds of samples, frequencies, radicessay procedures, etc., dascribed in the MPCA Final Report entitled Radioactive Pollution Control in Minnesote, and dated January 31, 1969 (see esoecially-pp. 139-143),
11.
During the first year of operation of the nuclear generating plant et 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 provide for and include at least-the kinds of samples, frequencies, radicessey procedures, etc., described in the MPCA Final Report on Radioactive Pollution Control in Minnesota, dated January 31, 1969 (see especially Table IV, pp. 135 and 136, and the section included.in pp. 114-139).
t g
- 12..All effluent and environmental monitoring progren resulta shall be reported monthly by the Northern States Power Company to the Agency.- All monitoring program resulte shall.elso be eve 11eble for inspection by the Agency at the plant site et any time.
13.
The Northern States Power Company shall cooperate to the full extent necessary with the MPCA-and with the Minnesota State Board of-Health (MS8H) for purposes of development by those egencies of an adequate end effecitve emergency protection plan designed to immediately control and.
minimize the effects of any accidental release of unexpectedly large quanities of radioactivity f rom the Monticello nuclear generating plant.
In particular, the Northern States Power Company shall immediately notify both the MPCA and the MSBH of any uncontrolled release of unexpectedly large quantities of radioactivity to the offsite air and/or water 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 MSOH.
14 The "Special Conditions Relating to Radioactive Wastes" part of this 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 and changed to the ex-tent deemed necessary by the Agency, and based upon the rceults 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 or genetic herm.
The annual average release rate limits contained in this Permit also refer to continuous lifetime.rediation exposure, rather than to momentary ^1evels, and are considerably more stringent then could be permitted 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 any member of the public, y
and should therefore not be Vieued as cause for great alarm.or for hasty and unreasoned action.-
I A4
[JohnF.Badolich,PE Executive Secretary and i
Chief Executive Officer Permit No.
5633 l.
Dated May 20, 1969 L.,...
...~