ML20127H607

Forwards Preliminary Draft of Waste Disposal Permit for Plant, for Info,Review & Comment

ML20127H607
Person / Time
Site:	Monticello
Issue date:	04/11/1969
From:	Badalich J MINNESOTA, STATE OF
To:	Seaborg G US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 9211180557
Download: ML20127H607 (18)

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1 pB~ 2118 STATE OF MINNESOTA 4

POLLUTION CONTROL AGENCY h

717 DELAWARE STREET S E.

(O AK AND DELAWARE STREETS 6.E.)

MINNE APOLIS. MINNEBOTA 5544o April 11, 1969 c

1 Dr. Glenn T. Seaborg, Chairman i

U. S. Atomic Energy Co::: mission Washington, D. C.

20545 Dear Dr. Seaborg I regret the lapse of time in acting and thanking you for the j

material you forwarded to me under cover of your letter dated.

I March 122, 1969 but the matter 'of radioactivity in the State l

of Minnesota has preoccupied a considerable amount of cy time as you may be well aware of.

4 For your information, review and also if you wish to comment, is a copy of the preliminary draft of a waste disposal permit for the Monticello Nuclear Generating Plant dated March 31, 1969 that was the subject of countless hours of discussion during our April 82 and 93 Agency meetings. Also enclosed, is a copy of the statement of our consultant, Dr. Ernest C.

Tsivoglou, made at this hearing.

The discharge permit for this nuclear power plant is being further considered by our Agency members with possible disposition at the next meeting of the Agency scheduled for May 122, 1969 Further questions have been developed by one of our Agency members which we would have clarified by our consultant before further action in taken on this permit.

In any event, the main purpose of my writing is that I expect to be in Washincton, D. C. on April 23-24 and possibly on the 25 in conjunction with the meeting with the International Joint Commission. I would, therefore, l'.ko to set up an informal meeting with you and/or members of your staff sometico during the latter two days of my Vashington trip (24-25). This visit would be'at your convenience to discuss matters relating to'the-subject of radioaotivity and Minnesota's future role in this natter.

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i Dr. Glenn T. Seaborg, Chairman April 11, 1969 Page 2 i.

Accompanying me on this trip will be one or two Agency members i

and a member of agr staff.

i I approoiate your interest in this matter and trust that the proposed arrangements can be made.

j Yours very truly, I

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l jJohn P. Badalich, P. E.

i Executive Director f

i JPB/ee Enclocures

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co Mr. Robert Tuveson i

Mr. Harold L. Price

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M2rch 31, 1969 g

MINNESOTA POLLUTION CONTROL AGENCY 717 Delewaru Strout, S.E.

3 University Campus i

Minnoopolis 55440 3

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WASTE DISPOSAL PERMIT j

Monticollo Nuclear Generating Plant',

Northern Staten Power Company, Monticello Township, Wright County 4

1 Pursuant to outhorization by the Minnocoto Pollution Control A00ncy, and-in accordonco with-tha provisions of Minnesota Statutcc,1967, Chapters 115 tand 116, a permit is hereby granted to Northern Stateo Power Company, Minneapolic, for dioposal of waste from a atcom electric generating plant bt3ng constructed by the comf any in the west half of,Section 33 Township i

122 N, Rondo 25 W, Wright County, including the diocharge of affluents, as herein below opecified therefrom to the Missicalppi River, subjectLto thc' conditione given below:

_Generni Conditions i

1.

This pornit shall not relcace, the parmittoo from any liability or obligation imposed by Minnesota statuten or-local ordinancos and shall' remain 1 force aubjuct to all conditions and limitationa now or hereafter imposed

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The. permit shall 00 porpipsive only ond shall not be.construbd as c.opping or limiting any. claimo~against tho' permittee for damage or injury i

person or.-

serty, or omissions of the permittee, its egento, contractors or cusigns.

.n as autoppinD or limiting any-1cgal claim of the stato cgainst the permittee, its egents, contraccora or assigns, for damogo to state pro-party, or for % violation of subsequent regulations or conditions of this permit.

2.

No assignment of this permit shbil be effective until it is executed in writing and signed by the parties ~thereto and thereaf ter approved by the A ency.

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3.

No major alterations or additions to the:diepcoal system shall bs stodo without the written concent of the Age,ncy.

4.

The use of the disposal cystem.oholl be limitad to the trcctmont or disposal of the waste materials or substances 'doscribed in the permit',

1 Agency.

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11, 1967, and casociqted material filed with'the

-opplication dated July 6

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The permit is oubject to modification or revocation, and may be nuoponded at uny.timo for rollero to comply with tho termo stated horoin or the provisions of any other ophlicablo regulations or standards of the A0ancy or its prodoconcoro, and is issued with the understanding that it doop not octop oubsequent cotablishmont of further requiromante for troatment or con-

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trol at any timo by insertion or oppropriate ad,ditional clauces horoin at tho diccrotion of the Agency if it is conoidered necessary in. order to pro-vent or reduce possible pollution of the environmont.

,G.

The permittee or casigns chull dorond, indemnify and hold harmlose tho Stato of Minnesota, its officero, ogents and employees, officially or poroonally, 00ainst any and all actions, claims, or domando whatsoever which may crito from or on account of the icouunce of this permit, or the conotruction or maintenance or any facilition huroundar.

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.7.

Cortification or completion of the project chall be inado immediately Reports on o fluent quality and oporational r

efter construction is finished.

practicos chall be submitted regularly ovary mtnth, and the permit holdor chall; cortify that ho is in all respects in conformonre with the conditiono given 4

in the Agency policy othtumont or August'22, 1967 ontitled, " Policy Rogording Oppretion Permito for Sowogo and Industrin1 Wooto Trootment Works."

t Special Conditiono Rolnting to Conventional Westos 1.

No raw onwage or treated sowogo offluont nhall be discharged to curroco watero of the stato from the plant site.

2.

Any. additional construction plans a,nd design data which may be re-quired for all dispouel systems nooded for collection, treatment and: disposal or sowo00, industrial *wastos and other unston originating at this.sito, and for otractive containment of stored liquido or other pollutional materials',

for the prevention of water pollution to conform with the requiramsnts of this permit, shall be submitted together with any.Other information requested j

for rovicw by the Aguncy. 'All such plans shall moet with the approval of l

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l the A0cncy and tho systems be completed borore operation of the plan't is 1

startod.

i 3.

The following standards of quality and purity applicable to the

-effluent of the bolding pond shall hot be exceeded at the point of dischargo i

l from tho piond:

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6.5 - 8.5 l

pH value-25 l

Turbidity value 25 milligramo/litar-5-day biochemical oxygen demand

,'Totel'ouspended solids

30. milligrams / liter.-

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Cooling recilitico choll be provided and operated to insure that the

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huat content or the coolinD wotor orter reoconablo dilution and mixing in tho' river doon not raiso tho temperature of the rivar abo'vo'the limito specified i

below i

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_Poriod

, _Maximurn Temperature

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July and August, inclusive 86*F (or 5'F obove the Dune and September, inclusivo 80'F ombient temperature May and October, incluoive 67'F

- of the river, which 55'F ever is Grector, ex April and November, inclusivu 1

March end Decembor, inclusivu 43*F ccpt'that in no ces January und February, inclusive

.37'r shall the river tom 1

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parature exceed 90' The design of troottnent works for compliunce with the stroom utandardo, unicso othorwiso specified, shall bu-based on the seven consecutivo day lou flow of the river which is equal to or excucded by 90% or such-coven-day f

ininimum overage flows or record (the lowcot seven-day flow with a anco in ten year recurrence interval) for the critical month.

The extunt of tho mixing i

rone to be permitted will be determined by the Agency at a lator dato ofter l

revieving the dato modo ovoilable on the choroctoristico of the river and the offluent and other pertinent considerationo.

5.

No inductrial westo, or other westen, treated or untreated, shall be diocharged into the watero 80 on to couco any nuiconco conditions, including without litnitation, the procence of cubstantial omounts or floatinD colids, e

ocum, oli, suspended solido,-diocoloration, obnoxious odors, slud0o deposito, climea, or fungue growths, or other offensivo ofrects; or to es to causo any motoriti increase in ony other. chemical y constituents; or causo-any.subotontial.

change in any characteriotics~which may impair the quality of the wotor so es to render it objectionable or unsuitable for fish and wildlife or as a source of water for municipal, industriol or agricultural purposes; or other-i j

wise impair the quality of the waters for any other uses.

6.

The company shall measure the quantity and characteristics of and i

complc and onalyzo the industrial wastes, other wastes end stored liquids at i

the site os may be requested by the Agency, and shall provide the A00ncV overy month with a complete report on such,monourements, samples and onelyoco, to-gather with any nther information ro'.ating' to weste disposal or pollution control which may be requested.

1 7.

Focilities for monitorin0 the quality:of the receiving waters shall

' bo provided and unod no requested. by the Agency.

Resulto of-the monitorinD H

shall be reported to the Agency at monthly intervals.

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8.

The company chall cause to be made without coot to _ tho' state, toch-nical ntudica and invest 100tions of the bioto and quality and related matters,

kI partnining to the waters'or the state which receive the plant effluents, or which are in the immediate vicinity of the plant, as may be requestod by tho Agency.

Complate reports chall be submitted annually, or more frequently upon request.

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Continuous operation of all of the trootmont works at their-maximum i

capability consistant with practical limitouans und maintenanco noud'u of such worko shall be maintained at all timon when the plant 10 in operation and when nococuory to provido odequate trootment of the scuogo, industrial waotus or -

other uostos by the terms of this pt emit.

10 in ce npany'shall c:peditinuoly muka ony chanDes in unote disposol, monitt 11 and reporting practicos, and provido any additional troatment j

workc bc disposal systems or other sofoguardo for the provantion of pollution of the environment upon the requent of the Aqcncy.

11.

Liquid subotencon which could constitute a courco of pollution of the waters of the L toto shall bo atored in accordmice with regulation WPC 4.

i Other wastes no defined by Minnusato statutco, ocction 115.01, oubdivision 4, shall not be deposited:in any manner auch that the onmo may be likely to gain entry into thouc wotoro.

In any coco whero such substances, oither liquid' or colid, os a result of accidunt or natural catootropha ohould Goin entry into any unture of the state, it chall be tHe responsibility tmd duty of the company to inform the Agoney in the quickest timo possible and immediotcly

' removo and recover all cuch pollutional substances to the fullest extent roosonably possible under existing conditions.

'2.

The industrial or other waste effluents os discharged shall comply.

with any and n11 opplicabic requirements of effluent otonderds or river.

clncsificationo cnd standcrds which may be adopted by the A ency for this D

type of courco ond/or for thcoe waters in the futurc.

Special Conditions Relating to Radioectivo Wastes 1.

It 10 the policy-of-the Agoncy that all radioactivo pollution of the environment shall bo held to the lowest level that is attainable within ~

i the limitations impoond by technological fcanibility and economic roosoncbic-ncco.

In no case shall members of the public be exposed to radiation beyond the limits recommanded by the International Commission on Radiological Pro-tcction.

In addition, the octual levolo of radiation exposure of members of the public shall be kept as for below those limits os possible, consistent with technological feasibility and reasonablanoss of cost.

2.

In kooping with the above policy of the A0cncy, all technologically, fencible and raosonable measures for treatment, control and containment of radioactive wastes from the Monticello nuclear generatinD P ant of the Northere l

States Power Company shol.1 be employed for the purpoco of proventin0 the re-lease of radioactivity to the environment.

Such measurce chall includo at 1 cost, but not be limited to:

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l (a) all measures for the trootmo'nt, control and containment of liquid ond gaseous radioactivo effluents that are indicated in the Final Sofoty Analysio Report of the Northern States Power Com-pony, Unit 1, Monticello 'nucleor gancrating plant; and I

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5 (b) routino removal of radioiudino and holo 0cns from the geocous offluento to the full cxtent foncible, the dourou of j

trootmant und removol' bein0 et luost the equivalent of that pro-vided by effectivo octivated charcoal filtration of the entire nir ejector offgas flow; and i

(c) routino ion exchange treatment (Powdox dominarolization j

or equivolent) of the combined low purity wasteo (primarily from floor draino) and the noutralized chemical wastco (primarily from laboratory draino and shop decontominati~on colution drains).

The combined cotirnated flow to 8,000 gol/ day; and (d) initial inopoction of fuel rods for curface contamina-tion with uranium before uus in the reactor, and decontamination or replacement of' fucl rodo that have detectoblo or significant omounts of uranium on their external surrecco, no no to prevent the uce of ouch' fuel roda in the reactor.

The plant oporator choll report in dotn11 to the egency the moocuron token in thin re0ard borore startup of the reactor; ond (c) initial thorou0h inspection of fuel rodo to identify those that might develop flusion product luoks, and rejection of such rods for una in the reactor; to the full extunt possible, developmant and application of methodo and techniques for locating and identify $nD lenkin0 fuel rodo after oporation of the reactor bcDinc, so that such rods may be removed during usual fuill replaco-mont operations, or, if necosuery, at other timos, to provent'ox-cessiva release of radioactivity to the environment.

The operator orn11 report in detail to the Agency the actual measuras taken in both of thene regards before startup of the reactor.

If necessary, he shall initiato renoorch and dovelopment activition designed to develop the needed effective procedurcs.

3.

The Oroos boto-gamma radioactivity of liquid effluents released to the plant discharge canal shall bo limited to the extent that the annuni aver-age Cross beta-gamma radigactivity concentration-of. the water in the' discharge canal shall net, exceed 105 pc/ml (100 pc/1) plus the background radioactivity.

4.

As an integral pa> t of Special Conditione 3 4 abovo, the concentrations 4

of specific radioisotopes if the discharge canal chall not oxceed, on en annual r

j overage basio, the followijg limits:

i Avernoo Daily Concentration, ge/ml '

Normal (a)

(b)

. Radioisotope Low River Flow River Flow l

(D (2)

(3)

H-3 4

2 x 10 4 x 10-7 F-18 8 x 10-13

'l x 10~11 q

Na-24 2 x 10-12 3 x 10-11 t

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5.

In addition to all of the foregoing liquid offluont radioact.ivity concentration limita, for any coven consocutivo day period the averago gross boto-gnmme radioactivity 7 concentration of the untor in the dicchargo canal ohn11 not excood 5 x 10 pc/ml (500 pc/1) plus the background radioactivity, l

end the overogo concentration of any spedific radioisotopo in the dischur00 canal chall not excocd a limit of riva time the value given in the abovo tobic. l t

6.

Thu grass-beta-gcmme radioactivity of' the geonaus offluent releaned i

vio the rato of' plant stock shall not oxcond, on on ennual avern00 baois, n releaco i

i O.01 curio por second.

Thio refore to a total otock air flow of 4,000 W

crm, and,thereby also specifico the limitinD concentration of gross bete-gemme radioactivity in the steck offluent before dilution in the atmosphero.

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Ac un integralpart of Special Condition 6 above, the_ concentrations, or specific radioinatopos in the otock before rolooso to the utmosphorn shall j

not oxceed, or en annual averaDe basis, the following limits:

Stack Concontration (a) i Endioisotone pc/ml H-3 4 x 10~E Ar-4) 3 x'10-6 s

1,x 10"b i

Hr-83m j

Kr-89m 3 x 10~4 Kr-85 2 x 10~7 l

Hr-87 ul x 10~3

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Ft-88 1 x 10~3 Mr-89 2 x 10~0 l

Xe-131m 1 x 10-6' Xe-133m 1 x 10-5

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3 x 10~4 l

i Xe-135m 4 x.10

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Xe-135 6 x 10~b

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'i Xo-137 5 x 10-5.

Xo-138

-2 x 10~3 l

J(o).At a total stock air flow of 4,000'crm.

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1 In addition to the specific radioicotops limite given in the table immedictoly abovo, and on an interim basis until pinnt operation providos more definito information, the ovoroga duily otock concentration of any other radioisotopo before roleoso to the atmucphcre shall not excnod 10 times the opacific ICRP limit for continuous occupational exposura, or 100 times the numerical limit for that radioisotops as specifiod in Appendix' B, i

Tbbis II, Title 10, Port 20, of the USACC Standardo for Protection Against Radiation.

o 8.

In addition to all of the forogoinD gaonous (stack) offluent con-contrntion limito, the grous beto-go:mne radioactivity of tho gnomous offluent released via the plant stock chell not oxceed a relnace rato of 0.05 curic per cocond for any seven coneccutivo day period.

During such o' period, the

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stock concentrations of specific radioisotopos chall. not exceed five timos the numerical limito given in Special Condition 7.

A stack rolceau rate of 0.05 curia per second shall automatically cound a plant alarm to warn the plant operator that thn' weekly reloano rato limit has boon reached.

In addition to all of the forc0ainD Dateous (otock) o[ fluent con-9.

centration limito, the Droso botn-gnmma radioactivity of the gescouc offluent released via the plant stack chall not exceed a release rato of 0.30 curio por second for any 15 minuto period.

During such a period, the stock con-centrations of specific radioisotopus chnll not exceed 30 timos the. numerical limito D von in Spuciul Condition 7.

i A atack release rate of 0.30 curic par second shall automatically cound n second und different alarm to warn the plant operator that the 'instantaneouc reluace rate limit has been reached.

Af ter a 15-minut~o deley, the air ejector; off0as isolation volve shall automatically close, shutting down t's recctor, if the radioactivity rolcace rate has not boen.ouccessfully reduced to the wockly reluoso rate limit, or lens.

10.

During the first year of operation of the nuclear generating plant at Monticello, the routino offluent monitoring program of the Northern States Power Company shell.be designed to identify and quantitatively account for all specific radioisotopen that are rolcased in a1 nificant quantitics, to 0

the full extent feasiblo and consonable.

This affluent monitoring program chall provide for and include at least the kinds of somples, frequencico, radioccony procedurco, etc., described in the MPCA final Report entitled Radioactivo Pollution Control in Minnosota, and dated January 31, 1969 (see copecially pp. 139-143).

11.

During the first year of operation of the nuclear generating plant at Monticello, the rousine environmental radiological monitoring.ond sur-veillanco program of the Northern. States Power Company shall be designed to detect and evaluate all radioactive releases. from' the plant, to the full ex-tant fooniblo and roanonebl'e.. This;cnvironmental monitoring program shall provido for and include at least the kinds of samples, frequencias, radioassay proceduras, etc., described in the MPCA Final Report on Radioactive Pollution Control in Minnesota, dated January 31,1969 (ces copecially Tablo IV, pp.133 and 136, and the section in.cluded in pp., 114-139).

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9 12.

All offluent and environmentel monitorin0 program rooulto chall bo All reported monthly by the Northern States Power Company to the A00ncy.

I monitoring program rooulto chall also be available for inopuction by the Agency at the plant cito at any time.

f 13.

The Northern States Power Comprny oholl cooperate to the full l

extent nococonry with the MPCA and with the Minnesota Stato Doord of Hoolth for purpouco of development by thoso 00ancios of on odoquato and c.fractivo omoracncy protection plan dooigned to immudiotely control and minimizo the offecto of any accidental roloaco of unexpectodly largo quonitico of radio-octivity from the Monticello nuclonr generating pinnt..In porticular, tho Northern Statoo Powcr Company shall immedintcly notify the MSCH of cn/ un-l controlled rolcoco of unogpoctedly largo quantition of radioactivity to.the offsito air and/or wotor onvironment due to operational failure of any of tho Also, the Northern Staten Power Company shall cooperato powcr plant cyotoms.

in this rc0ard to thu full. extant outlined in the MPCA Final Report on Radio-activa Pollution Control in Minnocota (o00 pp. 90-97), and in any other monnor requested by the MSDH.

14.

The "Special Conditiono Relatin0 to Radioactive Wootoo"'part of this permit is limited to the first year of operation of thu Monticello nucicar genurnting plant.

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

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A now permit relative to radioactive wantoo, modified and changed to the ex-tent deemed neccesary by the A ency, and based upon the results of the first 0

yont of poucr p) ant oparation, will be issued.by the ADoncy for the second 1

year of operation.

15.

It is emphooized that public ond environmental radiation protection practicq 10 booed upon n. concept of very long torm protection, rather than only immediate or mo'montary pr'otection.

The generally accepted I.C.R.P. limits'

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s oro don 10noo to rostrict radiation exposure, on a continuous basis and over a lifetime, to 19volo that will not produca detectable or.oignificant comatic.

or gonatic harm, The annual avera00 r010000 rate limito contained in this Parmit also raf ar to continuous lifetimo radiation exposure, rather than to momentary levais, and are considerably more stringent than could be parmitted accor. ding to 'eha I.R.C.P.rocommendations.

Hence, the olight, transitory (E.G., daily) variationo around those limits that era to be normally expected should not result in overexpos'ure to radiction of any member of the public, and should therefore not be ~ viewed as cause for groot nierm or for hasty and -

unreasoned action.

e John P. Bodalich, PE Executivo Socratary ond Chief Executivo Officer Parmit No.

5633 Dated April 18, 1969 0

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t 4-STATEMENT __OF E. C. TSIV0010U April 8, 1969 s

The main purpose of my statement today is to roview with you the Permit, that has beeh reconnended for tho first year of operation of the Monti, cello nuclear I

concrating plant by the Northorn States Powor Company.

First, I will briefly outlino the pr(misos upon which the Formit to basod.

I will then discuss 'the t

I main features.of the Permit in tormo of the catoguards' that have bocn built into it.

I hope that no will be able to etick to hard facts today, to the ortont that they are availablo, and that uo can avoid tho kind of t.;aggoration that has charactor-ized come of the rocent public -statements regarding radioactivity and the 'Honticollo plant. I hope that decisions regarding this new facility can bo based upon rational considoration of real facts, and not upon unfounded spocu3ations, emotions or politics.

T_ ITE PRE:11SES

. The permit that has been recommended for:the firot' year of operation of the Monticollo facility is' designed on the basis of tuo major premises. They are as fo130tio n (1) The radioactivity limits that have been reconctonded by the. International Cobainsion on Radiological Protection (ICIP) r'oprosont the best available information in the world today rogarding tho hazards of red $at$on exposure and the degree of protection that must,bo provided.-

(2) All radiation exposuro must be activoly nin32nized 'to the full extont-that is both technologically foanible.and economically renoonable. ' This, means that in no caso can t'ho limits recommanded by the (ICIP) be.

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exceeded, but'in addition,: the_ actual *lovol of radiation exposure should be kept as far below those limits as is achievable.in a practical ocnso.

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2-In regard to the first premiso, the radiation protection limits recomended by the ICRP are accepted by responsible public honith and pollution control agencion throughout the world. They fom the basis for virtually all other radiation protec-l tion standards, such as thoso provided by our National Comittee on Radiation Protection (UCIP) and 'those enforced by the U. S. Atomic Energy Comission (AEC).

The limits recomanded by the ICliP have boon designod to restrict radiation exposuro on a continuous basis and over a wholo lifotime to levels that will not produce detectable or significant bodily or genetic ham.

Regarding the second' promise, which I refer to no the Principle of Minimum Exposuro, all responsiblo agencies also agree th4t hum'.

radiation exposure should bo minimized. Even exposure at the low levels recomended as limits by the ICRP is taken to be harmful in principlo, although this has not been demonstrated as fact, and so it is comonly acrood that actual exposuro should be kept below hose limits to the full extent possible in a practical sense. As I describe the requiroments 4

of the pomit for the first year of operation of the Monticello facility, and tho safeguards that have been included, I think it will become quite evident that a very high degroe of radiation protection vill be provided. The pemit that has l

boon recommended does not provide for absolute zero radioactivity release, as that

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goal is not. regarded as practical at this time. The Pemit does provido for a higher degrou of protection than has yet boon required at any comercial nuclear

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power plant in the United State's. It is worthy of mention.also 'that no public ogoney, state, fedoral or international, has felt that absolute zoro radioactive pollution is either a practical o'r a nocessary goal.

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Thoso, then, are the premises upon which the recomended Pcmit is basedt that tho' radiation protection limits recomondod by the ICRP uould, by themselvos, provido I

a high and an adequate degroo. of protection of the public.and its environment; that

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actual radioactivity rolcasoo from tho Monticello nucion powsr plant should be kept as far below thoso 1.imits as pocoiblo; and that a goal of absoluto toro radioactivity roloaso from the plant 10 noithor practical nor nocoscary at thio timo.

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' Tits PattIT ATTD THE SAFEGUARD _S i

The Formit that has been recommended for the Monticollo nucicar gonorating i

w stationo soto limits on radioactivo wanto roloacos that aro $nuch moro sthi1 the limits that are procontly enforced or planned at any other commercial nuclear 1

pouer plant in the United Statoo.. In kooping with the Agoney policy of oliminating radioactivo pollution of the environment to the full oxtent pocoible, the Permit also requiros cortain wasto treatment and control moasures that aro new to tho y

nucicar pouer industry, but thoco are included to provi?e additional assuranco of i

environmental cafety. In addition to thcoo featurco, the Permit requires the opora-tion of comprchensive offluent and environmental monitoring, programs that are f

fully capablo of detecting any failure to comply with the specified radion'etivo rolcoco' limits, both liquid and gaseous.

Quito frankly, if the Permit is adopted as recommended, I. cxpect the environ-mental monitoring program to demonstrato clearly that the'radioactivo wacto releasco

.from the Monticello plant are so low as to be extremely difficult if not impossible I

to dotet in the nearby enviornment.

i To be novo spocific, and to stick to facts, lot us consider como of tho numerous i

oafeguards that are contained in tho Perkit. They includer 1.

The liquid and gaccous radioactive wasto releaso limits specificd by tho Permit would restrict such releases to n'o noro.than two or thrco percent of tho amonto that can be rolcased according to the current ICRP or AEC requiromonts. Tho Porait specifies effluent limits, rather than-moro com -

monly uso environmental lhtits, for the specific purpose of providing for l

clocar control of the radioactivity releasos'. Tno limits that are speci,

l ficd aro thus much more stringent.than those in offect at other commerciti nuclear power plants.

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l-Enforcement of the requirements of the Permit means that the actual radioactivity rolcacos win in most onces bo von below the two er t'hree porcont mentioned above.

(2) The Pomit that has boon rococon6ed apocities limits on individual, radiolootopes, as well as on gross radioactivity releason'.

T118 is an 3

unusual precaution at commercial nuclear power plants, and'provideo 3

additional'protoction against error or unsato procodurcs.

(3) A thorough liquid and gaseous offluent raonitoiing program is requircd i

by tho' Permit. Thio monitoring program is quito capable, by itooif, of promptly detecting any deviation from the limits opocitied by the Pormit.

It is a considorably more thorough effluent monitoring program than io practiced at other commercial nuclear power reactora, i

'(4) A quito extensive and thorough monitoring program for environmental radioactivity is also roquired by tho Parmit.. It win require compro-hensivo monitoring and surveillance of au phasos of the air and water 2

environment that might be affected by the Monticello plant. Tho environmental monitoring program win be capabie, by itself, of detecting any significant doviation from the radioactivity roloaso limits epocitied j

by the Formit. It win be considerably moro.comprehensivo and thorough 1

than c.nvironmental monitoring programs required in tho vicinity of other commercial nuclear power plants.

(5) The recor.:monded Pormit requirco that all liquid wasto realesos be treated and monitored on a batch basio, rather than as' a continuous flou. Thio providos a very pocitivo cystem of control, so that any batch of' liquid l

vasto that contains more than the allouod amount of radioactivity can' and win be withhold from the liississippi Rivor for further treatmont.

Thispracticoihcommonlyrequiredatnuclearpowerplants.

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not so coanon cloouhoro is the Permit requirecond thtt essentially all i

liquid waotos, ovon thooe from buildinit floor drains,' bo routinely oubjected to a high degrou of treatment by relatively costly lon* cxchango

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l methods. With propor handling and treatment of liqui'd wastes, thoro vill I

bo no oignificant radioactivity in the liquid offluonts from tho plant.,

lievertholoco, the monitoring programs specifiod by the Pomit will requiro

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l that overy offort be mado to evaluato tho radioactivity that is relcanod, f

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to insure this result.

(6) The Permit under consideration also requires the innta11ation of a highly

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.officient trontmont measure for the removal of radiciodine frca tho casoons wanto otream. Radiciodino is ono of tr3 most hazardous radio-isotopos that can.bo civon off by nuclear power roactero, as it very ooon findo its way into the milk produced by dairy cattle. Even though very littlo radioiodimo would be expected from the Monticello plant during normal operation, the now treatment noacuro is required by the Permit to provide positivo assuranco of'dafoty from this radioisotopo.

Escontially nono should.oscapo via the plant stack. 'The required treat-t ment neaucro for positivo removal of radioiodine'reprosonts another i

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'first' for Minnosota, I believe - this measuro has not bocn requirod as yet at other cc::nercial nucicar potter plants.

I (7) The main source of radioactivity from any such reactor is uranium fuol, l

oloments that develop tiny lesko, and thorcby permit ficolon prcMucts 3

to leak out into the primary cooMng system. The Pernit also req'uires

' the llorthern States Powo$' Company to mako ovory feasiblo positive effort

. to stop any radioactivo wasto releasos at their sourco - namely in the roactor'itself.

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Evon though great'offorto are end An manufacturo to do co, it is extremely difficult to provent euch looks in an absoluto senso - for examplo, the Monticollo reactor will contsin 23,716 Andividual fuel rods, and it is unlikely that none will develop pinholo loaks.

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The Permit will require the plant operator to develop a positivo program for finding any loaky'fuoi alcmont's or fuel assemblios,'. so that they can bo celectively removed from the reactor, oither during usual refueling operations, or, should it provo neccesary, as a spocial oporation.

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This is another measure that has not boon required beforo at commor-cial nuclear powor plants.

It may not provo an easy burden to assume, but the Permit requires the company to demonstrate that it is making overy i

offort to do so. It is emphasized that the successful dovolopmont and conduct of an effectivo program for finding and selectively removing j

l leaky fuel elements or.fuol assemblios would introduce a new and higher.

lovel of centrol over radioactive wastes from reactors'. It would

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l constitute a substantial practical. step forward in terms of really uinimizing radioactivo pollution of the environment.

(8) One other very $mportant cafoguard', which socms to be oither unrecognized

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or consistently ignored by so:ne others, deservoo emphasin. This safo-1 f,

guard automatically provides for ample time in which to take corrective

. actions, chould they becomo necossary.

l Tho limits on radiation exposure that havo bocn recommended by tho' l

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• ICW refer quito.specifically to continuous exposure over a lifotimb.

.They are decided.ly not momentary or instantaneous l'imits. The ICW -

t recommended limit for tritittn, for example, refers to the ainoun't. of

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producing dotectable or significant ham.

1 The important point is that it in the cu:nulativo radiation exposuro 4

over a lifetimo that is boing roculatod, not,just the momentary exposure.

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The risk of ham duo Lo exposure at the ICRP limit for a period of one i

• year, instead of lifetino, is proportionatoly amaHor than tho risk of exposure at the same levol.ovor'a lifetime, which is already taken to be negligible. The limits that are containod in tho Pomit also roter i

to continuous lifetimo exposure. As they are considorably more rostric-tivo than the ICRP recommendations, the associated risk of harm is that much smaller again.

As a result, the very important safoguard of availablo time in which correctivo actions can be takon, if they are over nooded,

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is definitely present.

SIMfAIN To st'marizo the real facts, the radioactivity release limits that havo Loon recomended for. the first year of oporation of the Monticeno nucicar l

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pouer plant win restrict such releases to quite sman fraction of the releases

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that could bo pomitted according to currently accepted worldtrido practico. A number of neu and positivo protective unste treatment and control measures aro N *

• r' qiiired by' the Pemit. ' A oystem of safeguards 'and chocks, 'ono suporimposod upon e

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anothor, is incorporated in the Permit,' to the extent that the risk of ham due i

to radioactivo roloases from the plant is cicarly negligible in tems of comparison to all currently accepted national end internat'ional radiation protection, standards.

Takon colloctively, the Pomit requirements are much moro rostrictivo as regarding environmental radiation protect', ion than any that have been placod 'upon.any other comercial power reactor 'thus far.

Thero are somo who insist that no radioactivity at an should bo. rolcased j

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Q-from nucicar plants - that, absoluto zero rolonso is the only acceptablo ancuer.

I can agroo zoro pollution of our environment is an ideal that wo should always scok as a matter of principle, and no matter what kind of pollution is involved.

I I cannot agroo that abooluto zero radioactivity roloaso is a reasonable or necessary Pomit requirement at this timo.

I would point out, hovover, that 'this Permit comes a good deal closor to requiring zoro rolonso of radioactivity than many poople cocm to realizo - in point of fact, if uo monsuro thio in toms of tho, limits f

that are currently regarded ao safo throughout tho world, wo.have como noro than I

98 porcont of tho way toward zero.

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