ML20127J799

Forwards Ltr to Governor Levander for Distribution to Minnesota Delegation,Per Recipient Telcon W/B Oneill

ML20127J799
Person / Time
Site:	Monticello
Issue date:	06/04/1969
From:	Christopher Henderson US ATOMIC ENERGY COMMISSION (AEC)
To:	Fain G CONGRESS, JOINT COMMITTEE ON ATOMIC ENERGY
Shared Package
ML20127J802	List: ML20127J799 ML20127J805
References
NUDOCS 9211190428
Download: ML20127J799 (1)

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Mr. Gerald Fain Joint Ccanittee on Atcxr.ic Energy Congress of the thited States

Dear Gerry:

With reference to your telephone conversation with Bob 0'Neill, I am enclosing 10 copies of the letter to Governor leVander for distribution to the Minnesota delegation.

We are not including the Minnesota per:::it and consultant's statement as Mr. O'!!oill indicated you did not want these enclosures.

Sincerely,

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4. L. Henderson Assistant Director of Pegulation for Administration Ehclosures Distribution:

Chainnn (2)

Conmissioner Ramey Conmissioner Johnson Conmissioner Costagliola Conmissioner Thonpson Secretary (2)

OGC (2)

General Manager (2)

Co:%pesional (2)

J. A. Erlewine, ACBD A. A. Wells, AS&LEP Ihrtin Biles, DOS Joe Fouchard, DPI H. L. Price C. K. Beck M. M. Mann R. L. Doan Forrest Western

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June 2, 1969 s

Honorable Harold LeVander

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Govemor of Minnesota St. Paul, Minnesota 55101

Dear Governor LeVander:

Thank you for your letter of t.by 12, 1969, regardirs the pemit recently issued by the Minnesota Pollution Control Agency (MPCA) cetting emission standards for the Monticello nuclear power plant of the Horthern States Power Ccepany (US?) which, you state, are " considerably more restrictive then standards set by the Atomic Enerr/ Cornission."

As you recognite in your letter, an AE0 operating license is necessary before US? is lerally permitted to operate the Monticello nuclear power plant. The views of the M?CA and any other interested Minnesota agency on the issuanco of tha operatins license will be carefully considered.

In your letter you state that, because the AEC was aware before thy 12 that regulations stricter than thre of the AEC were likely to be ig osed, and if, as we claim, the AEC has pree.rted the nuclear field, you "would have anticipated that ISC would have actsd affir:ratively" to assert it:

exclusive jurisdiction before the MPCA acted. The Corniscicn did, in fact, take such affinrative action. Cn several occasions, both orally and in writing, v:e have clearly ec=unicated cur position en preegtien to the MFCA. She M?CA, moreover, has received legal opinions frcm the Joint Co=tittee en Atomic Enercy, the AEC, and an AssistSnt Attorney General of m~ota - all of which point up the legal inpedimont to the action taken by the KOCA. Finally on this point, the AEC, before issuing a constructicn pemit for the Monticello plsnt, held a public hearing in Buffalo, Virnesota, on May 25-26, 1967; and representatives of the Minnesota Capartment of Health, the Finnesota Conservation Department end the Kirnesota Mater Control Co=dssion rade appearances at the hearirg and had no objections to the granting of the construction pemit by the AEC.

In your letter you express the hope that we "will now support" the IEA action. This we cannot da.

Although we have not yet received a copy of the pennit wnich was issued by the IECA on May 12, we have reviewed an earlier versicn which was sent to us by the ITCA. Aside from the ]egal-impedirent, we have scne substantive difficulties with the permit which are descrlbed in 'he enclosure to this-letter. 7he AEC, in acccrdance with guidmca frca the Federal Fadiation Council, recognises that releases 9211190429 690604 PDR ADOCK 05000263

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HonorableHaroldLehander 2-June 2, 1969 l

of radioactivity should be kept as low as practicable, and our experience to date with scme fourteen licensed operatirs power reacters shows that the radioactivity released in effluents has generally been a s-nll percentage of releases that ray be permitted under AEC regalations. These

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11:rdts, which are discussed in the enclosure, are based on raides developed by the Federal Radiation Council, and approved by the President for the raidance of Federal agencies.

As to the future, in view of recent substantial increases in nu~.ber and size of power reactors under construc-tion or planned, we have our regulations under review to dete mlne whether charges in so:re instances ray be desirable.

If the Comdssion decides to make any charJ:;es, they will be rade, in accordance with ou" usual practice, only after opportunity is afforded all interested groups to participate in the rule Iraking procedure.

The fact that the !?CA permit contains radiological conditions that are "more rectrictive" than those that would be imposed by the AEC does not mean that there is a correlative or even re Murable increase in the protection afforded the public. As discussed in the enclosure to this i

letter, so:re of the restrictions in the perdt, depending en how they a e -

interpreted and aidnistered, could be unduly burdensome without : raking a neaningful contribution to the public health and safety.

Indeed, again depending on its interpretation and ad-inistraticn, the permit could be viewed as not enhancing the public health and safety at all since it rdsht i

requ3re frequent changes in cperating conditions, including shutdowns and strps of the reactor, which might not be juctified by the ciretrnstances.

beyond this, the pe mit reflects an "ad hoc" approach to the regulatien

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3 of nuclear power plants which, in our view, cannot and should not be made the basis for a fair and effective regulatory program. The approach

- taken by the !?CA is that each nuclear plant should be regarded as an individual case so far as radioactivity releases are concerned; but the f?CA has no definitive criteria or standrds for determining on a case-by-cace basic what concentrations should be per:ritted. We are not aware that the !?CA now has the requisite professional staff to develop --

and a.idnister effectively perrits such as the one issued for the Monticello nuclear power plant. Nor do we believe that it is in the public interest for l'Jnnesota and other states to compete with one another and with the AEC for the 1trated nu~.ber of availabic persens qualified in the technical disciplines related to reactor safety in order to establish regalatory programs that would duplicate the AEC program for the regula -

tion of nuclear reactors.

For these reasons we rust decline to give_you the assurance which you-have requested "that the AEC not issue any operating perr.it for

- nuclear power generation in the State of Rinnesota which does not respect the stringent regalations the State Pollution Control Agency requires."

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'm' Honorable Harold LeVander June 2, 1969 j

Pather than atterpting to duplicate the regulatory activities of the AEC, it would seem far rcre appropriate that Minnesota take advantage of the rechanism specifica13y provided by the Congress to acco rodatt the interests of the states in radiological health and safety. Tnis mechanism is a cooperative agreement trith the /2C under section 274 of the Ato-Ac Energy Act whereunder certain regulatory responsibilities of the AEC ray be turned over to a state.

Under these agreements the states assume regulatory responsibility for control of the radiological effects of source ruterial.(thorium and uranium ores), byproduct raterial (radioisotopes),

i and crall quantities of special nuclear raterial (enriched uranium and plutonium).

We in the AEC understand and chare your interest in the health and welfare of the people of Minnesota. We hope that the State of Minnesota would see fit to join the other nineteen states that have thus far entered into cooperative agreerents with the AEC for the radiological protection of their citizens.

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l Cordially,

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/s/ Glenn T. Seaborg Chairman a

t inclosures:

Corents on Per:rdt Proposed by Minnesota Pollution Centrol Agency w/ Attachments (1) Sunm1ry or Releasec i

(2) 10 CFR Part 20 (3) Draft Pemit & Consultant's State.ent i

cc: Honorable Chet Holifield, Chaiman j

Joint Cc=mittee on Atomic Energy i

Congress of the United States i

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- COMETTS ON PERMIT PROPOSED BY MINNESOTA POLUJfION COI. TROL A0b.KCY The following co=ents relate to recomendations to'the Minnesota Pollution Control Agency (IECA) by its consultant, D". Ernest Tsivoglou, and to the !@CA pemit which 13 based on those reco=endations.

Releases from Power Plants Relative to AEC Ren11ations Releases of radioactivity from the operation of licensed nuclear power plants have generally been small percentages of limits 1:: posed under current AEC regulations. Attached is a su=ar/- (Attacrcent 1) of releases in uater and air from licensed reactors during 1967.

During the operation of nuclear power plants, s.all auantities of radioactivity are released from the plants as gaseous and liquid effluents under controlled conditions in accordance with the Atomic Ener g Connission's regulation,10 CPR Part 20, " Standards for Protection Against Padiation" Federal Radiation Councilg in Part 20 are based on guides developed by_ the-(Attach ent 2). Tne 11mi and app:9ved by the President for the guidance of Federal Agencies.

In evaluating acceptable risk from rullation exposure

-the Federal Radiation Council uses the best technical expertice in the field,-

and takes into account the reco=endations of the National Council on Padiation Prntection and Measureg) rts ("CRP) and the International Cornis:'on j

on Radiological Protection (ICRP Tne continuous human use of air and water containing concentrations of radicactivity at Part 20 limits would n:t result in individual exposures exceeding national or international standards.

T'7 Tne FTC us crohted by Executive Order 10831, Aurust 14, 1959, and nede statutory in September 1959 by an arendment to the Atomic Energy Act of' 1954 Tne Council advises the President on radiation ratters afrecting health, including guidance for all Federal Agencies in the forcalation

- of radiation standards and in the establishment and execution of programs of cooperation with the States.

-2/ Tne NCRP was formed in 1929 under the auspices of the National Bureau of Standards of the-United States.

It was incorporated by Act.of' Congress in 1964 Tne re::bership consists of scca 65 recognized experts in the field of radiation protection.

The ICRP waa established in 1928 by the Intemational Congress of Radiology to provide radiation protection guidance. -It_is looked to by national governments end by such international agencies as the World Health Organizatica, the Food and Acriculture Organization, and the International Labor Organization, all of which raintain liaison with the-1CRP, for basic guidance in all areas of protection against ionizing' radiation.

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In view of recent substantial increases in number and size of power reacters under corctruction er plarmed, we have Our re;:ulations under review to detennine whether changes may be desirable. Any changes the Cccriscion decides to make will be mde only after onnor-tunity is afforded all interected groucs to 09.rticipate in the rule makinc procedure.

Techr tal and Economic Feanibility of Recorrendations in t'ne Feoort and IGfA territ -

Phether oneration of the Monticello plant in accordance with the-

!?CA perrit will be technically and economically feasible will denend in large neasure on the technical cornetence and subjective judgment of the pocole adrdnistering it, and the extent to id11ch some of the special requirements will be rlgidly interpreted and applied. This is due to the nany crovisiens in tha ??CA consultant's report and in the pennit uhich are cualified by such words as "to the full extent that is feasible and reasonnble,"... "such measures shal] include at least but not be limited to,"... and "to the full extent pocsible."

Receundatienc 1 th otmh 14 in Section III of the IWA's contultent'c renoM deal generally with limits on releaces of radio-activity fron nuclear facilities within the State. Fncer m detions 5 and 9 provide radioactivity standards which, in rnny ways, do not differ cubntantial]y from those provided in AEC's rerulation,10 CE Part 20. However, the effluent linits that would be es ublished by the numerical niidance in the radioactivity staniards-in the report are :

unner lir3tn. t/uch icwer 1Mits would be imoosed en each reactor.

This philosophy is M 3ected in Seco nendations 6 and 7, t w es 59-60, t/nich provide that, notwithstandin:l "ecomended numerical limits, nuclear nlants should _be reauired to 9an effluent radioactivity concentratiom an -far below there'1$rits an'is feasible and reancnable and that each nuclean plant should be warded as an individual and different cace so far as radioactivity releanes are concerned.

In view of thefhet that the censultant pronosed no definitive criteria or ctonda:xis fer detemining on a case-by-case basis what

. concentratienc should be corc.idered to be "as fa" below those 1mits as 13 feacible and reascnable" we believe that technical and economic feasibility of innlenenting the reconnendations-in Section ~III of the renort decend unduly on the technical comoetence and subjective judment of the persors adninisterinr, them.-

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3-The recontrandations_ in Sections-IV and V of the report deal specifically;

with the. Monticello reactor and _have been implemented, with nodi,/ The pemit -ficat @

addition;,'in the MPCA pemit to Northern States Power Company.2 establishes (1) nurrerical limits on concentrations of individual radio-nuclides in air and; liquid effluent, and (2) special requirements on plant-

.: operation and monitoring to assure that the individual limits are not exceeded.

1 As mentioned earlier, the feasibility of these requirements is dependent on how they will be interpreted and applied, Following are two examples of requa ecments that, if strictly enforced, would be questionable from a '

tephnical and economic standpoint and could inpose a burden greatly out of proportion to the small incremental reduction-of radioactivity in the: effluent; that would be achieved.

Effluent Limits and Monitoring Recuirerents

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MPCA'c consultant emahasizes in his statement of Acril 8 that the recommendations of the International Co=ission on Radi0 logical Protection represent the best available infomation in the world today regmding the hazards of radiation exposure and the dc7;ee of-protection that _must be-provided. Nevertheless, the pe mit contains limits for many different radionuclides which are much lower than those recorcended in the Eeneral radioactivity standards contained in the consultant's ' report and by the ICEF.

In son.a. casca the 11 nits in the pemit for radionuclides in liquid effluent -

are as low as one billionth of the ICRP values.

Although the effluent monitoring requirc: rants in the pemit_ are not clear, it appears that the concentration of each of these radionuclides is required to be tonitored to demonstrate compliance with the specified limits.'

Such monitoring requirements would be unnecessarily burdenseme because trany -

of the radionu:liden are known fr^m experience to occu" in relatively_

uninportant concentrations. For exarple, the pemit-specifies limits for-a 14 different radionuclides of r 51e gases expected l to be released to the -

atnnsphere. The same. degree of radiation protection could be achieved by -

specifying a sincle limit for the total radjoactivity in the fom of_ noble gases, and the case of making the measurennt would be mach greater because 9

of the difficulty of treasuring the concentratior.s of. individual nuclides in the presence of so many others.

In view of the low eiG uent release limits wo do not believe that'an cnvironmental monitoring prognm as comprehensive as that; required in the pemit'is warranted.

In the presentation ;of the draft pemit _to the NPCA it was stated that the raTaired monitoring program will be "... considerably.

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was approved by the MPCA at a meeting' held May 12, 1969 LA copy of the draft permit and-a ccpy of the consultant's statement presented to the M CA in the rrecting of April 8-9, Mo9, are attached (Attachment 3). AEC comrants3 herein, are add"essed to the' draft permit.

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= i nore comprehensive and thorough than environmental programs mquired in-i the vicinity of other comercial power plants." At-the same tire, doubt was cast on the value of such an elaborateLand costly monitoring program-Nith the statement,:"Qaite frankly, if_the permit is adopted as recom-rended,-I expect the envirorc. ental ranitoring program to deronstrate clearly that-the radioactive waste releases from Monticello are so low as to be extrennly difficult,-if not impossible, to detect in the nearby

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environnent."; On the basis of existing infomation, including special studies in the environs of the nuclear power plants at Dresden and Indian-Point by the U. S. Public Health Service and New York State Department-of Health respectively, we agree with this evaluation.

Fuel Elerent Insoection and Irak Detection Reauirement

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Scction 2(e) of the permit provides, in part,

.. initial thorough inspect,1on of fuel rods to identify those that migI t alop' fission product leaks, and rejection of such rods for use in the reuor..." It is not clear whether this requirement is intended to impose inspection prccedures over and above the extensive fuel elerant-insoection procedures required to be carried out under the AEC licensing program.

Under 10 CFR Part 50 of the Carmission's regulations, reactor fuel elemnts are required to be designed to function throughout their lifetime withaut exceeding acceptable fuel darage limits.which have been specified and justified in the reactor license application. -:The. AEC also requires quality asmu'ance programs, test pmcedures and incpecticn criterda to be used in the fabrication of fuel elements. -

With regard to reactor. fuel, a typical AEC licer.se application describes rigid quality controls that are applied at every stage of fuel mnufacturing to ensure that the design specifications are n.et.

Written nunufacturing procedures and quality control-plans define the sceps in

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the ranufacturing process.

Ful cladding is subjected to 100 percent dinensional inspection and ultrasonic inspection to reveal defects in the cladding wall. Destructive tests are performed on representative samples-from each lot of tubing, including chemical analysis, tensile, bend, and burst tests. All tubes are subjected to afcorrosion resistance test (autoclave).. Integrity of end plug welds is. assured by standardization of weld processes based on radiographic and metallo6caphic inspection of welds. Completed-fuel rods are helium leak-tested to' detect the et ce of heliu:a through the tubes and end plugs or welded regions. UO,3 powder-

. characteristics and pellet densities, c_orposition, and surface finish are --

controlled by regular campling inspection. UO,3 wejghts at every stage-in manufacturing are recorded. Dimensional measurements and visual.

Linspcetions of critical areas such as fuel rod-to-rod clearances are

. performed after assenbly and after arrival at the reactor site.

The AEC believes that reactor fuel elements which are manufactured and inspected in accordance with such quality assurance procedures:will-t perform safely and satisfactorily without the need for"any additional g-

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4 inspection requirements such as may be imposed under the MPCA permit.

Further, the Cor.issien's requirennnts, which experience has shown to

technically and economically feasible, have been derenstrated in practice

' to result in the limiting _ of radioactive releases to the envirorcent to

_ levels well below acceptable standards.

Section 2(e) of the b?CA permit further provides for " development and application of methods and techniques for locating and identifying leaking fuel rods after operation of the reentor begins.... The operator shall report in detail to the Agency the $ctual measures taken.in both of these regards before startup of the reactor.

If necessary, he shall' initiate research and developrant activities designed to develop the needed procedures." In the presentation of the draft pem.it to the MPCA, it was stated: "This is another raasure that has not been required before at cormarcial nuclear power plants.

It may not prove lan easy burden to assume, but the pennit requires the cor"pany to demonstrate that it is mking every effoM to do so.

It is enphasized that the successful development and conduct of an effective program for finding and selectively removing leaky fuel elements or fuel assemblies would introduce a new and higher level of control over radioactive wastes from reactors. -It would constitute a substantial practical step forward in tents of really minimicing radioactive pollution of the envircrment."

Tne practicality of the above requirement depends l on how it'would be=

interpreted and administered. Under a strict interpretation it cannot be met with presently designed reactors. Redesign could be costly. 'It 'is more practical to fix limits on radioactivity in thy primry coolant and monitor it'.

Cperating erperience with these reactors indicates that radio-activity levels in plant effluents has not resulted in any safety problcm even though operation has been continued with small leako in the fuel.--Tnin-excerlence has not demonstrated the need for such changes in present reactor designs o" in existing regulation requirements. Further, the incentive for keeping radioactivity _ levels low in the primary system to mininine diffi-culties-de"ing refueling and maintenance operatione has led to-develcpment-and cu" rent use of fuel claddings with very high integrity. These efforts have resulted in actual radioactivity levels well within the Cordssion's regulatory requirements.

Desirability of Adention of Reconmendations Contained in Mi'A hencrt and l'ermit In view of the foreping, we believe that many of the recomendations in the report cannot be justified and, apart from the legal impediment to the issuance of the perit, that the inclusion _of the radiological conditions in the perrdt is not desirable.

As discussed above, some of the recom-mendations of the report and restrictions'in the-permit,_ depending on-how

they are_interpretod and adrdnistered,_could be unduly burdensome without making a meaningful contribution to the puLlic health and safety.- Beyond this, the report and the_ permit reflect an "ad hos" approach to the mgalation of nuclear power plants.which, in our view, cannot and should not be made

- the basis for a fair and effective regulatory prog"am.

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_ _ _ _ _ 7 sy 1967 OPERATEG EXPERIENCE IN BETFASES OF RADIOACTIVIW IN--

LIQUID /A'D CASE 0"S EFFLUEm'S FROM NUOLEE POWER REACTORS 2..

The release of radioactive raterials in liquid and gaseous effluents-from nuclear power reacters and other AEC licensed nuclear facilities is1

governed by the Atomic Energy Comission's regulation,10 CFR Part 20,

" Standards for Protection Against Radiation." The following Tables.I and.

II provide infomation on actual releases of radioactivity in 11guld and gaseous effluents frc 14 licensed nuclear power reactors in 1967 i

Radioactive Releases in Liould Effluents - 1967 - Table I-Licenses authorizing the operation of nuclear power reactors limit concentrations in liquid effluents to concentrations given in Appendix B,_

4E Part 20. Note 1 of Appendix B requires that the concentration pemitted for any one radioisotcpe tah into account other radioisotopes that ray be present. Under this requirment an individual member of the general public could_use continuously the water released by a nuclet" power reactor without exceeding radiation protection guides developed by the Federal-Radiation Council, the-Mational Council on Radiation Protection and Measu"e-ments, or the International Cor?lssion on Radiological Protection.

Actual use cf Note 1 Appendix D, to conpute the gross activity li-it 3

that must be met would reauire'the licensee to detemine the radioisotcaic composition of the radioactivity in the effluent. Tne ' licensee nny elei:t,

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under the provisions of Uote 2, to forego some or all of such deteminations if he tutes more restrictive limits which assume that all of the unidentified radioisotopes in the miyture have the same concentmtion limit as d:ss the most restrictive radioisotope which has not been detemined to be absent' from the unidentified portion of the mixture.

Table _ I of this attacicent lists for each of the operating licensed nuclear power reactors the curles of fission and corrosion products

-(second column), and the curies of tritium (fifth column) released in

- effluent waters. Part 20 concentratJon limit for fission and corrosien

_ products whic;f the licensee elected to use, in; accordance with the conditi ns of' Appendix S, Part 20, and the percent of that lirlt actually utili::ed a"e' shown in the third and fourth columns, respectively. The limit of~ _ _

1 x 10-/ ue/nG selected by most of the-licensees is sufficiently= restrictive-

- that it can be used for any clxture of fission and.ccrrosion products.

e without any identificacion of the specific radionuclides present -in the mixture. The typical radionuclides present'in water effluents from_ power.

reactors are such that,1f the licensee wishes to identify them and_'teasure.

their concentrations by radioisotopic analysis, limits which are less restrictive than 1 x 10M uc/ml by a factor of 100 or more 'c~ould be selected.

. For five of the reactors shown in Table I:the licenses elected to perfcm-tradioisotopic analysis and use a less restrictive 111-it.

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• Radioactive--Releases in Gaseous Effluents - 196*7 - Table II j

'l In practice, releases of radioactivity from nuclear power reactors to Li the' atmosphere are-controlled by release: rate limits incorporated in the

. respective operating licenses.- Each release rate limit:is designed to make

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-it unlikely that any individual in the vicinity of the reactor will be i

exposed to radiation in excess of FRC or ICRP radiation protection guides.

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'Ib provide-this assurance, there is cor:puted for each reactor release rate l

= limits in the atmosphere, taking into account local meteorology, geography, utilization of land and pathways of exposures of pe0ple. Simplicity of j

operation and a high degree of effectiveness are achieved by the development of limita for tuo basic groups of radioisotopes -

a) noble and activation gases, and b) halogens and particulates.

By asstmire that each group consists entirely of the most nacardous_ isotope likely to occur, limits for the total activity of each group can be established which at the same time are conservative from the point of view-of radiation protection and ndnimice the effort required by the licensee to -

maet the limit and demonstrate that he has done so.

Table II lists for each of the operating licensed nuclear power reacters -

the number of curies of radioactivity released, the limit in the license condition, and number of curies pemitted to be released, and the percent of_

j that limit actually utilized, j

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-- Facility li' enses require that the release of' radioactive -11gulds11n plar.t c'

effluents be in accordarse with 10 CFR Part 20, "Standardsifor Protecticn

- /qainst Padiation."- Wnere there -is a mixture -of nere than one radionuclide in the. effluent,- the pe=dssible concentration is dependent upon the extent to which the licensee detemines the isotcoic co=osition of the mixture.

In recognition of the! time and effort required to provide ccaplete infc=2-tien on the mixture, Mote 3 of Appendix-B to Part 20 provides a table fer -

detemining the li:riting permissible concer.traticn if it can.be denrnstrated

- that certain isotopes are not-present,.The values selected by licenseesf from that table are shown in this colum.

A'/In view of the consideratior.s expressed in I:cte 1 above, the values given 3

^

- in this column represent uoper bounds to the percentage of a limit that would be applicable en the basis of a complete analysis of the cerposition.-

1 Limits based on cceplete analysisi if perfored, nould be expected to be substantially higher than those used and the percentages in this column would be substantially less.

3/

-3

- The traximum permissible concentration of tritiu~. in water is 3 x 10 - uCi/mle 4/

- These reactors use no' lithium or baron in the ori~ary coolant and their only significant source of' tritium is fission. Tne fraction of fissions' prcducing tritium is so small tha; none of these reactors can produce 100 curica per yea", and rast of the tritium produced is retained-in the fue'.

. i eierents until they are dissolved in a chemical reprocessing planti. -

EThece data are for the first 8 nrnths and the last 4; months.of 1967, respectively.

Durinr the first 8 ncnths the licensee used the"concentra-tion lirit for a conpletely unidentified mixture of radioisotopes. Ener it beccra evident that the averap concentration for the year uculd probab13 e/.ceed th1t level, he made sufficient ar.11yses to demonstrate that the MFC uoald not be less than 3 x 10-3 uci/ra, a

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