ML20127L873

Provides Further Response to Addressed to Chairman Seaborg

ML20127L873
Person / Time
Site:	Monticello
Issue date:	09/12/1969
From:	Price H US ATOMIC ENERGY COMMISSION (AEC)
To:	Engstrom P MINNESOTA ENVIRONMENTAL CONTROL CITIZENS ASSOCIATION
Shared Package
ML20127L868	List: ML20127L864 ML20127L873 ML20127L886 ML20127L897 ML20127L904 ML20127L923 ML20127L928
References
NUDOCS 9211250295
Download: ML20127L873 (23)

Text

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P Distributior' 9

Chairvinn (2)

IF.SMpar t

Conmissioner Raney l'DH (50-263)

Conmissioner Johnscn Valeria Conmissioner Wcepson DR Reading Conmissioner Larson GErtter(DR-2272) i Genemi Manager (2)

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ILPrfce SEP 121969 CKBeck i

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CLHenderson PAMorris W. Paul H. Erigstatus, President WGDooly Mimenota Phvinnmental contml Citisens Association INestem 1053 South McKnirht Bond ERPrice Saint Paul, Mimesota 55119

Dear Mr. Ery:

stmmt him is in further rerme to your letter of Vay 211, 1969, addressed to Chaiman alem T. Seabort; of the Atanic Iberi;y Ccrrdssion, with which you enclosed a series of questions titled " List #3" by Mr. Steve J. Gadler of the Minnesota Pollution Contml Ar,ency.

% letter to you of June 17,1969, enclosed oopies of correspondence with the Minnesota Pollution contml Ar.ency answerire two earlier lists of qwsstions frcus Mr. Gadler which we felt also answered the main thrust of his third list, submitted in someWhat diffennt rom.

I as enclosirc our specific answers to the questions contained in Mr. Gadler's List #3.

Sincerely, 3 0, d.

krW liarmld L. Price Director of Rem 11ation Enclosurw:

Answers to Question List #3 oct Representative Joseph E. Farth l

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9 AEC A'48UDIS TO QUEST 10!;S PREPARED DY STEVE J. GADLER REGARDING Tile M0iTTICELLO NUCLEAR GEN 1 RATING PLANT (Question List #3 Dated April 30, 1969)

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, QUESTION 1.

Since the health and safety of the Minn'apolis-St. Paul metropolitan population down river and dcun vind from the llonticello Nuclear Reactor plant is of concern, why did the AEC -

a.

Approve the request to build and operate a reactor which according to the NSP rinal Safety and Analysis Report has undeveloped components?

b.

License the construction and operation of an experimental type of reactor under the Research and Development section of the Atomic Energy Act?

1.

Is the Monticello site or plant licensed? Or are both I

licenced ?

Permit the discharge of radioactive pollutants into the !!ississippi c.

i which 10 the source of drinking water for approximately one third of the people living in Minnesota and for the down river populations to the Gulf of Mexico and a cource of water for industry and for agricultural irrigation?

I d.

Fail to make any plans to provide a source of water supply for down river users in the event of a nucicar accident at !!onticello which

'vould destroy the river as a nource of drinking water?

e.

Not advice the USPHS that the Mississippi River water was used for irrigation down river f rom the Monticello plant?

f.

Overlook producing complete and thorough studies on the total effect to the Mississippi River Valley ecological cystem from the contemplated radioactive vaste discharges into the air and unter environnents from Monticello, Elk River, Prairic Island and other reac to rs ?

g.

Negicct to consider the damge to the quality of the water and to the river biota f rom the thermal pollutants to be discharged from Monticello, Elk River, Prairic Island and other being planned for this arca?

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ANSWQ 70_qujiST10N #1

'lhe Congress has established and the Atomic Energy Commission admin-i isters a system of licensing and regulation which considers the radiological health and safety aspects of each proposed nuclear paaer reactor, including 4

the design of the reactor and its engineere3 safety features, the outtability of the site, the quality of construction and fabrication of reactor componento I'

vital to safety, and the operating orpanization and ronner of operation.

There are two principal stages in thin licensing and ret.,ulation proccost (1) the construction permit stage, at which the AEC deternines there in reaconnbic assurance that a reactor of the design and pmer proposed can erated safely at the selected site, and (2) the operatin3 licenso ctage, 4

s assurance is obtained that the reactor has been constructed in enance with the permit, and the facility is tested for safety purposes

_nd brought to f ull power.

The !!onticello plant proposed by the Northern States Poser Cotapany (NSp) has successfully passed through the first stage of this licensing process in which a finding was made that there uns reasonahic assurance that the reactor could be constructed and operated at the selected site without endangering the health and safety of the public.

The construction permit i'

authorizes NSP to build the plant at the specific site, and the company has applied for a license authorizing operation of the pla,nt at this location.

In connection with its application for an operating license, which was submitted more than a year in advance of the expected fuel loading date NPS subnitted a Final Safety Analysis Report (FSAR).

During the AEC review period i

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any safety items remaining to be reco1ved, including areas specified as research i

and development at the construction permit stage, must be completed and docu-mented by amendments to the FSAR.

!io operating license will be issued until all plant conponentr. and research and developeent prograns having a bearing on safety are completed, and the regulatory' staff is satisfied that opera-Lion can be conducted without undue risk to the health and safety of the public.

All licenses for nucicar power plants built to date have been issued under Section 104 b. of the Atomic Encrry Act of 1954, as amended, which authorizes the licensing of nucicar facilitics involved in the conduct of research and development activitics leading to the demonstration of the

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prac'tical value of such facilitics for industrin1 or comercial purposes.

j The Act provides that whenever the Commission makes a finding that any type of reactor has been suf ficiently developed to be of practical value within the meaning of Section 102 of the Act, the Commission may thereafter issue "conmercial" Itcenses for such type of reactor under Section 103 of i

the Ac t.

Tliis economic question has no bearing on the safety of the Monticello plant, which is not considered to be an " experimental type of reactor."

The limits in AEC regulations on low levcis of radioactive materials that may be released in effluents from nucicar facilities are based princi-pally on the radiation protection guides developed by the Federal Radiation Council (FRC) and approved by the President for the guidance of all federal agencies. The TRC uses the best expertise in the ficid, and takes into I

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, I account the recommendations of the National Council on Radiation Protection and Measurements (NCRP) and the International Commisnion on Radiological 4

Protection (ICRP).

The AEC limits on concentrations of radioactivity permitted in any j

nuclear power reactor liquid ef fluents leaving a restricted area, prior to dilution in a stream or other body of unter, are such that a menber of the public could use the ef fluent as a source of drinking water throughout his lifetime without exceeding the FRC radiation protection guide for an individual in the population from this source of exposure. Monitoring prograts at nuclear power plants now operating show that radioactivity in liquid effluents is generally less than one percent of limita imposed by AEC regulations.

Concentrations of radioactivity that might be released in the effluents, of course, are further reduced by dilution in the body of water into which they are discharged. With respect to the use of water with such low concentrations of radioactivity for other activitics, such as irri-gation and industrial processes, the maximum exposure of the public that could result: f rom such uses sould be well within FRC radiation protection guides for the public. Copics of all applications to build and operate nuclear power plants, as well as the AEC's safety evaluations, are sent to the U. S. Public Health Service for its infornation and review.

4 Emergency plans and procedures to cope with.unlikely substantial radio; active releases offsite, including notification of appropriate public officials, must be developed and completed by NSP prior to the start of Monticello plant operations. These plans, to be incic3cd in the FSAR, will i

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be reviewed for adequacy by the AEC staff and the Advisory Committee on Reactor Safeguards before a license is granted, and will becote a part of I

the public record. The existence of adequate detailed procedures for implementation of the emergency plans ufil be ascertained by the Division of Cocpliance.

The AEC for more than 20 years has funded research programs on biological and environmental effects of radioactivity, and presently has budgeted nearly 10 million dollars toward environmental research for 1969.

Extensive studies have been conducted over the years of the Columbia River s

in the vicinity of the Connission's Hanford facilitics, and of the Clinch River in the vicinity of the Dah Ridge facilitics in Tennessee.

None of these studies has sheen any harmful effects on the environment.

Environ-l mental monitoring progrars also have been and are being carried out in the vicinity of nucicar power plants.

The quantitics of radioactivity released f rom nuclear power reactors are so small that it has been difficult to i

measure any increases in radioactivity above the natural background Icycis that could be attributed to effluents from the nearby nuclear reactors.

Based on experience thus far, no reason has been found to belicyc that i

routine discharges of radioactive materials f rom power reactors built, under l

construction or planned, will damage the environment; nonetheless, the AEC, I'

in view of the large inercases projected in the number of power reactors, I

is continuing to conduct and to support research in this area.

The AEC presently lacks authority to impose restrictions regarding the thermal effcets of discharges from licensed nucicar facilitics.

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- hicensing by the AEC, however, does not relieve the applicant from being subject to the appropriate jurisdictions in other areas which would also i

be involved if die plant were fueled by coal, oil, or other nonnucicar means, Each state, of course, has the same authority to deal with therral effects t

from nucicar power plants as it does from fossil-fuc3 cd power planto unicas 1

in some way restricted by state law. In this connection, the AEC keeps r

interested state and local officials inforced of applications received and licensing netfons taken on the proposed nuelcar projects, and cooperatcc with federal agencies regarding nonradiological f actors associated with nucicar power pinnts that fall within their jurisdiction.

We have been informed by the Northern States Pouer Company that it intends to conform to water quality standards as related to thermal effcets which have been adopted by the !!innesota Pollution Control Agency, with respect to both the Monticello plant ind the Prairic Island Nucicar i

Generating plant. We also have been informed that the company expects to cooperate closely with the U.S. Fish and Wildlife Service and the !!innesota l

f Department of Concervation regarding any thermal eff ects on the ecology from l

the projected operation of these plants. NSP states that a comprehensive ecoloE cal and radiological monitoring program has been in operation for i

a year in the vicinity of the ltonticello site, and that a similar. program l

is being formulated for the Prairie Island environment.

QUESTIOR l

2.

Since the public health is of concern what control will be imposed on the operator by AEC -

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In event the plant is closed down becatne of accident or obsolescence?

j b.

For disposition of site, radioactive structure and reactor after s

final close down?

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'c.

To provent abandonnent in order to protect the public interest?

I d.

To decontaminate and control arca as long as necessary to protect the public health and safety?

ANDUER TO QUESTToll #2 The AEC determines that an applicant for a nuclcar power reactor operating license possecsea or has reasonable assurance of obtaining the funds necessary to cover the esticited costs of permanently shutting the facility down and maintaining it in a safe condition. A licensee may not abandon a nocicar plant without authorization by the AEC.

Procedures for decontamination. disposal of facilitics and protection of the public health and safety in connection with the termination of licenses are provided for in Chapter 10 CFR Section 50.82 of the AEC's regulations as follows:

"Section 50.82 Application for Termination of Licensca

"(a) Any licensee may apply to the Comission for authority to surrender a license voluntarily and to dismantle the facility and dispose of its component parts. The Cottnission nay require information, including infornation as to proposed procedures for the disposal of radioactive material, decontanination of the site, and other procedures, to provide reasonable assurance that the dismantling of the facility and disposal of the com-ponent parts will be performed in accordance with the regulations in this chapter and will not be inimical to the corrnon defense and security or to the health and safety of the public.

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, "(b)

If the application demonstrates that the dismantling of the facility and disposal of the component parts will be performed in accordance with the regulations in this chapter and will not be inimical to the cormon defense and security or to the health and cafety of the public, and af ter notice to interested persons, the Commission may issue an order authorizing such dismantling and diaposal, and providing i

for the terndnation of the license upop completion of such procedures in accordance with any conditions specified in the order."

i QUESTION 3.

The AEC literature indicates that nany reactors such as Fermi, 7

Pathfinder, Piqua, Bonus, Hallum, Elk River, etc., have been clos ed and others such as Dresden, Peach Bottom, Oyster Creek, etc., have experienced difficulties due to many factors such as equipment failures, deterioration of metal, which has resulted in unscheduled radioactive waste releases to the environnent.

It therefore appears that the reactors are still in various stages of research and development and that all the necertsary experimental work has not been accomplished and in view of these salient facts affecting the health and safety of all Americans, why did AEC not -

n.

Conduct and complete all research and development work tes develop a reactor technology before -

1.

Imposing experimental nucicar plants on the econemy?

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2.

Exposing American citizens to the risks of ion!. zing radiation f rom the radioactive was te discharged to the anvironment from these reactors?

i b.

Disseminate complete information to the public concerning -

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The present health and future risks to the population f rom the exposure to the radioactive wastes discharged into the environment?

2.

. Accidents and accidental discharges of radioactive vastes from reactors?

3.

Total amount of radioactive wastes being discharged to environment, to be discharged, and the probabic effects to health?

c.

Close down reactors discharging radioactive wastes above AEC limits rather than to permit operations when reactors. were experiencing difficultics?.

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d.

Develop positive and secure instrumentation and monitoring methods to insure complete and off ective data concerning amounts of radio-active vastes dincharged to the environment?

Withdraw all operational licenses under the research and develop-e.

ment section of the Atomic Energy Act?

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Provide complete plans for establishing -

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Alert warning networks?

i 2.* Adequate medical fac111 tics and evacuation procedures in the event of a nucicar accident?

ANSWER 'm QUESTION #3 The preface to this group of questions, several of which have been answered in previous co mm..dence with the Minnesota Pollution Control Agency, implies that the difficultics or malfunctions experienced by the reactors nentioned here were indicative of serious risk to public health I

and safety. This was not the case.

While some of these reactors were early prototype reactors built and operated primarily to prove out the very extensive research and development which had gono into their design and construction, all of them had undergonc thorough reviews by independent groups.to assure that any credible malfunctions could not result in seriouc releases of radioactivity to dic environment. It would be unrealistic to assume that it is practical, before operation, to bring any complex process I

or equipment to a stage at Which no malfunctions or failures can be expected to occur and at Which one docs-not expect to effect further improvement based

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on actual operational experience.

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The Conmission has no infornation on releases of radioactive materials from nucicar power reactors and associated risks to public health which is l

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not availabic to the public. The entire process of safety review and t

licensing of nucicar power reactors is carried out openly and publicly, AEC regulations require licensecs to report to the Commission any signi-ficant radiation incident that may occur in licensed operations, which is investigated. These reports are placed in the Cormission's Public Document Room for public inspection.

Nucicar power plant liconacco also file periodic operating reports which are made availabic in the Public Document Room.

Contrar, to the implication in this question, no nuclear power plant licensed by the Commission has exceeded applicabic annual limits on releases of radioactive materials to the environnent.

Also, the Commission has not found it necessary to uithdraw any operating license for a nucicar power plant for health and safety reasons, since the safety record of thcoe plants I

has been excellent.

The instrumentation and monitoring methods used by operators of nucicar power reactors are determined to be more than adequate for the purposes.of 1

demonstrating that releases of. radioactive materials to the environment meet all AEC requirements.

In fact, they adequately demonstrate that releases are far too small to justify the detailed measurements on individual radio-nuclides that would be required to obtain completo data on amounts of radio-active materials released to the environment or to estimate actual exposures i

of people to such materials. For exampic,- operators of a considerabic number i

of reactors determine that the gross concentrations of radioactive materials, i

in effluent water is less than 1 x 10-9 microcuries per other than tritium, i

udlliliter. There is no radionuclide produced in a powec reactor for which i

the recommended maxinum concentration for human exposure is icss than i

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. i 1 x 10 microcuries per milliliter.

Consequently, if the total concen-

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Depending upon the average dilution of the ef fluent in surface waters, resulting exposures of members i

of the public nay be expected to be still smaller fractions of applicabic limits. The very considerabic ef fort that vould be required to perform

~ the radiochemical analyses on each batch of radioactive material released to the environment under such conditions could serve no useful purpose.

As indicated in our answer to Question fl. Northern States Power Co.,

as is required of all nuclear power plant license applicants, must dov lop plans for coping with emergencies before an operating-11censo can be i

These plans are reviewed for adequacy, including provision for i

issued.

establishing and maintaining contact with local and state authoritics,

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t and with hospital of ficials who night be called upon in the event of an j

Since accident at the facility that could have consequences offsite.

the authority to order evacuation of the local area or to impose other protective measures resides uith the local authoritics.and nut with the applicant, we determine that a plan exists in which the applicant notifics, assists and advises such groups regarding the extent of any accident which y

might affect the public and the desirability of initiating protective action I

NSP has also made provisions for treatment at local such as evacuation.

hosptials of injured and/or radioactively contaminated individuals.

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In addition to our prc-licenning evalmtion of an applicant's plans i

for coping with emergencies, AEC inspectors verify the adequacy of the ij detailed procedures for implementation of the emergency plan, as part of the Comission's inspection program extending over the lifetime of the

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f a cility.

In the event of an accident, a licensee is required to notify the AEC immediately, and to initiate energency procedures.

Emergency radio-

' logical assistance is made available under the AEC's Radiological Assistance Program which maintains regional coordinating offices throughout the country.

Under this plan, -if requested, the AEC would coordinate available export assistance fron f ederal and state agencies.

As a part of the Cor::nission's continuing activities to assure capability of the medical profession to j

treat radiation injuries, the AEC also sponsors periodic training seminars l

on a regional basis for physicians affiliated with nucicar plants or with local hospitals that have agreed to assist in the event of a radiation j

accident.

1 QUESTION 4.

The Sacramento Municipal Utility District plant is designed by Uestinghouse to clininate the discharge of any radioactivity to the water environment. Mr. Seaborg, Chairman of the AEC in a speech to an Air Pollution Symposium in Washington, D.C., in 1967 said that the AEC is capable of designing plants without snoke stacks.

In f

view of the SMUD system and the Scaborg statement -

How much time will be necessary to develop a reactor plant that a.

can contain all radioactive vastes?

b.

What are these costs per megawatt of ciectric power produced?

What is the amount of radioactive wastes produced per megawatt c.

of electric power in a BUR type plant of the Monticello size?

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ANSWER T0_ QUESTION #4 The Sacramento Municipal Utility District's Rancho Seco Nuclear 1

Generating Station differs from most nuclear plants in that a large supply of water such as a river or lake is not conveniently available. The nuclear 9

4 steam supply system will be provided by Babcock and Wilcox, and the waste disposal system will be designed by Bechtel Associates. The main difference a

between the proposed SMUD reactor and other pressurized water power reactor designs is that liquid effluents will not be discharged in a local body of water at the site. A special, more elaborate radioactive vaste treatment system'is provided which includes additional stages of ion exchange-deminera-i lizers and additional tanks for liquid storage. The processed liquids are stored for reuse and concentrated radioactivo wastes are converted to solid j

waste material, sealed in drums, and transported offsite by a licensed waste disposal contractor.

The complete containment of gaseous radioactive wastes, if it is ever possibic, will require technological advances to develop equipment for -

removing and permanently holding the radioactive noble gases which are inert, chemically inactive gases.

No estimate of-the cost of developing such a system is available.

I The remarks by Chairman Seaborg concerning the capability of designing stack 1 css nuclear reactor plants were intended to indicate that the amounts of gaseous radioactivity releases from these facilities are so small that some of them are built without stacks; c.g., pressurized water reactor plants.

These facilities do, however, still release some gaseous radioactivity.

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Regarding the amount of radioactive wastes groduced in a plant of the Monticello type, we believe the question was intended to relate to the amount of radioactivity in vastes released _ from the plant. Virtually all i

of the fission products produced during operation remain confined in the fuel cicments until ultimately removed at a, processing plant and stored.

1 The following data are based on the radioactive wastes released from from operating boiling water reactors designed by the General E1cetric

' Company, which would be indicative of the order of magnitude of releases to be expected from the Monticello nucicar facility. During 1967 and 1968, the total radioactivity of liquid vastes released by boiling water reactors ranged from approximately 3 to 65 microcuries per cicetrical megawatt. hour.

The gaseous releases ranged between about 0.3 and 3 curies per cicetrical me gawa tt ho ur,

i QUESTION f

5.

The literature indicates that the AEC has permitted all nucicar reactors to discharge tritium substantially above the icyc1 permitted for other l

' radioactive vastes, why does AEC -

I a.

Pernit tritium discharges to the environment?

b.

Only utilize estimates instead of accurate on-line measurements for tritium discharges fron reactors?

Why has USP11S recently established a tritium monitoring network?

c.

ANSWER TO QUESTION #5 Tritium is a radioactive form of hydrogen. :Some tritium produced

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during reactor operation is released to the environment in routine-air and water discharges. Tritium gas is oxidized over a period of time to form t

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water molecules. Water :ontaining tritium acts chemically like ordinary 1

water; most of it passes through the human body rapidly. This rapid turn-4 i

over, together with the relatively low energy of the radiation emitted, makes tritium relatively less hazardous for s given icvel of radioactivity j

in the water than most other radioactive malcrials. While AEC regulations set concentration limits for tritfum releases from nuclear f acilitics that are higher than for other radioisotopes, thcoe concentrations, under prcncnt and expected conditions in the operation of pmser reactors, could not exceed a small fraction (1cos than 1%) of icvolo considered acceptable for human use by national and international advisory bodies (ICRP, NCRP and FRC).

It is dif ficult to measure tritium in low concentrations.

Since meadurecent accuracy increases with higher levels, the arounts of tritium released to the environment from presently operating nucicar power plants generally are conservatively estimated on the basis of measurements in the l

plant where tritium icvels are highest.

This location is in the primary coolant system where most of the tritium is generated.

It is generally conservatively assumed that the total volune of liquid wastes released have the same concentration of tritium as that messured in the primary coolant, in estimating the aircunt of tritium released to the environment. This is an extrerely conservative esticate, since (1)- the bulk of the volume of t

liquid wastes is from sources other than the primary ~c,oolant; (2) the tritium is in the form of water in the liquid radwaste systen, hence would react like water with no potential means for reconcentrating it anywhere within the reactor system; and (3) the highest tritium levcis would be i

expected in the primary coolant.

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. The Bureau of Radiological llcalth Consumer Protection and Environmental Health Service, Department of Ilealth, Education and Welfare, gathers data on levels of several radionuclides, including tritium, as part of its overall program to maintain surveillance on radioactivity levels in the environment and to evaluate exposures to the public. Tl e agency began monitoring tritium levels in surface waters in the United States in 1964, started gathering data on tritium icvels in milk and food in 1965, and in 1967 began gathering data on tritium levels in precipitation.

Summaries of the data are published from time to time in Radiolonical !!calth Data and Reports, a monthly publication of the U.S. Public Health Service.

1 QUESTION 6.

. According to information released by AEC, it appears hold up tanks will be utilized at the Monticello plant to meet the requirements of the limitations imposed by 10 CFR 20.

In event of an inversion which should preclude discharge of radioactive wastes to the atnosphere -

n.

What action can be taken by plant operators if tanks are already full when inversion occurs and more radioactive gaseous wastes j

nust be handled?

i b.

Will plant be closed down under these conditions?

c.

Are tanks at Monticello of sufficient capacity to hold up all gaseous radioactive vastes under adverse conditions to protect, the public health and safety?

d.

What will be done with wastes produced during shut down if tanks are full?

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ANSWER TO OUESTION #6-Under the provisions of 10 CFR Part 20 of the AEC regulations the cffluents from a reactor facility must be controlled and limited to such.

i values that the cumulative whole body radiation exposure to an individual t

at the theoretical point of highest exposure would not execed the limit 4

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recomended by FRC and adopted by the AEC.

Irrespective of weather i

conditions or gascous effluent holdup. time, an operator of a nucicar l

power plant is not permitted to exceed release rates which are conscr-vatively calculated and specified as mandatory conditionn of the license to impicment this principle.

Continuous radiation monitoring of the off-gas system provides the means to demonstrate compliance with thc. stack release rate linits.

4 Radiation monitors are located before and af ter the holdup system.

If radiation icvels in execss of the allowable instantaneous release rate were detected, an alarm would he actuated, followed by isolation of the off-gas system from the stack. Thus, the high activity radioactive gas would be confined in. the holdup system, and would not be released to the stack until f

it could be ensured that the stach release rate limits would not be exceeded.

If corrective measures to reduce the activity level could not be made within the time delay period of the holdup system, then under the conditions of the license the plant would need to be shut down.

If the ' plant had to be shut down, the radioactive fission products would be contained within the facility's primary system or pricary contain-ment. Additional details on this subject are contained in the attached letter of August 18, 1969, to Mr. Gadler from Dr. Peter A. Morris, Director-of AEC's Division of Reactor Licensing.

l QUESTION

~7.

According to AEC if excessively high radiation Icvels are detected during periods when radioactive gases are held up from discharge to l

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. i environment or if unf avorabic weather conditjons prevail, release to the atmosphere will probably not be abic to meet conditions of 10 CFR 20.

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a.

In such an event does AEC advocate violation of its own regula tions ?

t b.

What are the possible courses of action and recommendations to avoid the discharges under the copditions set forth in item 7 above?

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ANSWER TO QUEST 10:1 #7 As stated in the answer to question 6, the applicant will not be allowe'd to operate in non-complianec with the~ provisions of 10 CFR Part i

20.

In the event thdt the instantaneous gaceous effluent ilmit is exceeded, the applicant may reduce the reactor power icvel to as low as is necessary J

to avoid exceeding these linits.

If need be, the applicant would be required to shut down the facility for an extended period of time.

QUESTION 8.

The Advisory Committee on Reactor Safeguards of the Atomic Energy

. Commission by a letter to Chairman Scaborg dated April 13, 1967, reconnended -

a.

Stress analysis report for the reactor vessel be reviewed by independent experts since this is the first Muclear plant to use a field welded and crected pressure vessel, a procedure new to the indus t ry.

I b.

That the AEC Regulatory staff satisfy itself uith respect to the adequacy of the isolation valve test program and follow

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the development of the detailed design since in the event of i

a steam line rupture external to the reactor containment the steam line isolation valves must close rapidly.

c.

That NSP provide supplementary facilitics for-retention of radioactive wastes during periods of low river f1mi since.

during periods when cooling teier arc. utilized for recirculation of condenscr cooling water the volume of discharge water into

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which the radioactive unstes can be diluted.,iill be greatly

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reduced.

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In view of the importance of the above itens to the health and safety i

of the public, detailed information should be presented to the Agency I

on the status and results of the ACRS Cottmittee's reconsnendations?

l ANSWER TO QUESTION #8 In accordance with the suggestion of the ACRS, the reactor pressure I

vessel stress analysis report is being reviewed by independent experts.

A contract has been let to Teledyne Materials Research Division of the t-Teledyne Company to perform this study. The Teledyno report will be sub-mitted to the AEC regulatory staf f.

Uith respect to the status of the isolation valve test program, valve closure tbsts have been completed, and a report of these tests has been submitted to the regulatory staf f.

Similar valves have been accepted by i

the 'AEC for use in the Oyster Creek and Nine Mile Point facilities. The f

staff and ACRS review of the steam line isolation valves for the !!onticello facility will be completed before an operating license is issued.

l The applicant will be required to comply with the provisions of 10 CFR l

Part 20 in the discharge canal prior to discharge into the Mississippi River.

Since the volume of condenser cooling water in the discharge canal will be greater during high river flow (open-cycle operation) than during f

low river flow (closed-cycle cooling tower operation), the permissible amount of radioactivity released during closed-cycle operation will bc less than during periods of open-cycle operation.

The,radwaste system had been designed and sized so that the facility will be capable of-operating during periods of any of the proposed modes of cooling tower operation.

During periods of extren:ely low river water flow, the liquid radioactive wastes could be continuously recycled through the liquid cleanup system until the radwaste levels were such that release to the discharge canal i

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was possible in compliance with the provisions of 10 CFR Part 20.

Northern States Power has stated that it expects releases to the river to_ be lower.

than,the amount alloued under the provisions of 10 CFR Part 20, even -

under the most adverse conditions.

The description of actions taken in response to these ACRS recomenda-tions, and the results of the AEC staff and ACRS reviews of the matters will-be placed on the public record and made availabic in the Comission's Public Document Room.

l QUESTION 9.

The Monticello Unit #1 design incorporated at _1 cast 12 features (itemized on page 16 of Partial Sumary of the Facility Description

. and Safety Analysis Report) which have not yet been demonstrated in reactor plant operation.

All of. these items were reviewed by the AEC Staff and the Advisory Comittee on Reactor Safeguards,- however since.

these important safety ' features which concern health and safety were only reviewed and not approved detailed information must be presented to the Agency showing -

t a.

Where and when the listed items were found approvable and capabic i-l of meeting all safetyL requirements to-protect the health and 1

safety of the public?

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b..Recornendations as to: the possiblity of safe operation of the'se

= items which are new features and.have not previously been operated in-BUR reactors, without undue risk to health and safety of the public?-

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Of the 12 listed items, 'which items. have:bcon completely developed and approved for use at'Monticello by the. AEC ataff and-_ the Advisory Comittee on Reactor-Safeguards? When and ty whom approved?

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Of remaining items.needing approval how many require additional-research and development?

e.

What is-estimated approval'date?-

f. - What are recomendations on operating the plant -without AEC approval

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l of-all the tested and necessary engineeral (sic)' safeguards?

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o, I ANSWER TO J ESTION #9 The twelve design f eatures ref erred to on page 16 of the " Partial Sutmary of the Facility Description and Analysis Report," which was pre-sented by the applicant at the public hearing on the Monticello facility, I

were, as indicated in the question, reviewed by our staff and the Advisory Comittee on Reactor Safeguards. These reviews, which were performed

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before c. construction permit was issued for the facility, determined that adequate research development programs had been proposed to resolve any safety questions associated with theco featurca.

Before the plant can be w

granted a provisional operating license by the Comission, cach of these

'I features will be reviewed in detail cither during the revicu of the Monticello f acility or during the reviews of other, similar, units which are performed prior to the completion of the Monticello review.

With reference to the twelve features comon with other facilities, the applicant stated, on page 16 of the " Partial Summary," that "the j

operability of cach of the cot:non features will have been demonstrated i

in full scale reactor plant operation prior to operation of Monticello Unit 1."

This is also our expectation.

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These features, as well as all other aspects of the plant, must be the health and capabic of meeting all safety requirements to protect safety of the public.

Several of these teatures, such as the Control Rod Worth Minimizer, i

the Control Rod Velocity Limiter, the Control Rod Drive Housing Support, I

the Main Steam Line Flow Restrictors, the Core Spray Systens, the Containment Atmosphere Control Systems, atid the In-Core Neutron t!onitoring System have j

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J i been considered by the staff and the ACRS in conjtmetion with the Oyster Creek and Ninc !!ile Point reviews, and were found acceptabic for inclusion 3

l in these units. Operation of _ the Monticello unit will not be authorized i

until a final review of any renaining items has been perforn.ed by the staff and the ACRS.

All of the featurcs are under current review with respect I

to their adequacy for use in the Monticello facility.

The results of final revicus of the staff and the ACRS will be placed on the public record and made available in the Commission's Public Document Room. When published, copics of these reports can be obtained by writing to the Director, Division of Reactor Licensin'g.

The anticipated fuel loading date for the facility is in early 1970, but we emphasize the operation of the plant will not be allowed without a Commission finding that the plant, including necessary engineered safety features, can be operated without unduo risk to the health and l

safety of the public.

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