ML20127M076

Provides Regulatory Staff Comments on Various Questions Raised in Ltr & Attachments from Gadler.Documents Bearing on Questions Encl

ML20127M076
Person / Time
Site:	Monticello
Issue date:	11/19/1968
From:	Price H US ATOMIC ENERGY COMMISSION (AEC)
To:	Badalich J MINNESOTA, STATE OF
Shared Package
ML20127M079	List: ML20127M076 ML20127M086
References
NUDOCS 9211250347
Download: ML20127M076 (8)

Text

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Docket Nos. 115-1 '

& 50-263 V NOV 101968 l

Mr. John P. Badalich Executive Director i Minnesota Pollution Control Agency l

459 Board of Health Building University Campus Minneapolis, Minnesota 55440 Dear Mr. Badalich In response to your letter of Septeinbar 3,1968, I am pleased to provide some regulatory staff conenents on the various questions raised in the letter and its attachments frotn Mr. Steve Cadler. Also enclosed are eight information documents bearing on these questions.

I hope the staff consents and information documents will be helpful to you and your colleagues of the Minnesota Pollution l Control Agency.

Siscerely yours, I '( tigned ) Harold L Prtes' Harold L. Price Director of Regulation f

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REGULATORY STAFF COMMENTS ON QUESTIONS .

j PREPARED BY "

MINNESOTA POLLUTION CONTROL AGENCf MEMBER, STEVE J. CADLER

/

! / Information bearing directly on many of the questions listed by Mr. Cadler is contained in the following documents, copies of which are transmitted herewith. .

1. 10 CFR Part 20 - Standards for Protection i

Against Radiation

2. 10 CFR Part 50 - Licensing of Production and Utilization Facilities

3. 10 CFR Part 100 - Reactor Site Criteria

4. TID 14844 - Calculation of Distance Factors for Power and Test Reactor Sites

5. General Design Criteria for Nuclear Power Plant' Construction Permits

6. ORNL-40 0 - Management of Radioactive Wastes at Nucicar Power Stations

7. Staff Safety Evaluation of Monticello Nucicar Generating Plant, Unit 1

8. Portions of Section 170 of Atomic Energy Act The first three references set forth the regulatory requirements which must be met in the siting, design, construction and operation of nuclear power plants. Radioactive releases from these plants into the i air or into contiguous waters during th'eir operating lifetime are subject to the provisions of Part 20 (Reference #1) designed to limit exposures of the public to levels well within limits recomrended by the Federal Radiation Council, the National Committee on Radiation 3 Protection, and,the International Commission on Radiological Protection.

4 As an administrative technique, these limits are translated into detailed operating restrictions based on a study at the site and of local meteorological and hydrological conditions. Instrumentation to measure releases into the air and water must be provided at each plant, and records must be kept of all releases. Both are subject to inspection by regulatory Compliance inspectors.

Factors that must be considered in evaluating proposed sites for nuclear plants are set forth in Part 100 (Reference #3). These relate both to the proposed reactor danign and the characteristics peculiar to the site. The procedures to be used in estimating potential radiation exposure of offsite populations under accident conditions are given in TID-14844 (Reference #4). Safety design requirements

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-2 to provide a wide margin of + ablic safety under both normal operating and accident conditions are given in Part 50 and in more detail in the Cencral Design Criteria for Nucicar Power Plant Construction Permits, (References #2 and #5). The latter document was published in the Federal Register _ for public comment in July 1967, and is expected ,to be issued as a formal design requirement in the near future.

There have been r.o accidents to date in any nuclear plant in the United States which involved a significant of fsite release of radio-activity. As regards releases during normal operations, the most recent experience information is contained in a report, ORNL-4070, (Reference #6) issued in January 1968 by the Oak Ridge National Laboratory. This contains a reference to Elk River.

Reference #7 is included in the information material being transmitted in order to give Minnesota Pollution Control Agency members an opportunity to see what matters were considered by the regulatory staf f and Advisory Committee on Reactor Safeguards in their safety review of the Monticello Nuclear Power Station. This report was prepared for presentation at the public hearing held on May 25-26, 1967, in connection with the issuance of the construction pe rmi t . Although the Northern States Power designation of Unit No. I appears on the cover sheet for this report, we know of no present plans for additional units at the Monticello location. Among the several supplementaty attachments to the staf f review is a letter f rom the Fish and Wildlife Service of the U. S. Department of the interior which may be of interest to Mh \ mco.bers.

Approximately half of the questions Usted by Mr. Gadler are <

concerned with various aspects of the radic tetive releases from Elk River and Monticello plants into thu .ir and into the Mississippi River during their operating lifetime. Our- comments will first be directed to the substance of these questions, then will go to the miscellaneous subjects covered in the remaining questions.

Boiling water reactors such as Elk River and Monticello release small amounts of radioactive gase. into the steam which go through the turbine and accumulate in the condensate system. These gases, which include tritium, xenon and krypton, and possibly some particulates, go to the holdup tank where any short-lived isotopes decay and measure-l

, ments are made of the icvel of radioactivity in the gas. If suitable for release into the high-velocity air stream going up the stack under s

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3-the limitations of Part 20 of the Commission's regulations, the gas is passed through several high-efficiency filters to trap sny particulates that may be present and then released to the atmosphere from a high stack at an exit velocity of the order of 50 f t./sec.

If excessively high activities are detected during the holdup period, or if very unfavorable weather conditions prevail, release to the' atmosphere will probably not be able to meet the conditions of Part 20. The Monticello plant has only a limited holdup capability which, however, should be suf ficient to meet the requirements of Part 20 on atnespheric releases under normal operating and weather conditions. If a situation should arise where release under Part -20 is prohibited and the holdup tanks are filled to capacity, it would be necessary to shut the plant down until favorable conditions develop.

In the event of an accidental escape of potentially dangerous amounts of radioactivity from the stack, emergency actions would be required. Although detailed emergency procedures have not yet been developed for the Monticello plant, the basic plan will be to notify local authorities such as fire and police departments and other civil agencies that previously planned procedures should be followed. If necessary, the twin-city art i would be notified. Notification would

> be by NSP officials or alternately by local police or fire departments.

Under extreme conditions, emergency radioactive monitoring assistance might also be supplied by the U. S. Atomic Energy Commission.

In addition to the radioactivity released to the atmosphere, some radioactive liquid ef fluents are generated during the courne of normal operations both in pressurized water reactors and boiling water These water residues are collected in onsite storage tanks,

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sampled to determine the activity level, and if the level is sufficiently low are eventually released into the condenser cooling water under the limitations imposed by Part 20 of the Commission's regulations.

Some tritium is present gn the liquid g{ fluent along with such other possible nuclides as Cs 37, Co60, Sbl , and Sr 90 Since MPCA has expressed a special interest in tritium, some comments on 4 this subject are in order. Tritium, incidentally, is one of the

- less hazardouc of the radionuclides produced in nuclear reactors because of its relatively low disintegration energy and relatively

' short residence time in the body.

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First, with regard to the tritium releases at Elk River, information in the regulatory inspection files based on RCP batch release records shows that during 1967, 12.5 curies of tritium were released to the Mississippi River with the condenser cooling water from the Elk River reactor. The cooling water had a flow rate of 28,000 gpm. The releases made in batches during the year amounted * -

to an average concentration in the cooling water of about one ten-thousandth of the maximum permissible concentration specified in Part 20 of the Commission's regulations. The average concentration

- of tritium in the cooling water from Monticello will depend on a number of operating factors, but must necessatily meet the i restrictions imposed by Part 20.

How much ef fect has the tritium release from Elk River had on the tritium content of the Mississippi River? This can be estimated from the following considerations. The 12.5 curies released during 1967 with the condenser cooling water gave an average concentration of 170 pico-curies per liter in that water (a pico-curie is 10-12 curie). Mixing of the cooling water with the Mississippi River gave a further dilution to approximately 3 pico-curies (pci) per liter. To place this number in proper perspective USPHS data for 1966 indicate a tritium concentration in surface waters of the United States ranging from 2000 to 15,000 pei/ liter.- The estimated 3 pei/ liter added to the Mississippi by the Elk River plant during 1967 is insignificant compared to the no'rmal background content.

It is much too small to be measured, since the minimum detectable level difference is 500 pei/ liter. Hence there would be no detectable difference between the tritium content of the Mississippi upstream and downstream of Elk River.

To reduce the level of radioactivity (other than tritium) in the liquid ef fluent released to the Mississippi River, the Monticello facility-will incorporate, in its liquid radwaste system, non-regenerative demineralizers empicying resins which af ter they are spent are disposed of as solid radioactive waste.

The liquid waste storage tanks are located in the reactor building which provides secondary containment for the reactor.

(The 230,000 gallon tanks referred to in one of the questions do not contain radwaste. They are condensate storage tanks and contain-only non-radioactive water.) The building in which the . radioactive t

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1 l liquid waste tanks are located is a concrete structure which could contain gross leakage f rom the tanks. The level of radioactivity in these liquid wastes will vary from time to tine, but normally a concentration cf the order of 0.1 curie per liter would be expecte,d.

1 At present there are 27,650 gallons of contaminated water at the Elk River reactor. It contains a total activity of about 1.5 curies.

We understand that it is planned to discharge this con'taminated water into the Mississippi River at a rate of 4500 gallons per month over a 5-month period.

! With regard to effect of dilution of the radioactive material discharged into the water on the reconcentration in the biota and the food chain, we have the following comments. Dilution will not prevent reconcentration in biota. But, since the equilibrium con-c2ntration in the biota is proportional to the concentration in the 4 vater, the dilution of the released radioactivity by the river will reduce the concentrations which would otherwise occur in organisms 4 growing in the water if there were no dilution. The meaningful question with respect to public health and safety is whether the average concentration of a given nuclide in the river will result in a concentrati. a in the biota such that the latter becones a signifi-cant source of exposure to man. Operating experience with power reactors and information on types and quantities of radionuclides likely to be released from such reactors indicate that this is not likely to be the case. Environmental monitoring programs of the facility licensets, various health agencies and the Atomic Energy Commission are designed (1) to confirm that actual radionuclide

releases from power reactors, and their behavior in the environment,

! are as anticipated or (2) to detect any significant variance that I

might occur.

Turning now to the substance of the miscellaneous questions in

( Mr. Gadler's list, each applicant for a construction permit to build l and operate a nuclear power plant at a proposed location is required I

to submit along with his application a Preliminary Safety Analysis Report containing detailed information on the site selected for the plant, and on the proposed plant design. The education of the applicant in the nuclear field is his own responsibility, but before a construction permit or operating license is issued there must be a i

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i finding on the part of the AEC that the

! qualified to construct and operate the propos dapplicant is technic i

technical competence is subject to n co ti e

plant safely. This

! Compliance inspectors throughout plant.

n the e tinuing scrutiny by the i re operating life of the i

that construction and operation express of thA number of questi his concern i to some or all of the difficultiese Monticello e plant may be subject i and Dresden 1. stations, such as Senn, xperienced-e Seini, at otherOyster nuclear Cre k i

not i think there is any essential relationshiThe same, -weanswer do to all th at any of these reactora anu what mayp be ex what happened

! Monticello. between t unforeseen factors associated withere power. theduedevelSome to of the o hone of them created a construction difficulties exper. hazard _ to public safety.oping technology o _

' deficiencies in quality assurance andienced to date have been due toMost of ,

up the finished nuclear plant.and fabrication of materials, co and systems that go to make ,

matters, and the CommissionMuch is taking av emphasis is being placed on e thes 3

i ment tion of of nuclearcodes, powerstandards plants. and criteria ery gove active part in the develop-

! rning the' design and construc- ,

i including Monticello. possibility Of course, this of difficulties.

now does not at preclude other plants the '

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before the plant will be permitted perate.necessarily be resolved to opotential e having the of af I

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feedwater heaters at Monticello e and othAs regards the u n the tube-side of the lations, this is done to minimize corr er similar nuclear instal-

!_ passing through the reactor core.

{ for the same purpose. osion products in the water Activation of corrosion products in thFeedwat and poses undesirable operating .

n unnecessarily problemscoolant e reactor ~

high level - wa

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potential consequences in are _

the applicant'sVarious analyzed for their- -type proposed nuclear power plants. : For the M safety evaluation of i-

' different types of accidents consider pages 14-19 of Reference #7. e d b plant several onticello '

y NSP eye' discussed on i

'15 and 16to the one- referred ~ to at Peach BottThe refueling accident c I assembly 'during refueling.This was assumed to result;from droppiom-N ng'a spent fuel'

Bottom reactor is' entirely at Monticello. -

ged. different ffrom those fuel rod The gas-cooled Peach

• rom the boiling water reactor'

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As regards the matter of sabotage, 10 CFR section 50.13 of the Commission's regulations states that an applicant for a license to construct and operate a reactor is not required to provide for design features or other neasures for the specific purpose of protection against the effects of attacks and destructive acts, including sabotage, directed against the f acility by an enemy of the United States. In connection with this rule, the Commission has pointed out that many of the safety features incorporated in the design of a reactor facility, while not having as their specific purpose protection against the ef fects of enemy attacks and destructive acts, could serve a useful purpose in that regard. Prominent among these are the massive containment for the reactor and procedures and systens for a rapid shutdown of the f acility in the event of an emergency. Moreover, to the extent that the matter of " industrial sabotage" of a nuclear reactor may be appropriate for consideration, it will be considered by AEC at the operating license stage.

As a final item of information, a licensee may not abandon a nuclear plant without first being authorized by the AEC to do so.

Chapter 10 CFR section 50.82 provides as follows:

Section 50.82 Applications for termination of licenses.

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

(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 con' mon defense and security or to the health and safety of the public, and after notice to interested persons, the Commission may issue an order authorizing such dismantling and disposal, and providing for the termination of the -

license upon completion of such procedures in accordance with any conditions specified in the order.

.