ML20127M618

Forwards Preliminary Draft of Waste Disposal Permit for Monticello Nuclear Generating Plant

ML20127M618
Person / Time
Site:	Monticello
Issue date:	05/08/1969
From:	Seaborg G US ATOMIC ENERGY COMMISSION (AEC)
To:	Badalich J MINNESOTA, STATE OF
References
NUDOCS 9211300329
Download: ML20127M618 (2)

Text

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0 O/r MAY 81969 So M3 Mr. John F. Badalich Executive Director Minnesota Pollution Control Agency 459 Board of Roalth Building University Campus Minnespolis, Minnesota 55440 bear Mr. Badalich:

With your letter of April 11, 1969, you saclosed a copy of a preliminary draft of a weste disposal permit, dated March 31, 1969, for the Monticello Nuclear Generating Plant. You stated that the Minnesota Pollution Control Agency is considering the issuance of this permit wit.h possible disposition at the meat meeting of the Agency scheduled for May 12, 1969. The perunit contains a number of "specist Conditions Relating to Radteactive Wastes."

I understand that Mr. Tuvesos and you met en April 24 with the Director of Regulation and other moders of our staff, and discussed the jurisdiction question.

giace you have invited our ca====ts, I believe it appro-priate that I again call your attention to the legal situation as we see it.

I understand that a copy of our General Counsel's opinion on this subject, which was pubitshed in the Federal Register of May 3,1969 (pages 7273-7274), was given to you during your recent visit here. The conclusions of the opiaton are sun-marised as follows:

By virtue of the Atomaic Energy Act of 1954, as amended, the individaal states may not, in the absence of an agreasest with the AEC, regulate g

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seurse, byproduct and special austear material from the standpoint of radiolosteal health and l

safety. sven states which have eatered into agreements with the AgC. lack authority to regu.

late the facilities described in the Atomic snergy Act, including nuclear power plaats and the die.

charge of effluents from such fact 11 ties, from the 1

l standpoint of radiological health and safety. To the extent that " Agreement States" have authority to regulate byproduct, source and special nuclear material, their section 274 Agreements require them to use their best efforts to assure that their regulatory programs for protection against radia-tion hazards will continue to be compatible with the AEC's program for the regulation of byproduct, j

source and special nuclear meterial.

Sincerely, Distribution:

Commissioner Ramey 1

Comunissioner Johnson G! 60 b l W3 Commissioner Costagliola P

CKBeck MMann mairman RLDoan CLHenderson Secretarial J

cc: Mr. gobert C. Twveson HLPrice 4

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ps 2118 STATE OF MINNESOTA POLLUTION CONTROL AGENCY 717 DELAWARE STREET S E.

(OAK AND DELAWARE STREETS S E.)

MINNE APOLIS. MINN ESOTA es44o April 11,1969 Dr. Glenn T. Scaborg, Chairman U. 9. Atonio Energy Coccicaion Vachington, D. C.

20545 Dear Dr. Soaborgs I regret the lapso of timo in acting and 'thtaking you for the material you forwarded to mo under cover of,your letter dated l'. arch 123,1969 but the matter of radioactivity in the State of Minnocota hac preoccupied a considerable amount of my timo as you may be well aware of.

For your information, review and also if you viah to co:mont, is a copy of the prolininary draft of a vasto dicpocal permit for the "onticello Nuclear Generating Plant dated March 31, 1969 that was the cubject of countleca hours of diccuacion durinc our April 82 'and 9th Agency mootings. Alco enclosed, is a copy of the ctatement of our consultant, Dr. Ernest C.

Toivoglou, made at this hes)inc.

The diccharge permit for thin nucioar power plant is being further considered by our Aconey memborn with possible dicposition at the next mooting of the Aconey coheduled for May 122, 1969 Further questions have been developed by'one of our Agency memb:rs which wo would have clarified by our consultant before further action in taken on this permit.

In any event, the main purpoco of cy writing to that I expect to bo in Uschington, D. C. on April 23-24 and poccibly on tho 25 in conjunction with the mooting with the International Joint Commicsion. I would, therefore, liko to cot' up on informal meetin3 with you and/or members of your staff sometimo durir' the latter two days of my Washington trip (24-25). This v..

a would to at-your convenience to diccucs mattera relating to tho cubject of radioactivity and Minnosota's futuro role in thio matter.

$ W [/ M Rec'd Off Dir.lMf Rep W '2118 bu/

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April 11, 1969 i

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Accompanying me on this trip will be one or two Agonoy members and a member of g staff.

l I appreciate your interest in this matter att trust that the proposed arrangements can be made.

j Yours very truly, i

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John P. Badalich, P. E.

Executive Director a

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co Mr. Robert Tuveson i

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Mr. Harold L. Price 4

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. March 31, 1969-i 1

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

I University Compus Minnonpolic 55440

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WASTE DISPOSAL PERMIT Monticollo Nuc1cor GoncretinD Plunt,

Northern Statco Powcr Company, Monticello Township, Wright County 1

Purcucnt to authorization by the Minnacota Pollution Control A00ncy, '

cnd in occordt.nce with tha. provisions of Minnesota Statutos,1967, Chaptero 115 t,nd 116, a permit in hereby Granted to Northern Stateo Power Company, Minnunpolin, for dioposal of waste from o utcom electric generot'ing plant i

bdng constructed by the company in the ucst half of Section 33, Township 122 U,.Ren0c 25 U, Ur1 ht Count /, including the dicchor00 of affluento, ao 0

l hercin belou opecified therefrom to the Micciosippi River, subject to the conditions given below:

Genern,1 Conditions 1.

This permit shall not relcace, the permittne from any libbility or obligation iraposed by Minnesoto statutes or local ordinances and chall remain in forco subject to all conditions and limitatione nou or hereafter impocad by low.

The permit chall be permissive only end ohn11 not bn construbd no ectopping or limiting any claims against the' permittee for dcmagn or injury to person or property, or omionions of the permittes, its agento, contractors or essigns, nor as notopping or limiting any 1e001 claim of thn stato caninct the permittec, its agents, contraccors or asoigns, for demDDo to state pro-party, or for any violation of subsnquent regulations or conditions of thic permit.

2.

No assignment of this permit shbil be, effective until it is executed in uritin0 and signed by the partico thereto and thereafter approved by the Agency.

3.' No major alterations or additions to the disposal system ohall be mode without the written consent of the Agency.

4 The use of the disposal cystem chall be, limited to the trouttaant,

or dicposal of the waste materials or substances. described in the permit opplication dated July 11, 1967, and associated material filed with'the Agency.

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5.

The permit is cubject to modification or revocation, and may he cunpended at any tirou for f ailure to comply with the termo ctated heroin or the provisiono of any other opplicable rc0ulations or standards of the Agency or its prodcccocora, and is incued with the understanding that it does not cotop uubsequent cotablichment of further requircmants for trootment or con-trol at any time by insertion of opproprieto additional cloucos heroin at the diocration of the Agoney if it is concidered necessary in order to pro-vent or reduce possible pollution of tho environment.

6.

The parmittoo or onsigns choll defend, indemnify and hold harmloss the Stato of Minnesota, its officero, ogents and employeco, officially or poloonally, 00ainst any and all actions, claims, or demands whatsoever which may criso from or on account of the issuance of this permit, or the construction or maintenance of any f acilitics hurcunder.

7.

Certification of comple' tion of the project chall be modo immediately ofter construction in finished.

Reports on affluent quality and operational practicco chall be submitted regularly every month, and the permit holdor choll certify that ho is in all respects in conIormance with the conditione given in the Agency policy statument of August 22, 1967 entitled, " Policy Rogording Operation Pormits for Sewego and Industrial Wasta Trootment Uurks."

Special Conditiono Relatinn to Conventional Woctes 1.

fJo rou ceungo or treated ocuogo affluent chall be discharged to surface waters of the state from the plant aito.

2.

Any additional construction pinns and design data which may bn re-quired for all disposal systems nooded for collection, treatment and disposal of ocwagn, industriol uastes and other wastes originating ot thib oite, and for effective containment of stored liquidG or other,pollutional matorials, for the. prevention of wotor pollution to conform uith the requirements of this permit, shall be submitted together with any other information requested for revicu by the Agency. ' All cuch plans shall meat with the approval of.

the A ency and the systems be completed before operation of the plant is 0

started.

3.

The following standardo of quality and purity applicable to the effluent of the holding pond shall hot be exceeded at the point of discharge I

from the pond:

pH value 6.5 - 8.5 Turbidity value 25 5-day biochemical oxygen demand 25 milligrams / liter Total suspended solids 30 milligrams / liter

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4.

CoolinD focilitics shall be provided and operated to insure that the hunt content of the coolin0 water af ter racsonable dilution and mixing in tho river does not raiso tho ternpurature of the river above the limita cpccified

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below:

Period Maximum Temperature July and August, inclusive 86*F (or 5'F obove tho Dune and September, inclusivu 80'F ombient temperature May and October, inclusive 67'F of the river, which April and November, inclusivu 55'F over is Dructor, ex<

March and December,* inclusive 43*F ccpt that in no ces January und February, inclusive 37'F shall the river, tem perature exceed 90'{

The design of treatment works for compliance with the strecm utandards, unicss otherwise specified, shall be based on the seven consecutivo day low flou of the river which is equal to or excucdad by 90% of' such coven-day minimum everage flows of record (the lowant seven-day flow with a once in ten year recurrence interval) for the critical month.

The extent of the mixing zone to be permitted will be determined by t' 3 Agency at a later date ef'ter reviewing the dato made available on the ch tacteristics of the river und the effluent and other pertinent considerations 5.

No industrial waste, or other wastes, treated or untreated, shall be dischar0cd into the watern no ac to ecusa any nuinanco conditions, includin0 without litnitation, the presence of nubstantici cmounts of floating colids, scum, oil, suspended solids, discoloration, obnoxious odors, slud e deposits, 0

slimes, or fungus growths, or other offensive effects; or so as to cause any materitlincrease in any other chemical constituents; or cause any substential change in any characteristics which may impair the quality of' the water so-as to render it objectionable or unsuitable for fish and uildlife or as a sourco ' of water for municipal, industrial or agricultural purposes; or other-wise impair the quality of the waters for any other uses.

6.

The company shall measure the quantity and characteristics.of and scrapin and analyze the industrial wastes, other wastes and stored liquids at the sito as may be requested by the Agency, and-shall provide the AgencV cvary month with a complete report on such rnaasurements, samples and analyses, to-gether with any..other information relating to waste disposal or pollution control which may be requested..

7.

Facilities for monitoring the quality of the receiving untura shall be provided and used as requested by the Agency.

Resulta of the monitoring shall be reported to the Agency at monthly intervals.

8.

The company shall cause to be made without cost to the state, tech-nical studies and investi0ations of the biota and quality and related matters pertaining to the waters of the state which receive the plant effluents, or which are in the immediate vicinity of the plant, as may be requested by the Agency.

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

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4 9.

Continuous operotion of all of the treatment works at their maximum capability consistent with practical limitoG3ns und maintenanco noudu of such f

works shall be maintained at all timos when the plant 10 in operation and when noccounty to provide adequate treatment of the uewoDe, industriol wastos or other wastes by the terms of thic permit.

10.

The company shall capeditiously make any changes in waste disposal, nonitorinD, and reportin0 practicos, and provido ony additional treatment works or disposal systems or other safeguards for the prevention of pollution of the environment upon the rcquest of tho Agency.

11.

Liquid substancos which could constitute a sourco of pollution 'of the waters of the state shall be stored in accordance with regulation WPC 4.

Other wastos as defined by Minnesuto statutes, section 115.01, oubdivision 4, shall not be deposited in any manner such that the same may be likely to gain entry into thcsc wator'.

In any coce whcro such substances, either liquid' s

or solid, as a result of accident or natural catastrophc should gain ' entry into cny unturu of the state, it shall be the ruoponsibility and duty of the coupany to inform the Agency in the quickest timo pousible and immediately remove and recover all such pollutional substances to the fullest extent reusoncbly possible under existing conditions.

12.

The industrial or other uuste effluents as discharged shall comply with any and all applicable requirements of effluent standcrds or river clacsificationa cnd standards which may be adopted by the Agency for this typa of sou.'co and/or for these waters in the future.

Special Conditions Relatinh to Radioective Mastes 1.

It is the policy of the Agency that all radioactive pollution of the environment shall be held to ~ the icwast icvel that is attainable within the limitations imposed by technological feasibility and economic reosanchic-In no case shall members of the public be exposed to radiation beyond nces.

the limits recommanded by the International Commission on Radiological Pro-tection.

In addition, the actual levcis of radiation exposure of memburs of the public shall be kept as for below those limits as possible, consistent with technological feasibility and rocsonableness of cost.

2.

In keeping with the above policy of the Agency, all technologically feasibic and reasonabic measurcs for treatment, control and containment of radioactive wastos from the Monticello nuclear generating plant of the Northerr States Pouer Company shall be employed for the purpose of preventing the re-lease of radioactivity to the environment.

Such measures shall include at least, but not be limited to:

(a) all measures for the treatment, control and containment of liquid and.goseous radioactive effluents that are indicated in the Final Safsty Analysis Report of the Northern States Power Com-j pany, Unit 1, Monticello nuclear Generating plant; and r

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(b) routino removal of radiciudinc and holo 0cnu from the caccous effluento to the full cxtent foncible, the dc0 roc of treatment und removal bein0 at luost the equivalent of that pro-vidad by ofrective octivated charcoal filtration of the entire air ejector offgas flow; and (c) routino ion exchange treatment (Powdox demineralization or equivalent) of the combined low purity wastes (primarily from floor drainn) and the neutralized chemical unsteo (prianorily from loboratory draino and shop docontaminntion solution drains).

The combined estimated flou is 0,000 gal / day; and (d) initial inspection of fuel rods for curface contumino-tion with uranium before uce in the reactor, cnd decontc.nination or replacement of fucl roda that have detectable or significant omounts of uronium on their external surfacco, so ao to prevent the use of such fuel rods in the reactor.

The plant operator shall report in detall to the agency the mecoures taken in this regard before startup of the reactor; and (c) initial thorough inspection of fuel rode to identify those that might develop fission product lenks, and rejection of such rods for une in the reactor; to the full extent possible, develop. Tant and application of methods and techniques for locating and identifyin0 lookin0 fuel rodo efter operation of the reactor beDinc, so that such rods may be removed during' usual fuel replace-ment operations, or, if necesoery, et other times, to prevent ex-cessive release of radioactivity to the environment.

The operator chill report in detall to the Agency the actual measures taken in both of'these regards before startup of the reactor.

If necessary, he shall initiate research and development activities ~ designed to develop the needed. effective procedurcs.

3.

The gross beta-gamma radioactivity of liquid effluents released to the plant discharge canal shall be limited to the extent that the annual aver-agegrossbete-gammarodigactivityconcentrationofthewaterinthedischarge canal shall not exceed 10 pc/ml (100 pc/1) plus the background radioactivity.

4.

As an integral part of Special Conditiono 3 above, the concentrations' of specific radioisota as in the discharge canal shall not exceed, on an annual r

cvorage basio, the following limits:

. Averone Daily Concentration, pc//ml,

. Radioisotope Normal (U}

Low (b)

River Flow River Flow (1)

(2)

(3)

H-3 2 x 10~0 4 x 10~7 j

F-18 8 x'10~13

'l x 10~11 No-24 2 x 10-12 3xlb"Il

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G Averone Daily Concentrntion, uc/ral Normul("}

Low (b)

Radioisotope River Flow River Flow (1)

T2)

(3) 1 x 10 9 x 10-13 Cr-51 5 x 10-12 4 x 10~11 Mn-56 9 x 10~12 1 x 10-10 Co-58 9 x 10~13 1 x 10~11 Co-60

~13 8 x 10~12 Sr-90 4 x 10 2 x 10~I1 4 x 10-10 Sr-91 4 x 10-12 8 x 10~11 Sr-92 1 x'10-10 4 x 10~9 To-99, Mo-99 8 x 10-10 4 x 10~11 I-131

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~9 1-133 2 x 10 4.x 10 6 x 10~11 1 x 10~9 I-135 6 x 10-13 1 x 10 Te-132 Co-136 6 x 10~1 1 x 10-12 Cs-137 2 x 10 4 x 10~13

~13 4 x 10~13 6 x 10-12 00-139 8a-140 4 x 10-12 6

10-11

~('a ) Open cycle - 93 percent of' days; no use of cooling towers; discharge canal flow 645 crs.

(b)- Closed cycle 7-percent of dayo; full use of cooling towers, dis-charge canal flow 36,cfs.

In addition to the specific radioisotopo concentration limits given in the above table, and on en interim basis until plant operation provideo more i

def'inite information, the -everage daily discharge canal concentration of any

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-other radioisotope shall not exceed one three thousandth (1/3,000) of the opecific ICRP limit or ene three-hundredth (1/300) of the numerical limit for!

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that radioisotope, as specified in Appendix B, Table II, Title -10, Part 20 of the USAEC Standards for Protection Against Radiation.

In cacu these two limit differ for any specific radioisotope, the lower limit shall apply.

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5.

In addition to all of the foregoing liquid offluent radioactivity concentration limitn, for any coven consecutive day period the average grous bein-gnmma radioactivity 7 concentration of the unter in the discharge canci chall not exceed 5 x 10 pc/ml (500 pc/1) plus the back round radioactivity, 0

and the overoga concentration of any spedific radioicotopo in the diuchur00 canal chall not excocd a limit of five time the vol'uc given in the above table.

6.

Thu Dross-beto-gtmma radioactivity of the gescous offluent released via the plant stack shall not exceed, on on annual overnDe basio, a relecon rate of 0.01 curie per second.

This refers to a total otock air flow of 4,000 cfm, and thereby also specifico the limiting concentration of gross boto-gamma radiocutivity in the stack effluent before dilution in the atmoophero.

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As un integral part of Special Condition 6 above, the concentrations of specific radioicotopos in the stack before release to the atmosphcre shall' not exceed, or an annual average basis, the following limito:

Stock Concentration (a)

Radioisotope pc/ml 4 x 10~9 H-3 3 x 10-6 Ar-41

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Kr-83m 1 x 10

~b Kr-85m 3 x 10

~7 Kr-85 2 x 10 1.x 10~3 Kr-87 1 x 10~3 Kr-88 2 x 10-5 Kr-89 1 x 10-6 Xc-131m 1 x 10-5 Xe-133m

,Xc-133' 3 x 10~4 Xc-135m 4 x 10 6 x 10~0 Xe-135 Xc-137 5 x 10 2 x 10-3 Xc-138

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At a total stack air flow of 4,000 cfm.

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8 In addition to tha specific radioisotopa limits D vun in the tabic i

inimediately abovc, and on on interim bosis until plant operation providos more definite information, the overego duily stock concentration of any other radioisotopo before release to the atmouphcre shall not excocd 10 times the opacific ICRP limit for continuous occupational exposure, or 100 times the numerical limi't for that radioisotopu as specified in Appendix B, Tobis II, Title 10, Part 20, of the USACC Stendards for Protection Against Radiation.

8.

In addition to oli of the forogoinD goocous (stack) offluent con-contrntion limito, the grous batu-go.nma radioactivity Jr the gasooua of fluent reloaced via the plant otack choll not exceed _o releace rate of 0.05 curio pet second for any seven contecutive day period.

During such a period, the stack concentrnLions of specific radioicatopes shall'not exceed five tir.cs the numerical limite given in Special Condition,7.

A stuck relenco rate of 0.05 curiu per second shall automatically cound

a. plant alarm to warn the plant operator that the weekly relanco rate limit has been reached.

9.

In addition to all of the forngoinD gaseous (otack) effluent con-centration limits, the gross beta-gamma radioactivity of the gescouu effluent released via the plant stack shall not exceed a release rate of 0.30 curie per second for any 15 minute period.

During such a period, the stack con-contrations of specific radioisotopen shall not exceed 30 times the numerical limits given in Spucial Condition 7.

A stack release rate of 0.30 curie per second shall automatically sound a second and different alarm to warn the plant operator that the ' instantaneous releace rate limit has been reached.

Af ter a 15-minuto' delay, the air ejector i offgas isolation volve shall automatically close, shutting down to reactor, if the radioactivity release rate has not been successfully reduced to the uoekly release rate limit, or less.

10.

During the first year _of operation of the nuclear generating plant-at Monticello, the routine effluent monitoring program of the Northern States Pouct Company shall be designed to identify and quantitatively _ account for all specific radioisotopes that are released in significant quantities, to the full extent reasibic and reasonable.

This effluent monitorinD program shall provide for and include at least the: kinds cf samples, frequencies, radioansay procedures, etc., described in the MPCA Final Report entitled r

j Radioactivo Pollution Control in Minnosota, and dated January 31, 1969 j

(sco capccially pp. 139-143).

i 11.

During the.first year:of operation of the nuclear generating plant at Honticello, the routino environmental radiological monitoring and sur-veillance program of the Northern. States Power Company shall be designed to y

detect and evaluate all radioactive releases from ths plant, to the full ex-tent feasible and roanonable.

This environmentel monitorin0 prggram shall provide for and include at least-the kinds of: somples, _ f requencias, radioassay; procedures, etc., described in the MPCA Final Report on Radioactivo Pollution Controi in Minnesota, dated January-31,1969 (see espec'ially Table -IV, pp. -135 P

and 136, and the ocction in.cluded in pp,. 114-139).

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All offluent and environmental-nonitoring program results shall be reported monthly by the Northern States Power Company to the Agency.

All nonitoring program recults shall also be ovailablo for inspection by the Agency at the pinnt cito et any tima.

13.

The Northern States Power Company chall cooperate to the full extent nececoary with the MPCA and with the Minnesota State Board of Health for purposea of development by those 00encies of an

• dequate and effectivo

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emer0cncy protection plan designed to immadiotely te trol and minimizo the effectc of any accidental rolease of unexpectedly large quanities of radio-octivity from the Montienllo nuclear gancrating plant.

In perticular,-the Northern States Power Company shall immediately notify the MSBH of any un-controlled release of unexpectedly large quantities of radioactivity to the offsite air and/or water environment due to operational' f ailure of any of the power plant nystems.

Also, the Northern States Power Company shall cooperato in this regard to the full extent outlined in the MPCA Final Report on Radio-active Pollution Control in Minnesota (oce pp. 90-97), and in any other monnor requested by the MSDH.

14 The "Special Conditions Relating to Radioactive Wastec" part of this permit is limited to the first year of operction of the Monticello nuclear generating plant.

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

A new permit relative to radioactive unstoa, modified and changed to the ex-tent doomed necessary by the Agency, and based upon the results of the first year of power plant operation, will be issued by the Agency for the sacand year of operation.

15.

It is emphasized that public cnd environmental radiation protection practico is based upon a concept of very long term. protection, rathar than only immediate or momentary protection.

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

are designed to restrict radiation exposure, on a continuous basic and over a lifetime, to le" ole that will not produce datectable or significent somatic or genetic harm.

The annual average release rate limits contained in this Permi+ nlso refer to continuous, lifetime radiation exposure, rather than to momentary levels, and are considerably more stringent than could be permitted according 'n +ha 1.R.C.P. recommendations.

Hence, the slight transitory (E.G., de ly) w riotions around those limits that are to be normally expected should not ;e5 Jt $n overexpos~ure to radiation of any member of-the public, and should therefore not be ' viewed as cause for great alarm or for hasty and unreasoned action.

n John P. Badalich, PE Executive Secretary and Chief Executive Officer Permit No.

.j533 Dated April 8,1969 2

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STATEMENT '0F E. C. TSIV0GIOU-4 April 8, 1969 s

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i The main purpoco of my statement today is to review uith yor. the Permit' that has been recommended for tho first year of operation of the Monticello nuclear i.

E generating plant by the Northorn States Povor Company. First, I will briofly -

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i outlino the primisos upon which the Pormit is basod.

I will then discuss the l..

nain features of the Permit in torms of the cafeguards that have bocn built into k

l it.

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I hope that uo vill be able to et,ick to hard facts _today, to the ortent that they t.ro availablo, and that uo can avoid the kind of t.;aggeration that has charactor- >

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'ized some of the recent public statements regarding radioactivity and the Monticello -

1 plant. I hope that decisions regarding'this new facility can bo based upon rational consideration of real facts, and not upon unfounded speculations, emotions or politica.

TliE PRE!USES

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'he permit that has been recosnonded for the first ' year of operation of the 4

l Monticollo facility is designed on the b' asis of two major premises. They are as follows:-

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(1) The radioact'ivity, limits that have been recom:nonded.by the International I

Comission on Radiological Protection (ICIP) represent the hast available J

l-information in the world today regarding_ the h'anards of_ radiation exposuro ' J i

l and the degree of protection that must bo 'provided.

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(2) All radiution exposuro must bo -actively ninimised t'o the full extent This that is both technologically fehoible andicconomically reasonabic. #

I means that 'in no caso can 'th'o limits recommended by the-(ICIP) bc l

exceeded, but' in addition, the -actual-_lovel of radiation exposure should i

bo kept as far below those limits as is achievablo {n a practical senso.

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4 In reCard to the first premiso, the radiation protection limits recomended by the ICIP are accepted by responsible public health and pollution control agoncios throughout the world. They form the basis for virtually all'other radiation protoc-tion standards, such as thoso provided by our 11ational Comittee on Radiation 1

Protection (11CTP) and thoso enforced by the U. S. Atomic Energy Comission ( AEC).

Tho limits recomended by the ICRP have boon designed to restrict radiation exposuro on a continuous basis and over a wholo lifotino to levels that will not produce detectable or significant bodily or genetic harm.

i Regarding the second promise, which I refer to as the Principle of liinimum Exposure, all responsible agencies also agree that hur t radiation exposure should bo minimized. Even exposure at the low levels recommended as limits by the ICIP is taken to be harmful in principle, although t,his has not been demonstrated as feet, and so it is comonly acrood that actual oxposure should be kept below thoso limits to the full extent possible in a practical sense. As I describe the requirements of the permit for the first year of operation of the !!onticello facility, and tho safeguards that have been included, I think it will become quito ovident that a very high degree of radiation protection vill be provided.- The permit that has bocn recommended does not provide for absoluto zero radioactivity rolcase, as that goal is not. regarded as practical at this time. The Permit does provido for a higher degree of protection than has yot boon required at any commercial nuclear power plant in the United States. It is worthy of mention also that no public ogency, state, federal or international, has folt that absoluto zero radioactive

}

pollution is either a practical or a necessary goal.

Tnoso, then, are the premises upon which the recomended Permit is based: that the r[diation protection limits recommended by the ICRP uould, oy them.selvos, provide I

a high and an adeq ato degroo of protection of the public and its environment; that E

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, sower plant should be actual radioactivity ro1 Loos from the !!onticello nucloac I

o copt as far below those lhits as possiblo; and that a goal of absoluto zoro radioactivity rolcaso from tho plant is noithor practical nor necossary at this timo.

4 i

'TITR PERMIT AND THE SAFEGUARDS The Pormit that has been recommended for the Monticollo nuclear gonorating stationo soto li:sts on radioactive waste roloases that aro. much moro stringent than tho limits that are preocntly enforced or planncd at any other commercial nuclear l

pouor plant in the United Statco.

In kocping with th'e Agency policy of olininating radioactivo pollution of the environment to the full extent possiblo,- the Permit I

i also requiron cortain wasto treatacnt and control measures that aro now to tho nuclear poner industry, but thoco aro included to provi's additional assurance of l

onvironmental safety. In addition to thoso'fcatures, the Permit requires tho opera.

1 tion of comprchensive offluent and environmental monitoring programs that aro l

fully capablo of detecting any failure to comply with the specified radi.oactive j-rolonce limits, both liquid and gasoous.

4 Quito fran1Gy, if the Permit is adopted as reco:enended, ~ expect the environ-mental conitoring program to demonstrate clearly..that the radioactive wacto roleases-2.

1 l

i from the Monticello plant are so low as to be extremely difficult it.not impossibic to dotet in the nearby enviornmant.

To be r; ore opocific, and to stick to facts, let us-consider some of the nucorous 1

safeguards that aro-contained in the Permit. They include 1.

The liquid and gascous radioactive waste rolcaco limito specificd by tho Pormit would restrict such' relocscs to no uore than two or throo percent l

of the amouato that can be-released according'to the current ICRP or AEC i

requiroments. The Porait specifies offluent limits, rather than coro con-

,i monly use environmental lhits, for the specific purpose of providing for 4

I I

closer control of the radioactivity releases. The limits that sro speci-fled are thus much more stringent than thoso in offect at (ther commercit.1 nuclear power plants,

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4 Enfor'ccment of the requirements of the Permit means thtt the actual radioactivity rolcasos vill in most cacos bo well below the two or three porcont mentioned above.

(2) The Formit that has been rocou:monded apocifies limits on individual radioisotope,s, as well as on gross radioactivity releacos. This is an unusual precaution at commercial nuclear power plants, and'provides additional'protoction against error or unsafo procedurcs.

(3) A thorough liquid and gaseous offluent monitoring program is requircd by tho' Permit. This monitoring program is quito capable, by itoolf, of promptly detecting any deviation from the limita cpocified by the Pormit.

It is a considorably more thorough effluent monitoring program than is practiced at othor commarcial nuc1 car power reactors.

(4) A quito extensivo and thorough monitoring program for environmental radioactivity is also required by tho Permit.

It will require compro-hensivo monitoring and sutveillance of all phasos of the air and water environment that might be affceted by the Monticello plant. Tho environmental monitoring program will be capable, by itself, of detecting any significant deviation from the radioactivity rolcaso limits epocified by the Permit. It will be considerably moro comprehensivo and thorough than cnvironmental monitoring programs required in tho vicinity of other commarcial nuclear power plants.

(5) The rocccmended Pormit requirca that all liquid wasto realeses be treated and monitored on a batch basic, rather than as a continuous flou. This providos a very pocitiva cystem of control, so that any batch of liquid uasto that contains more than the allowed amount of radioactivity can' and will be withheld from the Mississippi River for further treatm:nt.

This practico is commonly required at nuclear power plants. Uhat'is t

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v not so co=non olucuhoro is the Permit requiremem, that essentially all liquid wantos, ovon those from building floor drains, be routine)y cubjected to a high degroo of treatment by relatively cost 3y ion exchango methods. With propor handling and treatment of liquid wastes, thoro vill bo no cignificant radioactivity in the liquid offluents from the plant.

Nevertholoso, the monitoring programs epocitied by tae Pcmit vill requiro that every offort bo mado to ovaluato the radioactivity that is rolcased, to insure this result.

(6) The Permit under consideration also requires the inntallation of a highly officient troatmont measure for the removal of radioicdino from the casoous wasto stream.

Radiciodino is ono of th most hazardous radio-isotopos that can be givon off by nuclear power roactoro, as it very soon finds its way into the milk produced by dairy cattle. Even though very littlo radiciodino would bo oxpected from the Monticello plant 4

during normal operation, the now treatment naasuro is required by the Pernit to provido positivo assurance of cafoty from this radioisotopo.

Essentially nono should escapo via the plant stack. The required treat-ment noaucro for positivo removal of radiciodino reprosents another

'first' for Minnosota, I believo - this censure has not bocn required f

as yet at other cocmercial nuclear power plants.

(7) Tho main source of radioactivity from any such reactor 10 uranium fuel i

clomonto that develop tiny leaks, and thereby permit ficcion pr6 ducts i

to leak out into the ptimary cooling system. The Peruit also requires i

the !!orthern States Power Company to mako cvory feasible positive effort

.y

. to stop any radioactive wasto releasos at their sourco - namely in the reactor itself.

I l

.I 9

1 6-Even though groat efforto are mado in manufacturo to do so, it is extremely difficult to provent such looks in an absoluto senso - for examplo, the Monticollo reactor will contain 23,716 individual fuel rods, and it is unlikely that nono will dovolop pinholo locks.

The Formit will require the plant operator to develop a positive program f' r finding any leaky' fuel elements or fuel assemblies, so o

j 1

that they can be selectively removod from the reactor, either during usual refueling operations, or, should it provo necessary, as a special operation.

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

It may not prove san easy burdon to assume, but the Permit requires the company to demonstrate that it is making overy effort to do so.

It is emphasized that tho successful development and conduct of an offectivo program for finding and soloctively removing leaky fuel elements or. fuel.assemblics.uould introduce a new and' higher level of control over radioactive wastos from reactors. It would.

constitute a' substantial practical step forward in terms of really minimizing radioactivo pollution of the environment.

~

(8) One other very k.portant cafccuard', which s'ecms to be either unrecogniced or consistently ignored by se:ac others, doserves emphasis. This safo-guard automatically provides for ample time in uhich to tako corrective actions, should they becomo necossary.

Tho limits on radiation cxposure that have bocn recommended by the ICEP refer quito.specifically to continuous exposurc over a lifet3mo.-

- They aro decidedly not momentary or instantaneous limits. The ICEP-recommended limit for Gitium, for exc:nplo, refers.to tho amount of

,tritiu:n that can bo ingosted overy day, over a lifetime, without 4

6 s

i t

-7 s

producing dotectable or significant ham.

l TheimportEntpointisthatitisthecumulativeradiationexposuro l

over a lifetimo that,is boing regulatod, not just tho momentary exposure.

The risk of ham due to exposure at the ICRP limit for a porio$ of on'e l

your, instead of lifetimo, is proportionately smaller than the risk of exposure at the same levol ovor a lifetime, which is already taken i

t to be negligible. The limits that are contained in the Permit also refer 3

i l

to continuous lifetime exposure. -As-they are considerably uore'restric-tive than the ICRP recommendations, the associated-risk of' harm is that b

much smaller again. As a result,_ the very important safeguard of availablo timo in which correctivo actions can be taken, if they are over :noeded, i

l

,is definitely prosent.

SIM!AIN j

To summarizo the real facts, the radioactivity ' release limits that-have F

been recommended for the first year of oporation.of the }!onticello nuclear i

.pouar plant will restrict such releases to quite! small traction of the releasos i

j thc.t could be pomitted according to currently accepted worldtride practice.

A l

number of neu and positive protective unste treatment and control' mcasurcs aro I re.qdired by' the Pomit..A system of safeguards 'and checks, 'ono suporimposediupon l

I

[

anothor, is incorporated in the Permit, to. the extent-that the risk of harm due f

to radioactive roloases from the plant-is clearly'nogligible in tems of comparison l

j to all current]y accepted national and in+.ernat'ional radiation protection standards.

l Taken collectively, tho Permit requirements are much moro rostrictivo as regarding h

environmental radiation protection than any that havo been placed 'upon any Athor L

comercial power reactor thus far.

i There are como who insist-that-no radioac'ivity at all should be released t

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from nucicar plants - that absoluto zoro roloaso is the only_ acceptable ansuor.

I can agroo zero pollution of our environmont is an ideal that we should always scok as a matter of principle, and no matter what kind of pollution is involvod.

I cannot agroo that absoluto zero radioactivity release is a reasonable or necessary Por.ait requiremont at this timo.

I would point' out, honover, that this Permit comes

(

a good-deal closer to requiring zoro release of radioactivity than many people-coca to realizo - in point of fact, if vo monsure this in terms of the limits that are currently regarded as safe throughout tho worldi we have como coro than

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j 98 porcont of the way toward zero.

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t Prelimi.ry Drnft

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Eri3I E 1969 g-Rnvised April 10, 1969, MINNESOTA POLLUTION CONTROL AGENCY s

i 717 De. owcro Stroet, S.R.

1

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University Compus w-Hinncopolis 55440 3.

WASTE DISPOSAL PERMIT Monticello Nuclear Generating Plan,t, Northern States Powcr Company, Monticello Townohip, Wright County Purouent.to authorizat' ion by the Minnesota Pollution Control A ency, D

.and in cccordance with the provisions of Minnesota Statutos,1967, Chaptcra 115 cnd 116, o parmit is hereby grnnted to Northern Stateo Power Company, Minneapolin, for disposal of unste from a etuum electic generating plant bei,ng constructed by the company in the west half of Section 33, Township

,122 N, RenDo 25 W, Wri ht County, including the diochargo of eff'luents, es D

'her'cin below specified therefrom to the Mississippi River, subject to'the conditions D von belou:

i General Conditions 1.

This parmit uhell not relcecc the puraittue from any liability or i

obligation imposed by Minnesota statuton or locnl ord5nancos and nholl remain in force subject to oli conditions and limitations nou or hereaf ter iraponed by law.

The permit nSall be permissive only and shall not be construod as

-/

octopping or limiting any claims ngoinct tha permittee for demage or. injury to person or property, 3r omissions of the parmittec, its egsnts, contractore or assigns, nor as estopping or limiting any legal claim of the ntate against the permittee, ito agents, contractors. or assigns, for damage to stato pro-party, or for any violation of subsequent regulations or conditions of this l

permit.

No ecoignment of this permit chall be effective until it is executod 2.

in writing and signed by~ the parties thereto and thereaf ter approved by the Agency.

3.

No major alterations or additions to the disposal. system shall be

}

mada without the writton consent of the Agency.

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4.

The ush of t.he disposal system shall be-limited to the treatment j

or r!iuoosal of ths is' acts materials or substancos described -in the permit application dated' July 11, 1967, and associated material filed with tho' Agency.

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5..The permit is nubject to modification or revocation, and may bc

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suspended at any time for failurn to comply with the terms ateted hercin or q

the provisions of 'any other opplicable regulations or standardo of the Agoney i

or its prodccessors, and is issued wit'h the underntanding that it does not estop subacquent establishment of further requiromento for trootmant cir con-trol at any timo by insertion of oppropriate additional clauses heroin at the discretion of the Agency.in order to prevent or reduco possible pollution of the environment.

G.

The permittee or ancigno shall defend, indemnify and' hold harmless the Stato of Minnesota, its officers, egents and employees, officially or p'ersonally, against any and all actions, claims, or demands whatsoever which may arise from or on account of the issuanco of this permit, or the construction or maintenance of any f acilities hereunder.

l

?.

Certification uf completinn of the project shall be mado immediately ofter construction is finished.

Reports on effluent quality and operational i

practices shall be submitted regularly every month, and the permit holdar shall certify that he is in all respects in conformance with the. conditions given in the Agency policy statement of August 22, 1967 entitled, " Policy Regarding Operation Parmits for Sawago and Industrial Wasta Treatment Ucrks."

i Special Conditions Relat'inq to Conventional Wastes 1.

No raw sewage or treated sewage effluent shall be discharged to surface waters of the state from the plant site.

2.

Any additional conotruction plans and design data which may be

/

required for all disposal systems needed for collection, treatment and dis-posal of scuage, industrial wastes and other wastes originating at this site,

.md for effective containment of stored liquids or other pollutional materials,-

I for the prevention of water pollution to conform with the requirements of this permit, shall be submitted, together with any nther information requestod for i

revicu by the Agency.

All such plans shall moet with the approval of the Agency and the systems be~ completed before operation of the plant is started.

3. - The following standards of quality and purity applicable to'the effluent of the holding pond shall not be excecded at the point of dischar00 from the pond:

6.5 - 8.5 pH value Turbidity value

's 25 5-day biochemical oxygen deman'd 25 milligrams / liter Total suspended solids 30 milligrams / liter

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4 Cooling'faciliticochallbeprovidedandoperatedtoincurejthatthe temperature of the cooling water at the point of dischargo to the river doca not exccad the limits.specified below l

. Period Maximum Temperature July and August, inclusivo OG'F (or 5*F above the umbient Juno and September, inclusive 80'F temperature of the river, May and Octobar, inclusive.

67'F whichnver is Orcator, ex-April and November, inclusive 55'F capt that in no case stull March and December, inclusivo 43'F the cooling water temperatura

.Jonuary and Februcry, inclusive 37*F an.dischar0ed exceed 86*F)

.The design of treatment works for compliance with the stream standards, unicss otherwies specified, shall be based on the seven consecutivo day low flou of. the river which is equal to or exceeded by 90% of such seven-day minimum overage flows of record (the lowest seven-day flow with a once in ten year recurrence interval) for the critica'. month.

4 5.

No industrial waste, or other wastes, treated nr untreated, shall

'be discharged into the waters.so as to caucc any nuisance conditions, including, without limitation, the presence of substantial amounts of floating calids, scum, oil, suspended solids, discoloration, obnoxious odora, slud e deposits, 0

slimes, or fungus growths, or other offensive offncts; or so as to cause any materici increase in any other chemical constituents; or cause any substantial; change in any characteristics which may impair the quality of the water so as to render it objectionable or unsuitable for fish and wildlife or as a source of water for municipal,. industrial or agricultural purposes; or other-wise impair the quality of the waters for any other uses.

"f 6.

The company shall measure the quantity and characteristics of and sampic nny analyze the industrial wanten, other (Jastos und stored liquids at the site as mcy be requested by tiL A ency, and shall provide the Agency every 0

month with a complete report on such measurements, samples and analyses, to-gather with any other information relating to waste disposal or pollution control which may be reque'ted.

a 7.

Facilities for monitoring the quality of the receiving waters shall be provided and used as requested by the Agency.

Results of the monitcring shall be. reported to the Agency at' monthly intervals.

nical studies and investigations of the biota (ithout cost to the state, tech'.

8.

The company shall cause to be made t

'and quality and related matters portaining to the waters of the state which' receive the plant effluents, or which are in the immediate vicinity of the plant, as may be requested by the Agency.

Complete reports shall' be submitted annually, or more frequent:ly upon request.

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Continuous operation of all of the treatment works at their maximum capability consistent with practicel limitations and maintenance needs of such works shall be maintained at all times when'the plant is,in operation end uhen necccoory to provide udnquate treatment of the scwege, industrial wantco or other waston by the terms of this permit.

10.

Thu compeny shall expeditiously mekc ony changen in weato dispoeni, monitoring, and reportin0 practices, and provide any additional treatment works or disposal systemo or other safeguards for the prevention'of pollution of the environment upon the request of the Aguncy.

11.

Liquid subhtonces which could con.stitute a source of pollution of the waters of the state shall be stored in accordance with reOulation WPC 4.

Other wantec as definod by Minnesota statutes, section 115.01, oubdivision 4, 5

shall not be deposited in any manner auch that the same may be likely to gain entry into thcoe waters.

In any coac uhore such subatences, either liquid or colid, as a renuit of accident or natural catastrophe should gain entry into ony waters of the stnte, it shall be the rceponsibility and duty of the company to inform the Agency in the quickest time possible and immediately remove and recover all such pollutional substances,to the fulleet extent reasonably

. poosible under existing conditions.

w 12.

The industrial or other waste effluenta as discharged shall comply with eny end all appliceble requirements of efflue'nt standards or river classifications and standards which may be adopted by the Agency for this type of source and/or for these waters in the future.

Special Conditiono Relating to Radioactive Wastes 4

/

1.

It is the policy of the Agency that'.cIl radioacti,vn pollution of the environment shall ba held to the lotest level that is attainable within the limitations imposed by technological feasibility and economic reasonable -

ness.

In no case shall members of the public be exposed to radiatiun beyond the limits recommendcd by the Internationel Commission on Radiological Pro-tection.

In addition, the actual levels of radiation exposure of members of

'1 the public chall be kept as f ar below those limits as possible,. consistent

?

with technological feasibility and reasonableness of cost.

2.

In keeping with the above policy of the Agency, all practical measures for treatment, control and containment of radioactive westes from the Monticello nuclear generating plant of the Northern States Power Company,

shall be employed for the purpose of proventing the release of radioactivity.

to the environment.

Such measures shall include at least, but not be limited

'to:

(B) all measures fnr the treatment, control and containment.

of liquid and gaseous radioactive effluents that are indicated in }

the Final Safety Analysis Report oE the Northorn States Power Comp;any, s s' Unit 1, Monticello nuclear ganarating plant; and J.

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(b) routina removal of rediciodinc and hologens from tho,

j' gascous effluents to the full extent ftusible, the degree of treatment end removal being at loost the equivalent of that prolI vided by offcctive activated charcoal filtration of the entiro air ejuctor o00 00 flow; and 0

(c) routino ion exchange treatment (Powdex demineralization or equivolont) of the combined low purity wastes (primorily from floor drainn) and the neutralized chemical wastes -(pr1marily from laboratory drains and shop decontamination solution drains).

The i

combined estimated flou 10 8,000 gal / day; and.

(d) initial inr.pection of fuel rode for surface contamino-tion' uith uranium befora use in the reactor, and decantumination

'or replacement of fuel rods that'have detectable or significant-emounts of uranium on their external surfaces, so os to' prevent the use of such fuel rods in he reactor.

The plant operator choll report in detail to the agency the measures taken in this regard beforc startup of the reactor; and (e) initial thorough inspection of fuel rods to identify those that might develop fission product leaks, and rejection of such rods for use in the reactor; to the full extent possible, developaent and application of methods and techniques for locating and identifying leaking fuel rods'after operation of the reactor begins, on that such rods may be removed.during usual fuel replace-ment operctionn or, at other times, to prevent excessive ralense of radioactivity to the environment.

The operator shall report in detail to the Agency the octual measures taken in both of these regards before startup of the reactor.

If necessary, he shell

/

initiate rescarch and development activiities' designed to develop the necded effectivo procedures.

j The gross beta-gamma radin ctivity of liquid affluents relessed to 3.

a the plant discharge canal shall be limited to the extent that the annual aver-canal shall not exceed 10 getivity concentration of' the water oge gross beta-gamma radio 1

0 4

As an' integral part of Special Conditions 3-above, the concentrations

- of specific radioisotopes in the discharge canal shall not exceed, on en ennual average basis, the following limits:

Avernoe Daily Concentrations, pc/ml a)

Low (D) 4 Radioisotope Normal River Flow O-River Flow I

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(2)

(3) 4 4

h-3 2 x 10 4 x 10

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8 x 10~13

-1 x 10-11 l

t F-18

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2 x 10-12 3 x 10 pa-24 w

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e Avercqo Dnily Concentration, pc/ml r

Radioisotopo Normal (")

low ID) i River Fl_ow i _ River Flow (f)

(3)_

(1)

Cr-51 9.x 10~13 1 x 10~11

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• Mn-5G 5'x 10-12 4 x.1011 i

Co-58 9 x 10-12 1 x l'0-10 Co-60 9 x 10~13 1 x 10-11' f

Sr-90

'4 x 10~13 8 x 10-12 Sr-91 2 x 10-11 4 x 10-10 4 x 10~12 8 x 10~11 p. 92 l,

Tc-99,'Mo-99 1 x-10~10 -

4 x 10~9 I-131 4 x 10~11 8 x 10-10 2 x 10 k.

4 x 10~9 I-133 I-135 6 X 10-11' 1 x 10-9 Te-132 6 x 10~13 1 x 10-11 Cs-136

'6 x 10~14 1 x 10 /-

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Cs-137 2 x 10~13 4 x 10 1

t-4-x 10-13 6'x 10-12 '

.Ba-139-Ba-140 4 x 10-12 6 x-10-11 (a)- Open cycle - 93 percent of days;~no use of-cooling towers; diochargo canal flow 645 cfs.

(b)

Closed-cycle - 7 percent of days; full use of-cooling-towers; dischar00 canal-flow 36 cfs, s

In addition to the specifin.'radioisotopo concentration limits Diven in

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the,above tabin, and on eninterim. basis-until plant' operation provides moro i

definito information, the everage daily. discharge canal concentration of any other radioisotopo chall not excedd one three tho.usandth (1/3,000) of) the D. specific-IC'.P-limit for continuous occupational cxposure.or one threc6hundrndth (1/300) of the numerical. limit for-that radioisotopo as specified in Appendix.

'3, T'ublo II, Title 10, Part 20 of,the.USAEC Standards for Protection Against Radiation.

In caso theso tw6 limits diffnr for any specific radioisotope,'the lower limit shell apply.-

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5.

In addition to all of the forcDoinD liquid effluent radioactivity concentrrtion limito, for any cuvan cuncocutiva day perit;d the overogo Droos beto-Damma rodioactivity7 concentration of the water in the dicchar00 conni ohn11 not exceed 5 x 10-pc/ml (500 pc/1) plus the background rr.dinactivity, and the everogo concentration of any specific radioicotopo in the diocharga canal choll not exceed a limit of fivo times the volus given in tho above table.

The groco-beta-Damma r.edioactivity of the Occoous effluent releaced G.

via the plant stack shall not.cxceed, on an annual average bosio, e 'rcloesc rate of 0.01 curie por occand.

This refers to o total stock eir flow of 4,000 cfm, and thereby also opecifics the limiting concentration of Oross beta-gamma radioactivity in the stack effluent before dilution in the atmosphere.

As on integral part of Special Condition 6 above, the concentrations 7.

of specific radioisotopos in the ateck before release to the atmosphora shall not exceed, or on annual everego basie, the following limits:

Stock Concentration (c)

Radioisotope pc/ml r

4 x 10~9 H-3 3 x 10-6 Ar-41

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Mr-83m 1 x 10

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3 'x 10 Mr-85m 2 x 10~7 J

Kr-85 1 x~107 Mr-87 Mr-88 1,x 10~

2 x 10-5 Mr-89

-6 Xe-131m 1 x 10 Xe-133m 1 x 10-5 3 x 10' f

Xe-133 4 x 10

• Xe-135m t;

s 6 x 10~4 s

Xe-135 i.

5 x 10~5 p

'Xe-137 2'x 10~3 i

,. N Xo-138 To)

At a total stack air flow of'4,000 cfm.

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In addition to thu specific radioisotopo limits given in the table inmediately above, nnd on on in';erim boois until plant opnrotion providca more definito i'nformation, the averngo daily stnck concentration of any other radioluotopo before relonse to the atmosphore shall not exceed 10 timco the specific ICRP limit for continuous occupational exposure, or 100 times the numericol limit for that radioisotopo as specified in Appundix 0, Tablo II, Title 10, Port 20, of tho USAEC Standardo for Protection Against Radiation..

'O.

In eddition to all of the foregoing gescous (stack) effluent con-centration limits,,tha gross beta-Damma radioactivity of the Duseous affluent relcased via the plant stock shall not excoed a reloose rate of 0.05 curie per nucond for nny seven consecutive day period.

During such a period, the stock concentrations ur specific radioinotopos shall not exceed five times the numerical limits D van in Special, Condition 7.

i A stack roleese rate of 0.05 curie por second shall automatically cound a plant alarm to. warn the plant operator that the ueekly release rato limit has boon reached.

9.

In addition to all of the foregoing gaseous (stack) cffluent con-l centration limits, the gross beta-gamma radioactivity of the gnscous effluent released via thH plant steck shall not oxceed a release rate of 0.30 curie por second for any 15 minuto period.

During such a per' lod, the stack con-centrations of specific radioisotopos'shall not exceed 30 times the numerical limits given in Speci,al Gondition 7.

A stack relonse rate of 0.30 curie por second shall automatically nound a second and different alarm to warn the plant operator that the 'instanteneous' release rato limit has been reached.

Af ter a 15-minute delay, the air ejectof off as isolation Vulvo shall automatically Closa, shutting down the reactor, 0

if the radioactivity relonse rate has not been successfully reduced to the weekly. release rate limit, or less.

10.

During the first year of operation of the nuclear generatinD plant at Monticello, the routine effluent monitoring program of the Northern States Powar Company shall be designed to identify nnd quantitatively account for all spccific radioisotopes that are relcesed in significant.quentitics.. This

,0ffluent monitoring program shall provide for and include at loest the kinds of somples, frequencies, radioassay procedures, etc., described in the MPCA' Final Report entitled Radioactive Pollution Control in Minnesota, and dated January 31, 1969 (see especially pp. 13F-143).

at Monticello]g the first year of. operatioh of the nuclear generating plent 11.

Durin the routine environmental radiological monitorin0 and sur-veillance progrem of the Northern States Power Company shall be designed to detect and ovaluate all significant radioactive releases from the plant.

This environmental monitoring program shall provide for and include at least

~~the kinds of samples, frequencias, radioassay proce'dures, etc., described in the MPCA Final Report on Radioactiva Pollution Control in Minnesota, dated January.31, 1969 (see copecially' Table IV, pp. 135.and 136, and the soc, tion-inc.ludod in pp. 114-139).

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12.

All effluent and environmental monitorin0 pro 0rnm resultu ohall bc reported mnnthly by the Nort.hern Statoo Power Compnny to the Agency.

All monitoring program recults choll also be available for inspection by the Agenc$ at thu pinnt cite nt ony time.

13.

The Northern Statoo Pouer Company shall cooperato to the full extent nccuccory with the MPCA und with the Minnecotn State Doord of !!ccith (MSfH) for purpoacs of development oy thono ngencies of nn edequate end effective ener0cncy protection plan deuigned to immedintaly control nnd minimize the ofrccts of any occidental relcase of unexpectedly large quanitico of rudinactivity from the Monticello nuclear acncrating plant.

In porticular,

'the Northern Stateo Power Compeny shell immediately notify both the MPCA and the MSGH of ony uncontrolled rnlease of unexpectedly lor 0c quantitics of rndicactivity to the off aite air ond/or voter environment due to operational fullure of ony of the power plant systems.

Also, the Northern Staten Power Compeny sh'cIl cooperate in this reDard to the full extent outlined in the DPCA Final Report on Radioactive Pollution Control in Minnesota (oce pp. 90-97% and in eny other manner requested by the MSBH.-

14.

The "Special Conditiano RelatinD to Radioactive blantes" part of thio

' permit in limited to the first year of operation of the Monticello nuclear generating plant.

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

A new permit relative to radioactive wastes, modified and changed to the ex-tent deemed necessary by the Agency, and based upon the results of the first year of power plant operation, will bn issued by the Agency for the cocond year of operation.

35.

It is emphasized that public and environmental radiation protection practico in based upon a concept of very long term protection, rather than /

only immudiate or momentary protection.

Tho Generally eccepted I.C.R.P. limitt cru designed to rootrict radiation exposure, on n. continuous basis and over o lifetime, to levels that will not produca detectable or ei nificent nomatic.

0 or genetic harm.

The annual average release rate limite contnined in this Perdit alco refer momentary levels,, to continuous lifetime radiation exposura, rather than to and are considerably more stringent than could be permitted according to the I.R.C.P. recommendations.. Hence, the slight tronaltory (E.G., daily) variations around thosa limits that are to be normally expected should not result in overexposure to radiation of any member of the public, and should therefore not be viewed as cauce for great alarm o'r for hasty and unreasoned action.

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• John P. Badalich, PE N

Executivo Secretary and Chief Executive Officer-i f

Parmit No.

5633 s.

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Dated May 12, 1969 g

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