ML20127N023
| ML20127N023 | |
| Person / Time | |
|---|---|
| Site: | Monticello |
| Issue date: | 07/02/1969 |
| From: | Seaborg G US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Fraser D HOUSE OF REP. |
| References | |
| NUDOCS 9211300541 | |
| Download: ML20127N023 (1) | |
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- Cccmis u oner Ramey Cm missioner Johnson
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HLPrice CKBeck HKShapar p
RNie Dormld M. Pmser NF. ann PDR (50-263)
House of Representatives ELDoan DR Reading CLHenderson GErtter (DR-2218)
Deer Mr. Pmser:
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'nkyou fv your letter of June 17, 1969, referrine to correspondence we Wlai with Mr. Paul H. Envram, President of the Mirmsota Fn-vin;rrental Contml Citizens Associatim.
I am enclosing, as you equested, the excharre *,f correspmdence between
/cerning questions relatirs to nuclear power plants iMr. Engstrom and W n Minesota. Also enclosed am tw excharves of earlier correspondence between Mr. Price an! W. John P. Badalich, Executive Dimetor of the Pimesota Pollutim Contml Agency, on the same subject, which also were furnished to W. Engst m.
As Mr. Price noted in his letter to Mr. Encstrm, it was hoped that the answers to two earlier series of questions pcned by Mr. Stew J. Gadler of the MPCA were adeqtmtely responsive to answer the third series, submitted in scnewhat different fom by Mr. Figstrcxn.
I unoerstand biat Mr. Hen $erson of Mr. Price's staff has been in touch with Mr. Mach =r of your office on this rntter and if further infoma-tien is needed, phase let us know.
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Ltr to Mr. Engstrce w/ enclosures dtd 6/17/69 in reply to his Itr dtd 7/24/69 e
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UNITED STATES ATOMIC ENERGY COMMISSION
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Mr. Paul H. Engstrom, President Xtre.esota Environmental Control Citizens Association 1C53 South McKnight Road St. Paul, Minnesota 55119
Dear Mr. Engstrom:
I an. pleased to respond to your letter of May 24, 1969, addressed to Chairman Glenn T. Seaborg of the Atomic Energy Comission, cubmitting a series of questions by Mr. Steve J. Gadler, a member of the Minnesota Pollution Control Agency.
In a letter to me dated September 3,1968, Mr. John P. Badalich, Executive Director of the Minnesota Pollution Control Agency, submitted certain cccants and a list of 83 questions by Mr. Gadler. On November 19, 1968, a response to this letter with enclosures was sent to Mr. Badalich. A copy of this letter and its enclosures is enclosed for your information.
On December 20, 1968, the Executive Director of the Minnesota Pollution Control Agency addressed,another letter to me submitting another series of 27 further questions by Mr. Gadler. Copies of the response to this letter, dated February 17, 1969, and its enclosure (Congressional Joint Cemittee on Atomic Energy Hearings on Licensing and Regulation of Nuclear Reactors held in April and May 1967) are also enclosed.
We trust that the enclosures which represe... a comprehensive response to questions posed by Mr. Gadler in two earlier series are adequately responsive to the series submitted with your letter in somewhat'different form. Copies of the two letters from the Executive Director of the 4
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t' TY. Paul H. Entr,strem Finnecotn Pollution Control Arency cbovo referred to find the irquiries
'j of 19. Gadh theroto attached exe enclosed 30 that their charactor and j
the references in the respectivo respences may be identified.
Sincerely, onsines punw e g, s.a
'iarold L. Price Director of Ec;$ ntien Enc 1mures:
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STATE OF MINNESOTA MINNESOTA POLLUTION CONTROL AGENCY 459 BcARD oF HE ALTH BUILDING ONivER$1TY CAMPUS MIN N E APOLIS 55440 September 3, 1968 i
Mr. Harold L. Price Director of Regulations U. S. Atomic Energy Comission
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Dear Mr. Price:
The matters of nr. clear power plants and nuclear radiation still hold.ad play an important part in our monthly Agency meetings.
The AEC-owned reactor at Elk River, Minnesota, periodically makes news, as does the NSP Monticello plant now under construction.
One of our Agency members, Mr. Steve J. Gadler, is greatly concerned about the operation of the Rural Electric Cooperative Ascociation's nuclear power plant at Elk River, and I am enclosing for your information a letter dated f
August 12, 1968, addressed to Mr. R. C. Tuveson, Chairman of this Agency.
This letter was read into the record at one of our recent meetings and does emphasize Mr. Gadler's concern about this AEC-owned reactor and its future operation.
I am also enclosing for your review and comment six pages of questions posed by Mr. Gadler that need clarification.
I believe the AEC is in the best position to answer these questions. Would it be possible for your staff to prepare these answers? An acknowledgment of this request would be appreciated.
Another question that has been discussed at various times is the leve' of tritium in the Mississippi River below and above the location of the RECA' nuclear plant at Elk River. It is my understanding that information is au -
able from ti, AEC on these tritium levels, and I would therefore request that the MPCA be pplied this available data. The infomation should encompass the period prio-to the construction of the Elk River reactor to the present data.
Our consultant, Dr. E. C. Tsivoglou, is presently under contract with our-Agency and is gathering pertinent information, meeting with persons other than
, the Agency who are concerned with nuclear radiation, and with representatives of Northern States Power Company, General Electric Company, and others. It is an-ticipated that an interim report on nuclear radiation standards for Minnesota will be presented to the Agency by Dr. Tsivoglou within 45 days, and firal i
reco=mendations made within 100 days.
In the event Dr. Tsivogisu requests
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2-9/3/1963 s Mr. Harold L. Price Washington, D. C.
additional information fro:n the AEC regarding nuclear power plants in Minnesote.,
We would appreciate your cooperation in this matter.
Again, I wish to express my appreciation to you and oth.rs of the' AEC staff for your cooperation in the past, and I trust this cooperative effort' will, con-tinue in the future.
Very truly yours,
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John P. Badalich, P.E.
Executive Director 7.~-
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'e Steve J. Gadler 2120 Corter Avenue St. Paul, Minnesota.55108 645-5005 August 12, 1968 Mr. R.C. Tuveson, Chairman Minnesota Pollution Control Agency Albert Lea, Minnesotn Dcar Mr. Tuvoson:
g, At the July meeting of the Minnesota Pollution Control Agency, Mr.
Miller read into the record a letter addressed to the agency wh!ch had been signed by Mr. Edward E. Walter, General Manager of the Rural Electric i
Cooperative Association at Elk River, Minnesota, in view of the fact that the letter cast aspersions on the Minnesota Pollution Control Agency and
_..__ specifically,upon thc intcDrity and motives of one of Its membcrc, I asked for permission, which has been granted, to make a public statement concern-ing the referenced letter.
4 The letter' appears to indicate to rac at least, that It maybe an attempt to silence the many paople who arc concerned by the amount and type of radlo'
. activo contaminants discharged and being discharged into the Mississippi River at Elk' River by the AEC owned reactor.
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- 1 Since thb operator of this facility has admitted discharging radio active contcminants including tritium into the Mississippi River which is the source of St. Paul and Minneapolis water supplies both for drinking
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and industrial purposes, it may just be possible that clams placed in water taken from or near the reactor discharge point acy up-take some of this discharged radio activity.
Clams and other Biota are unaware that the g
radio active contaminants have been diluted by water to AEC Spacifications.
The literature is repicto with references to the bloaccummulation in the fish, shcIl fish and the biota.
Apparently all blota has the capability of up-taking and concentrating radio activity.
Ev.1dence for this is well j
documented.
As an examplo:
Dr. T.R. Rico, Chief Radiobiological Program, B,ureau of Commercial Fisherics Biological Laboratory, Beaufort, North Cololina, in U.S. Dept. of I!calth f. Welfare pu.blication //999-R-3 Studios of fato oT certain " Radio-nuelldes in Estuarino and other Acquatic Environments", Page 35 and 36, said "Ji.cn tho' Maximum Permiss!blo Concentrations (MPC's) worc calculated for the different radionuclides wnich occur in drinkin'9. water, the asst.m;; tion i
asst hcvc been mode that such concentration of radionuclides in the cc. vatic s
environment would result in not only an insiginificant return; of activity to man, but would also be of no harn to aquatic organisms.
This' assumption has not been validated and wil.1 rcquire the collection of considerabic data before any confidence can be attached to _ i t."
And ho continues, "It is kno?n) f ro:n experiracntal evidence that certain organisms, In ' addition to those of' I
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f-i cor.mercial value, service as a vital link in c~crtain food webs and can concentrate some radioisotopos to levcis much greater than those occurring in the ambient water."
I And finally, "With the expanding nuclear. energy industry which has developed in Icss than 15 years, man will probably find that keeping his i
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environment free from radioactive pollution will be more and more difficult..
l Thus a respon'ibility rests upon those who pollute the environment with these materials and non those who must protect human health and insure the safckeeping of the living resources."
4 In addition to the literature, many experiments have bcon conducted
'l in this area as an exampic, Dr. Willicm A. BrunDs, Jr., Research Acquatic Biologist, Fish Toxicology Activities, NPCA, J.S. Dept. of the interior, discusses an experiment by the Cooperative Studies Unit, Radiological
, Health Roscarch Act.lvitics of Mc Taft Engineering Center, i n Public Henith Service Publication #999-RH-2L.
The experiment concerns bioaccummulation of Radionuclides in fish, tadpoles, snails, cit.ms, including Lcmpsilis and j
Anodonta clams and other blota. A large pond, specifications detailed'in cited pubilcation, was used for this experiment According to Dr. Brungs, all biota,d into the radio active. ter.
including the cicas, a entrated radionuclides which had been introduce 1
1 The MPCA is concerned with the prcbicas of water andoair pollution and 1, in addition, am concerned with the integrity of the St. Paul and Minneapolis water supplies that may becocc unsafe because of the radio active l
contaminants discharged into the river by the AEC reactor.
f Why am I concerned, first, because the American !!calth Association j.
in their publication entitled "Public Exposure to ionizing Radiations" caution that the ever.tual contanina, tion of the environment by reactor pro-ducts are a grave health question and the effects are cumulative and l
irreversibic.
Second,' Dr. Karl Z. Morgan, Director, llcalth Physics Division of the
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U.S. Atomic Energy Commission's Oak Ridge National Laboratory on Page 39 of the July 1968 issuo_of the American Engineer said, and l-quote, "I t
believe that it is probabic and desirable that the working level.will be further reduced in the near future.
This is because present scientific-
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evidence seems to indicate there is no threshold icvel of exposure to any 5
form of'lonizing radiation so low that the risk of radiction damage becomes 1
xero.
In other words, there are certain types of radiation induced risks such j
as leukemia, bonc tumors, thyroid, cancers, and scactic da, mage that seem to l
j relt.tc morc or less linearly with the dose",
question, are genetic mutations' a future event in spite of AEC regulations to the contrary..
i in his letter, Mr. Walters said,"The Rural cooperat bec Power Associat -
t ion has always operated and will-continue to operate the ERS with the utmost concern for the safety 'of' the_ public and fccis that the public is entitled p
to t.he facts and 'infonxation concerning any matter af fecting the public i
interest." No ona con disagree with this statement since we are all con-ccrned with the health and' welfare of the public and particularly in faciuol Information -,so leb 9 9 the public a chance to look at the' record.
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' fir. Ri A. Tuvoson August 12, 1968 i
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RCPA letterl. dated Jan. 18, 1967, oddressed to Dr. P.A. Morris, l
Director Division of Reactor Licensing, U.S. Atomic Energy Coamission, VashinDton, D.C. thru lir. K. A. Dunbar, Manager, Chicag6 Operations Of flee f rod l!r. Edward E. Walters, General ManaCor, explaining the accident which reicased radio active lodine 131 to the environment and stating that ' corrective measures have f
been taken to -- avoid repetition of this incident'.
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letter
- f rom Lawrence D. Low, Director, Division of Couplianco, i
U.S. AEC, Washington, D.C., dated Deccaber 26,'1967, sent thru Mr. K. A. Dunbar, General Ma.u.ger, Chicago Operat ions Of fice, addressed to RCPA, Elk River, attention of Mr. Edward E. Walter.
Mr. l.ow complains that reactor operatiorts at a relatively high power Icvol without reactor c'oro emergency coolin0 and primary cooling make up capability and 'your associated increase of the d
reactor power level to 100% of the licensed limit, are contrary to prudent safety practices and should be discontinued'.
1 3.
Page 501 of.the Jan.Feb. M68 Ilcarings before the Joint Committee on Atomic Energy Congress of the United States (Part I), the U.S.
AEC presented the following, "A reactor can potentially be des-troyed by a nuclear excursion or by the loss of core coolant re-sulting in release of fission products".
This loss of core i
coolant could Icad to a molt dcwn of the fuel which would probably result in a breach of the containment releasinD radio active fission products to the environment.
Reactor core emergency cool-4 ing system is for use in prevention of a core melt down in the event of loss of primary coolant.
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Publication C00-651-49 " Elk River Reactor System Monitoring Data" for July 1, 1966, throuDh June 30, 1967, reports 23 leaking elements, 4,,,
increase-in, primary coolant activity and lodine 131, higher tritium,-
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levcis, fission sesses migration from the primary to secondary and primary system leakage.
5.~ ' Mr. 'HarordT." Price, Director of Regulation, U.S. AEC by let ter/.
dated 28 March 1968 advised Mr. John T. Conway, Executive Director Joint Committee on Atcmic Energy Congress of the United States that ' prior to current shutdown of ERR minor Icakage of water into the lower reactor cavity was :xperienced' and as a result of further checks water contr.it.ing radio active iodine was found which he sal @ uas ' indicative of a leak in the primary system'.
This letter then reemphasixes my concern about the radio active con -
tauinnts that are discharged into the '41ssissippi River, above the St. Pa'ul tnd Minneapolis watcr intakes and my concern for the safety and health bf our 1
citizens.
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-h-August 12, l!)fe Mr.'R. A.-Yuvoson I believe a rer.ponsibility rest >. upon thouc who contcialnote the er.viron'-
i know that a greater responsibility 3
ment with radio octive materlais but rests upon those of us whose duty it is to protect and insure the present and fu'ture public wolfaro.
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Letters attached as follows:
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Page 3, item S.
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"The haards associated with potential cirborne radloactivity require devclop-1 uen: of methods for removing these_ radio _ active fission products frca the cas streans and for determining the disposition of radio act v,ity released to the environment" appears on page 504 of the cudget ilcarings. -4oco this indicato or !aply that NSP has nothbcon given completc information by the AEC on the dancers of radlo active discharges?
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,3 Is stainicss stcol to be utilized in the feed water heaters to prevent. accumulation -
l of corrosion products?
f Broken lower tic rods, forced the closing of the Scini reactor in April, 1907, ;
what preventive action has been taken to prevent similar ocet.rance at the Montic'cIlo reactor?
i f'
Due to erratic operation the Scan reactor was closed down on January 21, 1968 and upon r movcl of the reactor head it was discovered that broken pieces tentatively J
Identificd as part of the reactor internals were found in the steam generators l
In this respect wilj the Monticello operation take preventive action to prevent such an occurance7d How?
i 7 Will the vessel crack problem of the Oyster Creek Jersey Central Power and Light j
Company which revired recheck -of all field welds employed to install control housings l' utub tubes attached to. bottom head of reactor vessel because 137 stub welds contained defects require NSP to reassess to insure integrity of*the Monticello reactor and insure safety of the operation? '
f Does the Tarapur reactor problems which are similar to Oyster Creek in that 67 stub
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tubes in vessel #1 and 70 of 69 in vessel #2 were cracked require welding control practices at Monticello to prevent the extensive delays being experienced at 1
Tarapur?
9 in tha event of a Fermi type, of accident does AEC authorize NSP a license to
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abandon the plant?:? What are the provisions In 'the permit issued by AEC to NSp7 Aru abandoning proc ~cdures, in event of nuclear excursion, provided for in the license?
J ja Does the extensive cracking of fuel elements cladding in the SSER facility require qualitive and quantative check clearances between fuel 'r,ods and the cladding tubes in the Monticello'rcactor to insure irnproved safety?
(481)
// Should, sjace AEC states that "a reactor can potentially be destroyed by a nucle'ar excursion or by loss of core coolant resulting.in the release oft fission products",
action bc taken by NSP to protect its safety and economic operation?
(501) position-and to mcet both the goals of
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11 Hac AEC furnished NSP with the necessary technical criteria for the controlled dis-pocal of radio active contaminants into the environment under both normais opera: Ions and in.the event of a reactor accident or nuclear cxcursion?
(503) fj in the Safety Evaluation for_the Moaticello plant 'and in other documents it is referred to as Monticello //l does this mean that there wil' be two reactors at this location?
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l In the event that a number' of f uel rod:. slipped f roca the charco machine end.
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',L d reppe.l Into the parking hole of the core reflector and,several feet of the ciecaent would break of f and bounce back out of the hole as happened at,the Peach Botto.a Reactor on February 21, 1963, would this constitute the 4
postulateil scr'ious accident on' page lla of NSP Accident Analys,is?
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4 fff 'Has the Fermi Plant " incredible accident" so classified by Mr. Shaw of AEC in the hearing before the Joint Com.nlttee on Atomic Energy Coni;ress of the United States point up to NSP that nuclear power plants are not checp?
/p Would the amount of rcdio active contaminar.ts relec cd to the environment J
3 by this nuclear' excursion be of concern to the Metropolitan residents?
It is noted that the Public Service Company of Colorado contract specifies j7 terraination if Price-Anderson coverage and property dcmLDe and licbilit.y I
are not obtained and la this respect do6s NSP have a contract of this type with AEC?
f Peach Cottom rcccior operated by Phil. Electric Company was shut down on Janucry 11, 195S after 150 days of operation to investigate the increase in prinary loop
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activity of a risc.from 1/3 curic to approxicately 4 curies cppcrently due to crccked clement or blocked parte flow through the cicmont in this respect has. NSP i
followed up on this occurance to become familiar with-the reason for such-risc in curic production?
. Has NSP cor.sidered the Fort St. Vrain containment problem in building the Monticello
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plant sinco apparently this ulded protection will help safeguced the environment?
Jf \\! hat will be the total amount of thernal cdditive,s that will be discharged to the Mississippi River water by MonticcIlo //l cnd //27@lill water carrying therm &l f
additives 'bc contarainated with radio active tritium?
l Based on AEC cxperience on the Columbia River, what will be the effect on the 32 crology of the Mississippi River by the thermal additives to the water?
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) ~., Ctn the extensive relccsc of lodinc 131 which spread the radio active contaminen:
over curope in the Vindscale accident occur at the Monticello fccility?..df such anaccidentoccurswhopaysforalltheradioactivomilkthatwouldhah'e'tobe destroyed due to lodine 131?
I Beccuse Piquo Nuclcar Fcc!1ity which experienced 12 major shut <!cwn periods and
<r cxperienced difficultics with control rod drives was permanently closed down will
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this r.eces'nitate a re-evaluation of the Monticello reactor with reference to control rod driver.?
i From page 171 of 1956 AEC publication "Mcjor Attivitics of Atomic Energy" uc Icarn that t.itium was produced by fission through fuci eleacat cicd: g and P.attile Mc:c.nriel institute recommended collection of the primary leakate at PM-1 facility witn off sitadisposal of the radio active tritium 61Will Monticello follow these j
recorr:endations and dispose of oli tritium contaminated water byvsite shipraent i
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to AEC burial groands?
cf RS since fission product relenses to the environment are the ranin hazards of nuclear t
j recctors how will NSP guarantee the integrity of the Monticello rpactor to prevent a public he.zard?
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'M What arc costs per 13/HR Produced for necessary equipment to provide maximum cleaning of..all radio active cases destined for dischari;c into the atmosphere?
?Vhat will be costs for off shipment of,all radio. active liquid, 3 p ror water?
solid and particulate raatter?
and in this respect will AEC cxpect Monticello to be utilized to assist in carrying out the experiracntal program that in any case will reduce its ow" safety due to the f- --
gerami-type of event that can't happen but did7 (491-497) i S., What new method will Monticello employ to prevent the discharge of SR 90, C 137, 4
l 1 131, and il 3 into the river?
f yp in view of the water supply uses down river from the Mo6tTcello site why was-this site chosen for the facility?
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3fHas NSP becomo familar with delay occassioned in Dresden #1 of Coca.onwealth j
Edison due to cracks in the primary system in-April of 19677MWill the closing of Dresden in February, 1968.to check and repair all cracks 'rcquire a new
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. material program at Monticello?
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J7 Will Monticello have enough capacity to contain and hold up discharge of gaseous wastes pending favorable winds?
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,y3 How many venting or exhaust methods will be employed and will be available to vont radio active gases and materials to the atmosphere by the Monticello plant?
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pp in the event of the cecape accidentally of radio active gasch froai the plant cither through the regular channels or throuch a r.uclear excursion penetrating
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i the integrity of the building.wlli the Twin Citsu, be notified and warned about the forthcoming radio active cloud?- How will the of.ficials be notified? Who will do the notification?
/0 is all radio active materials and waste released through the stock or other out-sideventsproperlyfilteredbeforcrolcosc?].Willany-radioactivecontaminant g
be relcosed to the atmosphere without, filtration even after delay for_one-half-life decay?
/.? What will it cost NSP to operate the towers on closed cycle to prevent thermal discharge to the river 7;dflhat is the ccst expressed in cost per 141HR7 yln both i
y capital equipment and in' operating costs?
p What are the-costs for transporting the radio activo Monticell' wastes to the AEC perpetual burial grounds 7pWhat are the cost for burial by galion bnd by cubic i
f c:. ':."How many curies of" activity will be shipped by mesa watt of electricity-gancrated?
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</T~Uhat action will NSp take to prevent installing the engineering field adaptations cmployed at Fermi' which was the probabic cause of the incredible accident.that l
forced closing and _kept the $120,000,000 plant closed down for the past two / cars 7 g
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-[f During periods-of fumigetion or during fumigating conditions what racons'will bc craplos/cd to withho;a radio active discharges to the atmosphere froa the stack?
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a t.gf(f,/p Arc in it.. hudst rce,ue ' of 2 billion, nine hundred ul " 'on in f i sca l 09.'s.~. '.,7 (f
be'ayn:.i' $75,000du fo studien. of the envi ron...:nt Inc...dlnp envi ronmental-i espects of ut:cicer operations cnd the eficcts of these rndio octive effiace.ts on th. environaent which is approxi;aately one p:nny for every $30,000.00 in the AEC budcet. C '.'..'"".'c'-
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i g;/ Preoperational testing of the ERR incility' developed thous.cnd of gallons of radio active boric acid which was released into the river by Allis Chalmers Compcny'.'
-Ulll this performance be repeated at Monticello by G.E.?
4,0.Does AEC impose a regulrcment on NSP Monticello plant to test safety systems cnd safety fet.tures and to conduct in-plant and engineering scale tests related to safety fectures design-and ' engineering of large nucicar pli/ntsp.;,Nould this type of r.cscar-:h and development endcnger facility and in turn the metro arca?
(507) i 40 Does NSP plan to join in the CSE (Contalr. ment Systcqs Experiment) Program in studying the effects of a simulated loss-of coolant accident and' consequent i.-
release of radioactivity upon systems employed to reduce the post accident pressure and upon the efficiency (of engineered safety systems in restricting the novement of redicactivity?
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s'S In cycn; of a coximud accident as por.tulcted by the AEC lin the " Theoretical Possibilitics and ConscqUcnces of Major Accidents in large Nuclear Plan'ts", arc j
plans'bcing formulated for reimbursing property losses for evccuted areas cnd 1
cvecuted people?
j $ Will suff'cient medical f acilitics be cvailabic in the event of such an emar>;cncy?
ary Have plans been made for the medical requirements for this.probcbly impossible nucicar event?
JS P1caso present an evaluction of the amounts of radio active products escaping from/
1 1
the containment structure in jhc cvent of a partial malt downl@n the event of e 50% ncit down of the fuel?,(nlhat is the significance of the dangers from thesc radio active contaminants released to the environment from this type of accident?
ff What action will be taken to..sofcguard the 230,000 ga'lons rotention tanks con-tainingradioactivewastor.df,'elhatprotectionisprovidedtoproventscopescof i
l radioactivecontaminantsintotheundergroundwaters?23thatamountofradio activity is contained in those tanks?
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- ,ggYhe current operation of Peach Bottom Plent and the planned PSC Plant is to demonstrate fuel elements, prostressed concrete pressure vessels and other key co aon
- nts of the llTGTt Plant which is beyond the present state of technology i
of 'this plcnt and the research and development is requirc ' for developing lorscr nuc1cxx plants and in this respect will AEC rce.nire the Monticello plant j
to enter into these AEC r.cscarch and development objectives?-
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! '.f ?. Vill diiction of the radio active contaminnnt discharged into the water prevent the.
reconcentrction in the biota and the food chain?
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$7 Th'e St. Nul Disi..ch for C August 195S con'.ained. aforcotion'that AEC i
clor.cd down the Em niver Recctor because of looks in the prinary.coolont Will-this closinD 'increose on.oent of concern t ;..SP ond to AEC?
systca.
In cddition to the 16 nuclear tocilitico that have been closed perbentcly 1
6S.
j dcun it now oppears that Fermi, Pothiinder, Elk River, Bonus and peach Dottom accctor plants may never reopen in view of those developments _has AEC advised NSP to participate in rccctor safety progrcms thru assignment of personnel to specific safety projects such as CSE ond LOFT progrcms?
- 69. When will AEC relcaso the study of the upper Mississippi on the predicative capcbility of a river basin?
Triitium which is produced in nacicer rccctors cod becomes c consituent of j
70.
watcr mcking the water a radio cctive and extremely dangerous and espebic of l
contaminating all parts of the environment and all life is called a radio active contcminant by Chairmcn Secborg of the AEC.
How much will be shipped j
4 from Monticello to AEC burial grounds?
l 71.
Since shcIl fish, according to ecdlological Mccith Data and Reports Vol.8 i
sc?t. 1957, are sensitivo indicctors of radio contcminants in water, will Monticello operations in tes:.ing the cr.vironment include shcIl fish in the l
Scmpling progrca for determinction if their uptake exceeds the proposed concentration guide?
l
/,EC divulges that cs the fuel material is recycled in the recovery operat-l 72.
ions the concentration of contcminants increates since the highly.irradicted power fuel will contain gccm or neutrons or both which emit contcminants
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Has AEC instructed i
which increase the bilological=shleiding requirements.
NSP in this matter to in order to protect the safety and. health of the peopic '
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at the Reactor.
When will AEC furnish MPCA complete informction on tritium production in 73.
all-the reactors liscensed by AEC in this state?
i Will AEC and NSP furnish to the MPCA the total cmount of tritium that the
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j 74.
proposed plants on the Minnesota and Missi.ssippi rivers'In Minnesota will dischcrge into the environment?
that cannot What will be the total amount of this radio activo contcminant, l
l 75 be removed, altered, changed or chemically treated coursing down the heart of j
America via the Mississippi River to'the Culf..
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What amount of insurcnce protecting the public from' nuclear excursions does b
76.
NSP plan to carry?' Will insurance be ccrried for damcoe to property, soil, l
plant life, people, etc. f rom rcdlo active contaminants continvolly dischcrged into the environment or from a nuclear excursion of the type which occurred l
in the-Fermi Nuclear Plant?
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,,y is learned that ground levol Inversions wi!
From AEC docket of May 4,--1967, it 77.
take picco at Monticello about 30%.of-the tinic will-radio active contaminant-discharges be automatically controlled to preven't discharges when wind is:not.
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j in cocpcretion, is meant by the statement "malrimum credible occident" in relation to u
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- 78. What
- the scfety of the residents of the Tviin City metropolitan arca and-the Monticello reoctor?i
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o Is information ovalloble os to the amoun'; of tritium produced in c IAI 79.
i Reccior? Will this be furnished to the MPCA7 1j-
$0.
How r.iuch radio octivo contaminants villi be discharged into the-Atmosphero,.
the river and thc.soll by the closed ERR at Elk River?
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For how lo ig?
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- 82. Whct amount and types?
.S3.
Why was ERR closed down? }low much radlo activo contcminants wcs it actually i
dischcrging to environment? What was effect on Plant Personnel? Did fear of a Nuclear Excursion-impel close down to prevent Fermi type experience?-
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Mr. John ?. Sadalich Execa:ive Dirac:or Minneso: Pollu ion Control r,oney
!.59 Socrd of Ho:lth Building.
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University C:mpus Minnospolic, Minnosota 55/4~
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Daar Mr. 3:d:lich:
of Septor.bor 3,1968, I am plossed-4 In response to your lo::o.
- o 3rovido e,oct roguictory staff commen:c on cho various l
e,uas:1ons reiced 17. the lo::cr and its :tachments from j
Mr. S:cvo C alor. Also 02 closed era oight inicreation docur.onts bearing on thoso questions.
I hope the c:sff co==.cnt.s.and infor=ntion documents will bo..
helpful to you cnd your collonguas of tho Minnesota Pollucion i
- l Control Aconey.
Sinceroly yours,-
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Stcff Co:::.cnts"ytth attachmonts 3[.,,,_. ; l.
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REGULATORY STAFF COMMENTS ON QUESTIONS PREPARED BY M1NNESOTA POLLUTION CONTROL AGENCY MEMBER, STEVE J. GADLER 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 Against Radiation 2.
10 CFR Part 50 - Licensing of Production and Utilization Facilities 3.
10 CFR Part 100 - Reactor Site Criteria j
4.
T1D 14844 - Calculation of Distance Factors for Power and Test Reactor Sites 5.
General Design Criteria for Nuclear Power Plant Construction Permits 6.
ORNL-4070 - Management of Radioactive Wastes at Nuclear Power Stations 7.
Staff Safety Evaluation of Monticello Nuclear 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 over plants.
Radioactive releases from these plants into the air or into contiguous waters during their operating lifetime are subject to the provisions of Part 20 (Reference #1) designed to limit exposures of the public to levels well within limits recommended by the Federal Radiation Council, the National Committee on Radiation Protection, and the International Commission on Radiological Protection.
As an administrative technique, these limits are translated into deta'. led operating restrictions based on a study at the site and of local asceorological 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.
Ec;a 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 design and the characteristics peculiar j
to the site. The procedures to be used in estimating potential i
radiation exposure of offsite populations under accident conditions are given in TID-14844 (Reference #4).
Safety design _ requirements 1
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2-i to provide a wide margin of _ public safety under both normal operating and accident conditions are given in Part 50 and in more detail in the Cencral Design Criteria for Nuc1 car Power Plant Construction Permits, (References #2 and #5).
The letter document was published in the Federal Renister for public comment in July 1967, and is expected to be issued as a formal design requirement in the near future.
There have been no accidents to date in any nuclear plant in che United States which involved a significant offsite release of radio-As regards releases during normal operations, the most activity.
recent experience information is contained la a report, ORNL-4070, (Reference #6) issued in January 1968 by the Oak Ridge National i
Laboratory. This contains a reference to Elk River.
Reference #7 is included in the informatior material being l
transmitted in order to give Minnesota Pollution Control Agency l
members an opportunity to see what matters vv.re considered by the regulatory staff and At /isory Committee on Reactor Safeguards in This their safety review of the Monticello Nuricar Power Station.
i report was prepared for presentation at the public hearing held on May 25-26, 1967, in connection with the issuance of the construction permit.
Although the Northern States Power designation of Unit No. 1^
appears on the cover sheet'for this report, we know of no present plans for additional units at the Monticello location. Among the several supplementary attach
- un's to the staf f review is a letter i
j from the Fish and Wildlife S. vice of the U. 2. Department of the
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Interior which may be of interest to MPCA members.
Approximately half of the questions listed by Mr. Gadler are 1
concerned with various aspects of the radioactive releases from i
Elk River and Monticelle plants into the air 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 j
small amounts of radioactive gases 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-cents are made of the level of radioactivity in the gas.
If suitable for release into the high-velocity air stream going up the ~ stack under t
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the limitations of Part 20 of the Commission's regulations, the j
gas is passed through several high-efficiency filters _to trap any particulates that may be present and then released to the atmosphere from a high stack at an exit velocity of the order of 50 ft./sec.
2 If excessively high activities are detected during the holdup period, or if very' unf avorable weather conditions prevail, release to the '
3 atmosphere will probably not be abic to meet the conditions of l
Part 20.
The Monticello plant-has only a limited holdup capability which, however, should be sufficient to meet the requi'ements of r
Part 20 on atmospheric releases under normal operating and weather 4
4 If a situation should arise where release under Part 20 conditions.
is prohibited and the holdup tanks are filled to capacity, it would l
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 I
required. Although detailed emergency procedures have not yet been developed for the Monticello plant, the b; sic plan will be to notify local authorities such as fire and. police departments and other civil agencies that previous 1.y planned procedures should be followed.
If necessary, the twin-city araa would be notified. Notification would be by NSP officials or alternately by local police or fire departr.cnts'.
j Under extreme conditions, emerge " radioactive monitoring assistance might also be supplied by the U. S. Atomic Energy Commiscion.
l In addition to the radioactivity released to the atmosphere, some radioactive liquid ef fluents are generated during the course of normal operations both in pressurized water reactors and boiling water These water residues are collected in onsite storage tanks, reactors.
l 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.
I Sometritiumispresentintheliquidg{fluentalongwithsuch other possibic nuclides as Cs137, Co60, 33 -, and Sr90, since 1
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>2CA has expressed a special interest in tritium, some comments on this subject are in order.
Tritium, incidentally, is one of the less hazardous of the radionuclides produced in nuclear reactors because of its relatively low disintegration energy and relatively short residence tine 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 avarage concentration in the cooling water of about one ten-thousandth of the maximum permissible concentration specified in Part 20 of the Commission's regulations.
Tne average concentration of tritium in the cooling watet from Monticello will depend-on a nudber of operating f actors, but must necessarily meet the restrictions imposed by Part 20.
How much effect has the tritium release f rom 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 1957 with the condenser cooling unter gava. an average concentration of 170 pico-curies por liter in that water (a pico-curie is 10-12 s
curie). Mixing of the cooling water with the Mississippi River gave a further dilution to approximately 3 pico-curics (pci) per litar. To place this nudber in proper perspective, USPHS data for 1966 indicate a tritium concentration in surface waters of the United States ranging from 2000 to 15,000 pel/ liter.- Tne estimated 3 pei/ liter added to the Mississippi by the Elk River plant during 1967 is insignificant compared to the normal bchkground content.
It is much too small to be measured, since the minimum detectabin-level difference is 500 pei/ liter.
Hence there would be no detectable difference between the tritium content of the Mississippt upstream and downstream of Elk River.
To reduce the level of radioactivity (other than tritium) in the liquid effluent released to the Mississippi River, the Monticello facility will incorporate, in its liquid-radwaste system, non-regenerative demineralizers empleying resins which after 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 i
only non-radioactive water.) The building in which the rrdioactive i,
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.- liquid waste tanks are located is a concrete structure which could contain gross leakage from the tanks.
The level of~ radioactivity in these liquid wastes will vary from time to time, but normally a concentration of the order of 0.1 curie per liter would be expected.
I At present there are 27,650 gallons of contaminated water at the Elk River reactor.
It contains a total activity of abcut 1.5 curies.
We understand that it is planned to discharge this con'taminated watcr into-the Mississippi River at a rate of 4500 gallons per month over a 5-month period.
With regard to ef fect of dilution of the radioactive material discharged into the water on the reconcentration in the biota and the focd chain, we have the following comments. Dilution will not prevent reconcentration in biota.
But, since the equilibrium con-centration in the biota is proportional to the concentration in the water, the dilution of the released radioactivity by the river will reduce the concentrations which would otherwise occur in organisms growing in the water if there were no dilution. The' meaningful question with respect to ;ublic health and safety is whether the average concentr,ation of a given nuclide in the river will result in a concentration in the biota such that the latter becomes a signifi-cant source of exposure to man. Operating experience with powar I
reactors and information on types and quantities of radionuclides likely to be released from such reactors indicate _that enis is not likely to be the case.
Environmental monitoring programs of the f acility licensees, various health agencies and the Atomic Energy Commission are designed (1)- to confirm that actual racionuclide releases from power reactors, and their behavior in the environment, are as anticipated or (2) to detect any significant variance that might occur.
Turning now to the substance of the miscellaneous questions in-Mr. Gadler's list, each applicant for a construction permit to build-and operate a nuclear power plant at a proposed location is required 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
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f finding on the part of the AEC that_ t.he applicant is technically i
qualified to construc and operate 'the proposed plant safely. This technical competence is subject to continuing scrutiny by the Compliance inspectors throughout the entire operating life of the plant.
A number of questions in Mr. Gadler's list express his concern that construction and operation of the Monticello plant may be subject to some or all of the difficulties experienced at other nuclear stations, such as Senn, Sclni, Oyster Creek. Tarapur, fermi, Piqua, and Dresden 1.
The answer to all the questions is the same, -we do think there is any essential relationship between what happened not 1
any of these reactors and what may be expected to happen at at
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Monticello.
Some of the operational dif ficulties were due to unforeseen f actors associated with the developing. technology of nuc.sar i
None of them created a hazard to public safety. Most of the i
power.
construction dif ficulties experienced to date have been due to.
de ficiencies in quality assurance and quality control in the selection j
and f abrication of materials, components and systems that go to make up the finished nucicar plant. Much emphasis is being placed on these mat ters, and the Commission is taking a very active part in the develop-of codes, standards and criteria governing the design and construc-ment l
l tion of nucicar power plants. Of course, this does not preclude the possibility of difficulties at other plants now under construction, including Monticello. - However, any difficulties that arise having the potential lof affecting public safety must necessarily be resolved i
before the plant will be permitted to operate.
!i l
As regards the use of stainless steel in the tube-side of the feedwater heaters at Monticello and other similar nuclear instal-1ations, this is done to minimize corrosion products in the water l
i passing through the reactor core. Feedwater demineralizers are used i
for the same purpose. Activation of corrosion products in the reactor coolant water raises its radioactivity to an unnecessarily high level and poses undesirable operating problems.
l Various types of postulated accidents are analyzed for their i
potential consequences in the applicant's safety evaluation of l
proposed nuclear power plants. For the Monticello plant several di f ferent types of accidents considered by NSP are discussed on j
l-pages 14-19 of Reference #7. The refueling accident corresponding to the one' referred to at-Peach Bottom No.-1 is-discussed on pages 15 and 16.
This was assumed to result from dropping a spent fuel assembly during refueling. The fission products released would be from those fuel rods mechanically damaged. The gas-cooled Peach-Bottom reactor is entirely different from the boiling water-reactor ~
at Monticello, t
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l On the subject of thermal releases, approximately 3.4 billion STU por hour will be released to the environment during full power operation of the Monticello plant.
This will be released to the-
,j Mississippi River when flow conditions permit. Whan'the river flow is too low to provide the required 1000 cubic feet per second of cooling water the heat energy will be dissipated to the atmosphere, via a cooling tower.
I Pre-operational and periodic tests cf safety feat,ures and plant protection systems are required at all nuclear power stations.
Such tests involve no hazard to public safety.- NSP will not be involved in any part of the Commission's safety research and develop-
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ment program involving loss of coolant experiments, although they will get the resulte of experiments conducted.
Evaluation of the amounts of radioactive products escaping f rom the B'JR containment structure in the event of a partial ec1 down af the fuel is discussed in section 5.4 of Reference #7 under the subject heading " Loss of Coolant Inside the Drywell."
This sets forth the assumptions and proced.res followed in estimating the potential offsite radiation exposure due to the postulated loss of coolant accident.
t As regards the matters of liability and indemnity, section 170 of the Atomic Energy Act sets forth two requirements which must be
)
met before any nuclear power reactor can be operated.
First, the company shall have and maintain " financial protection", i.e.,
insurance, to cover public liability claims.
In Northern States Power's case this would be in the amount of $74,000,000.
Second, the company must enter into an indemnity agreement with AEC whereby AEC provides indemnification for public liability over and above the $74,000,000 of insurance, so that the total insurance plus indeenity equals
$560,000,000. These funds are available to cover certain public 11abi.ity (legal liability) in the. unlikely event of a nuclear occurrence which causes significant damage to persons or property offsite. Moreover, provisions have beca made for speedy payments -
for damages. A copy of these provisions, as published for comment in_-the Federal Renister last May, is enclosed as Reference #S.
These 4
l provisions, with essentially minor changes, were published on October 31, 1968, in the Federal Renister:_as effective regulations.
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As regards the matter of sabotage, 10 CFR section 50.'.3 of tha 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 measures for the specific purpose of protection against the ef fects 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 that many of the safety features incorpogated in the design of a out reactor facility, while not having as their specific purpose protection against the effects 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 systems for a rapid shutdown of the facility in the avent 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.;2 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 i
dismantle the facility and dispose of its component i
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 3
assurance that the dismantling of the facility and disposal of the component parts will be perforced in accordance with the regulations in this chapter and.
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 f acility and disposal of the component parts will be performed in accordance with the regulations in this
~
l chapter and will not be inimical to the common dc2anse and security or to the health and safety of the public, i
anc af ter notice to interes ted persons, the Commission may issue an order a :horizing 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.
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- STATE O:: MINNESOTA MINNESOTA POLLUTION CONTROL AGENCY 459 BOARD cF HE ALTH BUILDINc UNIVERSITY CAMPU$
MINNE APOLIS 55440 3
I December 20, 1968 i
A 4
Mr. droid L. Price Ji actor of P.cculations
'J. 5. A omic Eno gy Co = ission
'c' ashing,on, L. C.
2(,545 Der.'.:. Price :
I wish to acknowledge receipt of your le,ters dat:d Novc=ber 19, 1968, j
'l regarding 1) i.tformation as to a gaseous diffusion plant in Minnesota, t.nd
- 2) response to my letter of Sept, ember 3,1963, regarding various questions su'amitted by yr. Steve J. Gadler, with attr.chments.
Your co = ents and that of your staff are greatly appreciated and are now being reviewed by members of the Agency, our staff, and also our con-i sultant on radioactivity.
I i
Since the original submission to you of some 80 questions posed by Mr.
j Gr.f.or, he has drafted an additional 27 questions that bear consideration by j
thc i.to:ic Energy Co=ission.
I have enclosed a copy of these questions
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signed by Mr. Gadler and aEain ask that these be answered in his behalf and as a matter of information to our Agency.
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r Cr.e further question I neglected to ask you at the outset, and for your c= an,, was a statement that was made by the Congressional Joint Cc=ittee on a;ctic Energy in the congressional report under date of February 1968, that s,ates:
"Until experience is gained and adequate safeguards are proved-out, prudence dictates that large reactor installations be fairly far re-novec, fro: population centers."
4
,f If this is true, tiny, then, was the Monticello nuclear po.ter reactor locatad only forty miles upstren frc the Einneapolis-St. Paul Xe:,ropolitan f
Arca, having a population of approximately two million people, and the water
'lould you please clarify for us supply for in excess of one million people?
the statement as it appeared and is quoted in the Congressional Record?
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-2 12/20/1913 "r. hrold L. Prico
':::. shin ton, D. C.
4 Acain I wish to expresc cy appreciation to you and others of the AEC 4
for your coo.5cration in providing the information requested in the pact, caf nd { trust that the above request for additional information and answers will oe forthcoming in the very near futuro.
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,Very truly yours, w
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John P. 3adalich, P.E.
Executive Director JP3 :r.r.b Enclosure I
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COS?A).IXATIOS OF S?. PAUL - >CtcdAPOLIS AD SUBU?3!d UA?E? SUFF,IM E,'
kO;'0IC4LLO A'..] ELX ICVid ATCEIC TGACTORS (1,.,-. hj; o
.p Want aro thb ;k..r~..-.:typon and n't.ounts of radioactivo po*Llutants that'Vi"L1 R..
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ba discharacd into tho Mississippi River by tho Monticello roactor por day? Por ycar?
4 2.
In tho oventof a serious atonic accidont that uould contav.inat,o tho J.icsissippi River with radioactivo po'llutants wi'L1 ASC provido tho Owin Citios wator for drinking and industrial purposos?
3 If not, why did the A3C approvo SS?i parrat at Monticello?
4.
Is an onor;;oney unter supply for the St. Paul and Minnenpolis a
water systens in oxisting U.S. Atonic Snorgy Com.ission p*Lans if tho rivor is contaninated with radioactivc pol'Lutants?
Ct.
5 Mas c.a probab'Lo atonic accident at^ the Monticollo roactor that would provent uti' Lit.ing Mississippi ?.ivor uator by St. Paul and,..
Xinnoapolis bacn discussed uith concerned public wator officia'Ls?
- 6. -In the ovont of tho energoney in (4) abovo how will industrsos,
dependant upon the hississippi wator stoy in op3 ration?
7.
In the ovent of an atorde or othcr accident at the Konticollo roactor that would polluto the Fississippi River water for a'L1 down-rivor users especiaTLy the St. Paul - Xinneapolis residonts who will ony for Oto added water costs if an onorgency sourco of wator bocones t.vailab'Lc; S.
Sinco the health and safoty.-of the public which includes integrity of tho St. Paul - Einneapolis wMor supplies is a responsibility of the 12cnic 2ner;;y Conniscion both by law and its era regulations, hou will-2.o Atoric 2norgy Connission provont tho po'llution of the Mississipp:.
River wi2. radioactiva pollutants which are a villion to a birlion times nore toxic than any cherical known to mani 9.
Since the Atonic Enorgy CorAssion has pornitted the construction of the Monticello roactor above the St. Paul and Etnnoapolis wator intakes on the Kississippi River wi'L't the Atomic Energy Con.ission carry out-s the intent of the con; ross and provont the discharging of radioactive naterials into the river thereby providing for tho hoalth and safety of tho down-river residents.
'LO. 'Tnat type of connunication networks aro. to bo provided in caso of -
the inovitablo atonic accident at the Monticollo atonic roactor which would destroy St. Pau'l - Minnaapolis water supplies?
- 11. iTnat are the prosont plans or arrangonant for alortin;; St. Paul -
Xinneapolis water officials of t.n accidental discharge of radioactive natorials into tho Mississippi Pivor at Monticollo?
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12 Sinca tha Ato:dc Jnnrny Co c..incion is responsiblo for tw "knt'.
e s c.c.fasy" how w.in they provens s.bota.;o of tho 250,000 galon radio-activo.:stor retontion tanks at Monticono?
0.
In the event of cabstar;c or accidenta bursting vf tho 250,000 r nion radioactive untor retention tanks'who ulu adviso St. Paul wator officials
- bout tho accidant.
U+.
'.'ho win adviso St. Paul and Finnospolis public officials of tho sarioun radioactivo contnr.ination of tho rivor?
4
- 15. 'Tno win dotarnin3 tho amount and typa of radior.ctivo ratorials disc'h,r;,cd into the river? 'Jno advisos.4ho, when and by what neans?
.5 succ ser.nntics plays such a largo role in nucicar literaturo and terninolory and the Ato.r.ic in.r;y Comissior, refers to scr cut: atonic o
.cej dr.tc as incidents or occurrances, is in possiblo te withhold in-for.nion affecting tho safety.nd health of paople by roporting an atonic accident at Monticono cs an incidont?
- 17.. Sinco it is incumbent unor the o,3 ration of any atonic facility 4
uinhhis state to ska fun anc conptoto disciosurcs concerning types and =ounts of radionctivo natorials to bo discharged into the environ-
~. nt, how doss NS? intent to provido the inforation and to whon?
15 Dass ESP intend to dilute rc.diocctivo r.aterials for dischargo into uhc Mississippi River at the sano ratio used by the U.S. Atomic Enorgy Comission's reactor at Elk River?
' 9.
Doos dilution of those radioactivo to:.:ic mtorit.ls that ::S? desiros a dischar;c into tho St. Paul - Finnanpolis water supplies reduco their cangers to the drinking populacos?
20.
Since dilution of thoso cumulativo typos of radiation dooo not reduce O.cir irroversiblo characteristics, hou can the NSP or the Atomic Energy Co=ission protect the public hocith and safoty sinco the populc.co win bo drinking radio active watcr?
- 21. 'inat win be savin; to tho ::SP stockholders in KG produced by the Monticono atorde rc:.nor thra the dischar+ ins.in.t..o the environ.ont u
yg c.nd thereby poHutin; St. Paul and Minneapolispistcad of out-stato j
shipnont for burial and perpatual Atoric Energy Conrission care?
t
- 22. Sinco radioactivo nuclidos or radioactivo natorials are an subject
-,i to t 1:.w of nature that the rato of physical decay natural to cach can-I not be ntered to mko then less radioactivo regardless of the amount o:, caution or c.:.cy.rsion or cc,.4,.v $ e.an, now docs t,ne Atorde :.,,ncrgy Comission proposo to proscrvo the environnont and prcvont the radio
)
activo pouution of tho St. Paul - Minnoapolis we. tor supplics?
l
- 25. Sinco tho..ississippi River is tho sourco of wator for St. Paul and Minneapolis cnd others doun-rivor, why does NSP dosiro to dischargo radioactive wastos into the rivcr?
2
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.;y c..x ld? u c.t to uso tho ;'isaict..ppi ;'avor for r.dioactiv s uatta
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- -t to tho huwgn
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. 5..my!.e ;ncrt:y Cor nt:rd.on t.0 fir.md ar.d aja. ovcd ;t.o.'ot.tico'L*.;
.';o: c. :.. a wor that war.tc to at;.charcc - radior.ctivo poTtutar.ts, ir.to
. :d s',*.. r nr.d tho atnos; toro 'choro'oy inercasin;; tho dosanc0 to dour -
r.ver.esidents with its roucos of wator.nr.d ate.oophorio disposa'L7 1
- 25. Sir.ca the r.o:,t ter.ptin; and noct econo ic.G radioactivo disposa*L routc for the e.onticoT.Lo rec.ctvr is tho hsiscippi Mvor, what
~
ssar.r.: e uiTL the FJOA 4.r.d C.:.*er.-river vator usors that 1:SP i
.s r.?
r'. din; tho rivor"?
?.
s' r.0 the U.S. Atorde Enorgy Co;.c.it,; ion 1:. r.ot cone-tr.od '<rith i
..:.o it.;c;rity of tho St. Pau'l t.nd Mr.r.ocpslis vator expp*das, Uhr.t Eght do they have to poTluto theso untera?
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UNITCo STATES
.. ',S ATOMIC ENERGY COMMISSION U il
'l' wAsmNGTON. O.C.
20 f,4 t,,
FEB 17 E3 Mr. John P. Badalich Executive Director Minnesota Pollution Control Agency 459 Board of Health Building University Ca:npus Minneapolis, Minnesota 55440
Dear Mr. Badalich:
.Thcnk you for your letter of December 20, 1968.
As recards the cdditional questions contained in your recent letter and its attachment, some further comments may be helpful..
The distance from dense population centers of nuclear poucr generating stations now under construction or in operation ranges from a few miles up to forty miles or more.
None o:i them are located in metropolitan centers, but other reactore may be eventually.
All of the plants, regardless of their location, are required by statute and tho' Commission's regulations to be designed, constructed and operated so as not to endcnger the health and safety of the public.
An extensive discussion of siting considerations is contained in the enclosed report of the Congressional Jc at Co=nittee on..tomic Energy Hearings on the Licensing and Regulation of Nuclecr Reactors held in April and Mcy 196:
!.pproximately half of Mr. Gadler's second list of queW m relctos to his concern about routine relec;cs of radio-activity into the Mississippi Ris or and into :he air durin; operat'.on of the Monticello plant.
Sinco a major part of the information transmitted with my cariier lett;r to you dated November 19, 1968 was devoted to this' subject in response to about half of Mr. Gadler's first list of questions, I will not try to repeat what was in that trans-mittal which shm:7 d serve to answer the environmental t
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Sc acicceed offci c cven in the ovene of credible ceciden:c.-.
n0ido thO Con ~cinOcn: c:ruccuro.
F.$c*.*.0cncy procedurCC to
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ine".uding notificction of cppropriato publ'ic officicic, aro 4
j ru, ired to 50 dovoloped by all licencoco prior to tho otort cf.aciccr poner plcn operationc.
Such proceduroc will be inc.udad in :ho final cafety cnclycic report propcred by
- ce
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- ::cc Foucr Ccapcny cnd revicued for adequacy by
- ho c cff cnd the Advisory Ccan'.ittoo on Recc or Scfcgucedc pr'.or Oc 2 ranting a licenco to oporato tho Monticello plcn:.
This rt.psr; will be a part.of the public recoi4, and c copy -
'.:111 bc placed in J.c Cc=miccion'c Public Document '.'.cen tit.cn ccr./ oted..
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"'""!S?tiinT**,
i June 17, 1969 1
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Dr. Glenn T. Seaborg, Chairman
~
U. S. Atomic Energy Commission
.l Washington, D. C.
Dear Dr. Seaborg:
On May 24, Paul H. Engstrom, President of the Minnesota Environmental Control Citizens Association, wrote you enclosing a list of questions relating to power plants run by Atomic Energy in Minnesota.
I would appreciate your having someone on your staff contact l
Mr. Maciver in my office to discuss these questions.
If you have prepared an answer to Mr. Engstrom and are able to share that correspondence with me, it would be helpful.
Your cooperation is appreciated.
Since. rely '
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!!NNESOTA ENVIRONMENTAL CONTROL CITIZENS ASSOCI A 1053 South McKnight Road, Solnt Paul, Minnesota $51
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l May th,1969 I
2 Dr. 01onn T. Seaborg, Choir. nan United States Atomic Energy Commission l
Washington, D. C.
Doar Dr. Seaborgt Tho Minnesota Pollution Control Agency recontly'gavo its approval for a vasto dischargo permit for a nucioar roactor at Monticello, Minnosota.
In the haste to pass this permit many questions about this facility remained unansworod to tho satisfaction of the people of this stato.
One combor of the Minnesoia PCA drafted savoral lists of questions he felt should be ansuored. One such list was intended for the U. S. Atonio Energy Commission. A copy of this sot of questions i
- ac rolcased to the press but it is our understanding that this list was never for.rardod to you from the PCA. The questions, tho n -
fora, remain unonswerod.
I am onclosing a copy of those questions for you. I hope you will give then your prompt attention.
Very truly yours, abh
<*fhh Paul H. x.ngstrom g
e-c3 Pmsident Mg
, cc: Senator Eucono McCarthy q'
l Sonator Walter Mondalo g'v p,.gl, i'.
gp congressman Jocoph Karth j
Congressman Donald Fraser
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W Congressman Clark MacGregor c
u s
R oc'd 011 at Date &l. Oirlg >geg' Q4yf&$ "] 7 }
3 De.7197 a.
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April 30,1969 I
Monticeno Nucisar Generating (Plant Questions Pertaining to. the AE List #3) e.
i 2
'by Steve J. Cadler, P.E.
i Member of the Minnesota Ponution Control Agency R
o 1.
Sinco the health and safety of the Minneapolis-St. Paul metropolitan popu-j lation down river and down wind from the Monticello Nuclear Reactor plant is i
of concern, why did the AEC -
)
I Approvo the request to build and operato a reactor which according'to' '
a.
the NSP Final Safety and Analysis Roport has undeveloped components?
b.
Licenso the construction and operation of an experimontal type of reactor under the Rosearch and Development section of the Atomic Energy
- Act?
a 2
1.
Is tho Monticello sito or plant licensod? Or are both licensod?-
i I
c.
Permit.the discharge of radioactivo pollutants into the Mississippi which is the source of drinking water for approximately one third of
- -~
the people living in Minnesota and for the down river populations to the t
j l*
gulf of Mexico and a source of water for industry and for agricultural irrigation?
)
'd. Fail to make any plans to provide a source of water supply for down river users in the event of a nuclear accident at Monticello which would destroy the river as a source of drinking water?
i l
e.
Not advise tho LGPHS that the Mississippi River Water was used for irrigation dcwn river from the Monticello plant?
i f.
Overlook producing completo and thorciugh studies on the total effect to the Mississippi River Valloy ecological system from the contemplated 1
l radioactivo wasto discharges into the air and water environments from l
Monticono, E:.k River, Prairie Island and other reactors?
i
}
- g. ~ Noglect to consider the damage to the quality of the water and to the river biota from the thermal pollutants to be discharged from Monticello, Elk River,, Prairie,I,sland and other being planned for this ar,ea?.
4 3
2.
Since the public health is of ' concern what control w;LI.1 be imposed on the operator by AEC - -
In. ovent the plant is,olosed d'own because',of accident' or obsolescence?
a.
l
..[;.;.([ ~,Page 1 of 5
- b.
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April 30 1969
',)
(Liot 3) j Monticello Nuc1 car Gonorating Plant Quoationo Portaining to the AEC 4
l b.
For disposition of sito, radioactivo structuro and roactor after final closo down?
To provont abandonment in order to protect t.he public ' interest?
c.
d.
To cocontaminato and control area as long as.necessary to protect the public health and safety?
d
- 3. ' The AEC literaturo indicates that many reactors such as Fermi, Pathfinder, Piqua, Bonm, Hallum, Elk River, etc., have been closed and others such as
.., Dresden, Peach Bottom, 0yster Crook, etc., have experienced difficultios -
....~..
, duo _,,to many factors such as equipment failures, deterioration of metal, which.. u..+
. has resulted in unscheduled radioactivo moto rolcasos to the environment.
It *"
'" therefore appears that the reactors are still in various stages of rescarch and development and that all the necessary experimental work has not boon -
~"-
accomplished and in view of those salient facts affecting the health and safoty of a.11 Americans, why did AEC not -
Conduct and comploto all research and development, work to develop a. ;
"E a.
.roact'or technology beforo -
4
.,.r 1.
Imposing experimental nuclear plants on the economy?
2.
Exposing American citizens to the risks of ionizing radiation a ".I-i I
from the radioactive wasto discharged to the environment from.
theso reactors?
j' '
b.
Disseminato comploto.information to the public concerning -
t t-s s
' ' 1.
The prosont health and future risks to'the population from I
exposuro to the radioactivo mstos discharged into the environ-mont?
- 2.
- Accidents and accidental discharges of radioactivo vastes from reactors?
4 e
3.
Total amount of radioactive wastes being discharged to environ-ment, to be discharged, arid the probable offects to health?
l 7
I f
c.
Closo down reactors discharging radioactive wastos abovo.AEC limits rather than to pormit operations when reactors une,oxperiencing difficulties?
t..
d.
Develop positivo and cocuro instrumontation and monitc, ring methods to insure' comploto and offectivo data concerning amounts of radioactivo wastos dischargod to tho environment?
. s Withdraw all operational licensos under the roscarch and development o.
section of the Atomic Energy Act?
Pago 2 of 5'
'. i
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j Apr 1 0,1969 e t l '. ' ' a ',
3 Mohticollo Nuclear Generating Phnt Questions Portaining to the AEC f.
Provido complete plans for establishing -
1.
Alort wrning notw rks?
t 2.
Adequate modical facilities and evacuation procedures in the event i
of a nuclear accident?
t i
The Sacramento Municipal Utility District plant is designed byllentinghouse'
. 4.
to clininate the discharge of any radioactivity to the water environment.
Kr. Seaborg, Chair an of the AEC in a spooch to an Air Pollution Symposium in 1.*ashington D. C. in 1967 said that the AEC is capable of designing plants i
. -without smoko stacks.
In view of the SMUD system and the Seaborg statement" *
- How much time will be necessary to develop a reactor p2 ant that can a.
I contain all radioactive wastes?
b.
1Trat are those costs por r,egawatt of electric power produced?
1Trat is the amount of radioactive wastos produced per megawatt'of -
c.
........... electric. power in a. Nil type plant of the Monticello. size?.......-............. _
- 5. - The literature indicates that the AEC has permittod all nuclear reactors to
.dischargo. tritium substantialJy above level permitted for.other.. radioactive.u..::.1
)
wastes, why doos AEC -
Permit tritium discharges to the environment?
4 a.
b.
Only utilice estirates instead of accurate on-line measurements for 1,
tritium discharges from reactors?
ilhy has USPHS recently established a tritium monitoring network?
,T c.
6., According to inforcation rolcased by AEC, it appears hold up tanks will be utilized at the Monticollo plant to meet the requirements of the -limitations imposed by 10 CFR 20. In event of an inversion which should' preclude dis-i r* charge of radioactive wastes to the atmosphere -
1Tnat action can be taken by plant operators if tanks are already full.
a.
when inversion occurs and more radioactive gaseous wastes must be l'
handled?
.' t ;
b.
Will plant be closed down under those conditioss?
.s Are tanks at Monticello of sufficient capacity to' hold up all gaseous i
- I c.
radioactive wastes under adverse conditions to protect the'public health
,,'g
- 1. -
~
and safety?.
g 1-I d.
What will, be done with vastes produced during shut down if tanks are'-
..; ' :-',N full?
. Gl.
,e a-
- Page 3 of 5 i
.x.,.3..-
- i '-
Apg0 969
' Monticollo Mucioar Contratin5 plant Questions Portaining to ths AEC
- 7. According to AEC if excessively high radiation levols aro detocted.during i
porieds whon radioactivo casos aro hold up from dischargo to environment or it unfavorablo weathor conditions provgil, rolcaso to tho atmosph9re will '
probably not bo able to moot conditions of 10 CFR 20.
a,.
In such an ovent does AEC advocato violation of its own regulations?- --.. e b.
What aro the possible coursos of action and recomendations to avoid
'~
the discharcos under the conditions sot forth in item 7 abovo?
8.
The Advisory Comitteo on Reactor Safeguards of the Atomic Energy Comission
...... by lotter to Chairmn Scaborg dated April 13, 1967 recommended '
a.
Stress analysis report for the reactor vossol be reviewed byhdepen
~
u' dont exports sinco this is the first Nucicar plant to uso a field volded and erected pressuro vossol, a proceduro now to the industry,.
b.
That the AEC Regulatory staff satisfy itself with respect to the ado-quacy of the isolation valvo test program and follow tho development of the dotailed design since in tho event of a steam line rupturo
-.- a
" ' ~ ~ ~
' external to the reactor containment tho steam lino isolation valves cust closo rapidly.
r h;...[.:c.c..,That JSP provido supplementary facilities for retention of.radioactivo - *
....,.wastos,during periods of low river flow sinco ducing periods when cooling
tower aro utiliced for rocirculation of condonsor cooling water the volume of discharge water into which the radioactive wastes can be di-luted will be greatly reducod.
In view of the importance of the abovo items to tho. health and -safety of the public, detailed information should bo presented to the Agency on tho.
status and results of the ACRS Comitteo's recommendations?
9 The Monticello Unit #1 deaign incorporated at least 12 features (itemized on page 16 of Partial Su=ary of the Facility Description and Safety Analysis Report) which have not yet been demonstrated in reactor plant operation. All of these items woro reviewed by the AEC Staff and the Advisory Comitteo for Reactor Safeguards, however sinco those important safety features which
~<~
concern health and safety were only reviewed and not approved detailed infor-ca, tion must be presented to the Agoney showing -
Whoro and when the listed items were found approvab'lo and capable of
)
a.
mooting all safety requiremonts to protect the health and safety of the public?
b.
Reco=endations as to the possibility of safe operation of those it' ens which aro now featuros and have not previously been oporated in BWR 1
reactors, without unduo risk to health and, safety of the public?
- +
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'. 2 9 'page y og 5 g
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--_--_--_-___._-_______________)
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April 30,194 (List #3)
.M6dticollo Nuclear conorating Plant Questions 'Portaining to the AEC i
Of the 12 listed items, which items have boon complotely dovoloped c.
and approvod for use at Monticollo by tho AEC Staff and the Advisory Co.=itta on Reactor Safeguards? When and by whom approved?
d.
Of remaining items nooding approval how rany roquire additional re-scarch,and developmont?
o.
What is cotimated approval dato?
ht aro rocomondations on oporating the plant without A30 approval f.
of all tho tostod and nocoscary onginocral safeguards?
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1 Re/3 latory rp, g, NOMTHERH STATE 5 POWER COMPANY M I N N E A P O L.i t M I N N E q
SEP 13876 Q I'#
September 10, 1976 4
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^
f Director, Office of Inspection and Enforcement 7
U S Nuclear Regulatory Comission
/g h
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Washington, DC 20555 hl.
9 kr,
Dear Sir:
MONTICELID NUCLEAR GENERATING PIANT 4
W Docket No. 50-263 License No. DPR-22
/%[
Monthly Operating Report Au gu s t 1976 Attached are ten copies of the Monthly Operating Report for August 1976 for the Monticello Nuclear Generating Plant.
Yours very truly, A
L 0 Mayer, Manager of Nuclear Support Services LOM/ak cc:
Director, IE-III, USNRC (1)
Director, MIPC, USNRC (2) 9 k
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9
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2025 Rev.3 Y/13/76 I
OPERATING DATA Rl: PORT DOC)1T N0.
50-263 UNIT 1
DATE 9/7Q6 Ca@LErD) BY
- w. A. Shamla TELEP110NE _612/295 5151 Ext.111 PIRATDC STAnlS 1.
Reporting Period:
August Gross llours in Report Period:
744 2.
Currently Authorized Power Level (hMt):
16_70_
Max. Depend. Capacity (bMe-NET):
_ 53 6 Design Electrical Rating (bMc-Net):
5T5.4 2.
Pcwcr Level to hhich Restricted (if any) (hWe Net) >
N/A
!!casons for Restriction (if any):
N/A TilIS FOND' YR TO DATE CWOIATIVE 5.
Nttnber of flours Reactor k'as Critical...........
570.6 5,413.4 35,262.0 6.
Reactor Reserve Shutdown llours.................
0.0 0.0 940.7
/. Ilours Generator On Line........................
554.3 5,311.2 34,048.4 8
Unit Reserve shutdown llours....................
0.0 0.0 0.0 9.
Cross Thermal Energy Generated (bMI)........... _825,249.6 8,179,47.8.4 58.498,716.2 d).
Grrss Electrical Energy Generated (?NI)........
274,880 _
2,773,200
_17,244,250
- 11. Net Electrical Energy Generated (hMI).......... _259,924 2,652,632 16,473,724
~7 Teac tor Service Factor.........................
76.7%
92.5%
- 77. 8_%
1s.
R:::cter Availability Factor....................
76.7%
92.5% _
_ 79.9%
' h n Sa v i c e Fac t or............................
74.5%
90.7%
_ _75.1%
i.
}*: Availabilit y Tac tor.......................
14.5%
90.7%
75.1%
'h, : Ccpacity Tactor (Using MDC)...............
65.2%
84.5%
67.8%
?7 "ni: Capacity Facter (Using Design hMe)........
64.1%.
83.1%
66.6%
1.
Unit Forced OutIge Rate........................
4.9%
_ 0.7%
9.9%
- 19. Shutdowns Scheduled over Next 6 Months (Type, Date and Duration of Each):
N/A 20.
If Shutdown at End of Report Period, Estimated Date of Startup:
I 1
j
l l
<.'oh i'cV. 0 3/3/76 AVERAGE DAILY UNIT P0hD LfYEL DOCKl?T 10. __50-263 UNIT I
DATE 9-9-76 COFLETED BY W. A. Shamla TELEI110NE 612/295 5151, Ext. 111
%.Wril gg, AVERAGE DAILY P0hH LEVEL DAY AVH',Vir DAILY TOhTR LLYEL DAY
(!ide Net)
(we Net) 3 406 17 q7 g 2
50 0 18 su 3
343 19 g33
'I
.6.
20 gm b
..__:_4 21 gu 6
.. _ a 22 g33_
_ ___...: 1 =
23 qu 8
-4 24 (nn 25 gx3 9
U>
_. _ 64 26 qu F-
.. =2 66 27 4t7 l
__.3 22.
28 27o 33
-... 4 51L 29 go I'
._... s1 n 30 xgo 36 8...
31 aeo (6
_ ___. 501
2027
+
i:a. 0
' d ?6 DOCITT NG. 50-263 UNIT NAME Monticello IFIT SUIDOWNS AND IMIR RIRETIONS DATE 09/08/76 COtPLEITD BY W. A. Shamla PHORT ?OhTil _ AUGUST TELEM ONE 612/205-5151 Ext. 111
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N I
SUITING DOWN I IIFATION Tile REACTm OR F: FORCED NO.
DATE-S: SOIEDiJLED (140RS)
REASON (1)
REDUCING IMER (2)
CORRIETIVE ACTIONS /CGDENTS 27 760803 S
160.9 B
1 Plant outage taken to repair leaks in feedwater heaters.
I 28' 760814 S
O B
4 Power reduced to 50% of rated for stop valve limit switch j
repair and feedwater pump seal cooler leak. Power reduction l
accomplished via manual reactor y
recire flow reduction.
l l
28.8 H
3 Automatic Scram initiated by 29 760828 F
l reactor high neutron flux.
i (1) REASCN (2) Em l
A: Fqui; ment Failure (Explain) 1: Manual i
B: Maint. or Test 2: Manual Scram 3: Automatic Scran C: Refueling 4: Other (Explain)
D: Regulatory Restriction E: Operatar Training.and License Exa: fnatico sp.3,1\\}.Y:' Operated as base loaded.
F: Ac%. inistratFte.'
unit except for load g:. Operational Error (Explain) following during first q.
M her (F wlain) three days of the month.
I savinoamentallibospyol*19 s
hg@
ET3100880 1222 fourth street s.e.
minneapolis, minnesota 55414 80-943 i
October 1, 1974 9
4
~
9 q
Mr. Dunald J. Skovholt fc Assistant Director for Operating Reactors 2;.
q Directorate of Licensing U.S. Atomic Energy Commission g
Washington, D.C.
20545 a
Dest Mr. Skovholt,
. I am writing on behalf of the Envieonmantal Libr)(ary of Rinnesota with regard to our public documents repositary status.
Due to a dwindling volunteer staff and a change of direction in our collection from environmental subjects to alternative life styles, we would like to divest ourselves of our status as a local public reposi-tory.
The Environmental Library was made a repository for materials con-cerning Northern States Power Company's Monticello Plant in April, 1970.
Later, we received the correspondence and reports concerning the Prairie Island Nuclear Plant from the Red Wing Public Library at the request of the Minnesota Pollution control Agency.
We would like permission to transfer the public documents depository materials we hold to the Environmental Conservation Library at the Minn-eapolis Public Library, which is the environmental library for the State of Minnesota. We would also like to request that any public document depository materials which would be sent to us in the future be sent to the E00L's address is:
q Environmental Conservation Library (E00L).
cocg '
The Environmental Conservation Library y
Minneapolis Public Library vI Il 1974 Pl_.5 300 Nico11ett Mall Minneapolis, Minnesota 55401 f
$genum$$
We have discussed this transfer with Julia Copeland of the Environmental onservatien Library and she would like to have the materials we have and is willing to take over our responsibilities as a public document repository.
4 Your mailing labels for us have read variously:
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f EIN d
Skovholt (AEC)'
page 2 m
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t Minneapolis Public Library j
Environmental Resource Center M M.1222-4th St. S.E.
Minneapolis, Minnesota 55414 4
(
~
Environmental Library of Minnesota J-.
1222-4th St. S.E.
1:
1 Minneapolis, Minnesota 55414
)
g I don't know how nuch red tape is involved in such a change. We 4
would apreciate some idea of how long this transfer of responsibility 1
will ta(e.
j
+
3 m
'Ihank you.,
Sincerely, i
- 4
[
(Mc
. Y
- ~
Nancy-L. Johnson ElR volunteer Copy to Julia Copeland Environmental Conservation Library 1
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