ML20127N650
| ML20127N650 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 11/28/1969 |
| From: | Ward E NORTHERN STATES POWER CO. |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| NUDOCS 9212010348 | |
| Download: ML20127N650 (31) | |
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.Om E.C. WARD November 28, 1969 ACRS/AEC GUESTS Attached is the program and the agenda for our
- . meeting tomorrow.
As indicated on the program, the meeting tomorrow afternoon will be in the Lower Level Auditorium
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No. 2. Persons expecting to receive phone calls -
should have them directed to No. 330-5523 as this is the phone booth adjacent to the meeting room.
It is suggested that you carry your luggage with you on the bus to Monticc1]o in that the bus will return us to the NSP building. Transportation will be availabic from the NSP building to the 7
airport as required.
E. C. Ward
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Attachment P.S. Also attached- is some background infc cmation on the Minnesota Pollution Control Agency-NSP situation.
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- e ACRS SUBCQo!ITTEE MEETING ,
t November 29, 1969 i Program Assembly Point-Nicollet Mall Entrance to Nicollet Hotel.
8:30 A.M. - Bus Leaves for Monticello-9:30 A.M. - Arrive Monticello Site Plant Meeting Room Presentation on Project Status and Completion Schedule Coffee and Dough.,_:s 10:00_A.M. - Begin Tour 11:30 A.M. -. Complete Tour Board Bus.for Return to Minneapolis 12:30 P.M. - Arrive Minneapolis Buffet Luncheon - NSP Building- Cafeteria - Lower Level
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'1:30.P.M.' - Presentations and Discussion - Lower Level Auditorium .No. 2 Agenda Attached .
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ACRS SUBCGNITTEE MEETING -
November 29, 1969
' Agenda 1] Minnesota Pollution Control Agency-NSP-Status Report 2] Reactor Vessel Fabrication-QA 3] Emergency Evacuation Plan 4] Staff Report Items-Subcommittee Questions L
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3,,. COPY Arthur v. a cnnarc 4-29-69 FNTINA NUCLEAR GENERATING PIANT Chronoloay of Significant Iboulatory Events Ihte Event Decerrber, 1965 Internal decision by NSP management that a generating unit in the 500-tw range would be required for service in 1970.
January, 1966 Discussion of suitability of htnticello site with staff of the Division of Reactor Licens-ing, Ato:ric Energy Camission.
Fubruary, 1966 Discussion with the staff of the Minnesota Water Pollution Cbntrol Ormission concern-ing suitability of bbnticello _ site.
Marca, 1966 Additional presentation of the pro;:csed use of the bbnticello site to the staff of the Division of Feactor Limnsing, Atcraic Energy Comnission.
April, 1966 Visit to htnticello site by staff mmbers of the Division of Peactor Licensing.
April, 1966 Public announeenent by NSP of intention to proceed with for:ral application to the Atomic Energy Co:rmission to construct nuclear power plant at bbaticello for service in May,1970.
May, 1966 Description of site and proposed plant presented to the Advirory Conmittee on Feactor Safeguards, Washingten.
June, 1966 Meetings with representatives of the Minnesota Departncnt of Conservation to discuss cooling water requimr_nts for tne hbnticello Plant.
July, 1966 Application for construction permit for Fbnti-cello Plant submitted to the Atom.c Energy Ccm-4 mission. Infor: ration capies sent at the sane tine to the Minnesota Water Pollution Control Carmission, the Minnesota Departnent of Conser-vation, Minnesota Departnent of Health, and to the Board of County Comnissioners of Wright County.
August, 1966 Contract signed with General Electric Campany
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5 Date Event to install 545-nw boiling water nuclear pcwer.
plant at Fbnticello on a turnkey basis.
August, 1966 Public meeting in bbnticello to describe pro-posed plant to cc:muJ.Yleaders and general public. .
October, 1966 Application to the Minnesota Water Pollution Control Co=nission for permission to discharge heated water and other plant waters to the Mississippi River.
October, 1966 Application to Minnesota Department of-Conser-vation for parmission to appropriate cooling water from the Mississippi River and to construct intake and discharge structures.
October, 1966 Submission to the~ Minnesota Departnent'of . Health' containing inforration required by Minnesota sta-tutes regulating use'of ionizing radiation.
February, 1967 Meeting with staff rerbers of the Water Pollution ,
Control 03mnission and the Minnesota Department -
of Health to report progress concerning-Atomic-Energy Commission review of NSP application ~for.
construction permit.
April, 1967 Meetings _with the-staff of the United States Public Health Service to assist them in~ their:
review of the site and' of NSP's' construction -
permit application to AEC.-
April, 1967 Advisory 03cmittee 'on Peactor Safeguards' con-pleted its revied of.NSP's construction permit.
application and advised the Chairman of thei Atomic Energy- Conmission that the. proposed re-actor could be constructed at the ebaticello site without undus risk to health and- safety _
of the public. Ccpies of ~ this report were trans-mitted .to the staffs of the interested State
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agencies.
April, 1967 Atomic Energy Connission scheduled public hear .,
ing on NSP's application for construction permit..
Scheduled-date May 25, 1967. NSP. transmitted-copies of the notice to staffs-of the: interested State agencies.
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Date Event bby, 1967 Minnesota State Iagislature created 'the Minnesota Pollution Control Agency to super-;
sede the Finnesota Water Pollution Control-Comrission. .
May, 1967 U. S. Public Health Service issued evaluation of the public health aspects of the proposed-
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plant-and concluded- that the Fonticello Plant:
"will not present an unacceptable risk to the health and safety of the public". -
May, 1967 Atomic Energy Co:rrission conducted public hear-ing in Buffalo, Minnesota, County Seat of Wright County, on May 25 and-26 to give rerbers of the public and of interested lccal and State agencies an opportunity to express their views.
Additional technical data was reviewed by the -
members of the Atcric Safety and Licensing Board,
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which conducted the hearing.- -
June, 1967 Atomic Energy Comnission issued construction per-mit to FSP on June 19, 1967. Ch this date the first substantial construction work at the site began.
August, 1967 Minnesota Pollution Control Agency held its first organizational recting.
November, 1967 Minnesota Dapartnent of Conservation conducted a public hearing at Buffalt to receive testinony from NSP supporting the application to ' appropriate cooling water frca the Mississippi Piver and to - -
give tne public and other interested State and Federal agencies an opportunity to present infor-mation.
Novenber, 1967 Minnesota Pollutien Control Agency appointed its Executive Director.'
Decerrber, 1967 NSP made a review and presentation of_its pre-viously submitted discharge application _to tha =
new staff of the Pollution Control Agency. 'Ihe Agency authorized public notice of NSP's appli-cation and requested conrents from the public.
January, 1968 NSP repeated its presentation for_the benefit l l of the nerbers of the Pollution Control' Agency.
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Date Event
'One nenber of the Agency- asked that. action on the permit be delayed to permit him to study the natter further.
February,1968 Cbjmetors to NSP's permit application appeared at the regular neeting of the Pollution Cmtrol -
h9ency.
May 12, 1969 Pollr? .v' Cbntrol Agency approved the obnticello disch - permit by a 5-1 vote. 'Ihe permit ccn--
tains vr. Tsivoglou's recommndations for radio-activity releases from the plant and contains limits for the release of other wastes. In gca-eral terns, cooling water discharges from the plant under the permit are restricted- to a 5' rise over the ambient river tenperature, after mixing.
Subsequent to the public objections in Feoruary,- 1968, the subject of the bbnticello permit has been brought up at alnest every nonthly neeting of L the Minnesota Pollution Control Agency. In spite of a -legal opinion from the Agency's staff attorney that only the Federal governnent could regulate-nuclear power plants, the Pollution Control Agency decided that it would establish State standards for release of radioactive wastes frcm the Fbnti-cello Plant. 'Ihe Agency hired a consultant, Dr. E. C. Tsitoglou of the Georgia Institute of 'Ibchnology, to review the Manticello project and'to draft a permit for consideration by the Agency. A permit drafted by Dr.
Tsivoglou established stringent restricticns on release of . radioactive wastes.
1 AVD/lj 1
NSF NORTHERH STATES POWER C O M P A N Y-M 4 N N E A PO Li t M I N N E s OT A 5 5401 moesm? w twetLe October 30, 1969 Mr Robert Tuveson, Chairman Minnesota Pollution Control Agency Albert Lea, Minnesota 56007 Dear Mr Tuveson With the hope that it will clarify our objections to portions of the Monticello plant permit and lead to early resolution of differences, we submit the attached material for consideration by the Minnesota Pollution Control Agency.
All will agree the subject of radioactive waste is an extremely technical one.
Our reluctance to put our permit objections in writing has not been based on any unwillingness to share facts with the Agency. Rather..we have found it most dif-ficult to state these in a way that the information would not be misconstrued and would be genuinely useful to you and to the other members of the Agency. We had therefore advocated continued face-to-face communication and discussion with your staff and consultant in an effort to find solutions.
But perhaps this written report will help to focus on the issues and clear the way for meaningful discussion. Your agency and our company have common objectives.
We both are committed to safeguard the health and well-being of the public. At issue only is the difference in opinion of'how to achieve these objectives.
We are confident the waste treatment and handling facilities at Monticello are, entirely adequate for the -intended purpose, which is the protection of public health and safety. The addition of more waste control equipment, we believe, is unnecessary; but we are willing to explore this subject further with^ your staf f and your consultant. It is our wish.to share and discuss facts-and to engage in mutual problem solving.
i Though we have filed suit, we have previously stated and now reaf firm our desire L to continue discussions with the MPCA. We do not consider litigation a barrier L
to reaching an agreement. There is no reason we can see why the MPCA and.NSP, working together, cannot find a solution for safeguarding the environment, and "
we wish to continue our discussions to resolve the differences.
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No. /HERN CTATED POWER C MPANY Mr Robert Tuveson Page 2 October 30, 1969 We hope the attached commentary on Permit No 5633 will be a constructive step in that direction. We look forward to bearing from you at your earliest convenience.
Very truly yours e #l n
/
Robert H Engels President i
cc John P Badalich
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x t,sRTHERN CTATCO POWER OMPANY Attachnent to Ietter Dated 0::tober 30,1969 f rm R. H. Engels, President, Northern States Pcuer Ctupany, to Robert Tuveson, 01airmn, Minnesota Pol-lution Control Agalcy.
MIMESOTA POLUJrICN CGTPOL AGDCY PERMIT 10. 5633 DATED MAY 20, 1969 In its review of the waste disposal pemit issued by the Pollution Control Agency for Northern States Power Ccrpany's Ibnticello tbclear Gen-erating Plant, NSP has no significant difficulties with the sections of the permit entitled " General Conditions" and "Special Conditions Relating to Cbn-ventional Wastes". However, the section entitled "Special Conditions Belat-ing to Radioactive Wastes" contains anbiguities and unworkable features which will be su:imarized later in this macrandum.
'Ihe Special Conditions Pelating to Radioactive Wastes are not limited to e specification of levels of pemissible waste release, but also contain conditions govertung plant operating facilities and operating methods. A ctrparison on an isotope-by-isotope basis of the pemitted levels of radio-active waste release as listed in the PCA pemit indicates that there is no consistent relationship between the PCA levels and those pemitted by Federal standards prua11 gated by the Atcmic Ernrgy Canrission in Title 10, Code of Federal Pegulations, Part 20. 'Iherefore, it is inaccurate to say that the PCA pemit is fifty times (or any other nunber) nore restrictive than Air !
standards or any other widely recognized standards. 'Ihe only statement which can be mde in this regard is that the PCA permit establishes waste release limits
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which are very substantially nere restrictive than those permitted by :
Federal law.
A su: mary of NSP's analysis of the PCA permit gives the following gen-eral conclusions with regard to the Special Corditicns Relating to Radio- !
active Wastes:
- 1. As presently designed, the mnticello Plant probably can emply with conditions 1, 2 (a) , 2 (d) , 2 (e) , 3, 9,10,11,12,13,14, and 15. Cmpliance with these conditions depends upon clarifi-cation of portions of the permit language.
- 2. With the additicn of a substantial anount of waste treatnent equip--
ner.c and with the consequent expense and-delay, the plant could be nodified to permit probable ccepliance with Conditions 2(b), 2(c),
4, and 5. Clarification of permit language, et.pecially regardirq techniques of neasurment, will be required.
- 3. With the addition of a substantial amount of waste treatment equip-nont and with constquent expens and delay, the plant could be nodified to permit possible empliance with Conditions 6, 7, _ and 8, but its availability as a reliable power-production facility could be cmpramised seriously.
- 4. Even if the substantial expenctitures for additional waste treatment equipment and the corresponding delays' in in-service operation are -
undertaken, the enforcenent of the PCA permit will not result in
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any significant additional protection-of the public health and safety. On the contrary, the permit will result in significant=
additional radiological exposure of plant personael, in the handl-ing of larger quantities of radioactive wastes, in an overall deg-radation of safety factors in plant equipment, and in unpredictable and undependable operatian of the plant as a power-production fa-cility.
%e following is a paragraph-by paragraph ccumentary on the fifteen canditions in the PCA permit. S e numbers in the following text refer to the nunbered Special Conditions Belating to Radioactive.' Wastes beginning on Page 4 of Permit No. 5633:
- 1. NSP is in ccuplete accord with the general policies stated in Con-dition 1. NSP has stated publicly that its goals are the same as ,
those stated in the PCA permit, namely that the actual levels of radiation exposure of mmbers of the public shall be kep'; as far below recognized safety limits as possible, consistent with tech- !
nological feasibility and reasonableness of cost.
- 2. We second condition of the PCA permit deals specifically with operating equipmnt and procedures. mis is inappropriate because the permit not only specifies the limits for waste releases, but also attenpts to dictate the equipmnt which must be used to achieve these limits. Specific ccmmnts relating to the five parts of Cbndition 2 are as follows:
b (a) mis provision rquires that ?EP treat liquid and gaseous wastes in the manner prcposed in ISP's Final Safety Analysis Report submitted to the Atcmic Energy Cannission. NSP ob--
viously will conply with this requirenent.
(b) m is provision requires the removal of certain gaseous radio-- -
isotopes to the extent obtainable "by effective activated charcoal filtration of the entire air ejector off-gas flcs".
Ccnpliance with this part of the State permit would require :
NSP to install substantial additional gaseous waste treatment cquipnent in the plant, with the attendant additional cost and delays. It is NSP's position that this is an unnecessary re-quirment, because environnental monitoring in the vicinity of toiling water reactors similar to bbnticello has indicated that reler;3es of these gases (radiciodine and other halogens) _
are so los that they are negligible when related to reccgnized standards. m erefore, installation of the filtration cquipment would not effect any inprevenent in public health and safety.-
me Fbnticello stack emission and environmental nonitorim pro-grams will serve as a control an halcgen releases.
(c) mis condition requires routine ion-exchange treatment ofIfloor-drain and chnmicM waster. As written, this is an unreasonable requirenent, because demineralization is not an effective-form of treatment for such wastes. me present treatment system in-stalled in the plant provirW for filtration of these wastes.
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, Additicnal evaporation aIuipment could be installed, with con-sequent expense and delays, to treat chemical wastes further,.
but tnere is no evidence that this would 'effect any inprowmmt of public health and safety. NSP is considering the use of ,
disposable clothing to minimize liquid laundry wastes.
(d) mis condition requires that fel rods- be--inspected for "de-tectable or significant anounts of uranium'on their externa 1 surfaces" and that the results of the inspection be reported "in detail" to the Agency. Application of this provision re-quires the definition of what constitutes " detectable or sig-nificant amounts" of uranium. 'Ihe fuel fabricator has developed assaubly techniques which minimize the anount of radioactivity.
on the external surfaces of the fuel rods, and NSP will conduct additional quality assurance inspections at the fabricator's plant to determine that these procedures are follcwed.
(e) 'Ihis condition requires, anong other things, the developuent '-
and application, "to the full extent possible", of the nethods P and techniques for lccating and identifying leaking fuel rods after operation of the reactor begins. .'Ihere are no inspection techniques kncun at the present tine which are adequate' to ident-ify all fuel rods which might develop leaks.- NSP obviously will not install any fuel rods in the reactor which are kncwn to be.
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-defective, and NSP will use the best' techniques available in i
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the industry to identify leaking fml elments. NSP will use-these technigms during refueling outages and at other tines when it is necessary to identify leaking fuel elenents in the-core.
- 3. mis condition limits the gross betaya:tma radioactivity of liquid effluents in the discharge canal to an annual average of 10-7 micro-curies per milliliter above natural background. As is custcmary, NSP assumes that tritium is not included in the neasurement of gross beta-ga:ma radioactivity. NSP has indicated publicly-it is prepared to meet the limitation in PCA Parmit Condition 3.-
- 4. mis ccndition lists permitted mncentrations in the discharge canal' for nineteen specified radioisotcpes, with limits given for canal flows of 645 cubic feet per second and of 36 cubic feet per second.
Rese permissible concentraticns are indicated as applying cn an annual average basis, but there is a confusing reference to average daily concentration. In additicn, the condition specifies'that the-average daily discharge canal cancentration of any other radioisotopes' not listed shall not exceed 1/3000 of the ICRP limits.or 1/300 of the AEC limits. Apart frczn the semantic problems intredaced by the mixing of annual and of chily levels, NSP is concerned because the discharge -
levels listed in the permit are in nest cases so lcw that it _is not -
technically feasible to measure the concentraticns. In all cases, it
! would be impossible to neasure the lcw levels of concentration in the l
discharge canal itself, so measurments would have to be made in the
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s waste sample tank prior to waste release. Even at the expected
-levels in the tank, the limit of detection sensitivity for nest of the isotopes is greater than the expected concentration in the waste tank. For these reasons, NSP believes that it will be im-possible to insure empliance with Condition 4.
- 5. The first part of Condition 5 permits a seven-day average gross beta-gamm activity release in the d scharge canal of 5 times 10-7 microcuries per milliliter, in excess of existing background' radio-activity and presurably disregarding tritium. NSP expects to ccr. ply with this part of Condition 5. The second part of Condition 5 per-mits an average concentration, assumed to be weekly, of any specific -
radioisotope to reach five times the value given in Condition 4. The problems of neasurenent listed in the ccmnents in Cbnriition 4 also pertain to Condition 5.
- 6. This candition limits the gross beta-ga: Inn activity of the gaseous, effluent to an annual average of 0.01 curies per second. The radio-activity in the gaseous effluent is related to the anount of fuel leaks in the reactor core. If the fuel performs in an unrealistically ideal nunner, it is conceivable that the limit of 0.01 curies per second might be net by the plant as presently designed, but the prob-ability of this circarstance occurring over a long-term basis is so small that this condition in the PCA permit allows no operating mar-gin in the event' that fuel performance is less than ideal. Operat--
ing experience from existing nuclear power plants fortes NSP to the-1
-l conclusion that the mnticello Plant nest likely' could not operate i for any substantial period of time under Candition 6 without being.
forced to shut down for the detection and replacment of-lehdng ]
fuel. Uhese frequent start-ups arus shutdcwns of the reactor would expose operating personnel to additional in plant radiation, would ,
require the handling of additional quantities of radioactive waste, and would degrade the overall safety factors of the plant equignent. -
In an attmpt to umt the extzwely restrictive waste release limi-tation of Condition 6, NSP could install substantial additional gaseous waste treatnmt equipnent, with the corresponding heavy expenditures and construction delays, but even with the installation of this equipment, cmpliance with Condition 6 'could_ not be guaran-teed in a manner which would be consistent with the need for reliable power production from the mnticello Plant.
' 7, This condition lists permissible concentrations of fifteen radio-isotopes to be neasured in the plant gaseous effluent stack before e
release to the atnosphere. -The condition also has an overall limi-tation on other radioisotcpes not listed. It is NSP's position that
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it is impracticable to identify and neasure these isotopes -in the -
stack in the manner required by the PCA permit. The approach of the PCA pennit in establishing an effluent standard in the plant-stack' differs fundamentally from the AEC approach to health and -
1 safety, which establishes limits at off-site -locations, where-the -
public is present. The isotcpic levels indicated e
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in the PCA permit to be measured in the stack are about one million times nere restrictive than the equivalent of AEC requirenants at the site bounduy. Because of the restrictive. levels in the PCA permit, it is probable that the plant wil', be able to operate only, for a limited per od of tire before refuiring shutdmn to search i
for arcl to renove leaking fuel. The installation.of the additional gaseous waste treatnent eqtupam mentioned in the discussicn of Condition 6 would pernit a c',oser approach to the lirrits listx!
in condition 7, but th vcblem of neasurement of the very loa levels of activity specified in the PCA permit would renain.
- 8. 7iis condition nodifies Condition 7 by allowirg a weekly gaseous release rate of 0.05 curies per second. This value corresponds to a nore reasonable long-term release rate based upon expected fuel perfornance, but it is likely that this rate of activity release could prevail for several weeks, rather than for sinply one week..
Under the terms of the PCA pemit, the plant, as presently designed.
and constructed, would have to shut daan frequently for work on the core, with the previously nentioned disadvantages of radiological exposure to the workers, hmdling of additioral wastes, and over-all degradation of plant ufety. The installation of the additional' waste treatment equignent nentionel the discussion of Cbndition 6 could be unde, but the difficulties of neasurenant discussed with Conditions 6 and 'i also apply to Condition 8.
- 9. 'Lhis provisica of the PCA permit establishea a maximum garrus waste
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release rate of 0.30 curies per second for any fifteen-minute period and esuh14ahes a limit on the radioisotopes.given in Condition 7. NSP expects to be able to meet the overall limit of 0.30 curies per second, although such a limit removes most of ,
the operating margin which should be available to the plant oper-ators for short-term energencies. 'Ihe portion of Condition 9 which refers to measurment of stack concentrations of specific isotopes cannot be cmplied with because of the technological difficulties of neasurment nenticned for Conditions 6, 7, and 8.
- 10. Condition 10 requires routine effluent mtnitoring "to identify -
and quantitatively account for all specific radioisotopes that are released in significant quantities". NSP's regular plant operating procedures provide for quantitative identification of ,
radionuclides which have a significant. relationship to public health. Hcuever, the language of the PCA permit, and its reference:
to statementsin the Tsivoglou Peport of January 31,1969,' leave considerable uncertainty as to the amount of; identification which would be required by PCA. It appears that the PCA permit contem-plates identification of the incremental addition by the plant of isotopes in quantities which are so minute as to be unidentifiable-by presently feasible techniques of analysis.-
- 11. 'Ihis condition requires that an env2romental nonitoring program as described in the 'Ibivoglou Report of January 31, 1969 must be
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conducted. NSP has inaugurated such a program, even' though.
nc c authorities who have reviewed the program regard it as un-wan *itedly extensive.
- 12. 'Ihis condition requires that the results of ef fluent neasurenants '
and of the envirormental raonitoring program be reported nonthly to the Pollution Control Agency. 'Ihis provision can be net, al-though custmarily enviromental nord.toring prograns provide for collection of data over a longer pericd of tine, usuauy six nonths or a year, and the submission of this data in a sani-annual or an- - ;
nual report.
- 13. This condition requires cooperation with the Pollution Control Agency and with the Minnesota State Board of Health in the de-velognent of mergancy plans to be follcwed in case of plant ;
accident. NSP's emergency plans contenplate full cooperation _ <
with all Federal, State, and local health and safety agencies, and these plans will beame a part of the AEC operating license for the tbnticello Plant. Condition 13 of the PCA permit is wriiten broadly and refers to language in the Tsivoglou Report of January 31, 1969, which seems to iniicate that State agencies should be allowed to take control of plant operations during emergencies. NSP will cooperaw with State agencies to the naximum practicable extent, but NSP must mnntain full control of plant cperations at all times, including emergency conditions.
- 14. This condition limits the PCA permit to the first year of plant i
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l' operation and provides for changes to the permit' at any tine and -
for annual renwal by the Igency. NSP reccgnizes the desirability of frequent revis of the plant cperatirg data by the Pollution Control Agency. NSP will keep the Agency fully informed of the -
plant operating results. In view of the limited nuclear pwer- -
plant expertise on the staff of the Pollution Control Agency, it appears that the requirement for annual renwal of the operating pemit could introduce serious procedural problem for.both NSP and the Agency. A mre workable provision would be the issmnce of a long-term permit, with prov2.sions that the permit limits be mdified by the Agency if required after a review of actual cper--
ating experience of the waste-treatment equipment.
- 15. 'Ihis condition seems to confizm statementsmade by NSP and by recognized authorities in the field of reactor health and safety- -_
to the effect that the very 1cw levels of radioactive releases per--.
mitted in the PCA permit are considerably more stringent than are required-for health and safety.
AVD/lj-
STATE OF MINNESOTA POLLUTION CONTROL AGENCY-717 DELAWARE STREET S.E.
(OAK AND DELAWARE STREETS S E.)
MINNEAPOLIS. MINNESOTA as440 May 28,1969 Mr. Donald E. Nelson General Counsel Northern States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401
Dear Mr. Nelson:
The application for a waste cisposal permit for the Monticello Nuclear Generating Plant in Wright County which was submitted to the Agency has been approved, and a copy of permit no. 5633 is enclosed.
Please review the permit carefully and let us know if you have any questions concerning it.
Yours very truly, John P. Badelich, PE Executive Director
- JPS/GRK
- bkl Enclosure cc: Mr. Arthur V. Dianhart, Chief Engineer, Northern States Power Company Mr. George Hickler, Chairman, Monticello Township Board Chairmen, County Boarc of Commissioners, c/o Auditor I
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STATE OF MINNESOTA POLLUTION CONTROL AGENCY 717 DELAWARE STREET S E.
(O AK AND DELAWARE STREETS S.E.)
MINNEAPOLIS. MINNE5OTA ss44o WASTE DISPOSAL PERMIT Monticello Nuclear Generating Plant, Northern States Power Company, 7
Monticello Township, Wright County -
Pursuant to authorization by the Minnesota Pollution Control Agency, and in accordance with the provisions of Minnesota Statutes, 1967, Chapters 115 and 116, a permit is hereby granted to Northern States Power Company, Minneapolis, for disposal of waste from a steam electric generating plant being constructed by the company in the west half of Section 33, Township 122 N, Range 25 W, Wright County, including the discharge of effluents, as herein below specified therefrom to the Mississippi River, subject to the conditions given below.
General Conditions
- 1. This permit shall not release the permittee from any liability or obligation imposed by Minnesota statutes or local ordinences and shall remain in force suoject to all conditions and limitations now or hereaf ter imposed by law. The permit shall be permissive only and shall not be construed as l estopping or limiting any claims against the permittee for demage or injury to person or property, or any waters of the state, resulting from any acts, operations, or omiasione of the permittro, its agents, contractors or assigns,.
nor as esttoping or limiting any legal claim of the state against the per-mittee, its egents, contractors or assigns, for damage to state property, !
cr for any violation of subsequent regulations or condition:. of - this permit.
- 2. No assignment of this permit shall be effective until it is executed in writing and signed by the parties thereto and thereafter approved by-the Agency.
- 3. No major alterations or additions to the disposal system shall be made without the written consent of the Agency.
4 The use of the disposal system shall be limited to the treatment or discosal of the waste meterials or substances described in the permit application dated July 11, 1967, and associated material filed with the Agency.
l
.-__-_--_--_-_-_-_____-_.______L-_____________----_-___-__._--__-_-_-___-____-_-----
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- 5. The permit is subject to modification or revocation, and may be suspended ~et_any time for failure _to comply with the terms-stated-herein or the provisions of any _ other applicable regulations or standards of;the-Agency or its predecessors, and'is-issued with the understanding that it >
does not estop subsequent setablishment of further requirements for treet-ment cn control at any-timeLby insertion of appropriate moditional clauses
- herein at the discretion of the Agency in order to prevent or~ reduce.possible ,
pollution of the' environment.
- 6. The permittee or assigns shell defeno, indemnify and hold harmless 1 the State of Minnesota, its officers, agents end employees, officially or personally, against any end all actions, claims or demands whatsoever which' may arise from or on account of the issuence of this pennit, or the construction- ,
or maintenance of any facilities hereunder.
- 7. Certification- of completion of the project shall be made immediately af ter construction is finished, reports on effluent quality and operational' practices shell be submitted regularly every month, and the permit holder 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 Permits in? Sewage and Inountrial Weste Treatment Works."
Scecial Conditions Relatino to Conventional Westen
- 1. No raw sewage or treated sewage effluent shall be discharged to surface waters of the state from the plant site.
~
- 2. Any additional construction plans and design cata which may be recuirso for all cisposal systems needed for. collection, treatment end dis posal of sewage, industrial westes ano other westes originating at this -site, and for effective centainment of stored liquido or other pollutional meteriale, for the prevemion of unter pollution to conform with the requirements of this permit, shall be submitted together_ with any other information requested for review by the Agency. All such plans shall meet wim the approvel 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 affluent of the holding pano shall not be excesced at the point of discharge from the pond:
pH value 6.5 - 8.5 Turdidity value 25 5-day bioenemical oxygen demand 25 milligrams / liter Total suspenoec solids 30 milligrams / liter t
+ = = ~~ --
--.'6 ,, r +,-..w y w e --i
3' 4.. Cooling f acilitise shell be provided and operated- to insure that the-heat content of the cooling water ef ter reasonable dilution and mixing in: the river does not raise the temperature of the river above .the limite specified below:
Period Maxinn;m Temperature-July and August, inclusive _ 86*F (or 5'F above the June and September, inclusive 80*F embient temperature May and -Octobes , inclusive 67'F of the river, which-April and Novemoer, inclusive 55'F ever is greater,:ex-March and December, inclusive 43'F capt thet-in no case 37'F
~
January and February, inclusive shall the river tem-parature be_reiend above 90*F by the dis-charge of this affluent.)J The design of treatment works for complience with the stream standards, unless otherwise specified, shall be based on the seven consecutive day low:
flow of the river which is equal to or exceeded by 90% of such seven-day minimum average flows-of record (the lowest 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 the Agency et a later date after reviewing the date made available on the characteristics of thel 1 river and the effluent and other pertinent considerations.
- 5. No industrial waste, or other wastes, treated or untreated, shell-be discharged into the waters so as to cause any nuisance conditions, including, without limitation, the presence of substantial amounts of floating solids, scum, oil, suspended solids, discoloration, obnoxious odors, sludge deposite, slimes, or fungus growths, or other cffensive effects; or.so es to cause any material increase in any other chemical constituents; or cause any substantial change in any characteristics uhich 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 qual 2y of the waters for any other uses.
- 6. The company shell measure the-quantity end characteristice-of and-semple _ and analyze the industrial wastes, other wastes and stored liquids at-the site as may be requested by the Agency, and shall provide the Agency every month with a complete report on such measurements, samples and analysee, to-gather.with any other information relating to weste disposal or pollution control which may be requested.
- 7. . Facilities for monitoring the-quality of the receiving waters shall be provided and used as requested by the Agency. Results of the monitoring shsll be reported to the Agency at monthly intervals.
- 8. The company shall cause to be maos without cost to the state, tech-nical studies and investigations of the biota and quality and related matters pertaining to the waters of the state which receive-the plant effluents, or l
which are in the immediate vicinity of the plant,-as may-be requested by the-L Agency. Complete reports shell be submitted annually, or more frequently upon l- request.
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- 9. Continuous operation of all of the treatment worke et their maximum capability consistent uith practical limitatione and maintenance needs of such works shall be maintained at all times when the plant is in operation und Wien-necessary to provide adequate treatment of the sewage, industrial westee _ or other westes by the terms of this permit.
- 10. The company shall expeditiously make any changes in weste disposel-monitoring, and reporting practices, and nrovide any additionel- treatment works or disposal systems or other safeguards for the prevention of pollution of the environment upon the request of the Agency.
- 11. Liquid substances which could constitute e source of pollution of the waters of the etnte shall be stored in accordance with regulaticn WPC 4 Other westes es defined by Minnesota statutes, section 115.01, subdivision 4, E shall not be deposited in any menner such that the same may be likely to gain entry into these waters. In any cess where such subetences, either liquid or solid, as a result of accident or natural ceteatrophe should gain entry into any waters of the state, it shall be the responsibility and duty of the company to inf orm the Agency in the quickest time possible and immediately remove and recover all such pollutional substances to the fullent extent reasonably possible under existing conditions.
- 12. The industrial or other weste effluente es discharged shall comply with any and all applicable recuirements of ef fluent etendards or river classifications and stenderds which may be adopted by the Agency for this type of source and/or for these waters in the future.
Scecial Conditions Relati.7o to Recioactive Westes
- 1. It is the policy of the p gency that all radioactive pollution of the environment shall be held to the lowest level that is attainable within the limitations imposed by technological feasibility and economic reasoneble-nese. In no case shall members of the public be exposed to radiation beyond -
the limits recommended by the_ International Commission on Radiological Pro-taction. In addition, the actuel levels of redistion exposure of members of the public shall be kept as f er below those limits es possible, consistent with technologicd feasibility and reasonableness of cost.
- 2. In keeping with the ecove 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 preventing the release of radioactivity to the environment. Such measures snell include et least, but not-be limited to:
(e) ell measures for_the treatment, control and containment of liquid end gaseous radioactive effluents that are indicated in the Final Safety Analysis Report of the _ Northern States Power Company, Unit 1, Monticello nuclear generating plant; and
5 .
(b) routine removal of radioicdine and halogens from the gaseous effluents to the full extent feasible, the degree of treatment and removal being at least the equivalent of that pro-vided by effective activated charcoal filtration of the entire air ejector offges flow; and (c) routine ion exchange treatment (Powdex deminarelization or equivalent) of the combined Icw purity westes (primarily from floor drains) and the neutralized chemical westes (primarily from laboratory dreine end shop decontemination solution dreins). The combined estimated flow is 8,000 gel / day; and (d) initial inspection of fuel rods for surface contamine-tion with uranium before use in the reactor, and decontamination or replbCement of furl rods that have detectable or significant amounts of uranium on their external surfaces, so es to prevent the use of such fuel rods in the reactor. The plant operator shall report in detail to the Agency the measures taken in this regard before startup of the reactor; and (e) initial thorough inspecition of fuel rods to identify those that might develop fission product leeks, and rejection of such rods for use in the reactor; to the full extent possible, development and application of methods and techniques for lousting and identifying leeking fuel rods after operation of the reactor begins, so that such rods may be removed during usual fuel replace-ment operations or, et other times, to prevent excessive release of radioactivity to the environment. The operator shall report in detail to the Agency the actual measures taken in both of these regards before startup of the reactor. If necessary, he shall initiate research er.d development activitien designed to develop the neeced effective procedures.
- 3. The gross beta-gamme radioectivity of licuid effluents ruleseed to the plant discharge canal shall be limited to the extent that the annual ever-age gross beta-gamme radioactivity concentration of the water in the discharge canal shell not exceed 10-7 pc/ml (100 oc/1) plus the background radioactivity.
4 As en integral part of Special Conditions 3 above, the concentrations-of specific radioisotopes in the discharge canal shall not exceed, on en ennual everage basis, the following limits:
Averece Oeilv Concentretions, pe/ml' Radioisotope Normal Low River Flow River Flow (1) (2) (3)
~
H-3 2 x 10~0 4 x 10
-1 -11 F-18 8 x 10 1 x 10
~ ~
Ne-24 2 x 10 3 x 10
. - - -, - - , .~ - , .- - -,. - . . -
. 6 Avereae Osilv' Concentration, uc/ml-Radioisotope = Normal el gg, N River Flow
~~~~
River Flow (1) (2) (3)-
9 x 10~l3 4
Cr-51 - 1 x-10-11 g x'10~11 Mn-56 5 x'10-12 Co-58 9 x'10-12 g x 10-10 9 x 10-13 - 1 x 10-11 a Co-60 Sr-90 4 x 10~13 8 x 10-12 Sr-91 2 x 10-11 4 x 10-10 Sr-92 4 x 10-12 8 x 10-11 Tc-99, Mo-99 1 x-10-10 4 x 10~9 I-131 4 x 10-11 8 x 10-10 I-133 2 x 10-10 4 x 10~9- ,
I-135 6 x 10-11 1:x 10-9 Te-132 6 x 10-I3- 1 x 10 Cs-136 6 x 10~1' ' l'x 10-12 Cs-137 2 x 10~13 4 x 10 ~1 Ba-139 4 x 10 - 6 x 10~12 8e-140 4 x 10-12 " 6'x 10-11 (a) Open cycle - 93 percent of-days; no-use of-cooling towers;. discharge canal floa 645 cfs.
(b) Closed cyrle - 7 percent of. days; full use'of-coeling. towers,.: discharge can el flow 36 cfs.
In addition to the specific radioisotop concentration limits given in the above table, end on en: interim basis until~ plant-. operation provides more
- definite _ information, the. everage daily discharge _ canal noncentration ofE.any other radioisotope.shall not exceed one three.. thousandth (1/3,000)'of-the specific ICRP limit for continuous occupational exposurefor.cne:three-hundredth
~
(1/300) of'the numerical' limit For that radioisotoon as specified-in Appendix.
B, Table II, Title 10, Part 20 of the-USAEC Standards.for Protection.Against" Radiation. In case these two limits differ for any specific radioisotope, the
' ~
- lower limit shall apply. ,
T,i < w y , w ira y ,.%.v* r t- -= ,s. ~.- ~ --.-g +g + yye ,p,'. e - , - g y 4, t-,-yri
t 9
4
- 5. In addition to all of the foregoing liquid arriuent radioactivity concentration limits, for any seven conoscutive day period the everage grose bets-gamme radioactivity, concentration of the water in the discharge canal shall not exceed 5 x 10" pc/ml (500 pc/1) plus the background radioactivity, and the everage concentration of any soecific t edioisotope in the discharge canal shell not exceed a limit of five times the value given in the above table.
- 6. The grose beta-gemme radioactivity of the geneous affluent released vie the plant stock shall not exceed, on en annual everage basis, e release rate of 0.01 curie per second. This refers to a total stock air flow of 4,000 cfm, and thereby eleo specifice the limiting concentration of grose bete-gemme radioactivity in the eteck effluent before dilution in the atmosphere.
- 7. As en integral part of Special Condition 6 above, the concentrations of soecific radioisotopes in the eteck before release to the atmosphere shall ,
not exceed, or en annual everage basis, the following limits:
Raciaisotoon Stock Concentration (8} '
pc/ml H-3 4 x 10-9 Ar-41 3 x 10-6 Kr-83m 1 x 10~'
Kr-85m 3 x 10-4 Mr-85 2 x 10-7 Kr-87 1 x 10~3 Mr-88 1 x 10-3 Mr-89 2 x 10~$
Xe-131m 1 x 10-6 Xe-133m 1 x 10-5 Xe-133 3 x 10~'
Xe-135m 4 x 10~'
Xe-135 6 x 10
Xe-137 5 x 10-5 Xe-138 -2 x 10~3 (e) At a total stock air flow of 4,000 cfm.-
_ _ _ _ _ _. . . . _ ._._-_-.__..a._...._ _ _ _ _ . . . . _ _ . . . _ _ _ _ . . - _ . . . - , . _ , , ,
I 8
In addition to the specific radioisotope limite given in the table ,
immediately above, and-on en interim basis until plant operation provides i more definite information, the everage daily stock concentration of any
- other radioisotope before relsses to the atmosphere shall not exceed 10 times the specific ICRP limit for continuous occupational exposure, or 100 ;
times the numerieel limit for that~ radiotectope os specified in Appendix 8, '
Table 11, Title 10, Part R20, of the USACC Standards for Protection Against Radiation.
- 8. In addition to all of the foregoing gaseous (stack) effluent con-centration limits, the gross beta-gemma radioactivity of the gaseous effluent released via the plant etack shall not exceed a release rate of D.05 curie per second for any seven consecutive day period. During-such a period, the st ack concentrations of specific radioisotopes shall not exceed five times the numerical limits given in Special Condition 7.
A stack release rate of 0.05 curie per second shall automatically sound ,
a plant alarm to warn the plant coerator that the weekly release rate limit !
has been reached.
- 9. In addition to all of the foregoing geneoue (stack) effluent con- l centration limits, the gross deta-gamma radioactivity of the gaseous effluent releaseo 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- i centrations of soecific radioisotopes shall not exceed 30 times the numerical limits given in Special 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 'instantaneoua' release rate limit has been reached. Af ter a 15-minute delny, the air ejector offgass isolation valve shall automatically close, shutting dow the reactor, ,
if the radioactivity release rate has not been successfully reduced to the weekly 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 L the Northern States' Power Company shall be 01eigned to identify and Quantitatively account for ,
all specific radioisotcpt1 that are released in significant quantities. This effluent monitoring program shall provide for and include at least the kinds of ,
samples, frequencies, radioasesy procedures, etc., described in the MPCA Final !
Report entitled Radioactive Pollution Control in Minnesota, and dated January 31, 1969 (see especially pp. 139-143). ;
- 11. During the first year of operation of the nuclear generating plant at Monticello, the routine environmental radiological monitoring and sur-veillance program of_the Northern States Power Company shall be designed to detect and evaluate all significant radioactive releases from the plant.
This environmental monitoring program'shall provide'for and include at least t
the kinds of samples, frequencies, radionssay proceduras, etc., described-in the NPCA Final Report on Radioactive Pollution Control in Minnesota, dated .
January 31, 1969 (see especially Table IV, pp. 135 and-136, and the section included in pp. 114-139).
- - = - - - . - - - . - _ _ . - -.-...a-,.~,,-.-.--.---,-,.w
l l
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- 12. All effluent and environmental monitoring program resulta shall be i reported monthly by the Northern States Power Compsny to the Agency. All monitoring program resulte shall also be eveilable for inspection by the Agency at the plant site et any time. '
- 13. The Northern States Power Company shall cooperate to the full extent necessary with the MPCA and with the Minnesota State Board of_ Health (MS8H) for purposes of development by those egencies of en adequate and effecitve emergency protection plan designed to immediately control and ;
minimize the effects of any accidental release of unexpectedly large quanities of radioactivity from the Monticello nuclear generating plant. In particular, the Northern States Power Company shell immediately notify both the MPCA and the MSBH of eny uncontrolled release of unexoectedly large Quentitise of radioactivity to the offsite air end/or water environment due to operational failure of any of the power plant systems. Also, the Northern States Power Company shall cooperate in this regard to the full extent outlined in the MPCA Final Report on Radioactive Pollution Control in Minnecote (see pp. 90-97), and in any other menner requested by the MSOH.
14 The "Special Conditions Relating to Radioactive Westes" part of this permit is limited to the first year of operation of the Monticello nuclear generating pl ant. During this perico that part of the permit may be modified by the Agency in- any menner and to any extent deemed necessary by the Agency.
A new permit relative to radioactive westes, 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 be iseued by the Agency for the second year of operation.
- 15. It is emphesized that public and environmental radiation protection crectice is based upon a conceot of very long term protection, rather then only immediate or momentary protection. The generally accepted I.C.R.P. limits are designed to restrict radiation exposure, on a continuous beste and over a lifetime, to levels that will not produce detectable or significant sonstic or genetic harm. The annual everage release rate limits contained in this Permit also refer to continuous lifetime-rediation exposure, rather then-to momentary levels, and era considerably more stringent then could be permitted according to the 1.R.C.P. recommendations. Hence, the slight transitory (E.G., daily) variations around these limits that are to be normally expected should not . result in overexposure to radiation of any member of the public, and snould therefore not be viewed Be cause for great eierm or for hasty and unreasoned action. I Jonn F. Beoelicn, FE l Executive Secretcry and Chief Executive-Officer Permit No. 5633 Dateo May 20, 1969