ML20128C660

Expresses Concern W/All Radwaste Matls Used & Disposed of in State of Mn

ML20128C660
Person / Time
Site:	Monticello
Issue date:	11/02/1970
From:	Badalich J MINNESOTA, STATE OF
To:	Seaborg G US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20128C652	List: ML20128C649 ML20128C660
References
NUDOCS 9212040501
Download: ML20128C660 (12)

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[idh!I5$.s., STATE OF MINNESOTA "" ";,"^1'/,D/g' -

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• MINNEAPOLIS 55440 consnY..c.7tuvtsoN.

• 6 e ua sia .37s.t sao November 2, 1970 Dr. Glenn T. Seaborg, Chairman United States Atomic Energy Commission 20545 Washington, D.C.

Dear Mr. Seaborg The Minnesota Pollution Control Agency, as you are -aware .

of, is concerned and rightfully so, with all radioactive materials used and disposed of in the State of Minnesota.

At a recent meeting of the Agency , (Attachment No. 1)

Mr. Steve J. Gadler of the Agency Board, reported on 0-statement made by counsel for the Atomic Energy Com-mission at the Atomic Safety and Licensing Board hearing held in St. Paul, Minnesota on the operational permit for the Northern States Power Company's Monticello Nuclear Generating Plant, that no radioactive wastes were buried in the State of Minnesota.

Mr. Gadler also requested the staf f to investigate and report on - this- as we are aware of the f act that the 3M Company of St. Paul, Minnesota is disposing of spent radioactive materials in rural Pine County, Minnesota' under a permit granted to the 3M Company by the .former Water Pollution Control Commission, s

The 3M Company was requerited to file a report, (Attach-ment No. 2) on the status of this burial and such _ a report was made to tne Agency under date of September 9, 1970, ,,

copy enclosed, (Attachment No. 3) and at the September meeting of the Agency, this report was filed with' the .

Agency , members f or their review and comment.

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, 4 Dr. Glenn T. Seaborg 11ovember 2, 1970 Page 2 At the October 5, 1970, meeting of the Agency, this matter was further discussed and I was instructed to bring this to the attention of the AEC in light of the statement made here by counsel to the Atomic Safety and Liconsing Board. Attachment t{o. 4 indicates the Agency 's position with respect to this as well as _ requiring an explanation f rom the AEC as to the conflicting statement and requesting that further action be taken by the AEC -

in preventing any further burial of radioactive wastes in the State of Minnesota.

Your earlien t attention - to this matter is greatly ap-preciated.

Yours very truly ,

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! John P. Badalich, P.E.

Executive Director JPB/ee Attachments

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- ' The following < corp'ts cro from 'the of fi . 31 minut0c of the August 10, 1970, Agoney meeting.

• 3TTACHMBNT NO. 1 Sewer Extensions (Continued) -

, Chanhassen (6,573) Burnsville (6574) Roseville (6575) North St. Paul (6576)

Mr. Luick moved and Mr. Fellows seconded the motion to approve these sewer extensions. Motion prevailed.

Stipulations Minnesota Power and Light Company, Aurora, Duluth and Cohasset Plants After a presentation from Mr. Lindall, Mr. Tuveson moved and Mr. Packard seconded the motion to approve this stipulation. Following discussion, the motion was carried unanimoosly.

Scanlon ,

Following a report from Mr. Lindall and discussion from the members, Mr. Tuveson moved and Mr. Gadler seconded the motion to give Scanlon an additional sixty days (60) for them to make a decision on all of the interim dates of the compliance schedule except for award of a contract for independent works for which an additional thirty dnys (30) is granted with the final completion date to remain the same. Motion carried.

Madison Lake Following a report from Mr. Lindall, Mr. Luick moved and Mr. Fellows seconded the motion to approve this stipulation. Motion carried unani-mously.

Meeting recessed until 1:30 p.m. for lunch. ,

Burial of Radioactive Wastes - Pine County Mr Gadler then requested the Agency staff to check out the burial of radioactive wastes in 1966 under pernit granted to 3M by the Water Pollution Control Commission. These wastes are near Askov in Pine County, Mr. Gadler reported that the AEC stated at the Atomic Safety and Licensing -Board hearings that no radioactive waste is buried in i Minnesota and none will be. Thus, he is making inquiries i n to the situation in Pine County and is requesting removal of any-radioactive was tes the re .

INFORMATIONAL ITEMS ,

Mr. Dadalich. announced that Dr. Andersen, Mr. Tuveson and hc would be attending the second session of the Federal-State Enforcement Conference on Lake Superior in Duluth, Minnesota on August 12-13, 1970, as conferees.

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August 27, 1970 Dr. Joe T. Ling

• Manager Wager and Sanitary Engineering Department 900 Bush Avenue St. Paul, Minnesota '

Dear Dr. Ling:

At the regular meeting of the Agency on August 10, 1970, the matter of the burial of radioactive unstes '

was brought forth by Mr. Steve J. Gadler of the Agency.

Mr. Gadler made reference to the burial of certain radioactive material that was undertak,en by the 3M Company near Askov, in Pine County in 1966.

The of ficial minutes of the Agency states th'c folloaing: .

l "Mr. Gadler then requested the Agency staf f to check out the burial of radioactive wastes in 19GG under permit granted to 3M Company by the Water Pollution Control Commission. These unstes are near Ashov in Pine County, Mr. Gadler reported that the AEC s tated at the Atomic Safety and Licensing Board hearings that no radioactive veste is buried in '

s Minnesota and none vill be. Thus, he is making in-quiries into the situation in Pine County and is re-questing removal of any radioactive unstes there."

As a follou-up to this action, I believe Mr. George ,

Koonce or Mr, Mike Lutz of the Agency's Industrial Waste Section of the Division of Water Quality con-tacted you regarding this matter.

I believe it incumbent upon your company to provide the Agency with an inventory of the waste burial and a memorandum on radioactivity levals in the area at-tributahic to this burial and alno other acti.vitics relating to this matter f rom the initial date, 1966, to the prenant.

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August 27, 1970

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I would appreciate receiving this report prior to the September 14, 1970, meeting of the Agency.

Your cooperation in this matter is greatly copreciated.

'Youra Vory truly ,,

y lkl*, V Y b J$hn P. Dadalich , P.E.

Executive Director

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September 9, 1970 f'\ SEP 101970

. f.'.l:T,!. POL 8.' TC:1 '

CONTROL AGEKY

'. Subject : Pine County .

Waste Disposal Area Kerrick, Minnesota WPC Permit 5227 ~

. l Mr. John Badalich, P. E.

Executive Director State of. Minnesota "

g Pollution Control Agency 717 Delaware Street, S. E.

• Minneapolis, Minnesota 55440

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Dear Mr. Badalich:

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I am enclosing a report on the use of our waste disposal area in Pine County, Minnesota, as requested in your letter of August 27, 1970. The present use of our disposal site is on an emergency bacis only.

If there are any questions which you may have, please

. contact me. Please keep us posted on the outcome of any action which the Agency takes on the report.

Your very truly, .

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Environmental Engineering and Pollution Control ,

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In June 1965 the 3M Company started investigation of potential sites in .,

*. '.,Hinnesota which would be suitable for waste disposal. The requirements ..

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• for the disposal site were proper geological conditions -(an impermeable i soil underlain by rock) accessibility by truck transport and isolation  !

from any population center. Initially. the site investigations were discussed.

with the Minnesota Water pollution Control Commission; (MWpCC) . After '

several potential sites were located personnel from the MWpCC reviewed l

. the ' sites in the field with 3M Engineering personnel. ,

Five hundred twenty acres of land in Section 34, Township 45 North, Range 17 West, pine County, Minnesota was selected as the site meeting the qualifi- -

. cations. This also was the site which roccived tht: best evaluation from the MWpCC in a letter dated August 11, 1965 signed by L. H. Smith. Another' . ,

letter from the FMpCC dated December 27, 1965 app' roved in principle- the

, type of facility which 3M proposed. On the olv.>ve hasis 3M prepared final

• plans and specifications which were submitted to the tMpCC on September' 8, .

1966. Approval of the plans were received at a FMpCC meeting held on October 6, 1966. 3M was notified of this action by a letter dated October 10, 1966. - -

The disposal area consists of a diked arca lined wit.h a clay bottom and, side slopes, the dimensions were approximately 150' .x 250' . The depth of the diked area is 8 feet. There is no overflow from this. diked area.

The diked area is graded so that storm runoff wa.ter is diverted from the ]

diked area. The diked area is accessible by a road and the arca is fenced with barbed wire fence." The existing farm type fences around the perimeter a of our property has been improved and No Treaspassing signs have been placed around the property. ,

Permit Conditions of WPC S5227 -

The permit required that there be no discharge of-'any type from or within,

'the diked area. 'It also provided that the facility be operated without ,

the development of a nusiance in the area.. A paragraph about radioactive

. materials was included. It indicated that the disposal of radioactive -

• wastes at- this site is not prohibitcd. if done in conformance with U. S.

Atomic Energy Commission requirements. . ,

3M Use of Disposal. Si_te,

g The following list is a chronological 'listiMg of the events that have

-taken place at the site. ,

-(1). December 7,196.6 - Approximately 220 - 55 galloin drums of radioactive material was buried in accordance with A.E.C. cogulations. Radioact'ive

- wastes consisted of material, equipment and carbon bed material ._

contaminated with natural uranium and thorium. T

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natural . uranium and thorium oxide buried at thLs pe timetotal -

amount--of -

was'10-pounds _

and 30. po0nds respectively. _ The total activity-of radioactive materials in the burial was 4.83 millicuries, well below 1the 50 millicurie limitation. -

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'(2) Letter to MWPCC dune 21, 1967 advising them of change in 'our original holding area size. The size was reduced by 200 feet.

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Construction of access road and diked area for liquid wastes was s' tarted in July 1967. -

'(4) ' July 18 and 20,1967 - Burial of the 2nd load of radioactive material.

. Radioactive wastes disposed of_ consisted of material, equipment, and 7 piping contaminated with uranium. The total amount of enriched

. uranium disposed on above dates was 508.3 grams. The activity at this burial was 35.6 millicudes again below the 50 ' millicuries 1evel for an individual b.urial. .

(5) On August 18, 1967 78 - 55 gallon drums consisting of non-radioactive liquid and solid wastes, were placed into the diked area. -

(6) Novcmber 27, 1968 - The burial of the 3rd load of radiouetive materfuls.

P.is consited of contaminated containers and equipment such as returnabit. Oxygen ey]Inders, electric motors, tools, piping and ventilation ductst The total amount of enriched uranium in thJs burial was 50 grams. The total activity of the radioactive mutcr?al in this burial was 3.5 millieurits again well below the 50 milli-curic limitation. . .

(7) November 24, 1969 76 - 55 gallon drums of rion-rtsdiometive liquid and solid material were disposcd of in the diked area. ,

s A.P.C. Renulations on Radioactive Disposal -

3M discusse'd the disposal of radioactive materlal with the Minnesota Board of !!calth, personnel were aware of our intentions to dispose of radio- '

active material a t our site. It is our understanding that thc MWPCC could not give formal approval since the State of Minnesota at that time did not ~

have regulations covering the disposal of radioactive material. .

The 3M' Company huu a permit to work with radioactive materials (A.U.C.

Special Nuclcar Materials License S.W764 and Source Materiels License

.SMB-239) . In accordanec with this license the disposal of radioactive materials is outlined in Title'.10 part 20, paragraph 20.304 Code of g Federal Regulations.

The A.E.C. regula tions spell out the following requirements for low activity ~

radioactive materials. *

'(1) Maximum activity per burial limited to 50 millieuries for uraniuni and thoriuta. .

Successive burials be separated by horizontal, distance of G feet.

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(3) A minimum cover of ti feet of earth over the burial alea.

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(4) Not more than 12 burials can be made in any one year.

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• The use of the disposal site for radioactive wastes has been on intermitent

- basis and in accordance with A.1;. C.

• regulations. The total activity of radioactive materials buried on our sito was 43.93 n.i(11 curies. If all of the radioactive ma+rr.al buried at the 3M disposal site was concentrated in a bingle point source,the dose rate would be 25 milliroentgens at a dista_nce of one foot. In view of the fact that the point source is covered with 4 feet (minimum) of earth the radiation cmitting from a point' source would not be discernable above existing natural background radiation. ..

.There is, therefore, no radiation hazard to human or wildlife standing directly over the burial sites. -

i The use of the disposal site for liquid and solid wastes has always been on an intermittent basis. The future use of the site is based on emergency '

basis. - -

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,, 4 _ , ATTFHMENT No. 4 ,

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. 3 ,' j Tho following excorpto cro from tho official minutco

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'of the October 5, 1970, Agency meeting.  ; ,

sawer Extensions ,

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. Tyler (6631) Worthington (6633) Goodview (6634) Freeport (6635) 'Way zata i cnd Minnetonka (6136) Metropolitan Sewer Board, Anoka, Hennepin, Ramsey l cnd Washington Counties (6638) Pelican Rapids (6640) l I

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Mr. Tuveson moved to approve the above-permits and Mr. Harris seconded  !

the motion. Motion prevailed.

INFORMATIONAL ITEMS Mr. Badalich reported, on the Lake Superior Enforcement Conference held on August 12th and 13th in Duluth. One of the conclusions reached at the conference was that the Reserve Mining Company at Silver Bay, Minnesota and other waste sources in Minnesota are af fecting the health and welf are of people in other states and, therefore , constitute's interstate pol-lution. It was also stated at the conference that Minnesota should be commended on their water pollution abatement program, enforcement and legal actions taken. The technical committe on Water Quality standards were'also commended for their work in developing criteria for standards on the open waters of Lake Superior and it was recommended 01at each state hold public hearings in six months to develop standards for the open waters of Lake Superior. Also, that Reserve Mining Company submit a report to the conferees and the PCA by December 1, 1970, specifying treatment and -

alternate disposal methods for their tailings that could be utilized to meet state and federal standards and that Reserve Mining Company submit plans and specifications to the conferees and the PCA for construction to meet federal-state standards by September 1,1971. The dates that Reserve Mining Company must award contracts and complete construction will be determined by the conferees at the next session of th'e conference. ,

Following Mr. Badalich's report on Lake Superior and discussion from the members , Mr. Tuvoson moved that the adoption of the standards for the open waters of Lake Superior be deferred until such time as the staff and the. Federal Water Quality Administration define the need more fully and that the Department of the Interior indicates what the recommendations will be for Wisconsin and Michigan. Mr. Harris seconded the motion and

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following additional discussion, the motion was carried with Mr. Gadler voting negatively and Mr. Luick abstaining, g The meeting recessed for lunch at 12:30 p.m.

MINUTES OF THE PREVIOUS MEETING Mr. Luick moved to approve the minutes of the September 14, 1970, Agency meeting. Mr. Harris offered the second and the. motion was carried gs. unanimously.

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INFORMATIONAL ITEMS

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Review of Waste Disposal Permits for Pine County _

Mr. Badalich advised that. memorandums relative to the disposal of radio-active material by the 3M Company and spent caustic material by North-western Refinery Company were submitted to the Agency at the last meeting.

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~' The following excerpts are from the of ficial minu.tes .

of the October 5, 1970, Agency meeting. .

Mr. Gadler mentioned that a statement had been made by the Atomic Energy Commission that no radioactive wastes had been deposited in Minnesota cnd, in his opinion, they were perjuring themselves. He felt that the MPCA should take some action compelling the AEC to prevent the dumping '

of radioactive wastes anywhere in the State of Minnesota. It was the j consensus that this should be called to the attention of the AEC.

SOLID WAS?E Hr. Tuveson then referred to Mr. Forsberg's report regarding disposable containers. Af ter discussion, Mr. Tuves'on moved that the Agency should adopt the policy and support the concept of recycling of wastes as proposed by the Minneapolis City Council and support the sale of returnable containers if necessary. Mrs. Nelson sec,onded the motion and it was carried unanimously.

' WATER QUALITY Su_mmary of Hearing and Findings of Fact on Regulation WPC-25 and 32.

Mr. Dadalich advised that the staff is preparing the findings of fact, and conclusions relative to there regulations and that the comments had been sont to the menbers by persons who had of fered testimony. ,

Aerated Pond Study h Mr. Badalich stated that this study and report has been completed bh' the consultant and that this is a good method of waste treatment.. He also advised that from the evaluation the consultant has made of the ones existing in Minnesota, it appears that this method of waste treatment will be used more extensively in the future. I LEGAL ACTIONS _

Mr. Robert Lindall gave a report on the current status of the litigation involving the Mengelkock Company in New Brighton. Following discussion, and a presentation from Mr. Wiik, Mr. Luick moved that the staf f initiate legal action against the Chicago North Western Railway at Hutchinson, g Gordon Rendering Company in New Brighton and the Minneapolis Hide and Tallow Company also of New Brighton, Minnesota. Mr. Harris seconded the motion and it was carried unanimously.

WATER OUALITY ,

Alexandria Irrigation Project

- Mr. John McQuire reported on this project. He stated that this is a waste q treatment project utilizing a spray irrigation system and that Alexandria is seeking federal funds to undertake this as a research and demonstration project. Following his presentation and discussion by the members, Mr.

Luick moved to endorse the grant application f or Alexandria for this spray irrigation project with the stipulation that if the project f ails, the City of Alexandria must meet Agency standards for treatment f acilities.

tir. Packard seconded the motion and it was carried. .

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