proposed Northern States Power plant "is subject to dispute among reputable scientists" regarding human health and genetics. "The state can ill afford to add one more source of contamination to waters already laden with pollutants," Mondale wrote, "especially one detectable only with instruments; impossible to remove from the water and whose possible ill effects will fall only on children and future generations." Mondale said he understands that a closed cycle system of recirculating cooling water with offsite disposal of contaminated water is technically feasible. He urged the PCA to set zero tolerance levels on radioactive discharges into the Mississippi. MINNESOTA ENVIRONMENTAL CONTROL CITIZENS ASSOCIATION, Governor HAROLD LEVANDER, Saint Paul, Minn. St. Paul, Minn., June 14, 1969. DEAR GOVERNOR LEVANDER: At the May hearing of the Minnesota Pollution Agency, the Waste Disposal Permit to discharge radioactive waste and heat into the Mississippi River and air at Monticello was approved. One member of the Agency felt that too many questions about the proposed plant remained unanswered for the permit to be passed at this time. We agree. We have further studied this Waste Disposal Permit. It has been examined by independent scientists and lawyers. We have found that instead of being the stringent document the public has been told it is, inconsistencies, undefined generalities, and serious omissions make it so loose that standards may be impossible to enforce or even to interpret. Inconsistencies concerned with radioactive waste disposal (see Appendix) can be cited. Paragraph 3, page 4, which is equal to United States Atomic Energy Commission standards, allows 100 times more radioactive waste to be discharged into the river than paragraph 4, page 4. If the more stringent paragraph applies, and if there is no intent to discharge the higher amount of radiation into the water, the more liberal standard serves no purpose in this permit. To further add confusion, paragraph 5, page 7 allows radioactive release into the river in any one week to be ten times greater than the entire yearly release allowance. Similar problems can be found in the limits set for radioactive waste discharge into the atmosphere. In three different levels of discharge allowed, we have found even the most stringent limit to be of an alarming magnitude. We are convinced it represents an immediate hazard to the people living in the vicinity. It is not, however, the scope or intent of this letter to get into such a discussion. Rather the concern here is with the effectiveness of this permit in setting discharge limits. Biologically harmful radioactive iodine has been omitted from the control list of radioisotopes (paragraph 7, page 7). Discharge of this hazardous radioactive element is essentially uncontrolled or left to the vague wording "routine removal . . . to the full extent feasible" (paragraph 2-b, page 5). Undefined generalities and omissions are major problems in the permit. Throughout the permit, discharge rates are qualified by such phrases as "within the limitations imposed by technological feasibility and economic reasonableness" (paragraph 1, page 4). Nowhere are such terms or phrases defined. They do not constitute definite discharge rates and have no place in a document that sets such limits. Definitions are left to the discretion of the plant owner. In other words, Northern States Power Company is writing its own standards. The serious problem of thermal pollution is evaded completely in the Monticello permit. While temperature levels of water discharges are indicated, they are meaningless because the point where temperature is measured is undefined and may be as far south as New Orleans. Where an exact mixing zone definition should be stated, the Permit uses the vague phrase, "reasonable dilution and mixing." Critical thermal factors such as rate of temperature change and avoidance of a thermal barrier across the entire width of the River have been overlooked in this permit. No limits, either, have been placed on the amount of chemical pollutants (used in softening water and cleaning turbines) that are allowed to be dumped into the river. A document like this, purporting to set limits, should be clear, concise, and completely self contained. This document makes reference to volumes of material, much of it prepared by Northern States Power Company, which become part of the permit. Finally, the permit not only allows Northern States Power Company to write its own standards, but to do its own monitoring. Instead of establishing definite procedures for monitoring, including types of detector used, their sensitivity, and the exact manner in which measurements are to be made, the whole problem is dismissed with such undefinable phrases as the measurement of "significant releases" to the "full extent feasible." And instead of assigning an independent agency to monitor the discharge in a scientifically provable manner that leaves no doubt as to whether or not the limits are adhered to, the permit leaves to the owners of the plant to measure what they consider "significant releases." As a document to protect the people in this state from radiation and the environment from pollution, this Waste Disposal Permit has little value. We urge you to recall the Permit and re-open the hearings, assigning a special committee, if necessary, to hear testimony and to re-write the permit for the Monticello plant based on that testimony. Yours truly, Reverend ENGSTROM. 11. June 23, 1969, at MECCA's request, the MPCA held a public information hearing in Red Wing, Minn., located downriver from the NSP Prairie Island plant then under construction. This plant was, and is, the object of great public concern, as, of course, is Monticello. Presentations were made by three MECCA scientists (Dr. Charles Huver, Dr. Richard Meierotto, Dr. Henry Romer), our Legislative Chairman (John Pegors), a local State Senator (George Conzemius), several leaders of the local Indian community who live in the vicinity, and others. 12. July 7, 1969, PCA hearing. Permit had already been moved, seconded, and discussed with NSP and the question called on the motion when three MECCA members respectfully requested the PCA to permit the public to have an opportunity to speak. This led to a motion to table the permit until such time as a public hearing could be arranged. Motion carried 4 to 2. 13. August 19, 1969, PCA hearing regarding NSP permit to dump chemical and thermal pollutants in the river at the Prairie Island plant. Spokesman for MECCA remarked that we had gone on record as preferring that the NSP application be considered as a single permit covering both thermal and radioactive pollution. This was turned down 8 to 1 by the PCA with only Colonel Gadler voting in favor of the environment. Then in view of this decision to divide the permit and the great public interest shown, a public information hearing was scheduled for September 22. 14. October 13, 1969, the MPCA took action setting the thermal waste discharge limit at 5 degrees above ambient temperature at point of discharge at the Prairie Island plant. No mixing zone was established. The point has been referred to earlier today by Mr. Badalich. 15. In December of 1969, a letter was received by MECCA from the president of NSP suggesting joint meetings to discuss environmental problems associated with the electric power industry. 16. In January of 1970, the MECCA Board of Directors voted to accept this invitation and to join in consultations with NSP and others. 17. Sunday, February 1, 1970, a public caravan of over 50 cars journeyed to Elk River, Minn., where they were met by a caravan coming from St. Cloud. Memorial services were held at the site of the defunct Elk River reactor to call public attention to one of many reactors that have been closed down. (See exhibit listing operating history of some U.S. nuclear reactors, infra.) 18. From February 1970, to the present time, MECCA representatives, together with other State citizens' organizations, State officials, and NSP leaders, have been meeting on a near weekly basis. The purpose has been to solve environmental problems associated with NSP's operations. The name of this group is, "Plant Siting Advisory Task Force". We have appreciated NSP's cooperation, evidenced by this venture and other consultations between officers of NSP and MECCA. 19. April 20, 1970, Karth-Fraser public hearing on the effect of nuclear power on the environment. (Operating history of some U.S. nuclear reactors follows:) OPERATING HISTORY OF SOME U.S. NUCLEAR REACTORS 1 Reverend ENGSTROM. Outstanding experts came to testify against the use of nuclear power in the metropolitan area. This was done as one more indication of citizen concern which apparently had been falling on deaf ears. 20. April 28, 1970 through August 7, 1970, the Atomic Energy Com mission's Atomic Safety and Licensing Board convened hearings in St. Paul on the matter of an interim operating permit for NSP's Monticello nuclear generating unit No. 1. MECCA and four individuals intervened in opposition to the granting of this permit. In addition, limited appearances were made by: (a) The city of St. Paul; (b) The State of Minnesota; (c) Minnesota Conservation Federation; (d) League of Women Voters; (e) Clear Air-Clear Water Unlimited; (f) Minnesota Environmental Defense Council; (g) Sierra Club; (h) Minnesota Committee on Environmental Information; (i) Zero Population Growth; (j) Adolf Ackerman, professional engineer; (k) St. Paul Planning Board; (7) St. Paul Zoning Board and (m) Other individuals. In spite of all this citizen and official opposition, the permit was granted. Recently the attorney general of the State of Minnesota asked the district court of Wright County for an injunction to prevent operation of the plant. This petition was denied. 21. June 10, 1970, MECCA and three citizens filed action in district court against the Minnesota Pollution Control Agency, the Minnesota Conservation Department, and Northern States Power Co., seeking relief from harmful effects of thermal waste discharges at Monticello nuclear generating unit No. 1. The case is still pending. 22. August 10, 1970, PCA hearing held in Minneapolis. There was discussion regarding permit for nuclear waste retaining facilities. MECCA requested public hearing before granting of permit. There was no response. The matter was scheduled to be decided at the September meeting of the PCA, but no public hearing has been had at this time. However, earlier this week the PCA met again and it was unanimously voted that the public hearing be held. This partial record gives some idea of the vast amount of time and energy invested in this whole matter by one corporation, one State agency, and thousands of concerned citizens with reference to only two nuclear-generating plants. Through the whole process it has appeared to us that to get a corporation, a municipality, a State agency, or a Federal agency to act in behalf of the people and their welfare, it is necessary to push relentlessly without respite or relaxation. This should not be necessary. II. COMMENTS ON THE BILL In the final analysis the Government must come to grips with this problem and we appreciate the fact that this committee has exhibited deep concern over it. We appreciate the time and effort, the money and research, the discussion and deliberation that have been invested to make this a good piece of legislation. We concur with the purpose of the bill, but we have some apprehensions about the means provided for fulfilling that purpose. 1. The real power, it seems, under the bill, lies with the agency selected by the President to administer the program. The head of the agency establishes the regions and sets standards. What if the President should relegate this authority to the Commerce Department, whose purpose is to stimulate business? This would be like using the fox to "protect" the chickens. What if he choose the Atomic Energy Commission? Our experience with this agency has been far from satisfactory. As you know, it has a dual purpose whose parts are in direct conflict with each other. It is supposed to promote the use of atomic energy, yet to protect the environment and the people. It is surely not doing the latter. The ultimate responsibility lies in the Congress. Its Members are the elected representatives of the people. Congress should indicate, in this legislation, the proper agency to administer this program. We suggest the Department of the Interior, or, better yet, a new Department of Natural Resources. The average citizen is too far removed. from the President. We have too little access to him. We feel closer to the Congress and to the men who represent us in it. 2. The bill provides that each Governor shall appoint a person to represent him on his regional board. This allows the Governor to appoint any person of his choice, regardless of qualifications, to a very important position. It is imperative that there be written into the law safeguards more stringent than those provided in section 4(b) (Figure 2). 3. Our biggest concern is the lack of provision for public participation in the decisionmaking process. The bill provides for appointment by each regional board of an advisory council on which the public shall be represented along with representatives of State and local governmental bodies, all segments of the electric industry, and other groups. We wonder who represents the public. In what proportion? How will proper balance be maintained? Will one environmentalist be locked in with, and diluted by, overwhelming power industry representation? We also wonder whether these councils will have any authority or whether they will be purely advisory and will serve only at the pleasure of the regional board. Section 4 (c) provides that the regional councils "may make such studies or conduct such investigations as requested by the regional boards." Should it not be possible for a regional council to take its own initiative? This section also states that "any studies, reports, or other information provided to the regional board by such advisory councils shall be made available to the public with reasonable opportunity for presentation of views by any person interested in the purposes of this act." This is a good provision, but it poses some practical problems. How can a large group of concerned citizens afford to travel from St. Paul to Chicago, for instance, to make their feelings known about a certain site location? It has been our regrettable experience that a "show of numbers" is sometimes more effective than a logical argument. But it costs money to travel. Could the councils hold meetings at various points in each region thus making them more accessible to the public? This section also provides that each regional council shall forward the views of interested persons to the regional board. This |