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Earlier parts of this chronicle are located in RAD 12: Section 2-B:  Safety Issues and Recent Events and RAD 12:  Section 5-B:  Decommissioning Chronicle, RAD 12: Section 5-E: Decommissioning Chronicle Continued: January  - December 1999 and RAD 12: Section 5-F: Decommissioning Chronicle Continued: January - May 8, 2000.

G. Decommissioning Nightmare

The unfortunate consequences of the ill advised decision to rush ahead with prompt dismantlement of the Maine Yankee Atomic Power Company reactor in Wiscasset, Maine made at its closing in 1996 are now becoming evident.  This new stage in the ongoing saga of Maine Yankee is most appropriately named decommissioning nightmare.  This decommissioning nightmare constitutes a historic event, not only for Maine, but for the nuclear power industry and the nation as a whole.  Despite the carefully controlled management and presentation of information pertaining to MYAPC's operations and decommissioning by Maine's electronic and print media, the following issues cannot be evaded, exorcised or ignored.

Visitors to this site please take notice of the following advisory
Due to the sloppy and hasty decommissioning techniques, inadequate historic site assessment and deficiencies in radiological surveillance techniques and databases at the Maine Yankee Atomic Power Company in Wiscasset, ME, the Center for Biological Monitoring is issuing the following advisory for the possible remobilization of hot particles, CRUD, activation products and spent fuel-derived fission products.  These include the long-lived isotopes in spent fuel, in order of their preponderance:
137Cs (1/2 T = 30 years), 90Sr (1/2 T = 29 years), 241Pu (1/2 T =  14 years), 242Cu (1/2 T = 162 days), 238Pu (1/2 T = 89 years), 240Pu (1/2 T = 6,260 years), 239Pu (1/2 T = 24,400 years) and 241Am (1/2 T = 458 years)
For more information on this subject see:
Brack, H. G., ed. A Review of Radiological Surveillance Reports of Waste Effluents in Marine Pathways at the Maine Yankee Atomic Power Company at Wiscasset, Maine--- 1970-1984: An Annotated Bibliography. Hulls Cove, ME: Pennywheel Press, 1986. (pg. 5-8).
Center for Biological Monitoring. Patterns of Noncompliance: The Nuclear Regulatory Commission and The Maine Yankee Atomic Power Company: Generic and Site-specific Deficiencies in Radiological Surveillance Programs. Brack, H.G., Ed., Hulls Cove, ME: Pennywheel Press, 1998.
Environmental Protection Agency. (1982). Draft environmental impact statement: Environmental standards for management and disposal of spent nuclear fuel, high-level and transuranic radioactive wastes. Report No. 520/1-82-025. Environmental Protection Agency, Washington D.C.
Oak Ridge National Laboratory. (1992). Integrated data base for 1992: U.S. spent fuel and radioactive waste inventories, projections and characteristics. Technical Report DOE/RW-0006, Rev. 8. Oak Ridge National Laboratory, Oak Ridge, TN.  http://www.em.doe.gov/idb95

Comments on this alert: please send email to: cbm@davistownmuseum.org

The strong tidal sweep of the Sheepscot back river combines with the labyrinth of coves, islands and river systems to allow MYAPC liquid effluent discharges and runoff to have the potential to impact a wide area of sensitive marine ecosystems in the coastal area between the Kennebec and Penobscot rivers.  The quantities, pathways and current locations of fuel assembly-derived fission products and other contaminants remain essentially unknown.  The first major decommissioning activity to impact the sensitive marine ecosystems in this area were the 1998 reactor water systems flush which released unknown quantities of radioactivity to the licensed radioactive waste disposal area (sewer) of Montsweag Bay.  Current decommissioning activities that also have or will impact this environment include the breaching of the reactor containment for large component removal (the breaching is completed) and the reactor vessel segmentation, which will commence shortly.  These activities combine with recent heavy rainfall events of the last few weeks to provide pathways for the spread of fission products such as 137Cs, 239Pu, 241Pu, 241Am and other long-lived isotopes over a wide area.

Most residents living in the area around the Maine Yankee facility appear to be satisfied with licensee, state, NRC and Friends of the Coast assertions of the relative safety of these decommissioning activities.  If you are in the extreme minority of persons living in or visiting this area who share our concerns about the undocumented releases of radioactivity from this facility you may find it prudent to:

Question of the Day

If failed and damaged spent fuel assemblies cannot be safely stored in the dry cask mode, is there any chance that prompt decommissioning cannot be completed at MYAPC, or at any other reactor site where a licensee has chosen the ill advised and hasty dirty decommissioning option?

May 11, 2000
Worker Safety Issues

Are MYAPC's 400 contracted workers aware of its history of fuel cladding failures?  Do they know that the quantities, chemical forms, pathways, destinations and current locations of the long-lived radioisotopes released by these fuel cladding failures have not been well documented and are essentially unknown?  Are the radiological controls at the MYAPC decommissioning site comprehensive enough to ensure that contract workers are not tracking fuel cladding failure-derived microcontaminants home to the kids?  What technologies, equipment and procedures were Radiological Services, Inc. utilizing prior to the May 11, 2000 announcement that they will no longer be working at the Maine Yankee site?  Has Radiological Services developed any additional radiological characterization information that will help pinpoint the current location of fuel cladding failure-derived spent fuel isotopes?  Will they share it with the public as they now head south?  Did Radiological Services consider the fact that most long-lived fuel cladding failure-derived radioisotopes, including all the plutonium except 241Pu, are alpha-emitting rather than gamma or beta emitters and are nearly impossible to track using conventional radiological surveillance equipment?  Who will now take over radiological surveillance of the decommissioning nightmare now unfolding at Wiscasset?

Historical Notes on the Decommissioning Nightmare
Re: The Maine State Legislature's 10-4 Site Release Criteria Agreement

If a piece of paper (State of Maine legislation) says that the environs of the Maine Yankee Atomic Power Company including Montsweag Bay will be cleaned up to meet very strict site release criteria, will the tooth fairy suddenly appear and rectify fifty years of AEC - NRC deficient historic site and radiological surveillance assessments?

May 16, 2000

The editor of this website would like to thank the NRC for their one and a half hour meeting with me yesterday.  While the meeting didn't result in any progress on the unresolved issues pertaining to the need for an immediate updating of the historical radiological site assessment of MYAPC, at least the issue was discussed.  The rapid decommissioning of the Maine Yankee facility was resumed on Monday by a temporary extension of the Stone & Webster contract with Maine Yankee that will extend through mid or late June.  The MYAPC site is one of the largest active construction projects in Maine at the present time.  The diverse nature of deconstruction activities, including many mundane chores with no radiological significance in and of themselves, have the potential to remobilize plant-derived radioactivity which now lies dormant in soil, dust, grease, construction debris, plant materials and equipment.  One of the purposes of the NRC visit yesterday was to use their mobile laboratory for spot checks of soil samples from the construction area around and underlying the proposed location for the new independent spent fuel storage installation (ISFSI).  The NRC mobile lab appears to have the capacity for 12 to 24 short count spectroanalytic samples (1/2 to 1 hour) per day or 2 to 4 long count samples (8 to 12 hours) per day.  The presence of the mobile lab graphically illustrates the historic deficiencies in NRC radiological surveillance programs.  The lab is only visiting for a few days to a week and is involved in only spot sampling of selected locations at MYAPC.  It is the only mobile lab associated with Region I.  Because of the unresolved issue of the quantities of fission products released from damaged and failed fuel assemblies, the lack of information about the present location of these isotopes and the tight control of the licensee over restricted radiological surveillance data that it may or may not now be collecting there is an urgent need for the NRC ( or a contractor such as GTS Duratek) to step in with an on site laboratory that would include a minimum of three high efficiency detectors operating around the clock doing long counts of sediment, soil and biotic samples from the plant environs.   Such samples should be taken not only in the vicinity of the reactor site, but should include sediment, sea vegetable and floc line samples from distant marine estuaries located five or ten miles or even further from the Maine Yankee site.  After long years of inadequate site assessment, only surveys with thousands of samples will tell us anything about the current radiological status of the area, including the marine environment, around Maine Yankee.

The credibility of the license termination plan (LTP), including the promise of extensive site characterization discussed at last night's 7:00 Wiscasset High School meeting, hinges upon the timely availability of radiological surveillance data that should include a broad sampling of all the pathways of exposure from plant-derived radioisotopes.  The upcoming LTP site characterization should also include, as discussed with the NRC at the 4:00 meeting, a consideration of the Food and Drug Administration's protection action guidelines (derived intervention levels (DLLs)) for long-lived isotopes such as 239Pu and 241Am as well as for the indicator isotope 137Cs.  Most radiological surveillance data now being compiled by the licensee is not available for public review.  As long as present and future characterization data is controlled by the licensee and not available electronically in a readable form and in standard reporting units, the license termination plan (LTP) characterization data will have no credibility, and will not serve to answer the unresolved questions pertaining to the releases from damaged and failed fuel assemblies.  The fundamental need at MYAPC is for an accurate understanding of the impact of decommissioning activities and their remobilization of fission and activation products that have already been released by loss-of-radiological controls in the past.  The frenetic decommissioning activities at MYAPC mandate radiological surveillance now, rather than at some point in the future.  The next few months mark a critical junction in the decommissioning process and provide the opportunity for the accumulation of biologically significant quantities of reactor-derived isotopes in marine food chains.  Only a vastly accelerated program of radiological surveillance will confirm the rosy optimism of the NRC, the licensee and Friends of the Coast.

(updated May 18)
The following memo to Mark Roberts, Health Physics Specialist at the NRC, expresses the main concerns of the Center for Biological Monitoring pertaining to the decommissioning debacle at MYAPC.  Obviously, CBM is dealing with a situation where the community of Wiscasset as well as Maine's media (what we call the information gulag) don't want to acknowledge that previous losses-of-radiological controls mean that not all spent fuel-derived fission products are in the spent fuel pool within the existing fuel assemblies.  We recognize we can't impact the community's need to deny the problems at MYAPC, but the issues pertaining to radiation protection guidelines are worth noting and discussing.  The historical significance of MYAPC's radiological footprints is a subject that will take generations to document.
Memo to Mark Roberts of the NRC
With respect to our 4:00 discussion of the NRC's annual limits on intake (ALI) in 10 CFR Part 20 Appendix B I'd like to make a few general observations. 
  • All radiation protection guidelines (FDA, FEMA, FRC [Federal Radiation Council], NCRP [National Council of Radiation Protection], AEC, etc.) have been traditionally divided into one or more categories with the emergency protection action guidelines one order of magnitude stricter than general radiation protection guidelines.  In writing about the ALI for occupational exposure in Patterns of Noncompliance in appendix 4, I utilized this general rule of thumb of one order of magnitude to extrapolate the general public exposure limits from occupational exposure limits.  This doesn't mean that I thought that these general public exposure limits were the sole governing NRC criteria.  They are only one in a confusing series of suggested or implied radiation protection guidelines.  You will note in the first chapter of Patterns of Noncompliance that I both acknowledge and discuss the numerous conflicting NRC radiation protection guidelines, especially including 10 CFR 20.1402 (25 mrem per year) pertaining to residual radioactivity and unrestricted use, which is summarized prior to the abstract of this publication.
  • 10 CFR 20.1301 (2)c discusses the 5 rem annual dose limit for the general public (restricted circumstances), which I used in this appendix.  You will note in chapter one of Patterns of Noncompliance that suggested NRC dose limits for the general public can be as low as 3 mrem/yr TEDE for the design criteria for reactor liquid effluents (see p. 10).  In making my comparison of the ALI with the FDA's DILs I was using the rule of thumb that would designate general public exposure as being one order of magnitude lower than the occupational exposure of 5 rems.  The public guideline I was discussing represents an upper boundary of exposure; obviously the state of Maine 10 mrem per year agreement with the licensee represents the lower boundary.  The NRC design criteria is almost never mentioned in discussions of radiation protection guidelines and can certainly never be verified with your existing radiological surveillance programs.  Maine's 10 mrem standard represents another pie in the sky guideline that is essentially an exercise in public relations and also cannot be verified.
  • My main point continues to be that neither the licensee nor the NRC nor any environmental organization has the radiological surveillance database necessary to validate site release criteria or public guidelines at 100 mrem, 50 mrem, 25 mrem or 10 mrem per year.  If the NRC would bring in enough equipment to analyze 2,500 samples from the biotic and abiotic environment around Maine Yankee it would just begin the catch up process required by the current outrageous deficiencies in the historic site assessment at MYAPC.  Right now the NRC and MYAPC don't have a robust enough database to decommission a donut factory, let alone validate the two currently operative NRC public exposure guidelines of 100 mrem and 25 mrem.
  • The FDA guidelines for contaminated foods provide a second more easily understood frame of reference for evaluating the impact of MYAPC operations and activities on the environment and on the public in and around the reactor site.  Were the MYAPC worker exposure to approach the CFR annual limit of intake (ALI - e.g. 100 microcuries of 137Cs, equivalent to 10,000 kg servings of food contaminated with 137Cs, which was the FDA's Chernobyl protection action guideline for imported foods), the NRC or its licensee could hardly argue that public exposure was only in the 10 to 25 mrem range.  If worker exposure at Maine Yankee in any way approaches the ALI limit it is very likely that public exposure would be much higher than the 10 to 25 mrem range.  The rule of thumb public exposure guideline extrapolated from the occupational exposure guideline in 10 CFR provides a reasonable model for this hopefully unlikely scenario.
  • Until the NRC and its licensees compile a credible radiological surveillance database that is open to public scrutiny (MYAPC's current radiological database is not available for my perusal), no conclusions can be drawn about the current radiological status of the marine environment surrounding the Maine Yankee reactor site nor about public exposure to microcontaminants that results from mixing seafoods harvested in the contaminated areas around MYAPC with those harvested from other areas along the coast of Maine. A key reason why the licensee as well as the NRC doesn't have much credibility with the general public is the unavailability of radiological surveillance data that would confirm assertions of no significant public exposure from MYAPC decommissioning activities.
May 18, 2000

The staff of the Center for Biological Monitoring and The Davistown Museum will be away during the summer on Davistown Museum related work and research projects.  There will be no further postings on this page pertaining to the MYAPC decommissioning fiasco until the fall.  If visitors to this site have any questions or comments, please fax them to the editor at (207) 288-2725.

November 9, 2000

A major development in the decommissioning debacle at MYAPC is the state of Maine's petition to the United States Court of Appeals to delay the NRC's rule approving the implementation of the NAC-UMS (NAC Universal Storage System) spent fuel storage system.  To review the state of Maine's concerns pertaining to the safety of this storage system, please go to our April postings.  The following posting is the state of Maine's legal challenge to the NRC's approval of the licensee's plan to seal spent fuel in the dry cask storage containment without resolution of the safety issues raised in April, and without an absolute DOE commitment to accepting the sealed spent fuel casks with no further inspection.

United States Court of Appeals for the District of Columbia. (November 9, 2000). State of Maine's motion for emergency stay of the Nuclear Regulatory Commission's rule approving the NAC-UMS spent nuclear fuel storage system. No. 00-1476. United States Court of Appeals for the District of Columbia, Washington, DC.

January 8, 2001

Below is a VERY IMPORTANT message from Dave Lochbaum about Maine Yankee and spent fuel onsite.  If you will all recall, Maine Yankee applied for and received permission from NRC to drop its off-site emergency preparedness,
all of us being told emphatically that there was no further potential for any kind of off-site radiological contamination. Obviously, that is no longer believed to be true.  Unfortunately, Maine Yankee has cut down warning sirens in towns in the 10 mile Emergency Planning Zone, which would be evacuated in case of a radiological emergency.  So, local areas are no longer prepared for such an emergency.  Great.  Let's see if the folks up at MEMA are prepared to do anything about this. How about the Governor, what measures is he taking to safeguard the public????
    Kris Christine

On December 20, 2000, the NRC staff sent the final report on spent fuel storage risks at permanently closed nuclear power plants to the NRC Commissioners. The transmittal indicated that the report (which has an ADAMS accession number of ML003762963) would be made public in ten days, unless the Commission directed otherwise. Well, the Commission directed otherwise. The report is not to be made public, at least for awhile.

It seems that the report, which was initiated after Maine Yankee sought to significantly reduce its onsite security requirements, concluded that the risk to workers and the public is so high that security cannot be relaxed. The threat is from long-lived isotopes in the spent fuel that can cause the metal rods containing the fuel to heat up if forced circulation is not available when oxygen is present. This threat applies to wet pool storage when the water level inside the pool drops to the point of partially uncovering the spent fuel assemblies. Without forced circulation, either by water or by air, the report concludes that there can be significant fuel damage with 10 CFR Part 100 consequences (i.e., people offsite can be hurt).

This threat also applies to spent fuel stored in dry casks. The casks use an inert gas (nitrogen or helium) that acts to transfer heat produced by the spent fuel. If that inert gas were to leak out and be replaced by air, the oxygen in the air can cause significant fuel damage. The heat generated by spent fuel in dry casks today is sufficient to cause damage if it is exposed to oxygen without forced circulation.

This report is extremely important. It shows that onsite spent fuel storage, whether in wet pools or dry casks, has greater risk than previously thought -- in fact, risk so high that people could get hurt. The report also shows that the transportation risk is higher than previously thought. It had been thought that there'd be no problem as long as criticality was prevented.  No so, according to the new report. Fuel damage can occur due to overheating.

I spoke with Mr. George Hubbard of the NRC staff about the report's availability. He provided me the accession number and its status (limbo). Mr. Hubbard can be reached at (301) 415-2870.

If the report is ever made public, I'll e-mail a copy out to everyone on this distribution.


Dave Lochbaum
Nuclear Safety Engineer
Union of Concerned Scientists

February 5, 2001
The report mentioned above is now public.  See our citation and annotations in the Decommissioning Bibliography.

February 21, 2001
Nonstandard Fuel Loading
NAC International news release:
"ATLANTA -- An amendment to NAC International's (NAC) Universal MPC System® (NAC-UMS®) storage Certificat of Compliance (COC) that allows nonstandard fuel loading at teh Maine Yankee Atomic Power Station (MYAPC) was confirmed effective today by teh U. S. Nuclear Regulatory Commission (NRC) by direct final rule.  Last fall, the NRC amended its 10 CFR 72 regulations to add the NAC-UMS® to its approved spent fuel storage systems designs.  The NRC approval allows utilities to use the system under a general license, without site-specific approval, to store spent nuclear fuel."

April 12, 2002
We have just reproduced a copy of a Union of Concerned Scientist's report on the Potential Nuclear Safety Hazards of Reactor Operation with Failed Fuel Cladding in a special appendix.

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