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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.
The rush to dismantle the contaminated MYAPC site was made in response
to extraordinary local state and business community pressures to eliminate
this environmental albatross from the Maine landscape as soon as possible.
PDQ, immediately, as of yesterday, etc. - easier said than done.
Now the uncomfortable question arises: can this site even be decommissioned?
Prompt dismantlement has proceeded far enough to eliminate the safe storage
option. No public discussion, no questions, no dissent allowed by
the information gulag in Maine. It was full blast ahead with the
rapid dismantlement of a reactor site that should have remained under study
and in the safe storage mode. Safe storage was the option used at
most other closed US reactors for reasons now becoming evident at Maine
The recent breaching of the MYAPC reactor containment for the purpose of
removing the three steam generators marks the beginning of the nightmare
stage of the decommissioning debacle at MYAPC: there is no turning back
to safe storage now.
The financial troubles of the decommissioning operations contractor (DOC)
Stone & Webster and their looming bankruptcy further complicate the
dirty decommissioning option chosen by Maine Yankee. MYAPC had the
misguided impression that prompt dismantlement would result in significant
cost savings. Now the licensee has fired the decommissioning contractor
and the steam generators sit out in the open in front of a breached reactor
containment graphically illustrating the nightmare stage in the decommissioning
process. Ray Shadis makes the following comment in the Portland Press
Herald "Shadis said he thought many subcontractors would be able to proceed
with different phases of the decommissiong process. 'It may well be that
this doesn't slow things down at all,' he said." (Portland Press
Herald, Saturday, May 6, 2000, pg. 10-A). We hope he is correct,
but doubt his optimism.
The unfortunate decision to rush ahead with rapid dismantlement of the
MYAPC facility was made prior to last year's licensee acknowledgment of
the presence of 66 failed fuel assemblies and +/- 200 damaged fuel assemblies
and other debris in the spent fuel pool.
The choice of the dirtiest decommissioning option was made prior to the
Duratek cursory site characterization, which disclosed, in a secret
supplemental survey, the presence of a 10,000 square foot area of spent
fuel-derived fission product contamination in soils located well away from
areas expected to be impacted by plant operations. This characterization
also showed abnormally high levels of fission products in swipe samples
taken from contaminated piping throughout plant water systems and very
high levels of soil contamination around the reactor base. All major
Maine media received summaries of this information at the time the ten
volume GTS report was published in June of 1998. These red flags
were ignored by the Community Advisory Panel, Ray Shadis and Friends of
the Coast and Maine's information gulag who chose not to report, discuss
or debate this licensee generated data when it was made public. This
misrepresentation serves as a paradigm for evaluating past, present and
future radiological assessments made by the licensee, the NRC and Friends
of the Coast. Everyone went along with this lie; what will be the
credibility of any future radiological characterizations of the dirty decommissioning
process now underway at MYAPC?
Prior to the publication of the GTS Duratek site characterization report,
the licensee, at a Community Advisory Panel meeting, made the startling
assertion that the MYAPC site was clean, presenting the +/- two to three
million nanocurie spill of 137Cs covering 10,000 square feet
(the largest on record for an NRC licensed facility) as 26 picocuries in
one gram of soil. The licensee further indicated that this one gram
of soil had been remedied. Ray Shadis, Maine's foremost environmentalist,
never spoke up publicly about this misrepresentation when it became evident
that the licensee was lying about this spill, nor does he disagree with
the licensee or the NRC about what they consider to be the insignificance
of the presence and impact of the 66 failed fuel assemblies. Most
recently, Tux Turkel wrote an informative and lengthy article in the Maine
Sunday Telegram (May 7, 2000) section F, page 1, pertaining to the storage
of spent fuel rods at MYAPC. Unfortunately, Tux only discussed the
damaged fuel assemblies noted in Governor King's consultant's comments.
No mention was made of the 66 failed fuel assemblies, which cannot under
any circumstances be safely stored for very long periods of time in 28
inch thick concrete storage containers. Turkel implies in this article
that the state may have some influence over the outcome of how this waste
is stored. What the state thinks and does about Maine Yankee is irrelevant;
they may be quite "entangled" but the state of Maine is very unlikely to
have any impact on the outcome of the decommissioning nightmare at MYAPC,
nor influence the technological solution, if any becomes available, to
the problem of what to do with failed fuel assemblies at defunct nuclear
The breached reactor vessel and the three steam generators now sitting
out on a tarmac exposed to the elements not only graphically illustrate
the nightmare stage of the decommissioning process, which is now beginning,
they symbolize the as yet unasked question: what quantity of fission products
was lost from the failed fuel assemblies and where is this contamination
now located? If we use the metaphor of a huge blueberry pie (+/-
700 acres) for the current radiological inventory of wastes at MYAPC (+200
million curies of spent fuel and spent fuel-derived wastes and activation
products), the radiological contents of the three steam generators represent
just a tiny slice of the pie. Nonetheless, the steam generators are
one of many locations where fission products released from failed fuel
assemblies now reside. Aside from the +/- 100 curies of activation
products in each steam generator, what quantity of spilled spent fuel-derived
fission products reside in the steam generators? What is the radiological
profile of the CRUD, debris and other materials in the crevices, the base
and the infrastructure of the steam generators? What does GTS Duratek
and the state of Tennessee do with the long-lived isotopes, hot particles
and CRUD in the steam generators after processing them for recycling and
release to the marketplace? Isn't this one among many of the interesting
topics pertaining to the decommissioning process at MYAPC whose debate
is suppressed by the information gulag of Maine (and the NRC)?
The decommissioning nightmare at MYAPC has two central
the environmental impact of the dirty decommissioning
option, including the controversial upcoming reactor vessel segmentation,
which will produce large quantities of radioactive effluents in the context
of a breached reactor vessel
the lack of options for the safe long-term storage, transport
and disposal of the 20% of MYAPC spent fuel assemblies that are either
failed or damaged
The final site release criteria of 10 mrem general exposure, 4 mrem water
pathway exposure are a theoretical ivory tower construct, which may never
be verifiable. Meaningful verification of these site release criteria
(by who? at what cost?) cannot occur until the quantities of failed fuel
assembly-derived spent fuel fission products are measured and tracked.
These admirable but theoretical site release criteria obscure the need
to focus on the immediate environmental impact of the dirty decommissioning
process with its breached reactor containment, highly radioactive reactor
vessel, 66 failed fuel assemblies, highly contaminated spent fuel pool
and contaminated reactor environs. The careful control and management
of information pertaining to MYAPC appears to be jeopardized by the inadvertent
release of Governor King's consultant's comments on the safety problems
associated with the long-term storage of damaged spent fuel. Kris
Ferraza (Lincoln County Weekly, May 3, 2000) made the first reference in
Maine media to "66 failed fuel assemblies" since the licensee revealed
their presence last year. The licensee's revelation
of the presence of these failed fuel assemblies was the smoking gun that
gave meaning to the red flags in the GTS site characterization report.
Is this the first stage in the unraveling of the cover-up of the actual
radiological status of the Maine Yankee site?
Bill Linnell of the Committee for Safe Energy Future (CSEF) has made reference
to the current decommissioning process, if done without rubblization, as
a Cadillac of a decommissioning. We take issue with this characterization;
the MYAPC site is a Cadillac of a mess. Now that the state legislature,
the licensee and Friends of the Coast have agreed not to rubblize (bury
on site) much of the debris at MYAPC, the next focus of attention should
be upon the most radiologically risky of all decommissioning procedures,
the reactor vessel segmentation. There is now no turning back to
safe storage; the reactor vessel must be quickly segmented and removed
from the MYAPC site. Now, however, there is no decommissioning operations
contractor who will execute the reactor vessel segmentation. What
company will carry out this segmentation process, who are the workers who
will be exposed to the high radiation fields in and around the reactor
vessel and what kind of oversight (if any) will attend this controversial
activity? What will the environmental impact of this dirty process
be on the sensitive and vulnerable marine ecosystems that surround the
Visitors to this site please take notice of the following
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.
Center for Biological Monitoring.
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
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: firstname.lastname@example.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
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:
Limit consumption of seafoods harvested from the sensitive marine ecosystems
of this area, especially sea vegetables (a sensitive bioindicator), shellfish
of any description and lobsters caught close in to the reactor site (+/-
Have children avoid contact with floc line debris (the seaweed and other
materials left at the high tide line in most all marine environs) anywhere
within 15 miles of the MYAPC reactor.
This advisory includes the following areas: the Sheepscot back river
from Wiscasset Harbor south to Robin Hood Cove including Westport Island,
northeast Arrowsic Island, the northern sections of Georgetown Island;
the Sheepscot River north of Wiscasset Harbor to the head of the tide at
Alna, and the Sheepscot River south of Wiscasset Harbor to Baker Island.
In view of the unknown amounts and locations of fission products lost
from MYAPC's 66 failed fuel assemblies, repeated official assertions
(MYAPC, NRC, state of Maine, Friends of the Coast) about the "safe" radiological
status of sensitive marine ecosystems cannot be verified by a nonexistent
In view of the breached reactor containment, recent heavy rainfall events
and the upcoming segmentation of reactor vessel internals, persons visiting
Maine during the summer season may wish to inquire about the point of origin
of Maine seafoods they are consuming.
Marine resources within 10 miles in any direction of the MYAPC reactor
site should have been closed at the time of the 1998 reactor water systems
flush and now should be closed while the reactor containment remains breached
and while reactor vessel segmentation and barge loading is taking place.
The licensee has recently closed a small area in the vicinity of the barge
berth; this closed zone should be greatly extended.
In the following weeks and months, the state of Maine, the licensee
and the seafood industry of Maine will be vehemently insistent that all
seafood consumed in the state of Maine is totally unimpacted by the dirty
decommissioning process now underway. If seafoods harvested within
10 miles of MYAPC are mixed with seafoods harvested from unimpacted areas,
the result could be a disaster for the Maine tourist industry.
Persons earning a living from the marine environment in the vicinity
of MYAPC should be compensated by the licensee and the state of Maine if
and when these areas are closed to the harvesting of marine resources.
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
May 11, 2000
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
The fuel cladding failures at MYAPC are first and foremost public safety
issues. To fail to acknowledge, quantify and track these releases
is the equivalent of a fire department refusing to answer the fire alarm
when the wind is high and a grass fire is spreading from yard to barn and
then house to house. Why would Maine's electronic and print media
decline to report Maine Yankee's disclosure of the existence of 66 failed
fuel assemblies and the contamination that resulted when one or more fuel
rods in each assembly "unzipped" and spilled some of its fuel pellets?
The Maine Yankee Atomic Power Company is part of the history of Maine.
Champlain sailed down the Sasanoa River from Bath and then up the Sheepscot
Back River past the town of Wiscasset, 396 years ago. The long-lived
radioisotopes dispersed by MYAPC's failed fuel assemblies leave a permanent
radiological footprint on the land and sediments along and in the Sheepscot
Back River, the Sasanoa River, Montsweag Bay and the many coves and estuaries
of this sensitive marine ecosystem. Will future generations overlook
this legacy of the misguided attempt to keep property taxes low in the
community of Wiscasset?
The two dirty secrets of the Nuclear Regulatory Commission, which are always
the subject of rituals of evasion during its ivory tower meetings with
the Nuclear Energy Institute, are:
The independent spent fuel storage installation (ISFSI) will be a semi-permanent
sculpture garden of 62 or more 150 ton dry casks - a virtual reliquary
of radioisotopes upon a palimpsest of hopefully erased nightmares.
These icons to the power of the dollar to subvert our society will endure
for generations to come. Will the residents who live in the area
impacted by MYAPC operations and decommissioning forget that not all long-lived
spent fuel-derived isotopes are contained in these monuments to human greed?
Historians will someday revisit last weekend's article in the Maine Sunday
Telegram (May 7, 2000), in the business section no less, on the subject
of spent fuel storage at MYAPC. Tux Turkel wrote about spent fuel
storage as a "hot topic" without mentioning that the licensee had announced
publicly over a year ago that it had 66 failed fuel assemblies in the spent
fuel pool. What corporate ritual of aversion necessitates this oversight?
The confidential MYPS-101 April 16, 1998 inventory of "spent fuel and
other radioactive materials stored in the Maine Yankee spent fuel pool"
was released by Mary Ann Lynch, MYAPC legal council, and given to Ray Shadis
over a year ago. "4.0 Table A.2 contains a list of fuel with
known failures. With the exception of assembly R033, the nature of
the failures are considered to be gross cladding defects. Other fuel
assemblies may also have failed fuel rods." (pg. A.3). Mary
Ann Lynch and MYAPC had the guts to admit that fuel cladding failures had
occurred at the Wiscasset reactor. Copies of this confidential document
were provided to all Maine media prior to the Hide
the Evidence Contest. Does Maine's print and electronic media
think the children of Maine won't notice that they didn't have the courage
to report these fuel cladding failures?
This week's federal court ruling eliminating the state of Maine as a participant
in the radiological characterization of the MYAPC decommissioning nightmare
appropriately ends the illusion that the state of Maine could have any
role in the documentation of the unfolding debacle at Wiscasset.
The state of Maine's failure to execute its share (297) of split samples
during the GTS Duratek site characterization epitomizes its long standing
complicity in the MYAPC debacle. Who will then track the pathways
and destinations of the long-lived isotopes, which have spilled out of
the failed fuel assemblies?
Neither the NRC, the state of Maine nor the licensee can be trusted to
document the consequences of these fuel cladding failures. Only a
"free enterprise entity," such as GTS Duratek, funded by large fistfuls
of ratepayers dollars will have the ($for profit$) motivation to fulfill
this unwanted responsibility. How much will this legacy of "entitlements"
cost the ratepayers and taxpayers of Maine in future years?
Maybe Rob Gardiner of MBPN, Tux Turkel of the Portland Press Herald, Greg
Lagerquist of Channel 13 and Jennifer Rooks of Channel 6 in Portland are
correct in saying that their audience, the general public, is too witless
to understand the details and implications of fuel cladding failure (all
have made this comments to this effect to this editor at one time or another.)
Maybe at least this can be understood:
Fuel cladding failures are the most common type of nuclear accident
and occur frequently over the lifetime of many NRC licensed reactors.
They are as commonplace as skidding accidents in an ice storm.
There is no known long-term safe storage or disposal option for Maine
Yankee's 66 failed fuel assemblies, or for those at any other NRC licensed
What significance does this have for the other 100+ NRC licensed reactors
yet to be decommissioned?
There has been a series of nuclear accidents at Maine
Yankee Atomic Power Company
The current quantity and location of contamination resulting
from these accidents is unknown.
There is no known surefire technological solution for
the long-term storage and disposal of failed fuel assemblies and the long-lived
isotopes they contain.
There is the possibility that nothing can be done about
Get used to it.
|Re: The Maine State Legislature's 10-4 Site Release
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
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.
May 18, 2000
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.
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.
"Pursuant to Federal Rule of Appellate Procedure 18, Fed. R. App. Pro.
18, and 28 U.S.C. § 2349(b), the State of Maine ("State") moves for
a stay of a Nuclear Regulatory Commission ("NRC") final rule amending Part
72 of its regulations, 10 CFR § 72.214. This amendment adds
the NAC Universal Storage System ("NAC-UMS") to the list of approved spent
nuclear fuel storage casks. 65 Fed. Reg. 62581 (October 19, 2000)
(Attachment 1 hereto). Without a stay, the rule will become effective
on November 20, 2000. Id. If it becomes effective, the amendment
will permit Maine Yankee Atomic Power Company ("Maine Yankee") to begin
loading spent nuclear fuel from its permanently shutdown nuclear power
plant into NAC-UMS casks. This NRC rule violates the agency's own
regulations requiring design compatibility with Department of Energy ("DOE")
programs to ensure that DOE will accept and remove such spent fuel to a
disposal site without additional examination or processing. Absent
a binding DOE commitment to accept spent nuclear fuel that could be stored
in Maine for decades in NAC-UMS casks, the State and its citizens will
be subjected to irreparable injury, including unnecessary and avoidable
health and safety risks. In order to avoid those risks, the State
has today petitioned this Court for review and asks the Court to stay the
effective date of the NRC's rules amendment pending that review." (pg.
"Most of the currently certified systems are suitable only for on-site
storage and may not be used to transport fuel off-site. They consist
of a sealed metal canister containing the spent fuel assemblies that is
inserted in a ventilated reinforced concrete cask that is then placed on
a concrete pad with other casks where they are monitored and maintained
by personnel at an operating plant. ... When DOE finally begins accepting
commercial spent fuel stored in these storage-only canisters from operating
plants, the fuel will have to be removed and transferred to different transportation
canisters. In contrast, the dual-purpose NAC-UMS system is designed
so that the sealed canister containing the spent fuel may be used for both
storage and transport, depending on whether it is placed in a storage or
transport overpack or cask." (pg. 3).
"[T]he State of Maine hereby requests that, as a prerequisite to approving
the proposed rule, the NRC acquire binding assurances from the DOE that
DOE will accept spent fuel for transport and disposal that has been stored
in accordance with NRC-approved procedures." (pg. 5).
"...so long as DOE refuses to remove Maine Yankee's spent fuel to a government
storage site, thus delaying by decades DOE's acceptance and transport of
all Maine Yankee's spent fuel, the State must anticipate the possibility
that Maine Yankee will no longer exist and that the State will be forced
to assume direct responsibility for ensuring DOE's acceptance and removal
of spent fuel." (pg. 5).
"Without a stay of the NRC's rule, Maine Yankee will load and seal storage/transport
canisters that cannot be physically inspected further without opening the
canister and possibly exposing workers and others to radiation." (pg. 6).
"By failing to take the reasonable step of soliciting DOE review and approval
of the system's design, however, the NRC rule jeopardizes the fundamental
safety and efficiency principle that underlies the NAC-UMS concept.
Before accepting spent fuel at the reactor site for transport, DOE will
be free to second-guess the NRC's determinations and demand that storage/transport
canisters be opened and inspected to determine whether the fuel or its
cladding has deteriorated over the decades of storage. Indeed, the
DOE letter to Governor King, on which the NRC relies for DOE's purported
assurances, 65 Fed. Reg. at 62596, expressly warns that DOE may delay accepting
spent fuel even further if questions about the fuel's condition require
it 'to address any technical issues that may be related to the fuel's safe
handling and disposal.' Attachment 12. The longer that DOE
postpones discharging its obligation to remove spent fuel (even to one
of its many interim storage sites, as it does now for research fuel), the
more likely DOE will be to demand additional investigation of 'technical
issues' that can and should be resolved before loading fuel in storage/transport
canisters." (pg. 9).
"The NRC has offered no logical explanation for refusing to take the rational
precaution of obtaining DOE approval of the design before sealing canisters
that are intended to remain intact throughout the interim storage and transportation
phases of spent fuel disposition. Thus, there is a substantial likelihood
that the Court will find that the NRC's approval of the rule was arbitrary
and capricious." (pg. 10).
"Once Maine Yankee loads its spent fuel in NAC-UMS canisters and welds
them shut -- now expected to begin in April 2001 -- it will be too late
for the NRC to consult with and obtain approval from DOE for this storage/transport
system, and the State will be irreparably harmed. Any questions that
DOE might have at that point about the capabilities of the NAC-UMS system
to maintain spent fuel in an acceptable condition for decades may only
be resolved by breaching the radiation containment barrier that the canister
provides. Because it has not been consulted and has not approved
the NAC-UMS system, DOE is in a legal posture to reject Maine Yankee's
spent fuel for transport unless and until the storage/transport canisters
are opened and the fuel physically inspected to determine its condition
at the time of acceptance. This will place an intolerable burden
on the health and safety of Maine's citizens and create an additional costly
burden on taxpayers, ratepayers or both." (pg. 10).
"The harm occurs when Maine Yankee begins to seal its fuel in canisters
for storage (as it plans to do in April 2001) when those same sealed canisters
will be used for transport. It will do no good for the NRC to solicit
DOE's approval of the storage/transport design after the die has already
been cast and fuel has been loaded in dual-purpose canisters." (pg. 11).
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????
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.
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
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
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