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 Yankee.
• 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 GTS 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 reactors.
• 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 issues:
• 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 reactor site?

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:

• 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 (+/- 5 miles).
• 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 database.
• 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 option?

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?

• 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:
1. 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.
2. 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 reactor.
3. What significance does this have for the other 100+ NRC licensed reactors yet to be decommissioned?
• 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:
• 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 this situation.
• Get used to it.

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?

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.

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.

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. 1-2).
• "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).

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

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.

Thanks,

Dave Lochbaum
Nuclear Safety Engineer
Union of Concerned Scientists