(July 21, 1997). DOE says remedies for missing waste deadline lie in disposal contracts. Hazardous Waste Litigation Reporter. pg. 32612.

• Case: EPCRA/Citizens' Suits: The Steel Co. v. Citizens for a Better Environment.
• "...neither the NWPA [Nuclear Waste Policy Act] nor a prior appeals court ruling compel it to provide interim storage services ... DOE [Department of Energy] says it has already met its obligation under the applicable waste storage contracts by offering credits or other means of compensation to nuclear waste generators for its admitted inability to meet the deadline."
• "Due to the staggered delivery schedule, DOE says it would be inappropriate to grant the petitioning utilities' request that they be permitted to stop contributions into the Nuclear Waste Fund until DOE's proposed Nevada storage facility is on-line."
• "While the petitioners criticized DOE for accepting spent nuclear fuel from foreign research reactors, the agency says it stores the waste in support of the United States' nuclear weapons nonproliferation policy. Its obligation to carry out that duty under the Atomic Waste Act, says DOE, has no connection with the storage of domestic waste under the NWPA."

• This publication is out of print. It may be obtained through inter-library loan or from the library at the University of Maine, Orono.
• The following list of citations from this publication provide secondary literature for research relevant to the ongoing site characterization process at MYAPC.
• Hess, C.T., Smith, C.W., and Price, A.H. (November 20, 1975). Model of the accumulation of radionuclides in oysters and sediments. Nature. 258. pg. 225-226.
• Hess, C.T., Smith, C.W., Churchill, J.H. and Burke, G.F. (May 1976). Radioactive isotopic characterization of the environment near Wiscasset, Maine using pre- and post-operational surveys in the vicinity of the Maine Yankee Nuclear Reactor. 68-01-2654. U.S. Environmental Protection Agency, Washington, D.C.
• See our review in the public safety bibliography section of this part of RADNET.
• Price, A.H., Hess, C.T. and Smith, C.W. (1976). A field study of crassotrea virginica cultured in the heated effluent and discharged radionuclides of a nuclear power reactor. Proc. National Shellfish Association. 66. pg. 54-68.
• Churchill, J.H. (1976). Measurement and computer modeling of the distribution of nuclear reactor discharged radionuclides in the estuarine sediment near the Maine Yankee Atomic Power Plant in Wiscasset. Department of Physics, University of Maine, Orono, ME. pp. 122.
• Hess, C.T., Smith, C.W. and Price, A.H. (August 1977). A mathematical model of the accumulation of radionuclides by oysters aquacultured in the effluent of a nuclear power reactor to include major biological parameters. Health Physics. 33. pg. 121-130.
• McCarthy, W.J. and Ryder, D.L. (1978). Uptake and deprivation of ⁵⁸Co, ⁵⁴Mn, and ¹³⁷Cs in two species of benthic marine algae growing in the effluent of the Maine Yankee Atomic Power Plant. Bulletin American Physics Society. 23(5). Abstract.
• McCarthy, W.J., Ryder, D.L. and Antonitis, J.D. (July 1978). Radionuclide concentrations in New England seaweeds following the Chinese nuclear bomb test of March, 1978. U.S. DOE Environmental Quarterly Report. 342. pg. 57-77.
• Bowen, V.T. (March 1981). The environmental behavior of transuranic nuclides released from water cooled nuclear power plants. NUREG-CR-T658. U.S. Nuclear Regulatory Commission, Washington, DC.
• This is one of the most important studies ever executed pertaining to the environmental impact of reactor operations in the marine environment. Bowen detected tiny quantities of MYAPC plant-derived plutonium in Montsweag Bay. His three year contract was quickly terminated after one year and no further radiological surveillance of Montsweag Bay has been executed by any independent contractor. The licensee, through phony radiological environmental monitoring reports, has controlled all data documenting the environmental impact of plant operations since Hess' last report, the samples for which were taken in 1978.
• Churchill, J.H., Hess, C.T. and Smith, C.W. (March 1980). Measurement and computer modeling of radionuclide uptake by marine sediment near a nuclear power reactor. Health Physics. 38. pg. 327-340.
• Lutz, R.A. and Hess, C.T. (1980). Biological and radiological analysis of the potential of nuclear power plant effluent waters for shellfish culture. In: Power plant waste heat utilization in aquaculture. Godfriaus et. al. Eds. Montclair, NJ.
• Lutz, R.A., Incze, L.S. and Hess, C.T. (1980). Mussel culture and harvest: A north American perspective. Elsevier, Amsterdam.
• King, E. (1981). Citizens' monitoring network. Environmental Impact Assessment Review. 2. pg. 198-201.
• Murray, S. (1982). Retention of Co-60 by the sediments of Montsweag Bay, Maine. Oceanography. pg. 71.
• See also the two Hess reports listed below which were not listed in this review.

• This is the first brief summary of 25 years of state of Maine monitoring around the vicinity of MYAPC, with a main emphasis on the extensive Thermo-Luminescent Dosimetry (TLD) data collected at 86 locations. The report also includes a summary of intermittent sampling of various media from 1972 through 1996. The data presented in this report shows occasional peaks of contamination, both plant derived and from Chernobyl and weapons testing. The latest data from 1996 shows some contamination from liquid releases (⁶⁰Co, ¹¹⁰Ag, ¹³⁷Cs) associated with steam generator repairs.
• The recommendations in this report include additional sediment pathway sampling and a more comprehensive assessment of background radiation (¹³⁷Cs, ⁹⁰Sr). This report is a graphic illustration of the inadequacy of the mostly one dimensional state radiological monitoring (TLDs) and the near total lack of data pertaining to both the environmental impact of MYAPC operations and the background contamination from other anthropogenic source points (weapons testing, Chernobyl) which is essential to evaluate this impact. "The number of points measured is not steady over time. Firm conclusions are difficult when only a small burst of data are available." (pg. 122).

• This is the only citation pertaining to MYAPC derived liquid effluents in Montsweag Bay not included in our 1986 publication A Review of Radiological Surveillance Reports of Waste Effluents in Marine Pathways at the Maine Yankee Atomic Power Company at Wiscasset, Maine -- 1970-1984. This, the latest and last of Hess' studies of Montsweag Bay (except the 1997 update) is particularly significant in that it represents the termination of the study of the patterns of accumulation of plant-derived radionuclides in estuarine sediments.
• "The work described in this chapter ... describes a larger area in Montsweag Bay, after the opening of a causeway in 1974, which improved the flushing rate. This change was accompanied by the construction of a diffuser discharge system. In June 1975, on the bottom of the estuary 12 m below the surface, and 100 m from the site of the surface discharge outlet. New transects of sediment samples were taken, especially in the vicinity of the new diffuser discharge. Major modifications of the computer simulation were programmed to describe the new physical situation of the diffuser waste discharge." (pg. 270).
• "We describe sediment sampling, high resolution gamma-ray spectroscopy, data analysis procedures, and the resulting patterns of radionuclide distribution at the water-sediment interface." (pg. 270).
• "The quarterly release of liquid radioactive waste in 1975 was 9.6 x 10¹⁰ Bq of fission and activation products ... The fission and activation products are in some instances attached to bottom sediments which will become a source of radioactive material in the sea when the harbor is dredged or when physical changes occur in the estuary such as opening a causeway, thus releasing these sediments to the ocean." (pg. 271).
• "Sediment samples were collected on 9 November 1978 and measured for emitting radionuclides in the laboratory. The sampling sites were along transect lines approximately perpendicular to dominant tidal flow (Fig. 11.1)." (pg. 271).
• "...we have observed the following radionuclides: reactor-associated ¹³⁴Cs, ¹³⁷Cs, ⁶⁰Co, ⁵⁸Co, ¹³¹I, and ⁵⁴Mn; fallout associated ¹³⁴Cs, ¹³⁷Cs, ¹⁴⁴Ce, ⁶⁰Co, ¹³¹I, and ⁵⁴Mn; and natural ¹⁰K, ^217,214Pb, and ²¹⁴Bl. In order to present a clear picture of the distribution of radionuclides in an estuary system, an isobecquerel map for each nuclide was drawn. The iosbecquerel lines (isopleths) correspond to constant radionuclide concentration in sediment." (pg. 273).
• "The distribution of ⁵⁸Co in the estuary demonstrates high concentrations of ⁵⁸Co near the reactor diffuser outflow in the Montsweag Bay location." (pg. 273). Hess and Smith measured values in excess of 280 Bq/m² for ⁵⁸Co (1/2 t = 70.8 days) near the diffuser.
• "From previous studies with pre-operational and post-operational measurements (Hess et al., 1974, 1976), we know that about half of the ¹³⁷Cs measured in this estuary is fallout and the other half from reactor effluent." (pg. 282).
• "...the measured pattern of ¹³⁷Cs is profoundly different. The high concentration is not centered over the diffuser but is shifted to the north and east. The Montsweag Bay pattern is no longer east-west symmetric but shifted to the east, and the pattern in Bailey Cove is driven to the north. The highest values in the estuary are not at the diffuser but at the north end of Bailey Cove. These pattern changes may be explained by (1) the longer t_1/2 and longer residence time of ¹³⁷Cs which allows one to observe long term sediment transport trends such as wind and ice (seasonal changes), and (2) freshwater incursion into Bailey Cove which serves as an additional major source of the radionuclide. The latter is responsible for the high concentrations in the north of Bailey Cove, while the former is responsible for the general shift of the overall pattern to the north and east." (pg. 282). (The freshwater incursion introduces additional quantities of weapons testing derived ¹³⁷Cs into the bay whereas the wind and the ice redistribute what is primarily reactor-derived ¹³⁷Cs to the Westport Island shoreline.)
• Peak measured values for ¹³⁷Cs exceed 1,000 Bq/m² at the north end of Bailey Cove and 800 Bq/m² on the Westport Island shoreline.
• This research graphically illustrates the necessity for a thorough characterization of the environmental impact of MYAPC operations in the estuarine environment surrounding the Maine Yankee reactor. The research sponsored by the Sea Grant Programs in the early and mid-1970's documented significant impact of plant operations in Montsweag Bay up to the date of this study. As evidence accumulated of the dimensions of this impact on shellfish and as sediment loading, opposition to funding further environmental radiological surveillance programs grew both from the reactor licensees who paid for this research and within the NRC which didn't want to hear the bad news presented by Vaughn Bowen and others documenting microcontamination in Montsweag Bay. Hess's studies were terminated after the publication of this report, and no studies whatsoever of the accumulation of plant-derived radioisotopes in sensitive bioindicators such as sea vegetables have ever been executed at this or any other NRC licensed installation.

• This is the second and last in a series of reports by this organization, which had a network of monitors and monitoring devices in the area around MYAPC.  It was also the Citizens' Monitoring Network that was responsible for the legislative mandate which required MYAPC to provide daily summaries of its gaseous and liquid emissions including a dedicated telephone line solely for this purpose.
• This report also references one of the more controversial incidents in the dark age of nuclear power production in Maine:  the refusal of the state of Maine to support the purchase of a real time stack filter monitor for MYAPC, a device which would have provided a great deal of additional information about the gaseous releases that the Citizens' Monitoring Network has monitored since 1979. "CMN lobbied unsuccessfully for years to have a continuously-reading stack filter feeding information directly to the office of the Radiation Control department of the State Department of Health and Human Services." (pg. 2).
• "We noticed fairly early in the course of our observations that although we had monitoring instruments distributed fairly evenly within a ten-mile radius around the plant, all the alarms and high readings occurred at the stations which were situated near tidewater." (pg. 2).
• "We also notice that these events correlated pretty well with temperature inversions coinciding with still air or low wind velocities." (pg. 2).
• "It seems possible that the radiation that was setting off the monitors was associated with these particles of radioactive 'dust' trapped in fog or light rain which might be contaminated by gases trapped under a temperature inversion." (pg. 2).
• "The most striking of these patterns is; that incidents of high readings and alarms on the citizens' monitors, which had been fairly frequent up until the end of 1990 (especially during refuelling) began to drop off sharply." (pg. 3).
• "Most interesting of all is the observation that since the plant went into cold shutdown in 1997 there has been no abnormal activity on any of the monitors." (pg. 3).
• A graphic illustration of the lack of NRC licensee documentation of reactor-generated gaseous emissions and a disturbing reminder of how little is known about the real-time stack emissions from MYAPC's reactor during its years of operation.

• This report is a startling example of why the State of Maine has no role to play in the decommissioning of the Maine Yankee Atomic Power Company. The brief summary of principal issues on page five could easily been extracted from the Bangor Daily News. Almost every major issue confronting the State of Maine during the initial stages of decommissioning is avoided. A bizarre waste of natural resources (paper).
• The main focus of the report appears to be a listing of what state agencies will be examining issues related to decommissioning and waste disposal when in fact these agencies will be doing little or no examination of these processes. The main content of the report is Appendix H, a reprint of the totally inadequate Maine Yankee PSDAR. Appendix J is a reprint of the decommissioning cost estimates provided by TLG Services. The report also includes a summary of vacuous Joint Select Committee meetings and a summary of public hearing and written comments received by the committee which voice some of the issues that this report fails to address. The comments and questions included in this report by Friends of the Coast are its only redeeming quality.

• This report has been reproduced on our website in a special appendix.

• "This volume presents a compilation of important information on the full range of radioactive waste forms that have been developed, or at least suggested, for the incorporation of high-level nuclear waste." (on-line publisher description).
• "This is the first publication to draw information on nuclear waste forms for high-level wastes together into a single volume. ... Of particular interest is a performance assessment of nuclear waste borosilicate glass and the crystalline ceramic Synroc." (on-line publisher description).

• The gist of this investigative report can be summarized by the suggestion of the licensee that any excess values observed by Inspector Dostie were in fact fluctuations in background radiation which exceeded the average background radiation level programmed into the radiological surveillance equipment used in this trash sorting process. The setpoints of first 20 nCi and then 2 nCi (nCi = nanocurie = 1,000 picocuries) were allegedly set too low to account for peaks in the background radiation levels and thus the readings on the monitor indicating contamination of the trash were allegedly false readings.
• "The WCM-14 monitors the bag for the specified count time and compares the background counts stored in memory to the bag (item) count rate to obtain the net count rate for the bag. This net count rate is converted to nCi..." (pg. 15).
• "According to the MDA [Minimum Detectable Activity] analysis located in Attachment C, a realistic MDA for the bag monitor would have been 45 nanocuries which is above the alarm setpoints found in the records of 20 nanocuries and finally 2 nanocuries and also below similar setpoints recalled by interviewees." (pg. 17).
• "No evidence of free release of detectable (licensed) radioactive material was discovered and none is thought to have occurred because the release procedures from this period included steps which were in accordance with the guidance from the NRC. This process included three to five checks before any bag of trash from the RCA could be free released." (pg. 18).
• "Even though the concept of Minimum Detectable Amount (MDA) was not formally standardized until 1996 and was not applied to the bag monitor, a reasonable MDA analysis demonstrates that the recorded alarm setpoints in 1988 were below those that would be used today." (pg. 18).
• This investigation report was presented at an April 7 meeting and was accompanied by landfill testing results which included a page entitled Perspective on Alarm Setpoints. This perspective delineates four setpoints: background, an average value for which is incorporated in the detection equipment; 45 nCi, which would be a contemporary alarm setpoint in view of the new guidelines in MARSSIM which are cited in Appendix C of this investigative report; 100 counts, a frisk rate equivalent to 5,000 dpm/100cm²; and 5 MR/yr, the NRC guideline which is surpassed when contamination exceeds 5,000 dpm/100cm². The 100 count frisk rate equals the 5,000 dpm guideline considering the efficiency of the radiological surveillance equipment (10%) and the size of the window of the frisker, which is a fraction of 100 cm².
• At the April 7th meeting the MYAPC Radiology Protection Expert, James Mallon, was unable to answer this editor's question about the reporting units used in the Perspective on Alarm Setpoints. A more detailed perusal of this report indicates that the chamber volume was 10 cubic feet, the mininmal detectable activity for a 10 second count time was 5 nCi for ⁶⁰Co and 10 nCi for ¹³⁷Cs (10,000 pCi or 370 Bq). (pg. 29). Typical reporting units for the bags inserted into the chamber ranged from a weight of 1.21 lbs. up to a weight of 5.06 lbs. for a sample of 10 bags, the analyses for which are provided in this investigative report. This report indicates that a typical pound of trash contains 15,000 square inches of surface area. This equals approximately 97,500 cm² which yields a guideline count rate of about 4,875,000 dpm, which equals 2,393,750 pCi or approximately 2,394 nCi/lb. This is consistent with the licensee's perspective on alarm setpoints which equates a frisk rate of 100 counts per minute with 2,000 nCi/lb of trash being sorted for disposal as low-level waste or for free release.
• This investigative report and the incidents from which it derived are significant in that it opens a window of opportunity to consider dysfunctional federal guidelines for disposal of low-level radioactive wastes. The federal guideline of 5,000 dpm/100cm² for surface contamination has been extended to volumetric contamination as illustrated in this report. Attachment G contains relevant references which extend AEC Rule 1.86 to cover volumetric contamination. The latest NRC guideline is revision 4 of procedure 9.1.22 which dropped the release limit to < 60 ccpm. These guidelines as well as the entire report are available from the licensee.
• 2,000 nCi/lb (2,000,000 pCi) total activity of plant-derived isotopes represents a defacto NRC free release guideline for contaminated versus uncontaminated trash. This investigative report suggests that in the trash sorting process, licensee employees would often dispose of trash with less than 2,000 nCi/lb as low-level waste, but nonetheless current NRC guidelines allow disposal of trash containing radioactivity up to and even exceeding this figure as uncontaminated, i.e. "below regulatory guidelines." NRC licensees may argue that the most recent release limit of < 60 ccpm drops the effective nCi/lb guideline to approximately 1,400 nCi/lb, but any under circumstances guidelines of this type allow free release of trash and decommissioning derived debris at levels containing significant amounts of anthropogenic radioactivity.
• Of particular interest is the assertion by the licensee in the presentation of this report that wide variations in background radiation often exceed the background radiation level programmed into the monitoring equipment and that therefore any radiation levels above the programmed background and up to at least 45 nCi are in fact only background and not plant-derived radiation. This leaves open the question of contamination in the gray region between 45 nCi per package (1 - 5 lbs) and the NRC guidelilne of 2,000 nCi/lb (actually 2,394 nCi/lb). In this case, the licensee has implied that any readings above 45 nCi would result in the trash being treated as low-level waste. This raises the question of what actually occurs during trash sorting at all NRC licensed facilities not subject to the intense scrutiny that has resulted at MYAPC from both the decommissioning process and Pat Dosties allegations.
• This report also includes an interesting correspondence from J. Darman (NRC) to J. Mallon (MYAPC) about MDA alarm setpoint calculations. (Attachment C).
• "Guidance which may be applicable to the operation of the WCM-14 Bag Monitor includes: NRC IEC 81-07, which in part states that material should be checked with instrumentation and techniques necessary to detect 5000 dpm/100cm² ; and IN 85-92, which states in part that a good monitoring program likely would include an aggregate check of each bag of waste." (Attachment C).
• "Given that NRC IEC 81-07 states that material should be checked with instrumentation and techniques necessary to detect 5000 dpm/100cm², and that the waste bags monitored by the system contained an estimated 15,000 square inches of material per pound (Attachment 2), the maximum activity, per pound, which could have gone undetected if the material had been surveyed by conventional monitoring methods can be calculated as follows: (Attachment C).

15,000

inches2  lb

x 6.45

cm2  inches2

x 5000

dpm  100 cm2

x

nCi  2220 dpm

= 2180

nCi  lb

• "The least restrictive alarm setting of the WCM-14 may have been 20 nCi/lb. This alarm setting is 100 times more restrictive than NRC guidance in IEC 81-07." (Attachment C).
• The presentation made by MYAPC on April 7, including the Trash Sorting Allegation Investigation Report, provide compelling evidence that in fact the licensee did send trash to the Wiscasset landfill contaminated with small amounts of reactor-derived isotopes. The low levels of contamination which were probably sent to the landfill have little health physics significance and are unlikely to be detectable in future monitoring of local water resources. Nonetheless, the incident provides one more example of the superior abilities of NRC licensees to obsfucate on most any topic pertaining to reactor operations or decommissioning as well as illustrates the chaotic and uncertain nature of existing NRC regulatory guidelines. That all waste monitor alarm ratings above uniform background radiation level were in fact further variations in background radiation is disingenious as well as brash self-serving spin on an incident that could have many other interpretations.
• We will now proceed to decommission over 100 nuclear reactors with artificial MDA (Minimum Detectable Activity) setpoints for surface contamination, trash, contaminated stainless steel and piping, and any other media contaminated volumetrically which are well above background radioactivity levels (including weapons testing, weapons production, nuclear fuel cycle and Chernobyl-derived contamination.) These MDA guidelines, which are defined in MARSSIM as being a percentage of a site-specific value guideline (SSVG), also known as derived concentration guideline levels (DCGL), allow NRC licensees to evade documentation of the environmental presence of a wide variety of plant derived contaminants in a broad array of locations (from trash to reactor vessel components to contaminated sediments etc.) Use of these "minimum detectable activities," which have nothing to do with the minimum detection capabilities of the state of the art radiological surveillance equipment now available, constitute a defacto BRC (below regulatory concern) guideline which is much higher (more liberal) than earlier BRC guidelines proposed by the NRC and rejected by environmentalists. Unfortunately, media both in and outside of Maine are too witless to report on this as well as many other controversial subjects pertaining to nuclear reactor operations and decommissioning (e.g. siting reactor vessels with GTCC internal components intact, spent fuel fragments as a component of reactor vessel dross, lack of routine radiological surveillance data to validate a TEDE of 25 mrem/yr, etc.)

• For a discussion of this citation, see November 21, 1997 in Part 5-B: Decommissioning Chronicle.

• For a discussion of this citation, see November 21, 1997 in Part 5-B: Decommissioning Chronicle.

• For a discussion of this citation see Patterns of Noncompliance: II-C: Deficiencies in the MYAPC Site Characterization Process.
• We have scanned a few short sections onto the web: Survey Package Number: R0500 and Special Survey Package Number R2501.

• Copies of four pages of this document and a discussion of its implications can be found in CBM's May 10, 1999 press release and a more recent scanned version in an updated appendix.  See  RAD12-5E:  Maine Yankee Decommissioning Debacle: Decommissioning Chronicle Continued (January 1999 onward).

• "This report provides NRC staff responses to frequently asked questions on decommissioning nuclear power reactors." (pg. iii).
• "The major benefit of decommissioning for the licensee as well as the public is that the levels of radioactive material at the site are reduced to levels that permit termination of the license and use of the site for other activities, rather than leaving the radioactive contamination on the site so that it could adversely affect public health and safety and the environment in the future." (pg. 2).
• "Radioactive contamination is radioactive material that is deposited on a nonradioactive surface.  The material may be deposited from the air, or it may be dissolved in water and subsequently deposited into material such as concrete.  Radioactive contamination is generally located on or near the surface of materials like metal or high-density concrete or painted walls.  It would travel farther into unpainted surfaces or lower density concrete.  Radioactive contamination can usually be removed from surface areas by washing, scrubbing, spraying, or, in extreme cases, by removing the outer surface of the material." (pg. 3).
• "Contaminated materials are transported through the facility by workers, equipment, and to some degree through the air.  Although many precautions are taken to prevent the movement of contaminated material in a nuclear facility and to clean up any contaminated materials that may be found, it is most likely that contamination will occur in the reactor building, around the spent fuel pool, and around specific pieces of equipment in the auxiliary building.  The areas known to contain contamination are marked by the licensee, who routinely checks for contamination." (pg. 3).
• "Activation products are radioactive materials that were created when stable substances were bombarded by neutrons.  The radioactive decay of activation products is the main source of radiation exposure to plant personnel.  Radiation activation products can be anywhere reactor coolant circulates, leaks, or  is processed." (pg. 3-4).
• The above description of radioactive contamination is yet another glaring example of why the NRC cannot be trusted to document the residual radioactivity levels in all locations and media that are the legacy of power reactor operation.

• This New York Times article reports that the Connecticut Yankee plant in Haddam Neck, CT "... has been widely contaminated by two fuel leaks and other problems that the power company, Northeast Utilities, tried to cover up, state officials charged Tuesday."
• "What we have here is a nuclear management nightmare of Northeast Utilities' own making, ... The goal is no longer to decommission a nuclear power plant, but rather to decontaminate a nuclear waste dump. ... largely concealed from both regulators ... The state is exploring the possibility of criminal charges against the company and its officials..." (Attorney General Richard Blumenthal).
• "...the plant has had two 'significant' fuel failure events in which the thin metal cladding around the nuclear fuel rods was punctured or cracked. ... serious design flaws allowed the radioactive coolant to escape into outside areas. In particular, unmonitored floor and roof drains in radioactive areas of the plant deposited contaminated liquids directly into the soil and the discharge canal. ... Management was aware of these problems but did not take effective steps to resolve them." (State's consultant, James K. Joosten).
• "State officials said that if the contamination was serious enough, tons of radioactive soil and even the entire plant structure might have to be hauled away."
• The Maine Yankee Atomic Power Company has also experienced fuel leaks, both in the early years of operation (1970's) and more recently just prior to closure. It is unlikely state officials in Maine, key players in the collapse of the nuclear pyramid scheme here, would be as forthcoming about plant area contamination in Wiscasset as were officials in Connecticut.
• For information on recently filed Connecticut Yankee Decommissioning Plan see RAD 11:4: U.S. Nuclear Power Plants.

• "The Commission has considered that the level of protection referred to as 'adequate' must be maintained in licensed activities regardless of cost. As the economic environment evolves, the NRC will continue to regulate to that standard."
• "...there appears to be an informal consensus in the technical community that the reactors currently operating, as a group, are meeting the Commission's safety goals, thus exceeding the adequate protection standard."
• "I believe that neither the NRC nor the industry fully appreciates the difficulty of making the transition to a less regulated economic environment while continuing safety regulation."
• "If the O&M costs of nuclear units had remained below those of fossil-fueled plants, we might not be discussing whether nuclear units could survive in a competitive environment. I believe the industry and the regulators will now have to learn a similar lesson with respect to operating nuclear plants in a competitive environment, only this time we will have to learn it with fewer missteps because the safety net of guaranteed cost recovery will be gone."
• "...the rapidly evolving deregulation of the power generating industry raises questions concerning the availability of funds for safe operation and decommissioning. It seems evident that restructuring could cause a nuclear plant licensee to lose its direct access to ratebased cost recovery or other sources of funds."
• "The NRC staff is also trying to identify changes in the utility operating environment that could affect safety in other ways. One obvious example is the issue of grid reliability. Station blackout has been a significant safety issue in the past. Its ultimate resolution for currently operating plants has depended in part on the fact that offsite power sources are stable and reliable. The new competitive environment may change a number of conditions which affect the grid. Reserve margins may decrease. Larger quantities of power may be transmitted over longer distances. Transmission system operations may change. In particular, the separation of generation from transmission system operation raises concerns about the ability of the independent system operator to command the resources it may need to maintain reliability."
• "The concern I expressed was that it would be difficult to maintain that kind of free flow of [safety] information in an environment where competitive advantage and economic survival could depend to a degree on others not knowing too much about your business. I urged that the lines of communication so important to public safety be kept open."
• "Power reactor licensees simply cannot afford to let marginal performers fail for safety reasons."
• "Trying to manage to a standard of minimal acceptability simply won't work."
• The author of these comments on "adequate" safety standards is a former NRC Commissioner.

• "Although the federal Department of Energy may want to get nuclear waste shipments moving to Nevada as soon as possible, one problem could prevent that: There aren't enough containers to ship the waste."
• "According to Energy Department official Jim Carlson, there are just seven truck casks in existence and a handful of larger casks designed for trains. Together, they could move 100 to 200 tons of nuclear waste a year - far less than the 3,000 tons a year envisioned, said Carlson, director to the waste acceptance and transportation division of the department's Office of Civilian Radioactive Waste Management."
• "The department spent several years earlier this decade trying to develop a 'multi-purpose canister' that could be used to transport waste on either trains or trucks, and for interim waste storage as well. But then Congress cut funding for the program last year, and development stopped."

• A report commissioned by Citizens Awareness Network containing suggestions for a robust storage strategy for spent fuel as a component of a homeland security strategy that provides solid protection for US civilian nuclear facilities.
• A copy of the executive summary of this report is on our website.

• For annotations see RAD 12: Maine Yankee: G. Decommissioning Nightmare: November 9, 2000.

• This testimony by a former high ranking NRC official is a result of a state of Connecticut review of contamination problems at the Connecticut Yankee Atomic Power Company. These problems also resulted in the issuance of a special NRC inspection report. It reviews the details of Connecticut Yankee's history of failed radiological controls.
• The testimony includes important information about the origins and composition of reactor-derived hot particles. Also included in this report is an excellent definition of one subgenre of hot particles, CRUD.
• This FERC testimony is the most graphic illustration of NRC licensee loss of radiological controls available anywhere in unclassified documents available for public review. A complete hard copy may be ordered from the Office of the Attorney General, state of Connecticut or from the Center for Biological Monitoring.

United States Nuclear Regulatory Commission. (May 5, 1997). 10 CFR 50.72 Event report number 32423. U.S. NRC, Washington, D.C.

• Seabrook Power Reactor "has identified a condition which resulted in one of the principal safety barriers being degraded."  "The licensee identified four fuel assemblies that have leaking fuel rods."
• See NRC letter about this event in RAD12: Maine Yankee: Part E: Sept. 27, 1999.

United States Nuclear Regulatory Commission. (June 30, 1997). Licensee event report (LER) 97-009-00 degraded fuel rods identified in Westinghouse fuel assemblies. LER 50-443/97-009. U.S. NRC, Washington, D.C.

• "On December 10, 1996 Seabrook Station experienced a step increase in Reactor Coolant System (RCS)[AB] activity that was subsequently attributed to fuel cladding degradation." (pg. 1).
• See NRC letter about this event in RAD12: Maine Yankee: Part E: Sept. 27, 1999.

• "... in general, for those nuclear facilities where contamination exists in soils and/or structures, the analyses in Chapters 1 - 6 of this final GEIS shows, in a manner similar to the draft GEIS, that achieving an ALARA decommissioning objective of 'return to a pre-existing background' is not reasonable as it may result in net detriment or because cost cannot be justified because detriments and costs associated with remediation and surveys tend to increase significantly at low levels, while risk reduction from radiation exposure from criteria near background is marginal." (pg. 7-2).
• "...both the draft GEIS and the final GEIS find that there is a wide range of cost-benefit results among the different facilities and within facility types and that there is no unique algorithm which decisively is the most beneficial result for all facilities which could be set as a residual dose criterion." (pg. 7-2).
• "NCRP No. 116, Chapter 15, notes that no single source or set of sources under ones control should result in an individual being exposed to more than 25 mrem/y." (pg. 7-3).
• "NRC's Advisory Committee on Nuclear Waste [ACNW] noted that 15 mrem/y represented an unnecessarily conservative fraction of the 100 mrem/y annual limit. ... [The] ACNW stated that a value of 25 percent or 30 percent of the 100 mrem/y limit appears more justified and appropriate based on the likelihood that no more than 3 or 4 separate regulated sources will affect the critical group at any instance." (pg. 7-3 - 7-4).
• "...suggests that the 15 mrem/y value may be too restrictive for its intended purpose of constraining doses from this category of sources in establishing an appropriate boundary constraint, and rather leads to a conclusion that 25 percent of the public dose limit is a sufficient and ample fraction to use as a limitation or constraint for decommissioned sources in that it provides a sufficient and ample margin of safety for protection of public health and safety." (pg. 7-5).
• "...there appears to be a strong indication that removing and transporting soil to waste burial facilities to achieve exposure levels at the site at or below a 25 mrem/y unrestricted use dose criterion is generally not cost-effective when evaluated against the range normally considered justifiable under NRC's regulatory framework present in NUREG/BR-0058 and NUREG-1530." (pg. 7-6).
• "...there can be situations where restricting site use to achieve a TEDE of 25 mrem/y is a more reasonable and cost-effective option than unrestricted use. ... For restricted use, ... while removal of soil to levels below 25 mrem/y may not be cost-effective, other simple and less costly measures, such as fencing or landscaping may be cost-effective and should be considered as part of the ALARA process." (pg. 7-7).

• "On March 31, 1997, PGE [Port General Electric Company] requested that the Commission issue a Type B Certificate of Compliance (COC) under 10 CFR 71, which would allow the one-time shipment of a decommissioned RV [reactor vessel], together with its irradiated internals, under the general license provisions of 10 CFR 71.12. Under this proposal, the RV, together with its irradiated internals intact, would be transported from the Trojan Nuclear Plant near Portland, Oregon, by barge approximately 434 kilometers (km) (270 miles) up the Columbia River to the Port of Benton, Washington, and then by special transporter to a disposal site..."
• "PGE's request to ship the RV with its internals intact, represents a departure from the shipping arrangements envisioned by PGE. Previously, the licensee had planned to remove the irradiated internals from the RV prior to its shipment, with the internals being shipped separately in Commission certified shipping packages."
• "PGE, in proposing this shipment, has assumed that the RV, intact with internals, can qualify for near-surface disposal. The basis for this assumption is the Branch Technical Position on Concentration Averaging and Encapsulation, issued by the Office of Nuclear Material Safety and Safeguards on January 17, 1995. In contrast, if the internals were removed for shipment separately, it is probable some of the internals would be classified as GTCC wastes, and would not qualify for disposal at a near-surface disposal site. PGE estimates that about 340 cubic feet of reactor internals would exceed Class C limits. Staff estimates that GTCC components contain about 80 percent of the total activity proposed for disposal. These GTCC components would require storage at the Trojan site until a suitable repository or disposal site is approved. Shipping and disposal of the RV with internals intact, would, if approved, eliminate the need to provide on-site storage for GTCC RV components. It should be noted that the State of Washington has made a preliminary waste classification determination that the Trojan RV with its internals is consistent with NRC's Branch Technical Position on Concentration Averaging and Encapsulation and could be disposed of, with the reactor internals intact, at the U.S. Ecology, Inc., burial facility in the State of Washington."

• This report inspected the radiological controls program including the licensee's plans and activities associated with radiological characterization of the site for decommissioning planning purposes.

United States Nuclear Regulatory Commission. (March 1998). Standard review plan for transportation packages for spent nuclear fuel: Draft report for comment. NUREG-1617. Spent Fuel Project Office, Office of Nuclear Material Safety and Safeguards, U.S. NRC, Washington, D.C.

• "The Standard Review Plan for Transportation Packages for Spent Nuclear Fuel, referred to here as the Standard Review Plan (SRP), provides guidance for the U.S. Nuclear Regulatory Commission (NRC) safety reviews of packages used in the transport of spent nuclear fuel (SNF) under Title 10 of the U.S. Code of Federal Regulations (CFR), Part 71 (10 CFR Part 71)." (pg. 1).
• Of particular interest in this draft are the surface contaminated object (SCO) guidelines on page xix, which are divided into two groups, SCO-I and SCO-II.
• "SCO-I: A solid object on which:

(i) The non-fixed contamination on the accessible surface averaged over 300 cm² (or the area of the surface if less than 300 cm²) does not exceed 4 Bq/cm² (10^-4 microcurie/cm²) for beta and gamma and low toxicity alpha emitters, or 0.4 Bq/cm² (10^-5 microcurie/cm²) for all other alpha emitters;
(ii) The fixed contamination on the accessible surface averaged over 300 cm² (or the area of the surface if less than 300 cm²) does not exceed 4 x 10⁴ Bq/cm² (1.0 microcurie/cm²) for beta and gamma and low toxicity alpha emitters, or 4 x 10³ Bq/cm² (0.1 microcurie/cm²) for all other alpha emitters; and
(iii) The non-fixed contamination plus the fixed contamination on the inaccessible surface averaged over 300 cm² (or the area of the surface if less than 300 cm²) does not exceed 4 x 10⁴ Bq/cm² (1 microcurie/cm²) for beta and gamma and low toxicity alpha emitters, or 4 x 10³ Bq/cm² (0.1 microcurie/cm²) for all other alpha emitters." (pg. xix).
• "SCO-II: A solid object on which the limits for SCO-I are exceeded and on which:

(i) The non-fixed contamination on the accessible surface averaged over 300 cm² (or the area of the surface if less than 300 cm²) does not exceed 400 Bq/cm² (10^-2 microcurie/cm²) for beta and gamma and low toxicity alpha emitters, or 40 Bq/cm² (10^-3 microcurie/cm²) for all other alpha emitters;
(ii) The fixed contamination on the accessible surface averaged over 300 cm² (or the area of the surface if less than 300 cm²) does not exceed 8 x 10⁵ Bq/cm² (20 microcuries/cm²) for beta and gamma and low toxicity alpha emitters, or 8x 10⁴ Bq/cm² (2 microcuries/cm²) for all other alpha emitters; and
(iii) The non-fixed contamination plus the fixed contamination on the inaccessible surface averaged over 300 cm² (or the area of the surface if less than 300 cm²) does not exceed 8 x 10⁴ Bq/cm² (1 microcuries/cm²) for beta and gamma and low toxicity alpha emitters, or 8 x 10⁴ Bq/cm² (2 microcuries/cm²) for all other alpha emitters." (pg. xix).
• 8 x 10⁵ Bq/cm² (20 microcuries/cm²) equals 8,000,000,000 Bq/m², a new paradigm in contamination guidelines.
• Another indicator of the guidelines of the future: the definition of radioactive material on page xvii: "any material having a specific activity greater than 70 Bq per gram (0.002 microcurie per gram)." This equals 70,000 Bq/kg = 630,000 pCi/kg.

United States Nuclear Regulatory Commission. (August 1998). Draft regulatory guide DG-4006: Demonstrating compliance with the radiological criteria for license termination. Office of Nuclear Regulatory Research, U.S. NRC, Washington, D.C.

This publication is a follow-up to NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) as well as NUREG-1505 and 1507.  This publication elaborates "methods acceptable to the NRC staff for demonstrating compliance with the dose criteria in Subpart E of 10 CFR Part 20" (total effective dose equivalent of 25 mrem/yr to an average member of the critical group) including "methods acceptable to the NRC staff for conducting a final radiation status survey for buildings and soil prior to terminating the license"  and "methods acceptable to the NRC staff to demonstrate that residual radioactivity has been reduced to levels that are ALARA" (as low as reasonably achievable.) (pg. 2).

This publication summarizes the NRC regulatory position as developed in MARSSIM on dose modeling, use of derived concentration guidelines, use of generic screening and use of site-specific information.  "Licensees should justify their pathway models and justify the elimination of pathways from dose assessments." (pg. 4).

Particularly revealing is the following paragraph pertaining to methods for conducting a final status survey.  "The final status survey is the radiation survey performed after an area has been fully characterized, remediation has been completed, and the licensee believes that the area is ready to be released.  The purpose of the final status survey is to demonstrate that the area meets the radiological criteria for license termination.  The final status survey is not conducted for the purpose of locating residual radioactivity; the historical site assessment and the characterization survey perform that function."  (pg. 5).  [Editors note - baloney:  no adequate historical site assessment or characterization survey exists at any NRC licensed reactor.]

The size of the survey units suggested by MARSSIM provide the licensee with wide leeway in averaging concentrations of residual radioactivity over areas up to 10,000 m².

Table 2.1. Suggested Survey Unit Areas (MARSSIM, Roadmap Table 1).

Class	Suggested Survey Unit Area
	Structures - floor area	Land
1	up to 100 m2	up to 2000 m2
2	100 to 1000 m2	2000 to 10,000 m2
3	no limit	no limit

"Class 1 Areas:  ...impacted areas that, prior to remediation, are expected to have concentrations of residual radioactivity that exceed the DCGL_W. (DCGL_W is defined in the MARSSIM (Ref. 3).)"

"Class 2 Areas:  ...impacted areas that, prior to remediation, are not likely to have concentrations of residual radioactivity that exceed the DCGL_W."

"Class 3 Areas:  ...impacted areas that have a low probability of containing residual radioactivity." (pg. 6, 7).

An explicit re-affirmation of the federally sponsored evasion of documentation of the environmental impact of NRC licensed nuclear reactors.  Since these guidelines allow survey units of up to 10,000 m² of "remediated" contamination (read:  covered over with 6 - 36 inches of uncontaminated topsoil) and utilize surveys for surface contamination only (rather than detailed spectroanalyses of biological media), nuclear leaks and discharges of every size and description and the resultant residual radioactivity can be present in virtually any quantity and compliance can still be demonstrated by these contrivances for evasion (NREG-1575, MARSSIM and associated NRC guidelines such as 4006).

Bogus regulatory guidelines essentially written by and for an industry and its government sponsors, which, in order to survive, must evade the documentation of the environmental impact of reactor operations and decommissioning.  There is no alternative to these evasions, which have now been institutionalized in MARSSIM and the license termination process.  Billions of dollars in licensee profits are at stake and depend on the continued success of this evasion.

You may post comments on this draft at the NRC Technical Conference Forum.

• "This refers to the results of several NRC inspections conducted between July 15, 1996, and March 15, 1997, and three investigations of Maine Yankee Atomic Power Company (Maine Yankee) conducted by the NRC's Office of Investigations (OI) between December 1995 and October 1997.  The inspections included an Independent Safety Assessment (ISA), as well as several inspections conducted by resident and Region I based inspectors to follow-up on the ISA findings.  The purpose of the ISA was to determine whether Maine Yankee was in conformity with its design and licensing bases; to assess operational safety performance; and to evaluate Maine Yankee's self-assessment and corrective action processes."
• "The investigations concerned (1) the adequacy of Maine Yankee's small break loss-of-coolant accident (SBLOCA) emergency core cooling system (ECCS) analyses, (2) the submittal to the NRC of inaccurate information pertaining to the capacity of the facility's atmospheric steam dump valve, and (3) the failure to perform station test procedures as required by facility technical specifications."
• "With respect to the ISA and related inspections, the NRC has determined that numerous violations of NRC requirements occurred. ...[there were] broader programmatic deficiencies underlying the violations which contributed to the performance problems at Maine Yankee. ... Additional violations identified subsequent to the March 11, 1997, conference (Reference:  Inspection Report No. 97-01) are also included in this enforcement action..."
• NRC inspections considered the following issues:
• The operability of safety related equipment.
• "These violations are generally related to four broad categories, namely, the failure to :  (1) adequately test equipment; (2) environmentally qualify equipment; (3) perform adequate safety reviews; and (4) either identify deficiencies, or take appropriate corrective actions in a timely manner to address known deficiencies, including design related issues."
• "Some of the violations led to safety equipment being inoperable or degraded for extended periods contrary to technical specifications."
• Failures to adhere to Technical Specifications (TS).
• "Maine Yankee's testing process failed to detect a cut wire in the safety injection actuation circuit for a high pressure safety injection (HPSI) pump which would have prevented that pump from automatically starting, as required, during an accident.  This condition had apparently existed since 1991, but was not detected until 1996 after prompting by the ISA."
• Inadequate environmental qualification.
• "(1) 30 instruments which were either not qualified or could not be qualified for submergence during containment flooding following a loss of coolant accident (LOCA); and (2) the component cooling water pumps which were not qualified for a harsh environment in the turbine building."
• Failure to perform adequate design basis safety review activities.
• "These violations are significant because they are indicative of Maine Yankee's failure to maintain strict control of the design basis of the facility."
• Conditions for which corrective actions were not taken in a timely manner.
• "...a design deficiency that could have rendered the containment spray building ventilation system inoperable was identified in 1991, the degraded condition was allowed to exist for 5 years due to failure to recognize the significance of the deficiency and weaknesses in Maine Yankee's corrective action programs.  These violations are significant both because of their programmatic nature and ... result in safety-related equipment being degraded or inoperable for extended periods."
• "...6 violations associated with your small break-loss-of-coolant (SBLOCA) analyses (RELAP5YA)."
• "The two most significant violations involve your use of unacceptable evaluation models (EM) to determine emergency core cooling system (ECCS) performance for Cycle 14 and 15 operations, contrary to 10 CFR 50.46(a)."
• "Maine Yankee relied on engineering judgment to conclude that the ECCS analyses had identified and bounded the most severe postulated loss-of-coolant accidents.  This judgment was not well-founded."
• "The NRC considers these violations, ... very significant.  In fact, when this issue was first identified, the NRC issued an Order on January 3, 1996 modifying the facility operating license to derate the plant to the original licensed thermal power limit to regain the necessary assurance that ECCS performance was acceptable for continued operation."
• "Maine Yankee operated the facility without having demonstrated that its ECCS systems were capable of mitigating the most severe postulated loss-of-coolant accident. ...instabilities and oscillation of the peak cladding temperature and other parameters resulted in termination of the RELAP5YA SBLOCA computer run."
• "It should be noted that the issues which constituted the Severity Level II problem cited in Section I of Notice 2 were considered by the Office of Investigations (OI) as willful acts on the part of Maine Yankee and YAEC.  The staff, however, after thorough review of all the evidence concluded these violations were the result of poor judgment being exercised in both performing and reviewing analyses rather than on willful acts on the part of Maine Yankee personnel."
• "...its actions constituted violations of 10 CFR 50.46, the NRC accepts Maine Yankee's explanations that it believed in good faith that it had sufficient justification to conclude that the limiting break for the SBLOCA region had been properly identified. ... Maine Yankee did not try to conceal the fact that it was unable to analyze the entire small-break spectrum. For these reasons, the staff concludes that the violations were not the result of willfulness on the part of Maine Yankee."
• A comprehensive summary of the central issues which resulted in the closing of MYAPC.  Neither the licensee nor its ratepayers nor state and federal authorities had the resources or the rectitude necessary to insure the safe operation of the mYAPC nuclear power plant.
• The failures in the design, safe operation, administrative supervision, citizen review and state and federal oversight made possible an extraordinary situation where NRC licensees could escape the consequences of endangering public safety by the reckless for profit operation of a nuclear power facility.
• This Notice of Violation is documentation of and commentary on insipid and waffling federal oversight of the twilight of the nuclear era -- the NRC knows what the problems are but is unable to execute effective sanctions for what is ultimately a federally sponsored racketeering enterprise.

• Fuel cladding degradation at Seabrook Station; "factors contributing to the localized cladding corrosion included crud deposition." (pg. 1).
• See NRC letter about this event in RAD12: Maine Yankee: Part E: Sept. 27, 1999.

• "The Project Manager reported that several fuel rods were known to have been broken and were stored in the SFP [spent fuel pool] cask pit.  He indicated that to the best of his knowledge, the fuel rods had broken during handling in the SFP." (pg. 7).
• This is the first indication that fuel-derived contamination is present in the cask upending pit, which is apparently located at the bottom of the spent fuel pool(?), and also the first indication that spent fuel rods had broken during handling in the spent fuel pool area.
• This report also references the Maine Yankee Spent Fuel Pool Non-Fuel Gamma Spectroscopy Characterization dated November 22, 1999, saying that the characterization indicates "out of 48 non-fuel items scanned, one trash basket (BT-16), which records showed contained five filters, a pipe, and a rope, had an elevated Cs-137/Co-60 ratio and indicated the potential for the presence of spent nuclear fuel." (pg. 7).
• These reports leave unanswered the puzzle of how much fuel cladding failure-derived contamination was retrieved by the plant vacuum systems and is now in the filters in the spent fuel pool previously described by the licensee in its confidential report.  Obviously, the filters contain some fuel-derived contamination, otherwise, they wouldn't be in the spent fuel pool, but as per usual with misleading licensee and NRC wording, the gamma spectroscopy report would lead one to believe such contamination exists only in one group of filters when in reality they're in all the filters, but not in such great amounts that it would be classified as spent fuel.  What are the isotopic profiles and curic content of the filters and other debris in the spent fuel pool and how much radioactivity can they contain and still be classified as low level wastes?  The NRC and the licensee appear to be claiming that if there are not high levels of spent fuel fragments in the filters then there is none at all.  Therefore, what is in the other filters which may number in the hundreds?  It seems perfectly clear that fuel cladding-derived contamination can and will be shipped as low-level waste, the misleading wording of the spent fuel pool characterization notwithstanding.

• The annotations below were done on an October 2000 draft that was available on the NRC website.  This document is now available on the NRC's ADAMS system.
• This report projects theoretical casualties from a spent fuel pool zirconium fire in the tens of thousands of additional cases of cancer, with worst case scenarios in excess of 100,000, especially at recently filled spent fuel pools.  In the case of Maine Yankee, the risk from the ruthenium isotopes discussed in this report will be reduced to insignificant levels after five years cooling, i.e. shortly.
• This report fails to address the issues raised by David Lockbaum (Union of Concerned Scientists): oxygen intrusion into dry casks containing spent fuel and the resulting damage potential to the zirconium cladding.
• This report also contains no commentary on the safety issues of most interest to Maine Yankee area residents as well as tourists and other visitors to the central Maine coast: the twofold conundrum posed by the need to transfer spent fuel from wet storage (spent fuel pool) to dry cask storage.  Maine Yankee Atomic Power Company derived documents indicate approximately 20% of the spent fuel assemblies are damaged and cannot be stored safely in the dry cask mode.  The ultimate "safe" destination is unknown - there may, in fact, be no fail-safe technological solution for final disposition of damaged spent fuel assemblies.  David Lockbaum has raised a second conundrum by pointing out even undamaged fuel assemblies may not be safely stored in the dry cask mode for long periods of time.
• Other unresolved MYAPC decommissioning issues include the difficulty of decommissioning the spent fuel pool, the risk of transferring spent fuel to the dry cask mode (the above report does address the major safety issue of a crane accident during lifting of filled dry casks from wet storage to the ISFSI) and the ultimate destination of highly radioactive debris, reactor vessel GTCC components and fragments of broken fuel assemblies now in the wet storage mode at MYAPC.
• "In its thermal-hydraulic analysis, documented in Appendix 1A, the staff concluded that it was not feasible, without numerous constraints, to establish a generic decay heat level (and therefore a decay time) beyond which a zirconium fire is physically impossible.  Heat removal is very sensitive to these additional constraints, which involve factors such as fuel assembly geometry and SFP [spent fuel pool] rack configuration.  However, fuel assembly geometry and rack configuration are plant specific, and both are subject to unpredictable changes after an earthquake or cask drop that drains the pool.  Therefore, since a non-negligible decay heat source lasts many years and since configurations ensuring sufficient air flow for cooling cannot be assured, the possibility of reaching the zirconium ignition temperature cannot be precluded on a generic basis." (pg. ix).
• "...as long as a zirconium fire is possible, the long-term consequences of an SFP fire may be significant.  These long-term consequences (and risk) decrease very slowly because cesium-137 has a half life of approximately 30 years.  The thermal-hydraulic analysis indicates that when air flow has been restricted, such as might occur after a cask drop or major earthquake, the possibility of a fire lasts many years and a criterion of 'sufficient cooling to preclude a fire' can not be defined on a generic basis." (pg. ix-x).
• "Because the possibility of a zirconium fire leading to a large fission product release cannot be ruled out even many years after final shutdown, the safeguards provisions at decommissioning plants should undergo further review." (pg. x).