ML20205G984

Discusses 1997 Maff - Sepa Radioactivity in Food & Environ

ML20205G984
Person / Time
Site:	Maine Yankee
Issue date:	01/05/1999
From:	Brack S AFFILIATION NOT ASSIGNED
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20205G983	List: ML20205G980 ML20205G984
References
NUDOCS 9904080008
Download: ML20205G984 (3)

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[ CHAIRMAN - MAFF - SEPA Radioactivity in Food and the Environment,1997 ~ Page 1[ ]

a From: Skip Brack <sbrack@p2. acadia. net >

]

To: GATED.nrcsmtp("nallen@p2. acadia. net") q Date: Tue, Jan 5,1999 4:33 PM

Subject:

. MAFF - SEPA Radioactivity in Food and the Environment,1997 j To whom it may concem:

The Center for Biological Monitoring has recently reviewed the latest edition of " Radioactivity in Food and the Environment,1997." (See

]

http://iame. acadia. net /cbm/ Rad 3c.html# RIFE-3) As a result of this review we have issued the following notice of violation which reiterates one of the most important of numerous violations cited in our June,1998 report

" Patterns of Noncompliance: The Nuclear Regulatory Commission and The Maine Yankee Atomic Power Company: Generic and Site-Specific Deficiencies in Radiological Surveillance Programs", We provide the following copy of today's notice for those who are interested in deficiencies in NRC l' radiological surveillance programs. Please feel free to contact us if you would like to obtain a copy of either or both of these publications.

Dear Shirley Jackson:

Enclosed is 1) a summary of generic NRC and NRC licensee violations of 10  ;

CFR Chapter 1, Part 60, especially 61.53 - 61.55 and 2) a copy of RIFE-3, i Radioactivity in Food and the Environment,1997, published by MAFF and the Scottish Environment Protection Agency (SEPA), the review of which occasioned this complaint. It is my observation that the NRC has neither the intellectual nor financial resources needed to upgrade current radiological surveillance programs to meet the challenges of the new millennium.

Yours truly, H. G. Brack cc: NRC Commissioners 10 :01 65 W January 5,1999 nas ng g,

Subject:

Generic NRC and NRC licensee (MYAPC) violations of 10 CFR Chapter 1, Part 60 10 CFR Chapter 1, Part 60 clearly mandates the systematic monitoring of all radionuclides contained in the wastes destined for near-surface land l disposal (661.53). Isotopes listed in Tables 1 and 2 (661.55) include long-lived radionuclides *whose potential hazard will persist long after such precautions as institutional controls, improved waste form and deeper disposal have ceased to be effective.* The Duratek Site Characterization Survey (1998) for the Maine Yankee Atomic Power Company (MYAPC) and a wide variety of historic licensee and other site assessments clearly document the environs of MYAPC as a radioactive waste disposal area. MYAPC and the l 9904080008 990315 l

PDR ADOCK 05000309 H PDR

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. l CHAIRMAN - MAFF - SEPA R&6is&ciivity in Food and the Environment,1997 Page 2] )

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NRC failed _to ' execute accurate environmental monitoring during reactor operations and during ecommissioning activities that included discharge of 290,000 of the 300,000 gallom af reiesctive water in the reactor water j

storage tank (RWST) during the spring of 1998, among other discharge, j These deficiencies have been exacerMtM by tha failure to evaluate, . 1 monitor or document the environmc,dmiimpact of the 1984 accident also involving the RWST, and other inadvertent plant-derived liquid and hot i particle discharges from 1972 1998. MYAPC has been, in effect, the I location of a small nuclear accident-in-progress. As such, the environs of MYAPC, including Montsweag Bay and the Sheepscot River Basin, are clearly an unmonitored, undocumented radioactive waste disposal area. The NRC and MYAPC, the licensee, are in habitual and generic violation of the requirements of 10 CFR Chapter 1, Part 60 et. al., especially that of

$61.53 mandating environmental monitoring of the

• impacts of ... operation

. . of a land disposal facility.*

Enclosed is a copy of RIFE-3, the third annual survey of radioactivity of food in the environment, published by Ministry of Agricultural Fisheries -

and Food (MAFF) and the Scottish Environmental Agency (SEPA), a review of which by the Center for Biological Monitoring prompted this citation. The RIFE-3 report is sent to you as an example of a comprehensive radiological surveillance program which includes extensive analyses in a wide variety of media of long-lived radionuclides characterizing spent fuel and reactor operations. The monitoring in the RlFE-3 report includes analyses for hard to detect (HTD) isotopes such as those listed in Tables 1 and 2 of 561.55 and includes H-3, C-14, S-35, Co 60, Zn-65, Sr-90, Zr-95, Nb-95, Tc-99, Ru-103, Ru-106, Ag-110m, Sb-125,1-125,1-131, Cs-134, Cs-137, Co-144, Eu-154, Eu-155, Pu-238, Pu-239+240, Pu-241, Am-241, Cm-242, Cm-243, u .d Cm-244 (See page 74 as a typical example.) The RlFE surveillance program clearly documents nuclear installation-derived plumes of many nuclides including Am-241, Eu-155, Pu-238, Pu-241, the surprising and widespread uptake of Tc-99 by lobsters and the ubiquitous contamination of trie environment by Cs-137.

No such unclassified comprehensive monitoring program has ever been undertaken by the NRC, the DOE or the EPA in the vicinity of any U.S.

reactoi or weapons production installations. The monitoring program in RIFE-3 provides a compelling and graphic contrast to the deficiencies in NRC surveillance programs discussed in Pattems of Noncompliance: The Nuclear Regulatory Commission and the Maine Yank % Atomic Power Company:

Generic and Site-Specific Deficiencies in Radiological Surveillance Programs issued by the Center for Biological Monitoring in June of 1998.

- The der,ciencies in NRC radiological surveillance programs are a component of a wider pattem of NRC licensee noncompliance and illegal activities (e.g. in Maine, the power uprate scam). The failure to implement comprehensive 10-61 type monitoring, as exemplified by the enclosed MAFF and Scottish Environmental Protection Agency reports, is consistent w1th the ongoing failure of timely funding of radioactive waste storage and disposal costs or of accurate documentation of nuclear accidents of the type that occurred at MYAPC in 1984.

Citizen Advisory Panels (CAPS), such as the one now convened for MYAPC l

J

l CHAIRMAN - MAFF - SEPA Radioactivity in Food and the Environment,1997 Page 3 l decommissioning, serve as facilitators of these evasions, omissions and illegal activities. The current CAP at MYAPC serves as a buffer, ensuring that ratepayers pay the full cost of the 'entitlements* derived from the traffic in nuclear waste. MYAPC stockholders, who should be responsible

- for these liabilities (including upgraded radiological monitoring) up to the full value of their equity in the participating companies, are, consequently, protected from any loss of profits. The fundamental purpose of federal oversight of the nuclear energy debacle is to perpetuate the l omissions and evasions which maintain stockholder immunity from these liabilities. Insufficient radiological monitoring is the first essential step in this program of institutionalized evasions.

j The failure of the NRC and its licenwes to comply with 10 CFR Part 60 et.

al. by monitoring environments used as defacto radioactive waste disposal ,

areas provides the legal bases for halting all reactor operations and '

decommissioning activities until a comprehensive monitoring program, such as that illustrated by the enclosed MAFF-SEPA report, is implemented.

\

Center for Biological Monitoring, Inc.

q Sponsor of RADNET: Nuclear information on the intemet i

SOURCE POINTS OF ANTHROPOGENIC RADIOACTIVITY '  ;

World Wde Web at http://home. acadia. net /cbm BOX 144, HULLS COVE, ME 04644-0144 207/288-5126 '

FAX:207/288-2725 EMAIL: sbrack@ acadia. net CC: " Ben Meilkejohn" <mezenben@aol.com>, " Bob Cummings..

I l