ML20212A598

Expresses Appreciation for with Respect to e-mail Message Re Site Release Criteria Standards Can Never Be Verified Using Existing Database

ML20212A598
Person / Time
Site:	Maine Yankee
Issue date:	08/16/1999
From:	Brack S AFFILIATION NOT ASSIGNED
To:	Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20212A597	List: ML20212A591 ML20212A598
References
NUDOCS 9909170072
Download: ML20212A598 (3)

Text

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, From: - Skip Brack <sbrack@ acadia. net >

~To: . "Bellamy, Ron" <rrb1@nrc. gov >, "Beranek, Ann - NUR...

Date: Mon, Aug 16,199911:33 AM ,

Subject:

Site release criteria standards -

. August 16,1999 -

172 Russell Senate Office Building L

Washington, DC 20510 l

Dear Senator Collins:

I Thank you for your letter of July 30,1999, with respect to my email

- message. I wish to clarify the main point of my email:. site release criteria standards can never be verified using the existing database. That doesnzt mean that theoretically extensive radiological surveys could not be l' ' implemented in the future that would differentiate between the 25 mrem /yr and 10 mrem /yr exposure standards, the latter being the one advocated by Friends of the Coast. It is my personal opinion that in view of the many .

, problems with MYAPC historical site assessment in the past, (a subject l which I have written about extensively in Pattems of Noncompliance: The l Nuclear Regulatory Commission and the Maine Yankee Atomic Power Company: ,

l Generic and Site-Specific Deficiencies in Radiological Surveillance :  !

Programs,) the detailed laboratory spectroanalyses of samples from the abiotic and biotic media surrounding Maine Yankee Atomic Power Company -

, necessary to verify any site release criteria is very unlikely, it is also .

l extremely expensive.

l Who would pay for such a detailed analysis of the environmental impact of l MYAPC operations? Who would determine what kind of catch-up surveys need to be implemented to make such detailed and exacting analyses of the impact

. of the Maine Yankee operations? Isnzt there a major conflict of interest

! between the pressures to keep decommissioning expenses low and the hign cost of accurate radiological monitoring? How can we depend on the Community Advisory Panel to oversee accurate analyses of the site release criteria when in fact the CAP (as well as Maine media, the NRC, the state

~of Maine and even all our Congressional representatives,' including your

! ' office) looked the other way when it became evident the licensee was not l _ being truthful about the radiological status of the MYAPC site. It was the ll licensees own "Duratek Site Characterization Management Plan," as inadequate and misleading as it was, as well as their own inventory of .

, damaged fuel assemblies and vacuum filters containing spilled fuel pellets, 1 l which provided (the smoking gun) evidence of multiple incidences of l l; loss-of-radiological controls at MYAPC. This licensee provided information l was given further emphasis by blatant inaccuracies in MYAPC Licensee Event l Reports filed with the NRC that failed to adequately describe the actual source term and pathways of liquid effluent spills that allowed some of the fission products released by fuel cladding failure accidents at MYAPC (first and last cycles) to enter soils surrounding the reactor containment and along and outside of the fence line on the west side of the plant.

So, here we have a situation at Maine Yankee where there have been a variety of incidents, events, and accidents, of which reactor water system

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,.f leaks have only been the tip of the iceberg. Everyone has looked the other way and pretended that the information provided at the CAP meetings by the licensee has been accurate and that the existing database derived from the

[ annual environmental radiological surveys has been adequate. And now, Mainers foremost environmental organization, Friends of the Coast, proposes a very strict site release criteria. Arenzt we missing something I in-between? How is this site release criteria to be verified when we ,

havenAt admitted that a series of small nuclear accidents have occurred at MYAPC and that they have had an environmental impact which has not been carefully documented? How much radioactivity was released into MYAPC water g systems when fuel cladding failure occurred in the first and last cycles l and fuel pellets spilled into the reactor containment? How much of this radioactivity was released to soil and Montsweag Bay sediments by accidentalleaks in the 1980As? By the deliberate planned decommissioning-related water tank discharges which occurred last year?

What other accidents occurred in-between these events (e.g. what lead to the extensive contamination on Bailey Point?) What are the current liquid and air particulate discharges during this time of frantic decommissioning activities - which must be executed as soon as possible because the Barnwell, SC, low-level radioactive waste facility will probably close by the end of the year? Who is overseeing the environmentalimpact of these frenzied activities and how will this rush to decommissioning impact the MYAPC environment? (An important side issue here: when Barnwell closes, what happens to the reactor vessel and all the accident debris it contains?

What happens to the nonstandard debris in the spent fuel pool, some of which may not fit into dry casks as currently designed? How will all this effect the site release criteria?)

Accurate determination of the environmentalimpact of MYAPC normal operations, accidents, accidental releases and frenzied decommissioning activities is extremely complicated, requiring exacting scientific measurements in the form of laboratory spectroanalyses, not unreliable gamma drive-over or walk-over seans. Site release criteria can never be l

verified without a much more e . tensive analysis of the historic impact of past plant activities including a detailed accounting of the source term (release inventories, pathways and destinations) of the fuel cladding j failure accidents of the past.

I object to Maine Yankee Community Advisory Panel activities because they i have never admitted that extensive loss-of-rr diological controls have I occurred in the past. In particular, the CAP (a well as the press, the I state of Maine, the NRC) went along with licensee representations about a l

clean site which were clearly contradicted by the data in volume 6 of the i

• Duratek Site Characterization Management Plan," including the secret  !

surveys hidden at the end of this volume. If the CAP is not going to admit that a series of fuel cladding failure and other accidents contaminated reactor water systems which then leaked contamination into the environs around MYAPC, how can site release criteria be accurately be verified?

DoesnEt the frenzied decommissioning of an ur' documented accident site further complicate site release criteria verification? What happened at Maine Yankee, when and why? How much radioactivity was released, where did 1 it go, where is it now? Why wonIt anyone admit the accidents of the past?

i; l CH AIRMAN - Site release criteria stand #rds Paga 3l IKd welcome any further comments from you and your staff, about what I call the 6 dysfunctional 6 decommissioning of MYAPC. On Thursday, August 19, at 5:05 PM, I will be hosting a WERU radio call-in show about MYAPC and the current objections of the licensee to further soil testing by the state of Maine. I would welcome input or questions from your staff or anyone else who receives a copy of this letter. Interested persons may call WERU 89.9 FM during the 55 minute program, werd like to hear what you have to say about the site release criteria and whether the state should or could execute additional soil samples; call (207) 469-0500.

.Thank you again for your letter in response to my previous email correspondence.

Yours truly, H. G. Brack Center for Biological Monitoring, Inc.

Sponsor of RADNET: Nuclear Information on the internet SOURCE POINTS OF ANTHROPOGENIC RADIOACTIVITY World Wide Web at http://home. acadia. net /cbm BOX 144, HULLS COVE, ME 04644-0144 207/288-5126 67h7

, FAX:207/288-2725 EMAIL: sbrack@ acadia. net i

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