ML20212B701

From kanterella
Jump to navigation Jump to search
Submits Comments & Raises Questions Re Generation of White Paper for Commission to Decide Merits of Rubberization
ML20212B701
Person / Time
Site: Maine Yankee
Issue date: 09/14/1999
From: Dostie P
MAINE, STATE OF
To: Greeves J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9909200214
Download: ML20212B701 (3)


Text

r:

w.^h 6

STATE OF M AINE DEPARTMENT OF HUMAN SERVICE 5 DivislON OF H EALTil ENGINEERING a

[

10 STATE HOUSE STATION l

AUGUSTA. M AINE ANGUS S KING.JR.

KEVIN W. CONCANNON September 14,1999 Mr. John T. Greeves, Director Division of Waste Management l

U. S. Nuclear Regulatory Commission l

Washington, D.C. 20555

Dear Mr. Greeves:

It is our understanding that the NRC staffis err. barking on generating a white paper for the Commission to decide the merits of rubblization, as envisioned by Maine Yankee and its decommissioning contractor, Stone & Webster. We are concerned that this technique raises policy issues not only for the Commission, but also for the State. We appreciate this opportunity to express our concerns and raise our questions to the Commission and the NRC staff. Besides our general comments below, additional remarks and queries are attached that expand upon the rubblization concept.

We believe that the rubblization concept represents a distinct departure from the traditional methods and philosophy that have guided past clean-ups.

If the proposed plan is approved, the radioactive inventory allowed to remain on-site will greatly exceed what the Commission has deemed appropriate for other decommissioning sites. We have difficulty supporting Maine Yankee's plan to rubblize concrete and urge you to seriously. consider the following concerns:

l We see no physical characteristics distinguishing the proposed plan from a radioactive i

j disposal facility. As such, we feel that it is inappropriate to terminate a license for any such facility.

In order to avoid certain reuse scenarios, Maine Yankee intends to flood the basements of rubblized s'.ructures by drilling holes in them.

We consider this to be an unsatisfactory method to avert the need to explore that scenario and, most importantly, an unnecessary contamination of the groundwater resource, which may not be bounded by the current Generic Environmental impact Statement (GEIS). In addition, l

we are very concemed about unknown long term risks associated with saturated concrete with pHs potentially in excess of EPA's toxicity level. This could possibly result in a hazardous condition to a natural resource.

There are no safeguards to ensure that, after license termination, any rubble remaining on-site, which exceeds free release standards, will remain on-site.

v 9909200214 990914 PDR ADOCK 0500o309 W

pop ftATUhw RhMll'P4M A OF FICE 157 CAPITOL STREET TTY (207) 287 2070 FAX: (207) 287 4172

. m...

STATE OF MAINE Comments on Rubblization If credit is taken for enginee ad barriers (the landfill configuration) and the leach rate for rubblized concrete (waste form), the licensee should be held to more appropriate dose models inclusive of the inadvertent intruder scenarios as required for 10 CFR 61 licensing for low-level waste facilities.

Since rubblization has no striking differences from the design of a low-level waste disposal facility, we question the wisdom of not also licensing the site as a Part 61 facility. In this light, we have specific concems that the plan may be generally in conflict with:

1. The extensive public hearing and siting requirements of a specifically licensed 10 CFR 61 facility;
2. Certain provisions of the Texas Low-Level Waste Disposal Compact;
3. The Maine Department of Environmental Protection's rules goveming the permitting of Construction and Demolition Debris;
4. A State Law stipulating that there is no level of radioactive waste below regulatory concern.

The current approach may lead to specific activities similar to those of a low-level waste facility, which is also held to a 25 mrem per year exposure limit to the public. However, unlike low-level waste facilities, the proposed landfill would have no ongoing monitoring requirements or institutional controls.

If licensable quantities of radioactive material remain on-site after license termination, why should the site not become a de facto 10 CFR 30 license? If the NRC has a defensible regulatory basis for stating that it is not a Part 30 license, we would appreciate the opportunity to review this basis.

Could holding contaminated concrete on-site for potential future dilution and backfill be construed as a conflict with the prohibitions relating to the dilution of waste streams of 10 CFR 207 Before rubblization is to take place, surrogate measurements of concrete to characterize the future rubble will need to be taken. Besides any number of unanswered practical and technical questions about this approach (such as effects on leach rate by acid rain or salt water intrusion, size of the rubble, etc.), there is no guidance from the NRC as to how the characterization should be performed.

Is it prudent and suitable to release a site that has specific activities of rubblized concrete that are in excess of acceptable levels if the buildings were left in a building configuration?

How applicable is the GEIS for decommissioned power plants for a disposal facility?

\\