ML20212C226
| ML20212C226 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 09/16/1999 |
| From: | Vanags U MAINE, STATE OF |
| To: | Greeves J, Myers D NRC, NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| FRN-63FR41604, RTR-REGGD-01.XXX, TASK-*****, TASK-RE 63FR41604-00009, NUDOCS 9909210181 | |
| Download: ML20212C226 (3) | |
Text
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38STATEllOUSih h AUGUSTA, M AINE ANGUS S. KING JR.
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'"a'c' a uIBUhliShC sp-a Mr. David Myers U.S. Nuclear Regulatory Commission t
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Mr. John T. Greeves, Director Division of Waste ?'n at U.S. Nuclear Rg :.;viy Commission Washington D.C. 20555 Dear Mr. Myers and Mr. Greeves The State of Maine, Division of Health Engineering (under the signatory of State Nuclear Safety Inspector, Patrick J. Dosue), submitted comments to you on M-14,1999 concerning Draft Regulatory Guide DG-4006, " Demonstrating Compliance with the Radiological Criteria for License Termination", and the issue of rubblization of contaminated concrete at the Maine Yankee Nuclear Power Station.
- I respectfully request your consuleration to accept additional comments from the State ofMaine that are attached with this letter. The comments pertain to the subject matenal described above and should be considered as an addendum to the submissions from the Division of Health Engineenng. The comments are authored by Dr.
Geotge E. Chabot of the University of Massachusetts at Lowel who is presently one of four members of the Governor's Techmcal Advisory Panel on the Decommissioning of Maine Yankee.
I greatly appreciate the cooperation the U.S. NRC has extended to the State of Maine on the
<t~~==issioning of the Maine Yankee plant. Should you have any questions concerning this submission, please contact me at 207.287.8936 or e-mail uldis.vanans@ state.me.us.
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State Nuclear Safety Advisor i
Attachment:
Comments from Dr. George E. Chabot, 2 pages Cc:
Mr. Patrick J. Dostse, State Nuclear Safety inspector, Division of Health Engineering Dr. Philip Haines, Dep. Dir., Bureau of Health Mr. Clough Toppan, Dir., Division of Health Engineering Mr. Jay Hyland, Mgr., Radiation Control Program Dr. George E. Chabot, Governor's Technical Advisory Panel p'
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OFFICES LOCATED ATz 184 STATE STREET PilON E: (207) 287-3261 Internets www. state.me.us/spo FAX: (207) 287 6489
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Comments Concerning the Proposal to Rubblize and Bury Contaminated Concrete on Licensee's Site - George E. Chabot Regarding the decision being considered to allow rubblization of contaminated concrete from buildings on-site and burial of the rubble in the ground, or in the foundation cavities of buildings, it seems to me that such action involves adoption of a philosophy that is different from and, in some respects, contrary to the philosophy of ALARA as we have cc...K.anly practiced it. In order to meet the goal of 25 mrem TEDE per year, with the added consideration ofimplementing the ALARA philosophy to reduce the dose further within certain cost-benefit resvaints, the usual approach has been to reduce the degree of in-place contamination such that when residual contamination is left in-place doses to the average member of the critical group will not exceed the ALARA objective. The proposed approach seems to be contrary to this in that, rather than reducing in-place activity to meet the ALARA objective, it actually involves increasing activity in an otherwise clean environment and, by such a process, increasing the TEDE of concern to the acceptable value. This process of on-site relocation of radioactivity as a means of meeting ALARA goals and the 25 mrem TEDE requirement seems inconsistent with the ALARA approach as it has been practiced in the past. It is highly likely that by rubblizing building concrete and burying it on-site, one would be able to leave considerably more activity on-site than would be the case if the contaminated buildings were left standing -i.e., they would have to be decontaminated to a greater extent in order to meet legal and ALARA requirements.
Independent of the economic costs involved, the notion of being " reasonably achievable",
embodied in ALARA, seems to be violated in this type of approach. I find it unlikely that most members of the public would buy off on this solution as being " reasonable", and I suspect that many electricity rate-payers would opt to pick up the cost for what they would deem to be a more reasonable approach (e.g., off-site shipment and disposal) rather than accept the on-site burial.
A similar situation might be envisioned for a site with some soil contaminated by one or more radionuclides. Under usual practices, the licensee would be required to reduce the soil contamination, normally by excavation and removal to an appropriate off-site waste
' disposal site, so that the residual radioactivity would meet the 25 mrem per year and
'ALARA requirements. A licensee might propose, using the rationale being considered by the Commission, that the requirements could be met by excavating some of the contaminated soil from the area of concern, excavating clean soil from another area on the site, mixing the clean soil with the contaminated soil, and reburying the mixture in what was a clean area on the site. Such an action as this might be appropriate if an analysis was done that demonstrated that the TEDE to the member of the critical group would be greater for off-site disposal of the contaminated soil (or concrete) than for on-site retention and dispersal; otherwise I would expect the action to be viewed in a negative light by many involved persons, including members of the NRC and EPA as well as members of the public.
. One might make a technical argument that, since the same TEDE might result from the proposed action of on-site burial as from other alternatives, such as leaving buildings in-L
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place, the proposed action should be acceptable. (Obviously if the option was to ship all l
the contaminated concrete off-site no dose would result for the resident farmer scenario, although some dose might accrue to a member of a different critical group.) At the least, however, the proposed course of action seems to violate the spirit of the concept of ALARA, and it may even violate some of the NRC's ow a directives and/or recommendations. For example, I would note that the NRC, many years ago, did away with the allowance in 10CFR20 for licensees to bury radioactive waste on their sites. The proposal being considered, if approved, would certainly appear to be reinstituting such an allowance and appear to be inconsistent with NRC desires and intentions.
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