Similar Documents at Maine Yankee |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217J0241999-10-13013 October 1999 Documents 991005 Telcon Between NRC & Util to Address All of Areas Identified in Reg Guide 1.179 & NUREG-1700 Re Final Survey Plan Except for One Area ML20217N8371999-10-13013 October 1999 Forwards Summary of Changes Made to Maine Yankee Defueled Security Plan,Iaw 10CFR50.54(p)(2).Without Encl ML20212F4321999-09-24024 September 1999 Responds to 990921 e-mail to E Poteat,Requesting Waiver of Late Charges of Listed Amount for Annual Fee Invoice AR0431-99.Request Denied Because 10CFR15.37 Does Not Provide for Waiver Based on Info Provided in e-mail ML20212M2431999-09-22022 September 1999 Expresses Concern Re NRC Consideration of Adoption of Policy Based on Requests from Licensees,To Allow as Part of Decommissioning of Nuclear Power Plants & Demolition of Onsite Structures at Reactor Plant Sites ML20212E4611999-09-20020 September 1999 Responds to Concerning Possible Involvement in Weekly Telephone Calls NRC Staff Has with Maine Yankee Staff ML20212F1361999-09-20020 September 1999 Confirms That NMSS Has Received 990916 Submittal & Will Be Included as Attachment to Commission Paper Along with State of Maine Submittal ML20212F2521999-09-20020 September 1999 Confirms That NMSS Has Received 990916 Submittal & Will Be Included as Attachment to Commission Paper Along with State of Maine Submittal ML20212B7011999-09-14014 September 1999 Submits Comments & Raises Questions Re Generation of White Paper for Commission to Decide Merits of Rubberization ML20212A5911999-09-0808 September 1999 Responds to 990816 e-mail & 990901 Telcon with Respect to Comments Re Decommissioning of Maine Yankee Site.Concerns Raised with Respect to Status of Fuel at Maine Yankee Have Been Raised in Previous Ltrs to Us NRC ML20211M9371999-08-30030 August 1999 Addresses Two Issues Raised in s to Senator Collins & Governor a King That Relate to Construction of ISFSI at Maine Yankee ML20212B2181999-08-30030 August 1999 Responds to Re 990707 Message from N Allen Re Transportation Incident Involving Shipment from Maine Yankee Nuclear Power Plant ML20212E4841999-08-27027 August 1999 Informs That at 990429 Meeting of Myap Community Advisory Panel,R Shadis,Asked If Given Lack of Resident Inspectors & Limited NRC-license Review Correspondence,If Shadis Could Take Part in Weekly NRC Conference Calls with Licensee ML20216F1891999-08-26026 August 1999 Forwards Copies of Maine Yankee & Yankee Rowe Refs Listed, Supporting Industry Position That Branch Technical Position Asb 9-2 Methodology over-estimates Spent Fuel Decay Heat ML20211C0591999-08-19019 August 1999 Forwards Addl Justification for Proprietary Request Re 990809 Submittal Info on Maine Yankee License Termination Plan ML20212A5981999-08-16016 August 1999 Expresses Appreciation for with Respect to e-mail Message Re Site Release Criteria Standards Can Never Be Verified Using Existing Database ML20210Q7201999-08-0909 August 1999 Forwards non-proprietary & Proprietary Draft Documents Re Info on Myap License Termination Plan & Diskette.Proprietary Info & Diskette Withheld ML20217M6501999-08-0909 August 1999 Responds to 990719 E-mail Re Cleanup Stds at MYAPC Station & Verification of Meeting Cleanup Stds.Informs That NRC Criteria for Licensing NPPs Contained in 10CFR50 & That 10CFR50.82 Addresses Requirements for License Termination ML20211D7041999-08-0909 August 1999 Forwards Rev 17 of Maine Yankee Defueled Safety Analysis Rept (Dsar), Per 10CFR50.71 & 10CFR50.4 ML20212B2271999-08-0606 August 1999 Discusses Concerns Re Recent Incindent Involving Transport of Nuclear Matl from Maine Yankee ML20210M8171999-08-0505 August 1999 Forwards Draft License Termination Plan/Amend Plan for Maine Yankee Atomic Power Co, to Enhance Dialogue Between Various Stakeholders & Provide Springboard for Clarifying Mutual Expectations.With Three Oversize Drawings ML20210L2211999-08-0202 August 1999 Forwards Two Copies of Objectives & Sequence of Events for Maine Yankee Emergency Preparedness Exercise for 990922. Without Encl ML20210G3751999-07-28028 July 1999 Ack Receipt of June 30th Ltr That Responded to EDO Backfit Appeal Determination Re Bdba in Sfps.Staff Completed All Actions Associated with Backfit Appeal & Awaiting for New Info for Consideration Prior to Taking Addl Action ML20216D4311999-07-19019 July 1999 Informs That Util Intends to Construct ISFSI Located on Owner Controlled Property Currently Part of Maine Yankee Reactor Site ML20217M6571999-07-19019 July 1999 Expresses Concern Re Verification of Cleanup Stds at Maine Yankee Atomic Power Co Power Station ML20210C6271999-07-15015 July 1999 Forwards Draft Site Characterization Summary in Support of 10CFR50 License Termination & Copy of Latest Decommissioning Schedule with Milestones Identified.Info Submitted Per License Termination Plan ML20196K4751999-07-0606 July 1999 Informs That Confirmatory Orders ,830314,840614 & 960103 Have Been Rescinded.Staff Determined That Due to Permanently Shutdown & Defueled Status of Facility,Orders No Longer Necessary for Safe Operation & Maint.Se Encl ML20209C7731999-06-30030 June 1999 Responds to EDO Backfit Appeal Determination Re Emergency Plan Exemptions for Decommissioning Plants ML20210G3981999-06-30030 June 1999 Discusses Review of Ltr Re Maine Yankee Backfit Appeal with Respect to Emergency Plan Exemptions for Decommissioning Plants ML20209B4611999-06-29029 June 1999 Submits Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. Plant Is Y2K Ready.Contingency Plans Developed to Mitigate Potential Impact of non-plant Y2K-induced Events ML20196D9191999-06-22022 June 1999 Informs That NRC Has Completed Review of Issues Raised in of Appeal to NRC Edo.Submits List Summarizing Actions Taken Since ML20195H1741999-06-15015 June 1999 Forwards Original & Copy of Request for Approval of Certain Indirect & Direct Transfer of License & Ownership Interests of Montaup Electric Co (Montaup) with Respect to Nuclear Facilities Described as Listed ML20207H3371999-06-11011 June 1999 Expresses Appreciation for Participation at 990413 Reactor Decommissioning Public Meeting & Responds to Concern Re Absense of Timeliness on Part of NRC Replying to Letters ML20195G9411999-06-10010 June 1999 Informs That Maine Yankee Considers Backfit Claim & Appeal Request of 980716 & 990316,to Be Acceptably Resolved Based on Staff 990518 Response ML20195F6721999-06-0707 June 1999 Forwards Insp Rept 50-309/99-01 on 990214-0513.No Violations Noted.Operations & Radiological Protection Programs, Including Radioactive Liquid & Gaseous Effluent Control Programs,Were Inspected During Insp ML20195F7531999-06-0707 June 1999 Forwards Copy of Insurance Endorsement Dtd 990429,reflecting Change in Nuclear Energy Liability Insurance,Iaw Requirements of 10CFR140.15(e) ML20206U9711999-05-18018 May 1999 Responds to & Addl Info Re Appeal of NRC Determination Re Claim of Backfit Concerning Permanently Shutdown Reactor Security Plan ML20207A2851999-05-14014 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization, Division of Licensing Project Mgt Created.Organization Chart Encl ML20206H1391999-05-0505 May 1999 Forwards Amend 164 to License DPR-36 & Safety Evaluation. Amend Consists of Changes to License in Response to 970930 Application ML20206H2311999-05-0404 May 1999 Responds to to Chairman Jackson.Forwards Copy of Recent Staff Response to Petition Submitted on Behalf of Ucs Re Fuel Cladding at Operational Reactors ML20206G5561999-05-0303 May 1999 Forwards Amend 163 to License DPR-36 & Safety Evaluation. Amend Revises Liquid & Gaseous Release Rate Limits to Reflect Revs to 10CFR20, Stds for Protection Against Radiation ML20206J2801999-04-30030 April 1999 Forwards 1998 Annual Financial Repts for CT Light & Power Co,Western Ma Electric Co,Public Svc Co of Nh,North Atlantic Energy Corp,Northeast Nuclear Energy Co & North Atlantic Energy Svc Corp,License Holders ML20206D7191999-04-29029 April 1999 Forwards Listed Radiological Repts for 1998 Submitted IAW Relevant Portions of License DPR-36 & ODCM ML20206E3101999-04-28028 April 1999 Forwards Data Diskette Containing 1998 Individual Monitoring NRC Form 5 Rept,Per 10CFR20.2206(b).Without Diskette ML20206E2911999-04-28028 April 1999 Requests NRC Review of ISFSI Licensing Submittals,As Scheduled & ISFSI Approval for Operation by Dec 2000.Util Will Support Any NRC RAI on Expedited Basis.Licensing Milestone Schedule,Encl ML20206A5521999-04-23023 April 1999 Forwards Environ Assessment & Finding of No Significant Impact Related to Util Application Dtd 980714,for Amend to License DPR-36 to Revise App a TSs to Change Liquid & Gaseous Release Rate Limits to Reflect Revs Made to 10CFR20 ML20206A6871999-04-22022 April 1999 Informs of Completion of Review of Re Nepco in Capacity as Minority Shareholder in Vermont Yankee Nuclear Power Corp,Yaec,Myap & Connecticut Yankee Atomic Power Co ML20205K6541999-04-0707 April 1999 Submits Nuclear Property Insurance Coverage Presently in Force to Protect Maine Yankee at Wiscasset,Me ML20205N6211999-04-0707 April 1999 Ack Receipt of Which Appealed NRC Staff Determination That Util Had Not Raised Valid Backfit Claim in to Nrc.Staff Began Process of Convening Backfit Review Panel to Evaluate Appeal ML20206H2401999-03-30030 March 1999 Informs That Myap Recently Revealed That Approx 20% of Fuel Assemblies Now in SFP Are non-std & Require Special Handling & Dry Cask Packaging.Info Confirms Growing Evidence of Periodic Loss of Radiological Control ML20206A6951999-03-29029 March 1999 Request Confirmation That No NRC Action or Approval,Required Relative to Proposed Change in Upstream Economic Ownership of New England Power Co,Minority Shareholder in Vermont Yankee Nuclear Power Corp,Yaec,Myap & Connecticut Yankee 1999-09-08
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20212F4321999-09-24024 September 1999 Responds to 990921 e-mail to E Poteat,Requesting Waiver of Late Charges of Listed Amount for Annual Fee Invoice AR0431-99.Request Denied Because 10CFR15.37 Does Not Provide for Waiver Based on Info Provided in e-mail ML20212F2521999-09-20020 September 1999 Confirms That NMSS Has Received 990916 Submittal & Will Be Included as Attachment to Commission Paper Along with State of Maine Submittal ML20212E4611999-09-20020 September 1999 Responds to Concerning Possible Involvement in Weekly Telephone Calls NRC Staff Has with Maine Yankee Staff ML20212F1361999-09-20020 September 1999 Confirms That NMSS Has Received 990916 Submittal & Will Be Included as Attachment to Commission Paper Along with State of Maine Submittal ML20212A5911999-09-0808 September 1999 Responds to 990816 e-mail & 990901 Telcon with Respect to Comments Re Decommissioning of Maine Yankee Site.Concerns Raised with Respect to Status of Fuel at Maine Yankee Have Been Raised in Previous Ltrs to Us NRC ML20212B2181999-08-30030 August 1999 Responds to Re 990707 Message from N Allen Re Transportation Incident Involving Shipment from Maine Yankee Nuclear Power Plant ML20211M9371999-08-30030 August 1999 Addresses Two Issues Raised in s to Senator Collins & Governor a King That Relate to Construction of ISFSI at Maine Yankee ML20217M6501999-08-0909 August 1999 Responds to 990719 E-mail Re Cleanup Stds at MYAPC Station & Verification of Meeting Cleanup Stds.Informs That NRC Criteria for Licensing NPPs Contained in 10CFR50 & That 10CFR50.82 Addresses Requirements for License Termination ML20210G3751999-07-28028 July 1999 Ack Receipt of June 30th Ltr That Responded to EDO Backfit Appeal Determination Re Bdba in Sfps.Staff Completed All Actions Associated with Backfit Appeal & Awaiting for New Info for Consideration Prior to Taking Addl Action ML20196K4751999-07-0606 July 1999 Informs That Confirmatory Orders ,830314,840614 & 960103 Have Been Rescinded.Staff Determined That Due to Permanently Shutdown & Defueled Status of Facility,Orders No Longer Necessary for Safe Operation & Maint.Se Encl ML20196D9191999-06-22022 June 1999 Informs That NRC Has Completed Review of Issues Raised in of Appeal to NRC Edo.Submits List Summarizing Actions Taken Since ML20207H3371999-06-11011 June 1999 Expresses Appreciation for Participation at 990413 Reactor Decommissioning Public Meeting & Responds to Concern Re Absense of Timeliness on Part of NRC Replying to Letters ML20195F6721999-06-0707 June 1999 Forwards Insp Rept 50-309/99-01 on 990214-0513.No Violations Noted.Operations & Radiological Protection Programs, Including Radioactive Liquid & Gaseous Effluent Control Programs,Were Inspected During Insp ML20206U9711999-05-18018 May 1999 Responds to & Addl Info Re Appeal of NRC Determination Re Claim of Backfit Concerning Permanently Shutdown Reactor Security Plan ML20207A2851999-05-14014 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization, Division of Licensing Project Mgt Created.Organization Chart Encl ML20206H1391999-05-0505 May 1999 Forwards Amend 164 to License DPR-36 & Safety Evaluation. Amend Consists of Changes to License in Response to 970930 Application ML20206H2311999-05-0404 May 1999 Responds to to Chairman Jackson.Forwards Copy of Recent Staff Response to Petition Submitted on Behalf of Ucs Re Fuel Cladding at Operational Reactors ML20206G5561999-05-0303 May 1999 Forwards Amend 163 to License DPR-36 & Safety Evaluation. Amend Revises Liquid & Gaseous Release Rate Limits to Reflect Revs to 10CFR20, Stds for Protection Against Radiation ML20206A5521999-04-23023 April 1999 Forwards Environ Assessment & Finding of No Significant Impact Related to Util Application Dtd 980714,for Amend to License DPR-36 to Revise App a TSs to Change Liquid & Gaseous Release Rate Limits to Reflect Revs Made to 10CFR20 ML20206A6871999-04-22022 April 1999 Informs of Completion of Review of Re Nepco in Capacity as Minority Shareholder in Vermont Yankee Nuclear Power Corp,Yaec,Myap & Connecticut Yankee Atomic Power Co ML20205N6211999-04-0707 April 1999 Ack Receipt of Which Appealed NRC Staff Determination That Util Had Not Raised Valid Backfit Claim in to Nrc.Staff Began Process of Convening Backfit Review Panel to Evaluate Appeal ML20205D5141999-03-26026 March 1999 Forwards Ser,Accepting Util 980819 Request for Approval of Rev 1 to Util CFH Training & Retraining Program.Rev 1 Adds Two Provisions to CFH Training Program & Changes One Title ML20196K9111999-03-26026 March 1999 Forwards Insp Rept 50-309/98-05 on 981101-0213.Determined That Two Violations Occurred Based on Insp Results & Review of 1997 LER Prior to Permanent Shutdown Determined That Addl Violation Occurred.Violations Treated as NCVs ML20205G7431999-03-26026 March 1999 Documents 990224 Telcon During Which Issues Raised in to NRC Were Discussed.Issues Discussed Re Appeal of Directors Decision on Claim of Backfit Re Beyond DBA in SFPs ML20205D4011999-03-26026 March 1999 Responds to Sent to Lj Callan Re Emergency Preparedness & Financial Protection Exemption Requests Made by Util & Requests Meeting Scheduled at NRC Headquarters Be Rescheduled & Held in Vicinity of Myaps ML20204C4501999-03-16016 March 1999 Forwards Amend 162 to License DPR-36.Amend Revises App a TSs of Subj License to Change Limiting Condition for Operation for Fuel Storage Pool Water Level from 23 Feet to 21 Feet ML20204F2481999-03-15015 March 1999 Responds to Expressing Concern Re 10CFR61, Licensing Requirements for Land Disposal of Radwaste & Perceptions of Insufficient Radiological Monitoring of NRC Regulated Facilities.Addresses Issues Raised ML20205G9801999-03-15015 March 1999 Responds to to Chairman Jackson of Nrc,Expressing Concerns Related to 10CFR61, Licensing Requirements for Land Disposal of Radioactive Waste ML18107A6911999-02-25025 February 1999 Responds to 990218 e-mail Re Listed Questions Concerning SFP Partial Draindown Analysis Info ML20203H1901999-02-19019 February 1999 First Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety ML20203B9001999-02-0808 February 1999 First Partial Response to FOIA Request for Documents. Forwards Documents Listed in App a Already Available in PDR, Documents in App B Released in Entirety & Documents in App C Being Withheld in Part (Ref Exemption 6) ML20203D6751999-02-0303 February 1999 Responds to Requesting NRC Evaluate Two Issues Pertaining to Maintaining Isolation Zones & Vehicle Barrier Sys as Backfits Under 10CFR50.109 ML20199C9031999-01-0707 January 1999 Forwards Exemption from Certain Requirements of 10CFR50.54(w) & 10CFR140.11 for Util.Exemption Issued in Response to Licensee Application Dtd 980120,requesting Reduction in Amount of Insurance Required by Facility ML20198J9181998-12-23023 December 1998 Refers to 981109 Response to Notice of Violation Re Violations Stemming from Independent Safety Assessment Team Insp ML20198J3831998-12-21021 December 1998 Reesponds to Which Continued to Raise Several Concerns Re Belief That NRC Regulatory Action Resulted in Loss of Nuclear Generation & Put Industry Future at Risk. Assures That NRC Addressing Impact of Policies on Licensees ML20206N7481998-12-15015 December 1998 Responds to Re NRC Regulatory Oversight of Maine Yankee Atomic Power Station.Although Staff Does Not Agree with Charges That Staff Acted Inappropriately & Ineffectively,Ltr Referred to NRC OIG for Action ML20196G0291998-12-0202 December 1998 Forwards EA & Fonsi Re Util Request for Exemption from Financial Protection Requirement Limits of 10CFR50.54(w) & 10CFR140.11 for Plant,Submitted in Ltr of 980120 ML20196G2751998-11-27027 November 1998 Forwards Insp Rept 50-309/98-04 on 980803-1031.No Violations Noted.During three-month Period Covered by Insp Period, Conduct of Activities During Continued Decommissioning at Maine Yankee Facilities Was Safety Focused ML20195C3771998-11-0606 November 1998 Discusses Directors Decision Re Maine Yankee Atomic Power Co Claim of Backfit Re beyond-design-basis Accidents in Spent Fuel Pools.Copy of Author Memo to NRR Staff Directing Them to Address Issues Encl IR 05000306/19960091998-10-0808 October 1998 Discusses Results of Several NRC Insp Repts 50-306/96-09, 50-309/96-10,50-309/96-11,50-309/96-16 & 50-309/97-01, Conducted Between 960715 & 970315,three Investigations Repts 1-95-050,1-96-025 & 1-96-043 & Forwards Notice of Violation ML20154J3421998-10-0808 October 1998 Responds to Forwarding Response of 2 Individuals to NRC DFI Issued 971219 to Yaec & Duke Engineering & Services Inc.Dfi Did Not Require Response from Individuals Identified in DFI as LOCA Group Mgr & Lead Engineer ML20154J8451998-10-0808 October 1998 Responds to Which Forwarded Response to NRC Demand for Info Issued on 971219 Re OI Rept 1-95-050. Related Ltr Also Issued to Maine Yankee Identifying Apparent Violations ML20154J4511998-10-0808 October 1998 Responds to Which Replied to NRC DFI Issued 971219 to Yaec & Duke Engineering & Services,Inc.Nrc Staff Completed Review of Responses of Yaec & Duke Engineering & Services Inc & 2 Individuals ML20154J4361998-10-0808 October 1998 Responds to Forwarding Response of Duke Engineering & Services,Inc to NRC DFI Issued 971219 to Duke Engineering & Services,Inc & Yaec ML20154D7271998-10-0202 October 1998 Forwards RAI Re Spent Fuel Pool & Fuel Assemblies.Response Requested within 30 Days of Date of Ltr ML20154A9041998-09-28028 September 1998 Forwards Insp Rept 50-309/98-03 on 980503-0801.No Violations Noted.Insp Exam of Licensed Activities as They Relate to Radiation Safety & to Compliance with Commission Regulations ML18066A2981998-09-23023 September 1998 Forwards RAI Re GL 97-01 Degradation of Cibtrol Rod Drive Mechanism Nozzle & Other Vessel Closure Head Penetrations Responses for Plant & Relationship of Responses to Topical Report CE NPSD1085 ML20153G0941998-09-18018 September 1998 Refers to CAL 1-96-15 Issued on 961218 & Suppl Issued 970130,confirming That Facility Will Not Restart Until Addl Actions Were Completed.Issues That Were Subj of CAL & Suppl Were Re Operation of Facility & Not Permanent Shutdown ML20153C0851998-09-16016 September 1998 Responds to 980723 e-mail to Senator SM Collins of Maine Re Several Concerns Raised About Disposal of Reactor Vessel from Maine Yankee Atomic Power Station.Nrc Made No Generic Decision,Acceptable for All Rv with Internal Components ML20197J5931998-09-16016 September 1998 Informs That on 980903 NRC Granted Exemption to Maine Yankee Atomic Power Co from Certain Sections of 10CFR50 Re Emergency Response Planning,Allowing Licensee to Discontinue Offsite Emergency Planning Activities 1999-09-08
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'oi September 20, 1999 j
L Mr. Uldis Vanags.
State Nuclear Safety Advisor
~ State of Maine Executive Department.
State Planning Office -
' 38 State House Station -
. Augusta, ME 04333-0038' q
1
SUBJECT:
THE STATE OF MAINE'S COMMENTS ON THE RUBBLIZATION APPROACH j
. FOR DECOMMISSIONING
Dear Mr. Vanags:
This letter is to confirm that we have received your September 16,1999, submittial, and it will be included as an attacnment to our Commission Paper along with the State of Maine's submittial dated September 14,1999. The Commission Paper discusses the rubblization approach for decommissioning nuclear power reactors that is currently being considered by some licensees.
The staff is currently developing the rubblization paper, and we will provide you a copy of the paper once it has been approved.
We appreciate your timely response. If you have any questions, please contact Larry Pittiglio, of i
my staff, 'at (301) 415-6702 or at cloanrc.aov.
Sincerely,
[0riginal signed by:]
. Larry W. Camper, Chief j
Decommissioning Branch Office of Nuclear Material Safety and Safeguards SCIRf CLfMP er For PUBLIC:
Th'is document should IX/ should not / / be made available to the PUBLIC 9/17/99.
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l-Mr. Uldis Vanags -
, State Nuclear Safety Advisor-State of Maine Executive Department ~
State Planning Office..
38 State House Station.
. Augusta, Maine 04333-0038.
SUBJECT:
THE STATE OF MAINE'S COMMENTS ON THE RUBBLIZATION A ROACH FOR DECOMMISSIONING.
Dear Mr.'Vangs:
- This letter is to confirm that we have received your September 14,1999, ubmittial, and it will be included as an attachment to our Commission Paper. The Commis n paper discusses the rubblization approach for decommissioning nuclear power reactors th is currently being considered by some licensees. The staff is currently developing the bblization paper, and we will provide you a copy of the paper once it has been approved.
We appreciate your. timely response.. If you have any question, please contact Larry Pittiglio.
I He can be reached at (301) 415-6702 or at clo@nrc.aov.
Sincerely, Lar W. Camper, Ghief D ommissioning Branch fice of Nuclear Material Safety and Safeguards For PUBLIC:
- This document should /X/ sho d not / / be made ayallable to the PUBLIC 9/17/99.
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l September 20, 1999 Mr. Uldis Vanags State Nuclear Safety Advisor State of Maine Executive Department State Planning Office j
38 State House Station Augusta, ME 94333-0038
SUBJECT:
THE STATE OF MAINE'S COMMENTS ON THE RUBBLIZATION APPROACH FOR DECOMMISSIONING
Dear Mr. Vanags:
This letter is to confirm that we have received your September 16,1999, submittial, and it will be included as an attachment to our Commission Paper along with the State of Maine's submittial dated September 14,1999. The Commission Paper discusses the rubblization approach for decommissioning nuclear power reactors that is currently being considered by some licensees.
The staff is currently developing the rubblization paper, and we will provide you a copy of the paper once it has been approved.
We appreciate your timely response. If you have any questions, please contact Larry Pittiglio, of my staff, at (301) 415-6702 or at clo@nrc.cov.
Sincerely, l
W.
La W. Camper, Chief De cmmissioning Branch Office of Nuclear Material Safety and Safeguards l
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. September 14,1999 l
Mr. John T. Greeves, Director m
Division of Waste Management,
U. S. Nuclear Regulatory Commission
' Washington, D.C. 20555
Dear Mr. Greeves:
'It is our understanding that the NRC staff is embarking 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, additiona! 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 j
supporting Maine Yankee's plan to rubblize concrete and urge you to seriously consider j
' the following concerns:
We see no physical characteristics distinguishing the proposed plan from a radioactive e
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 structures 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,
.we are very concerned about unknown long. term risks associated with saturated
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L concrete with pHs potentially in excess of EPA's toxicity level. This could possibly result in a hazardous condition to a natural resource.
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There are no safeguards to ensure that, after license termination, any rubble remaining on-site, which exceeds free release standards, will remain on-site.
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STATE OF MAINE Comments on Rubblization L
If credit is taken for engineered 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 h
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 concerns 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 governing the permitting of Construction and Demolition Debris;
- 4. ALState 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.
. lf 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.
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. s it prudent'and suitable to release a site that has specific activities of rubblized concrete
.l 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?
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