ML20212F252

Confirms That NMSS Has Received 990916 Submittal & Will Be Included as Attachment to Commission Paper Along with State of Maine Submittal

ML20212F252
Person / Time
Site:	Maine Yankee
Issue date:	09/20/1999
From:	Camper L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Vanags U MAINE, STATE OF
References
NUDOCS 9909280093
Download: ML20212F252 (4)

Text

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'oi j September 20, 1999 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 ,

For PUBLIC:

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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 l 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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September 20, 1999 Mr. Uldis Vanags State Nuclear Safety Advisor State of Maine l Executive Department State Planning Office j 38 State House Station  !

Augusta, ME 94333-0038 1

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. I The staff is currently developing the rubblization paper, and we will provide you a copy of the paper once it has been approved.

l 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: l e We see no physical characteristics distinguishing the proposed plan from a radioactive 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,

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

7 e' 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.

l

..ls 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? ,

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