ML20212M243
ML20212M243 | |
Person / Time | |
---|---|
Site: | Maine Yankee |
Issue date: | 09/22/1999 |
From: | Johnsrud J Environmental Coalition on Nuclear Power |
To: | Pittiglio C NRC |
References | |
NUDOCS 9910080234 | |
Download: ML20212M243 (4) | |
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September 22,1999 TO: C.L. Pittiglio", U.S. Nuclear Regulatory Commission FROM: J.H. Johnsrud, Ph.D., Director, Environmental Coalition on Nuclear Power (ECNP); Trustee, New England Coalition on Nuclear Pollution (NECNP); Chair, Sierra Club National Nuclear Waste division (For identification purposes only)
RE: Comment on Rubblization, Standard Review Plan for Decommissioning
' The Nuclear Regulatory Commission (NRC)is considering adoption of a policy, based on requests from licensees, to allow, as part of decommissioning of nuclear power plants and potentially ther nuclear facilities, the demolition of onsite structures at reactor plant sites and elsewhere (*rubblization"), and disposition of the rubble, either onsite as
" fill" or release of rubble offsite for disposal, presumably in solid l
waste landfills or as construction and demolition waste, or for recycle and reuse without restriction. ECNP and NECNP, with which I am associated, advise the NRC against, and strongly oppose, such a policy.
j Decommissioning Standards l
The NRC has chosen to set decommissioning criteria for license termination at an all-pathways dose level of 25 millirem per year plus ALARA to the average member of the critical group of those expected to be the most I
exposed at or on a site that is released for unrestricted use. This I
standard remains embroiled in controversy with the more restrictive EPA exposure standards of 15 mrem /yr and 4 mrem /yr ground water dose limits and with even more restrictive dose limits that may be imposed by the states subsequent to termination of NRC license and of federal preemptive authority. Either EPA or the state may then require additional decontamination of former nuclear reactor sites, at potentially quite significant additional costs to either the former or present site owner, in the past, NRC regulations have prohibited onsite disposal of low-level radioactive wastes (LLRW) altogether and had limited onsite storage of LLRW to merely five years. As the realities of LLRW disposal have set in
- in terms of costs and, for a time, the lack of an available disposal facility
- the NRC has relaxed its requirements. However, licensing of nuclear reactors in the first place carried, at the minimum, an implied contract with the resident public that the wastes generated by an operating reactor would be removed from the site for regulated disposal offsite. Now, however, the NRC has set exposure limits that will permit a utility to walk away from a site that remains less than fully decontaminated, and in cctuality will be allowed to be contaminated by residual radioactivity, which is in fact low-level radioactive waste.
l The maximum permissible dose limit to an individual member of the public from a regulated LLRW disposal facility is 25 mrem /yr. We are reminded that many years ago NRC did away with the allowance in 10 CFR 20 for h
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,a licensees to bury radioactive waste on their sites. At a surface reading of 25 mrem /yr, the buried concrete would fit the definition of a LLRW disposal facility " which in this instance may be correctly described as a
" dump." Should the buried concrete contribute that total portion of the permissible dose, the entire remainder of the site would need to be decontaminated to a level that would be below limits of even the best available detection equipment. As a result, there would be, in essence, no 1
ALARA. Moreover, ALARA is limited to a mere $2000 discounted per person rem of avoided dose. Its applicability to extensive rubblization might be very limited, or the costs might prove to be very high.. To our knowledge, the NRC has not addressed these impacts on decommissioning or their costs. (I would add, however, that providing for the costs of reactor decommissioning properly belongs in the purview of state public utility regulatory commissions, not the NRC.)
Of great concern is the likelihood that this approach would be consistent with, and could lead to, the mixing of clean and heavily contaminated soils in order to reach NRC's " acceptable concentration limits." If merely surf ace or shallow ( few inches) burial readings are allowed to be used, under the NRC's Regulatory Guide DG-4006, " Demonstrating Compliance with the Radiological Criteria for License Termination," or averaging of concentrations is allowed, the buried rubble and contaminated soils could in reality be substantially higher than was supposedly the intent of the Commission's Decommissioning Cnteria.
Impacts on Ground Water The consequence of onsite burial of radioactively contaminated concrete l
rubble would be the creation of the " bathtub"effect. This concern had earlier caused potential LLRW Compacts and Host States to require above grade monitored retrievable disposal technologies. But the NRC has chosen not to take account of ground water contamination in a manner that is consistent with other federal mandates for protection of drinking water supplies. The NRC cannot rely on speculation that any future leaching would be offset by binding below the burial trench (or platform if the flooring were not reduced to rubble, ignoring that cycles of dissolve and bind wih eventually concentrate the radiological contaminants at the bottom of the shallow land burial " basket," and outflow will occur.
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Impacts of Methods of Decontaminating and Rubblizing Concrete if the presumably hard, durable concrete of nuclear reactor-related structures is to reduced to rubble, the first step will have to be very 4
substantial decontamination. Since the entire post-license termination f
residual radioactivity doses will not be entirely from this one source, the j
clean-up will have to be to very low levels of remaining surface activity.
(
How deeply into the concrete will activity be detected? We recall that at
{
Three Mile Island Unite 2, contaminated water had soaked into the concrete walls to a substantial extent. Whether washing down the walls or mechanical removal
- chipping, scabbling, sand-blasting or other abrasive f
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)
T. -
~
techniques
- are ernployed, or potentially biological organisms currently being researched for effectiveness are used, all of the processes of decontamination prior to converting a building to rubble will result in potential additional doses to offsite populations that will not be included
'in calculations of remaining residual radiation for the final site survey _
that accompanies the licensee's license termination application at the end of the decommissioning process.' It would seems that they will be in a regulatory limbo, neither operational fish nor post-license termination fowl.
Entirely ~ unknown at this time would be potential adverse im' pacts of experimental biological agents on either human populations or other organisms that inhabit the biosystem. The uninvestigated long-term experimental nature of such methods must preclude them from consideration.
We are left with processes that will either contaminate water used for washing down the walls, or solvents that may form mixed wastes (vay costly to " dispose of"), or large amounts of dust, contaminated particulates which may be airborne for either short or long distances and deposited in lungs, or as dust which may be ingested, on agricultural land or in potable
- surface water supplies or enter the food chain via aquatic organisms, it would appear that any or all of these transport mechanisms will supply an added dose to human populations, either nearby or distant, that is not taken into account under operational dose limits or post-decommissioning
-limits. Workers as well as the public will be placed at additional risk for which they receive not comparable individual benefit.
Impacts on Air Quality-
. As described above, the decontamination processes prior to "taking down" structures will be expected to constitute additional airborne doses to workers and the public. The ability to demolish concrete buildings without creation of very large quantities of fine to coarse particulates
- dust
- is limited. Therefore, this process will add further to releases from the site in the cource of decommissioning, willlinger, will be available for uptake from the surrounding sudaces in moderate to' high wind, and to permeate the soil, washing downward eventually into ground water, or be
' associated with erosion and deposition with further opportunities to become airborne and received as inhalation doses onsite or offsite.
Other Consequences of Rubblization Since the NRC is also considering allowing release of por%ns of a nuclear power site during operation decommissioning of a reactor, there are unacceptable potentialities for " spreading the doses" that would ultimately a
result post license termination via rubblizing and then burying the rubble onsite prior to fractional deregulation. A future lessee, renter, or purchaser of the early released portion of a nuclear facility site might find him or herself liable for later remedial site decontamination and waste disposal. Both the quality and the fair market value of the land
- would thereby be diminished.-
i If the NRC allows " rad rubble" (as it will inevitably be called) to be released from the site, it will be recycled, and reused for industrial or consumer purposes under proposed " clearance levels" or " release of solid materials"
- or back to NRC's earlier terms for the same thing:
deregulation, de minimis or BRC. Whether recycled as construction fill, or roadbed materials, or simply dumped into solid waste or C&D landfills, this "slightly contaminated" rubble will be totally out of regulatory control and will add inevitably to unassessed radiation exposures, a thickening of the radiation environment for all far into the future. This is unacceptable, and we call on the NRC to drop the proposal and not to permit "rubblization or release.
The additive, cumulative, and potentially synergistic radiation exposures to the public, including those from interacting radiation in concert with other environmental contaminants will be ignored by the regulatory agency.
The impacts of such multiple, additive, cumulative, and synergistic sources and doses on human health at low doses are unknown. However, despite.the current er deavors on the part of both national and international agencies entrusted to protect, not damage, human health or the quality of the environment to relax radiation standards, to deny the existence of low-dose and low dose rate irradiation that may affect humans in the form of non fatal, non cancer illnesses and disorders and to return to the unsubstantiated theory of a " safe threshold" of radiation exposure, or even to hormesis, or " adaptive response," the trend of progressive regulators is in the opposite direction. In other nations, under consideration is the obligaticn for radiation protection standards for all organisms the comprise the ecosystems in which we live: protection for the environment for its own sake. The United States should be leading the way.
Thank you for this opportunity to comment.
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