ML20216F878
| ML20216F878 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/13/1998 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20216F861 | List: |
| References | |
| ASB-300-98, NUDOCS 9803190128 | |
| Download: ML20216F878 (162) | |
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OFFICIAL 1 TRANSCRIPT OF PROCEEDINGS
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4 UNITED STATES OF AMERICA 1 I
NUCLEAR REGULATORYfC'OMMISSION
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Title:
' :PUBLIC MEETING'
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'(YANKEE NUCLEAR POWER STATION t M LICENSE TERMINATION PLAN)-
Docket No.:-
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. Work Order _No.: ASB-300-98 -V L
- LOCATION: Shelbourne, MA1 <
- DATE: Tuesday, January 13,1998 . PAGES: 1 - 117 4
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l ANN RILEY & ASSOCIATES, LTD.
12501 Street, NW, Suite 300 O Washington,D.C. 20005 (202) 842-0034 1
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1 1 UNITED STATES NUCLEAR REGULATORY COMMISSION
-3' 4 ***
5 PUBLIC MEETING 6 YANKEE NUCLEAR POWER STATION 7 LICENSE TERMINATION PLAN 8 ***
9-10 11 Mohawk Regional High School 12 26 Ashfield Road 13 Shelbourne, Massachusetts
'14 O
(ms/ 15 Tuesday,. January 13, 1998 16 17 18 The public meeting commenced pursuant to notice at 19 7:00 p.m.
20 2:
22 23 24 25
() ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
2 s 1 PROCEEDINGS
() 2 [7:10 p.m.]
3 MR. COUNCILMAN: I'd like to begin the meeting.
4 My name is Brad Councilman. I'm a selectman in 5 the Town of Montague and the current chair of the Frar.klin 6 Regional Council of Governments.
7 I think it's important to note that this is not a 8 meeting of the Franklin Regional Council but, rather, a 9 meeting of the NRC. I was asked to chair the meeting. I'll 10 try to do the best that I can. I hope you'll. forgive me if 11- my performance isn't quite what we both might want it to hy;. ,
12 My understanding is that the purpose of this 13 meeting is to inform the public of the process and to 14 solicit questions and comments regarding the Yankee nuclear 15 power station license termination plan.
16 It's important to note that this is an 17 informational meeting, it's not a formal hearing, but the 18 proceedings will be recorded and transcribed, and that l 19 transcript will be made available to anyone who requests it.
20 If you haven't done so already, if you provide HyIG> n 21 your name and address to Etoy Fultan -- could she raise her 22 hand? Okay. She'll be happy to ensure that you do receive 23 a transcript.
24 Also, if you have written comments or if the l l
25 comments that you will make later on this evening are in 1 i
I
() ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
3 1 written form, if you'd please include your name and any
-( j 2 affiliations that are relevant on those written comments if 3 you provide them to the folks from NRC, they'll ensure that 4 they ama incorporated into the transcript, as well- .
5 We hope that we'll be able to proceed on a 6 schedule that I'm about to lay out and that we will conclude 7 around 10 o' clock this evening.
l 8 The staff from the NRC will be available to meet !
9 with people on an informal basis after tb5 closing of our 10 meeting at 10 o' clock, although I understand that the school l
11 folks need the building empty by no later than 11 o' clock i 1
12 this evening. I 13 There will be a period of time set aside for n
14 public comments, and we hope, given the time, that everyone !
k,,) 15 who has signed in as a speaker will have the opportunity to 16 speak, and if time is available, anyone who has not 17 pre-registered will also be given an opportunity.
18 Our forum will be a rather simple one. The folks 19 from Yankee Atomic Electric Company will speak. We'll take 20 some brief and, hopefully, to-the-point questions. Folks 21 from the NRC will then speak, and both parties, hopefully, 22 will take about 30 minutes for their presentations.
23 Subsequent to the NRC's presentation, we begin our 24 formal period for public comments and questions, and in the 25 absence of any additional business, I would like to begin 9
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O Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
4 k
1 with Yankee Atomic Electric, and if you can introduce A
( J' 2 yourself -- excuse me. One last point.
3 Because of the need for transcription, I'd 4 indicate, if someone speaks, if you we'.ld, please, clearly 5 identify yourself and any affiliations you have that you 6' think might be relevant.
7 Excuse me. Go ahead.
8 MR. DAVIS: Thank you.
9 Good evening. My name is Don Davis. I'm the 10 chairman and the CEO of Yankee Atomic Electric Company.
11 I've held this position for a little over a year, and we've 12 had several changes at Yankee during that period of time.
13 One change was that we've sold our nuclear 14 services division to Duke Engineering late last year, and p)
(_, 15 that comprised about 90 percent of the employees in Yankee, j l
16 and that provided the owners the opportunity to look at j 17 Yankee to help management, to help in some other 18 decommissioning activities in Connecticut. So, I've also 19 take responsibility for the Connecticut Yankee 20 decommissioning project.
21 These changes at Yankee will not have any effect 22 on the decommissioning of Yankee Rowe. Yankee still remains 23 the NRC licensee, responsible for the safe decommissioning 24 of the plant. The funding for decommissioning is unchanged, 25 and the employees doing the decommissioning at Yankee Rowe fM
(,) ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
5 1 are the same.
() 2 We have contracted with Duke Engineering for the 3 support services, provided in the same manner that Yankee 4 ' Atomic was providing those support services.
5 This meeting tonight is an indication that Yankee 6 Atomic has delivered and is delivering'on its commitment in 7 Project Greenfield to safely decommission Yankee Rowe and to i
8 return the site for unrestricted use. I 9 You know, I think, Ken Heider, who is the site 10 manager at Yankee Rowe, and Ken will give us an update on
- 11. the status of decommissioning at the Rowe plant and describe 12 our plans for returning the site to unrestricted use and 13 terminating the license. l l
14 MR. HEIDER: I'd also like te welcome everybody '
15 here this evening, and on behalf of the hundreds of people 16 that'have worked on Yankee's decommissioning activities,-
17 thank you very much for coming this evening. I know the 18 weather looked pretty prohibitive a little bit earlier this 11 9 afternoon, but we seemed to be able to get a good clear moon 20 to be able to navigate here tonight.
21 So, thank you very much for coming. I really am 22 happy to look out in the audience and see quite a few 23 familiar faces that we've met over the years. I'm glad to 24 see you're all here.
25 About six years ago, Yankee had to make a very
() ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
{
6
( 1 difficult decision. At that time,'we decided to permanently
() 2 shut down our nuclear power station in Rowe, Massachusetts, 3 and begin a process called decommissioning. That's the 4 process where we remove residual radioactivity from the site 5 and we return the site back for unrestricted access.
6 It was a difficult decision, but when we announced 7 that decision, we also announced that we would continue to 8 safely store fuel on-site, and we've met that promise, and 9 that we would eventually return the site to a green field.
10 I'm proud to say this evening that we have made 11 very significant process towards the goal. Right now, most 12 of the equipment that doesn't support spent fuel storage 13 operations has been removed from the site. As you'll see in 14 some of these slides, many of the rooms are empty and clean 15 and ready for the final part of our decommissioning 16 activity, the process of license termination that includes a 17 very important survey of the site to demonstrate that we've 18 met the values that will be approved by the NRC to 19 decommission the site.
20 Tonight we're talking about the plan that we have 21 submitted to the NRC to finish our decommissioning 22 activities on the site. It's called a license termination 23 plan.
24 And what I'd like to do this evening is to, first 25 of all, talk a little bit about where we've been in our ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N . W .. , Suite 300 Washington, D.C.. 20005 (202) 842-0034
f 7
1 decommissioning activities and then take a look into the L( I 2 future to be.able to'see what we're doing over the next year 3 and over the next several years to complete our l
4' decommissioning activities and then, after that's done, talk 5 a little bit-about our license termination plan, as well.
6 Most of you are probably familiar with the larger 7 decommissioning activities that we've completed over the
. 8 past couple of years. It began in 1993 with the removal of 9 our four steam g"nerators from the containment building 10 on-site and the transportation of those vessels.down to 11 Barnwell, South Carolina. They took a route from the plant 12 down River Road to-the Housac tunnel where they were placed 13 on trainc and sent to Barnwell.
14 That was followed late last year by our last most
() 15 significant removal activity, which was the removal of the 16 reactor vessel. In the spring of last year, we also shipped 17 that down to Barnwell, South Carolina, by train.
18 In addition to that, we've been quite_ busy 19 on-site, as well. We've removed tanks on-site. You can see 20 .two tanks from our storage -- tank storage farm over here --
21 that are no longer with us anymore. A tent was put around 22 them, the tanks were removed, the tents were cleaned, then 23 the tents were taken down again after the decommissioning 24 activities were completed.
25 Those are certainly large projects, but probably 1
() ANN RILEY & ASSOCIATES, LTD.
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1250 I Street, N.W., Suite 300 Washington, D.C. 20005 !
(202) 842-0034
8 1 the most significant activity to those of us who have spent
[) 2 a, lot of time on-site, were there for 31 years of operations 3 and now another six years' worth of decommissioning, was 4 what occurred in our control room.
5' Our control room is no longer where it used to be.
6 We didn't need this large control board anymore that was 7 there to control the reactor vessel operations, so we also 8 decommist,ioned this area, as well, and as you can see, it's 9 a completely different room now. In fact, it's even emptier 10 than in this picture.
11 The one panel that remains in the room right now 12 is the reactor control panel, and that is currently being I 13 packaged for shipment to the Smithsonian Institute.
14 But in addition to those more important removal 15 activities, we had a lot of removal activities that were 16 occurring on a day-to-day basis, equally.important, and thcy 17 constituted the majority of our activities during the past 18 six years.
19 We have removed miles of piping, tubing, thousands 20 of valves, hundreds of pumps from the site, to be able to 21 bring the rooms gradually to empty rooms where we could 22 clean the walls, the ceilings, and the floors to prepare 23 them for the final survey process of decommissioning.
24 Many of our rooms look like this now. The walls, 25 the ceilings, and the floors have been cleaned. Certainly O ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washingtcn, D.C. 20005 (202) 842-0034
1 9
1 all the process equipment, the pipes, pumps, and valves, )
2 have been removed from those rooms, and we're really ready 1
3 for the-final stages of decommissioning, the demonstration I 4 that we've completed our decommissioning activities, and 5 that's what we're going to be talking about when we talk 6 about our final status survey plan.
)
1 7 In addition to the many removal' activities, we've I 8 been also quite busy in taking radiological measurements 9 on-site. We're using a' process called site characterization 10 to be able to guide our decommissioning activities 11 throughout these past six years.
12 We've taken thousands of samples around the site 13 to be able to determine where the radioactivity is and what 14 the levels of the radioactivity are on-site.
-15 In this picture, you see one of our technicians 16 taking a radiation measurement around a pump.
17 In addition to those measurements, we also spend a 18 lot of time outside the plant, taking measurements in the 19 soil, in the asphalt around the buildings, in the sediments, 20 and even in the water around the site. These samples are 21 all in addition to the radiological environmental monitoring 1 l
22 program that we've been implementing since before startup.
23 This process, though, is different than the one 24 that we will use to complete decommissioning. Site 25 characterization tells us where the radioactivity is and ANN RILEY & ASSOCIATES, LTD.
Court Reporters i 1250 I Street, N.W., Suite 300 l Washington, D.C. 20005 1 (202) 842-0034
10 1- what levels they're at.
V 2 The final status survey that I'll be describing a L3 little later this evening describes how we will complete-4 decommisrioning -- or determines where the radioactivity is 5 on-site -- excuse me. Let me start again.
6 A final status, being different, verifies that 7 we've met the site release criteria, that we've reduced the 8 radioactivity below the limits that will be approved by the 9 NRC and to demonstrate that our decommissioning activities 10 have been completed.
11 Well, the plant really doesn't look a heck of a I
l 12 lot different than when we started, at least from the 13 outside. A few tanks have been removed, but by and large.
14 the buildings look the same, and really, it will probably
) 15 'look very much the same when we're done decommissioning 16- activities, as well. I 17 The decommissioning on-site really focus inside 18 the buildings. We have to be able to remove all the 19 contaminated systems inside the buildings -- the pipes, 20 pumps, and valves -- as well as to clean the soils around 21 the buildings and eve:' underneath some of the buildings, but )
22 these activities won't change a lot of the site that you see 23 here.
24 Over the next year, our decommissioning activities 25 will focus in the containment building. In addition to ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
11 1 that, we will also be initiating. final status surveys in
() 2 areas where decommissioning activities have-been completed.
3 Once those activities are done in the areas that 4 don't support spent fuel storage operations, each mission 5 will stop for several years until fuel is permanently 6 removed from the spent fuel pool.
7 Once fuel is taken out of the spent fuel pool, we 8' will then begin decommissioning those buildings that 9 supported spent fuel pool operation, remove the systems that 10 cool the spent fuel, and also clean the buildings, 11 decontaminate the walls, the ceilings, and the floors in 12 those buildings, as well, and proceed with a final status 13 survey in those areas, and then decommissioning can be 14 completed except for the areas where fuel may still be 15 stored on-site if we determine that we have to go with a dry 16 cask storage facility.
17 This is our license termination plan. It's a 18 road-map to describe how we will complete decommissioning 19 activities here at Yankee Rowe.
20 In this document, you'll see that it contains some 21 very important information about the limits that the NRC 22 will approve for decommissioning the site and also the 23 process they will use to demonstrate that we've met these 24 limits.
25- We submitted this document to the NRC in May of
() ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
12 1 1997, and a little later that summer, they publicly noticed
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( ) 2 it in the Federal Register as available for review and 3 comment.
4~ We also distributed copies of this document to 5 various libraries in the area, as well as various 6 governmental agencies for their review and comment, as well.
7 In fact, the Franklin Regional Council of Government 8 Planners presented Yankee with an extensive list of 9 questions and comments regarding the license termination 10 plan, and we just very recently have responded to those 11 questions.
12 What's in the license termination plan? It 13 contains quite a bit of information about how we'd like to 14 end the decommissioning process at Rowe. It contains a lot b(_/ 15 of information also that was approved in our decommissioning 16 plan for Yankee Rowe.
17 For example, it describes the site 18 characterization program that I talked about a little 19 earlier this evening and summarizes some of the data that we 20 gathered as part of that process.
21 It also discusses what remains in decommissioning 22 on-site both in terms of what systems have to be removed as 23 well as what buildings have to be cleaned and potentially 24 what soil has to be cleaned.
25 We even have a very brief section describing the ALN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N . W .. , Suite 300 Washington, D.C. 20005 (202) 842-0034
1 I
t 13 1 end use for the site. It's brief because we really don't t
(s-)I 2- have any plans at this time.for the site other than it will
- 3. remain Yankee Atomic Electric Company property once we've 4 completed decommissioning and released the site from the NRC 5 license.
6 We present the remaining costs associated with 7 decommissioning, and to date, we seem to be doing very well, 8 which is a good thing for me.
9 In addition to that, we present our environmental 10 statement. The environmental statement is a summary of our 11 environmental report that we submitted, along with our 12 decommissioning plan that was approved by the NRC a couple 13 years ago.
14 And then finally the part that I'd like to focus
() 15 on now, the final status survey plan, and in the final 16 status survey plan, we present two pieces of information, as 17 I said earlier, the limits that we will use that will be 18 approved by the NRC that tells us that we'have completed our 19 decommissioning activities and then it also describes the 20 process that we will use to demonstrate that we've met those 21 limits.
22 These are Yankee site release criteria. They're I 23 the same values that were reported in our decommissioning 24 plan several years ago when we submitted it to the NRC.
1 25 The first value that I'd like to talk about is the i 1
i t ANN RILEY & ASSOCIATES, LTD. I Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
14 1 total effective dose equivalent. This value is~the most
'( ) 2 general of the four site release criteria. It presents'the 3 overall impact _to a person if they were to come on-site and 4 not just visit the site but actually establish a home on the 5 site. This is done for' conservative reasons in order to 6 establish the maximum impact of the site.
7 When people establish a home on-site, they plant a 8 garden and they eat the vegetables that are grown in that 9 garden, and we also assume that they put a well on-site and 10 drink the ground water that's on-site, and when you add up
-11 all the radiation exposures from the exposure from the 12 ground, from any exposure associated with eating the 13 vegetables or drinking the water on-site, the total dose for 14 that must be less than 15 millirem per year.-
) 15 As you can imagine, the dose would be far less for 16 visitors on-site, and it also is a very local effect. Our 17 preliminary calculations and our models for the site 18 post-decommissioning show that this is a very localized 19 dose. In fact, as soon as you move off the sitre, it rapidly 20 drops to zero, so that the people in Franklin County, the 21 Town of Rowe, or the Town of Monroe have no exposure from 22 the site after decommissioning activities are completed.
23 It should be also noted that this value is less 24 than the 25 millirems per year that is presented in the 25 recently issued NRC regulations on the generic criteria for I ANN RILEY & ASSOCIATES, LTD.
\ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 m.
15 1 completing decon?.ssioning activities.
2 We also have three other limits on our 3 radioactivity on-site to further reduce and quantify the 4 type of radioactivity that can remain on-site.
5 The first one is that the water that remains 6 on-site -- that'would be any surface water or groundwater 7 remaining on-site must meet EPA drinking water standards for 8 radioactivity.
9 In addition to that, the surface contamination !
10 --that's the amount of radioactivity that may be left on any 11 surface.on-site -- must meet the NRC guidelines for 12 decommissioned plants. Those are presented in Regulatory 13 Guide 1.86 for decommissioning.
14 And then, finally, the amount of radiation that's O
V 15 emitted from any surface on-site must be less than 5 ,
i 16 one-millionths of an R per hour on average, and any surface 17 can't have a high point that's any greater than.twice that 18 value. l 19 I'd like now to talk a little bit about the 15 20 millirem per year, because that's really the value that ;
21 expresses most clearly the total impact of the site on any 22 individual that may come in contact with the site or may be !
23 near the site.
1 24 Now, I'd like to look at that relative to the 25 amount of radioactivity that's present, as well as any l ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
16 1 . variation in that radioactivity in the area.
) 2 It was said at one of'the meetings that'we had or t
3 that was held on. Yankee's decommissioning that we-live in a 4 sea.of radioactivity, and that's.a very true statement. No i
5- matter where you are in this world, you walk around, you're i 6 exposed to radioactivity;from many different sources.
-7 I've listed here a' categorization of those 8 sources.
9 You have radon and its daughters, which is a 10 primary source of that radioactivity. Radon is a gas, a 11 naturally radioactive gas that emanates from the earth.
12 In addition-to that, the soil, the rocks, and even 13l the sun contributes a significant source of radioactivity to 14 our every-day life.
15 Medical diagnostic tests and therapeutic analyses 16 and therapeutic agents also contribute a significant portion 17 to your every-day dose, as well as even the food you eat and 18 the water that you drink from naturally occurring sources 19 contribute radioactivity.
l 20 What I'd like to do is to look at one of these 21 sources, because they all vary depending upon the lifestyle 22 that you have, where you live, the type of geology that's 23 around you, and even the weather on a day-to-day basis will
]
24 make these values vary.
]
25 What I'd like to look at is just one of them, the 1
() ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 1
17 1: radioactivity that comes from the soil, the rocks, .and
() 2 cosmic. rays, to see how that varies in and around the 3 Franklin County area.
4 This is a map of the Harper-Deerfield river 5 valley. That's Sherman Reservoir there, Sherman Pond, the l 6 Yankee power station, and what I've done is I've presented a 7 few data points from our radiological environmental j 8- monitoring program in order to get a view of how radiation j l
9 levels vary in and around the valley, and as you can see 10 here, they vary significantly. In fact, the difference 11 between Heath, Massachusetts, and Florida, Massachusetts, is 1
12 over 30 millirem per year. 1 i
13 In addition to that, we went out on a little l
14 measuring -- l 15 AUDIENCE MEMBER: Excuse me. Is there a way to 16 make that a little clearer? I don't think anyone back here
]
17 can see it.
18 MR. HEIDER: Okay. Well, let me tell you what we 19 have there. This is Reedboro, Vermont. It has a value of 20 72. Florida, Massachusetts, near Fifebrook Road, has a 21 value of 75. The units of these are millirem per year.
22 Florida, near Route 2, is 60. Rowe, near the Rowe School, 23 is 46. Heath, near Route A, is 42, and Shalimont, near 24- Lagatier Road, is 54. And for a further reference point, in 25 and around the plant where we have several different
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18 1 measuring stations, the average is around 60 to 65 millirem v) i 2 per year in areas that are well away from the site but in 3 the general area.
4 In addition to those measitrements, I believe -- I I 5 think most of you picked it up, but we have a sheet out 6 front where we went out on a measuring trip last week -- I 7 think Stan Gawle went out on this trip with a technician 8 from the lab. Stan wasn't left anywhere near the instrument 9 by the way. But on this you can see that, as well, in the 10 areas around Franklin County -- and I'm sure you can't see 13 these values, but I'll just point on the page -- that the 12 Franklin County Courthouse had a reading of 99 millirem per 13 year, and the entrance to the Poet Seat Tower was the low 14 value on our trip at 59 millirem per year.
O)
(, 15 All these values are within what we would consider 16 natural variations in radioactivity from area to area. l I
17 Our decommissioning for Rowe, which is specific to 18 the site and, as I said earlier, really only affects i
19 somebody that moves onto the site and assumes all those l 20 sources of radioactivity, including eating the vegetables 21 from the garden, drinking the water, and being exposed to 22 the soil, is 15 millirem per year, which is significantly
' 23 less than the amount that your radioactivity, our 24 radioactivity for people that live in the valley, varies 25 from home to home, location to location.
l (f ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
19 1 We'll, how do we determine ~whether or not we've met 7m \
( j 2L these criteria that the.NRC will approve in our license J 3 termination plan? We'll use a process called a final status
'4. survey to verify that we.have met the site release criteria 5 that are identified by the NRC.
6 We have assembled a team of experts from around 7 the . industry to work on our decommissioning project at Rowe, 8 Massachusetts. We've taken people from Fort St. Vrain, 9 Shoreham; we're using state-of-the-art techniques and 10 equipment in order to develop a best-in-the-industry 11 approach to assuring that we meet the site release criteria 12 at Yankee Rowe.
13 We've also reviewed the lessons that have been 14 learned at all the decommissioning sites and incorporated
() 15 .those lessons into our procedures and programs to assure 16 that we do the job right.
17 We begin with a room that looks like this, i 18 typically, on a contaminated area of the site that's already 19 been decommissioned. The ceilings, the walls, the floors 20 have been cleaned. There may be plastic over them to 21 prevent any re-contamination from other activities on-site.
22 Those materials will be removed, and we'll begin the process j 23 of preparing the room for survey.
24 The first thing that we'll do is we'll put 25 grid-marks on the walls, the ceilings, and the floors.
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20 1- These ones happen to be at 1-meter increments, so we develop
/)j 2 squares on the. floors and the walls that are about
(
3 three-foot square. i 4 Once that's been completed, we will then affix i 5 bar-codes very similar.to the products that you buy in the ;
i 6 supermarket to each of those areas in order to uniquely 7 identify it, and then the technicians, when they go in the 8 field to do whatever measurements they may have to do -- and 9 they may do several measurements for each of these' areas 10 on-site -- will use a bar-code scanner, scan the bar-code, 11 which will be stored on the hand-held computer, and then 12 take whatever type of measurement is necessary from that i 13 particular work activity.
l 14 We expect to take over a quarter-million j O
(_,/ 15 data-points as part of our final status survey program at 16 Yankee Rowe.
17 Once those data are collected -- and I realize 18 you're not going to be able to read a thing on this one, but 19 I'll explain this, as well -- it will be stored in a 20 computer database, and that computer database has a map of 21 the area associated with it, and this is a picture of a 22 building. This is the floor area here, and then each of the 23 four. walls are shown to be laid down on their sides in order 24 to facilitate looking at it.
25 In addition, we have four other areas of the room ANN RILEY & ASSOCIATES, LTD.
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a 21
'1' which are blind walls that are also shown here for data i
- f- i 9 2 reporting.
- 3. This: picture has about.100 different data 4 locations of which there may be several different i
5 data-points. Those areLreferenced to values that are f
'6 measured out'in the field, and then we will generate graphs, 7 plots, tables, and reports to be able to assist us in.our 8 analysis and our defense of our final status survey results.
.9 In addition to doing this outside of buildings, 10 we'll:also do it inside. Excuse me. In addition to inside 11 of buildings, we'll also do it outside of buildings. Well, 12 'this is an outside-area, and you can even see the path that 13 the technicians will take when.they move through to do one 141 of their survey measurements in that work area.
15 One final component and probably the most 16 important component of our program is the quality assurance 17 part. Yankee will use the same quality assurance program 18 that we use to assure the successful operation of the site 19 and the successful to-date decommissioning activities 20 on-site. ;
21 We'll use quality assurance to ensure that the 22 technicians are adequately trained, to ensure that they get 23 out to the field and take the right measurements and they do 24 it using the best of techniques. We'll also use it to 25 assure that the data are appropriately evaluated and ANN RILEY & ASSOCIATES, LTD.
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22 !
I 1 reported to the NRC.
s
'(v) . 2 But in addition to Yankee's oversight, the NRC 3 will.also perform a very critical oversight role by i 1 4 inspecting us during the surveying-process and by also. l 5 taking their own measurements to confirm the results that- l 6 Yankae has.
7 Once all thesn processes are complete, the license l 8 termination process will continue at the NRC, where they ;
9 will continue to review our data and make a final decision-10 relative to termination of license.
11 Forty years ago, we~ began our mission to l 12 demonstrate the peaceful use of nuclear power in New 13 England. We have been able to successfully demonstrate 14 construction of a nuclear power station, safe operation of
[ )
(_/ 15 that power station for 31 years, and now we've shown that we 1
.16 can also decommission a nuclear power station, and we're j 17 well on the way to showing that we can terminate the license 18 and complete the cycle, making it safe from start to'linish, 19 so we can transition from a fully operating nuclear power 20 station in 1992 to one that is a green field, hopefully 21 sometime in the next several years, l 22 Thank you.
23 MR. COUNCILMAN: Okay. We will take a few minutes 24 for questions at this point. We may not be able to field 25 them directly, but we'll do the best we can, and folks, if ANN RILEY & ASSOCIATES, LTD.
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1 23 1 you'd please understand, the lighting in the auditorium is
() 2 kind of poor, and 1 may not see you if you're near the fdr 3 reaches. If you have a flare gun you can fire off or some 4 other form of signaling, I'd app _aciate it.
5 Do we have any questions for Mr. Heider at this 6 time?
7 MR. DOSTIS: Yes, I do. What was the initial --
8 MR. COUNCILMAN: Excuse me, sir. We'll need you 9 to identify yourself, please.
10 MR. DOSTIS: John Dostis from East Salem. I 11 MR. COUNCILMAN: Thank you.
12 MR. DOSTIS: What was the initial cost of Yankee's 13 construction as compared to ics decommissioning?
14 MR. HEIDER: The initial cost of Yankee was about 15 $55 million. The decommissioning project is quite a bit 16 more expensive than that. It's about $350 million.
17 MR. COUNCILMAN: Other questions at this time?
18 Yes?
l 19 MS. KATZ: I'm Debbie Katz. !
20 I have some questions. You can make it all sound 21 really easy in a certain way, and if I didn't know things 22- about problems in the past or questions about fuel pools, it l 23 would all seem really simple, and I believe that Yankee will 24 do a very good job trying to do a detailed job of cleaning 25 up the contamination, but there are a number of concerns we O
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i
24 1 have.
2 You didn't really address the issues.of the fuel
[%)h 3 pool or whether Yankee would potentially go to monitor the 4 storage or whether you would use dry cask storage or use an 5 all-purpose canister, and this is c.aarly part of what will 6 be the end game of decommissioning, and I really wish that 7 you could talk some about that so we could all. hear, 8 because, you know, one thing about the decommiasioning plan j 9- that you have is that it doesn't really -- it's a relatively ;
10 generalized document. It doesn't specifically say in detail 11 what you are going to do.
12 One of the things it doesn't make clear -- and you 13 maynotcompletegbeclear,butyoucertainlyhavesomeideas 14 of different approaches you're going to take to that - it
) 15 would really help if you could specify that as much as 16 possible, and then maybe there will be some more questions. i 17 MR. HEIDER: Okay. I think I got that.
18 First of all, although my presentation did 19 simplify the process, you're right, on a day-to-day basis, 20 there were many challenges that faced us in our 21 decommissioning activities, and the bottom line is that we 22 did get through those challenges, and I thank you for your
.23 compliment that we've done a good job on it.
24 In terms of fuel storage, the reason that we did 25 not discuss it formally in this presentation is that from a
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25 1 regulatory perspective, it's not part of the license h) m.
2 termination process. The license termination plan really is 3 designed to talk about how to release the site.
4 However, to 9.ddress that question, our fuel 5 storage plans are not complete at this time. We are 6 approaching it from several different ways in order to 7 assure that fuel is removed from site as soon as possible.
8 It's certainly our desire to have fuel off-site safely j i
9 stored at a government facility in the near future, and that 10 requires legislative involvement, it requires congressional 11 action, and we're working in that area.
12 In addition to that, we are also working to 13 license a dry cask storage facility that's a facility 14 somewhat like a spent fuel pool in that it stores spent 15 fuel, but rather than using water as a storage and shielding 16 medium, the dry cask storage facility stons fuel in l
17 stainless steel containers and uses air as a cooling medium '
18 outside of those containers which ar.s hermetically sealed 19 and uses concrete to shield people from the radiation that j 20 may be emitted from the fuel.
{
21 We don't have a definite answer for you on whether 22 or not we're ready to move out to the dry cask storage 23 facility. It-depends on the Department of Energy. If they 24 were to remove the fcel in the near term, we would want to 25 leave the fuel in the spent fuel pool and then shift it to ANN RILEY & ASSOCIATES, LTD.
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26 1 the Department of Energy.
52 If that process takes a long time -- long being 3 10, 15, 20 years -- then we can safely store the spent fuel 4 in a dry cask storage facility on-site until that time and 5 be able to get on with our decommissioning activities 6- associated with the spent fuel pool.
7 That decision won't be made in the next month, and 8 it seems that, over the past six years, we've been making 9 that decision incrementally, responding to the outside 10 influences and forces that really are shaping this issue 11 throughout the country.
12 So, we expect that decision-making process will 13 continue to be done incrementally, and it's certainly 14 something that we have been talking a lot about.
15 In fact, we've had many different meetings with 16 community representatives, and it's certainly a very 17 important topic on our tours that people have had on-site, 18 as well as any press visits that we've had on-site, because 19 it is an important issue associated with the closure of the 20 site, and even if it's not, from a regulatory perspective, 21 contained in the decommissioning regulations, it's certainly 22 something that will be handled between now and the final 23 green field on the site.
24 MS. KATZ: Well, I'm a little confused, and you 25 may be able to clear this up, because as long as the fuel ANN RILEY & ASSOCIATES, LTD.
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27 1 pool and the ion exchange pit are e vite, is the NRC still 2 regulating the site?
3 Let's say you go into dry cask storage but you 4 keep the fuel pool there, which means the ion exchange pit 5 would stay there. Does that mean the NRC is still
- 6 regulating the site?
7 MR. HEIDER: The NRC will be licensing our site 8 and regulating our site until the fuel is all removed from 9 'the site and any radioactivity that remains on the site 10 meets site release criteria that will be regulated through 11 our license termination plan, and that won't happen until 12 the NRC -- the final release of the site won't happen until 13 the NRC terminates that process themselves. The NRC will be 14 with us until all the fuel is removed from the site and any 15 radioactivity that remains on-site meets the site release j 1
16 criteria. !
17 MS. KATZ: When you mean the fuel removed -- once 18 it goes into monitored retrievable storage and you remove 19 the fuel pool, then is the NRC's responsibility ended and 20 the DOE takes over?
21 MR. HEIDER: No.
22 MS. KA?'Z : No. Okay.
23 MR.-HEIDER: When I say " removed from the site," I 24 mean removed from the site and taken somewhere else -- for 25 example, a government facility.
h
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1 l
28 1 MS. KATZ: You're actually working with NAC? ;
() 2 MR. HEIDER: We're in contact with NAC. We worked 3 with them to begin 'd censing the project.
l 4 MS. KATZ: I think they bought out another 1
l
'l 5 company. Are they related to Beckdro or to some of the 6 other companies?
L60 i
7 MR. HEIDER: TOlan'Tremblay is the engineer 8 responsible for our dry cask storage project, and he's been 9 working directly with NAC International.
10 Can you answer this question?
11 MR. TREMBLAY: Yes. NAC is not a company that was 12 another company at one point. It used to be called Nuclear 13 Assurance Corporation, and they just simply changed the name 14 to NAC International It's not Beckdro. It's not Sierra l
( 15 Nuclear. It's not Trans-Nuclear. It's a company that's 16 been in business for some time.
17 MR. COUNCILMAN: Any other questions?
18 MR. HEIDER: I want to assure you tnat we are 19 responsible for cleanup at the nuclear power plant.
20 MS. KATZ: No, that was not my point. This is a 21 whole experimental process that's taking placo, not just at 22 Yankee but for the country, and we're very concerned about 23 the kind of cask that is being used, because many have had 24 problems that have been certified by the NRC. So, we want 25 as much information about the kind of cask, since this is ANN RILEY & ASSOCIATES, LTD.
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29 1 going to be the new cask that has gotten approval and has n
(v) 2 been certified for a transport cask, but the multi-purpose 3 canister is in the design stage, and we are very concerned 4 that it works right.
5 MR. HEIDER: Thank you. Yankee Atomic is very 6 concerned with that, as well, and in fact, we've been 7 spending a lot of time studying the other people's designs 8 to assure that NAC develops one that incorporates those 9 lessons that nave been learned at other sites to assure that 10 we do have a safe facility.
11 MR. COUNCILMAN: Anyone else?
12 {No response.]
13 MR. HEIDER: Thank you very much.
14 MR. FAIRTILE: Good evening, ladies and gentlemen.
f (3_,/ 15 My name is Mort Fairtile. I'm the NRC decommissioning 16 project manager for the Yankee nuclear power station near 17 Rowe. As project manager, I'm the principle point of 18 contact at the NRC for the decommissioning of Yankee Rowe, 19 and I'm located at NRC headquarters in Rockville, Maryland.
20 We have a court reporter who -- as mentioned by 21 Brad, we have a court reporter who's transcribing this 22 meeting. Again, I want to repeat, when you get up to speak, 23 please give your name and any affiliation you may have 24 that's appropriate.
25 The transcript, as mentioned, will be made i
r'N
( 8 ANN RILEY & ASSOCIATES, LTD.
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30 1 available at the Greenfield Community College library, which
() 2 serves'as the NRC local public document room, and Etoy, will 3 you wave-your hand again? Etoy also, I'll repeat, has a 4 sign-up sheet for those who would like to receive a copy.
5 Please be judicious with such requests. ' Copies are 6 expensive, and we hate to see more trees cut down.
7 The purpose'of tonight's meeting, as Mr.
l 8 Councilman stated, is to inform you about the Yankee Rowe l
9 license termination plan and to gather public comments and 10 answer questions about it.
i 11 The NRC revised its decommissioning regulations in {
i 12 July of 1996 in recognition of the reduction in risk after a !
13 plant is permanently shut down.
14 As noted, this is a meeting, not an adjudicatory O
k_s/ 15 hearing. However, the license termination plan constitutes 16 what the NRC defines as a license amendment, and as a 17 consequence, the public is offered an opportunity to request 18 such a hearing or adjudicatory hearing.
19 The NRC will publish this request in the Federal 20 Register. It will be published very quickly. We sent it to 21 the Federal Register on January 9th. It will be published 22 sometime after the 15th of January, maybe within three days.
23 We recognize that not many of you read the 24 register as a steady diet, so Etoy has an additional sign-up 25 sheet, and we will send interested parties a copy of the
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31 1 Federal Register notice on request. So, if you want to get (n) 2 a copy of it, as soon as it hits the Register, we will send 3 it to you.
4 There is a 30-day limit on filing for a hearing 5 after the date it is published in the register, and some 6 limitations exist in our regulations as to who is eligible 7 to request a hearing.
8 We have an attorney here from the NRC, Ann 9 Hodgdon.
10 Ann, could you wave your hand?
11 She's sitting down there, and if any'of you are 12 interested in what these limitations are, you can speak to 13 Ann sometime after the meeting, and she can give you 14 specific requirements about hearings.
O
(_s/ 15 With me tonight is Mr. Pittiglio, Larry Pittiglio.
16 Larry, do you want to wave your hand?
17 And he's going to supply the details of the I
18 license termination process from a regulatory perspective.
19 Larry has extensive hands-on experience in this ;
20 area at two other decommissioned plants that have already 21 had their licenses terminated. Larry brings a lot of 22 experience to this process.
23 However, in summary, I'll go over the new 24 regulation. It requires that the plan include the j 25 following: l l
1 I
\
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I 32 I i
1_ First of all, a site characterization. l
() 2 Secondly, identification of remaining 3 dismantlement activities, plans for site remediation, )
1 4 detailed plans for-the final radiation survey, a description !
5 of the end use of the site, if restricted. i 6- Now, what.that means is, if the site, for some i 7 reason, can't be properly cleaned up and there has to be 1 i
8 some sort of a restriction in its documents, papers, then 9 the licensee has to come up with an end use for the site, i
10 otherwise it need not. i i
'1 11 We need an updated site-specific estimate of '
12 remaining decommissioning costs, and lastly, a supplement to 13 the environmental report, pursuant to our regulation, 10 CFR l 14 51.53, and this report has to describe any new information l 15' or significant envircnmental change associated'with the 16 licensee's proposed termination activities.
17 Next I'd like to introduce the folks we have here 18 tonight from the'NRC who will-assist in answering your 19 questions.
1 20 First of all, my immediate supervisor, Dr. Michael l 21- Masnick.
I 22 Mike, do you want to wave your arm, show your i 23 face?
24 Mike'is the section chief of decommissioning, and !
25 he supervises 10 project managers who are assigned to the l
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33 1-I oversight of power reactor decommissioning. Mike brings a
() 2 lot of experience to us.
3 Mike's immediate supervisor is Dr. Seymour Weiss.
4 Sy,-do you want to show your face?
5 Sy has the responsibility for non-power reactors, 6 as well as decommissioning at the NRC. Mike and Sy are not 7 medical doctors but hold Ph.D.'s in science or engineering.
(64 i&bipn 8 Joe Nick is a Region I rr;ulatisa protection 9 inspector with extensive experience in inspecting Yankee-10 Rowe. He's been coming to the plant for six or more years 11 now, and he's very familiar with the site. In fact, he's 12 conducted inspections here since the plant first shut down.
13 I'm going to bring Joe up to the stage in a few minutes to 14 discuss the future oversight by NRC at the plant.
15 And also from Region I, Neil Sheehan, a public 16 affairs officer.
17 Neil, do you want to wave your arm?
18 Ann Hodgdon has already been introduced. She's an 19 attorney from our NRC headquarters Office of General 20 Counsel. Ann is one of our leading Epecialists on 21 decommissioning and has been sa attorney on several recent 22 shutdown reactors.
23 Again, Larry Pittiglio -- he's going to be up on 24 the stage right after Joe Nick. As I mentioned before, he's 25 worked on a couple of these projects. He's a very
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l s
34 1 experienced staff member in the area of site release
' () 2 criteria and decommissioning costs. He's from the 3 headquarters Office of Nuclear Materials Safety and. i 4 Safeguards. The license termination plan that Yankee has 5' . submitted to the NRC is being reviewed by Larry's office.
6 In fact, Larry is the chief reviewer.
l 7 Etoy you've seen and heard many times now. We've {
i 8 singled her out a lot. She's our licensing assistant, and i 9 she's here to assist in administrative issues this evening.
10 She can be of help for the media and members of the public.
i 11 Just ask her and she'll help you,-I hope. j l
12 I'd like to conclude by saying that I'm one of the 13 many of MRC staff members involved with the oversight of 14 Rowe's decommissioning, and I've introduced some of the i 1
15 others. The NRC has had an experienced and knowled.pchle t
16 crew assigned to Rowe decommissioning. We'd like to answer l 17 your questions, listen to your comments.
18 These experienced professionals with me tonight 19 are dedicated to protecting the health and safety of the i 20 public, which is the primary objective of the U.S. Nuclear 21 Regulatory Commission.
22 That's all I have to say, and I'd like to turn the I 23 floor over first to Joe Nick for a discussion of future NRC 24 oversight.
25- As soon as Joe gets finished, then Larry will ANN RILEY & ASSOCIATES, LTD.
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35 1 teach all-we ever wanted to know about details of the G
Q 2 license ' tennination process, and each of them will tell you 3 a little bit about their professional experience.
4 MR. NICK: Good evening. My name is Joseph Nick, 5 as Mort introduced me. I'm the assigned inspector from our 6 NRC Region I office based near Philadelphia, PA, for the 7 Yankee facility. I've been performing inspections at Yankee 8 for about six years, as Mort said, and I've been working in 9 the nuclear field for over 15 years.
10 I'd like to say a little bit about what our 11 inspection program is at the Yankee facility and give a 12 brief overview of what we have planned for the immediate 13 future.
14 The NRC Region I office maintains the 15 responsibility for the inspection program at Yankee Rowe and 16 at other licensees -- NRC licensees throughout the 17- northeast. Those include shutdown reactors and reactors in 18- the decommissioning process.
19 In the past, we've performed NRC inspections at 20 the Yankee facility approximately every three months for the 21 past two years, or as events have occurred, we've also done 22 a followup based on the need to respond.
23 Our plans for the future are basically the same.
24 We plan to continue to have scheduled performance l 25 inspections every three months, and our emphasis is really ANN RILEY & ASSOCIATES, LTD.
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l' 36 1 on the oversight of the licensee's final survey program 2 that's approved.
3 We have preliminary plans in place to not only 4 have myself but have other inspectors and have national labs 5 serve in the field that will help support the 6 decommissioning project at Rowe. These other organizations 7 .are affiliated with national labs, and they help the NRC 8 produce many of the standards and regulatory guides that we 9 have in place.
10 We plan to have these inspections have a. broad 11 review and detailed review of the licensee's performance 12 during their final survey process. We will review their 13 data as they perform it in the field, review their 14 log-keeping, their record-keeping, their data that they have 15 already performed.
16 In addition to that, we will perform independent 17 measurements, and what I mean by independent measurements is 18 we will have our instrumentation calibrated by our own 19; facilities, having no relation to the licensee's instruments 20 at all, and we will perform these surveys with the licensee 21 at times and even without, we'll check in spots where we 22 want to determine surveys be taken and we will verify the 23 licensee's data.
24 These independent surveys and the results of these 25 inspections will be used to -- will be documented in our NRC ANN RILEY & ASSOCIATES, LTD.
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37 1 inspection reports, and at the end of the process, the t 2 information in these inspection reports will be used to help
~
3 support the determination for'the termination of the license 4 at the Yankee facility.
5- That's all I really have to say, and I'll leave 6 questions until after Larry's presentation. Larry Pittiglio 7 will be next.
8 MR. PITTIGLIO: Good evening. As Mort has 9 indicated, my name is Larry Pittiglio, and'I'm with the 10 Nuclear Regulatory Commission, and I'm in the Office'of 11 Nuclear Material Safety and Safeguards, and we have the 12 responsibility for the technical review of the license 13 termination plans.
14 Before I str-t the presentation, let me just take )
15 a minute or two and talk a little bit more about the 16 experience that I'll be bringing with me to this project, 17 which I think will be of benefit to everybody involved, and 18 that is that not only hate I been involved in many different 19 surveys for what we call the site decommissioning management
-20 plans, I was the project manager from start to finish for 21 both the Shoreham Nuclear Power Plant located in Long 22 Island, yhich we terminated the license for unrestricted use 23 in 1995, and recently the Ft. St. Vrain Nuclear Generating 24 Station in Denver, Colorado, and we terminated the license 25 for that for unrestricted release.
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38 )
1 I think one Of the key points to point out related
/~
t 2 to that is that because I was involved with both of those 3 proj ects, I had the opportunity to participate in over $30 4 million worth of money spent on final surveys.
5 The Shoreham Nuclear Power Plant's final survey 6 consisted of over 250,000 measurements and I think ran over 7 $12 million. The Ft. St. Vrain plant, because of the 8 significant amount of imbedded piping, had over 400,000 9 measurements at a cost of over $20 million for the 10 licensee's final survey.
11 I think that having worked five years on Shoreham 12 and six years on Ft. St. Vrain and had the opportunity to 13 actively be a part of the approach for final surveys, it 14 will be of great benefit to everybody involved in this 15 project.
16 Now we'll start on the presentation. j I
17 One other thing. The packages that were available l
18 in the back had some additional slides that I put in for 19 informational purposes. In case it scared you on the length l
20 of the presentation, we don't intend to go through all of ;
21 those.
22 The license termination plan is basically the 23 requirements are dictated by two changes in the regulation.
24 The first change occurred in July of '96 related to the 25 decommissioning rule, and the second change was in July of O ANN RILEY & ASSOCIATES, LTD.
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39 1 this year,-which was the change in the new Part 20, and that
() 2 is the regulatory basis for the license termination plan.
3- Next slide, Mort.
4 , The requirements again on the license termination-5 plan are dictated by 50.82 (a) (9) , and that specifies'again 6 that the license termination plan I think will be submitted 7 no later than two years before termination, and the key 8 point is it will be approved by license amendment.
9 Again, let's just take a couple seconds to talk 10 about the 50.82 (a) (9) requirement, which is really why we're 11 here tonight. Of course, there's been the notice of 12 availability of the license termination plan. We are here 13 tonight holding a public meeting.
14 Again, the license termination plan will be 15 approved by a license amendment, and the regulation also 16 says that there is an opportunity for a hearing, and 17 depending on the disposition of the spent fuel,'the hearing 18 could fall under Subpart G or Subpart L.
19 The license termination plan can go either one of 20 two ways. You can have the release of the facility for 21' unrestricted use, which is the way this particular plant 22 will go, or there can be some restrictions.
-23 Mort had indicated about restricted release.
24 That's not applicable to this particular site, but it is an 25 option for the termination of particular licenses, and Part ANN RILEY & ASSOCIATES, LTD. -
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a 40 1 20 -- the new Part 20 has set a whole bunch of criterion to (g) x 2 cover those cases.
3' Now, this really just talks about under the change 4' in the regulations,ht d-unde:IJuly of this year, Part 20 changed.
5 This particular site is grandfathered and will be used in 6 the existing criterion. They are allowed to do that under 7 the provisions of the rule, and the new criterion also 8 exists, which we won't address a whole lot, but it was 9 really what was talked about as far as the 25 millirem 10 criterion.
11 What we'll do is just talk a little bit about the 12 license termination plan review process. Again, it was --
13 : requirements come under both 50.82 (a) (9) and under 10 14 CFR Part 20, Subpart E.
/ %
(m,/ 15 Basically, the license termination plan is a 16 supplement to the FSAR equivalents. It includes, again, a 17 Gummary of the license site characterization. It identifies 18 -- it has to identify the remaining dismantlement task. It 19 includes plans for the site remediation. It includes 20 detailed plans for the final survey.
21 In addition, again, what we have done here is 22 talked about the new Part 20 requirements, and it would talk 23 about the -- if you were using the new Part 20, you would 24 have to talk about your dose assessment methodology to 25 demonstrate the 25 millirem criterion.
m I I ANN RILEY & ASSOCIATES, LTD.
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l 41 1 Again, under the new Part 20, there is a
() 2 restricted release scenario, and let me just again emphasize 3 that that's not the approach that we're taking for this
~
4 site, but it is available.
5 In addition, the license termination plan again 6 has to provide an updated site-specific cost estimate of the 7
.Nw&
. remaining decommissioning costs, and aregany significant 8- changes from the original environmental' report, then they-9 have to submit a supplement to the environmental report.
10 What I put up next is really what we_ consider the 11 focus of what we look at. While we do review all the 12 regulatory requirements, obviously there are some key areas i
13 that we were certainly worried about or focused on in that 14 plant, and really the first one is, of course, the final (O
m/ 15 survey.
16 When you look at the supplemental information that l 17 I provided you, there's one or two pages of identification 18 of just block type items that we look at that I included as 19 a reference for you related to the final survey.
l 20 The final survey is a big project. As they had 21 indicated earlier, it's going to be over 250,000 22 measurements, and it's really the mechanism by which the 23 licensee demonstrates both to the NRC and to the public that 24 they have met the release criterion.
25 The next slide really is, again, a reference to l ANN RILEY & ASSOCIATES, LTD.
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42
'l the Part 201 requirements. Specifically, if they were to use
\) 2 the 25 millirem'or a restricted release scenario, then you 3 ~ would have to do dose assessments.
4- Finally, we do take a close look at the updated
.5 site-specific decommissioning cost estimate to make sure 6 that there is sufficient funding availablefto complete the 7 decommissioning of the site.
8 That pretty much concludes the presentation 9 related to the requirements.of the license termination plan.
10 MR. FAIRTILE: We can take questions now of the 11 NRC.
12 MS. PRESLEY: My name is Carolyn Presley. I live 13 'in Greenfield.
14 My question is about jobs and salaries. Is there
) 15 any way that people here tonight working for the NRC are 16- paid salaries related to the protection of your industry?
17 In other words,.are there fees coming from nuclear 18 . generation that pay-the salaries of the NRC --
19 MR. FAIRTILE: Yes. The NRC is defined as a 20 100-percent fee-bearing agency. What that-means in general 21 is/that funding for the NRC comes from our licensees through 22 a' series of fees.
23 You want to add something?
24 MR. WEISS: We charge the licensees so many 25 hundreds of dollars per hour of work that we do on their ANN RILEY & ASSOCIATES, LTD.
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I 43 1 docket. I think it's currently about $130 an hour. So I U
2 keep track of Mort's time and the other decommissioning 3 people, and then it gets allotted on a quarterly basis to 4 various licensees, who have to then pay these fees.
5 We also charge annual fees, so operating reactors 6 have to pay in a substantial amount of money.
7 Now, where does this money go? This money goes to 8 the Federal Treasury; it doesn't go to us. Our budget is 9 determined by Congress. The manpower allocations, the 10 amount of money we can spend, all of that is determined by i 1
11 Congress, and then following that, the licensees pay this j 12 money back to Congress, to the Treasury Department.
13 MR. DOSTIS: I have a question for Joe. My name ;
14 is Josh Dostis from New Salem. l
(^h !
( ,/ 15 Joe, you said you inspect these plants once every 16 three months. How many plants are you responsible for 17 inspecting?
18 MR. NICK: That's a fair question. Currently, I'm 19 only assigned to the Yankee Rowe facility and the Haddam 20 Neck, Connecticut Yankee facility. In the past, that's not 21 always been the case. I've been assigned to various l 22 facilities at a time, and my time is split up. It's not a 23 hundred percent devoted to the Yankee facility.
24 MR. DOSTIS: Okay. When you say you go once every 25 three months, how much time do you spend when you do go that N
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44 1 one time?
[
v) 2 MR. NICK: I roughly put 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in every 3 inspection. I typically put in a minimum of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> for 4 inspections, but it varies depending on what activity I 5 perform.
6 I'm also just the principal assigned inspector.
7 We have also other specialists inspectors who also perform 8 inspections at various times, depending on needs determined .
i 9 by the regional office and regional management on what type 10 of inspection needs to be performed at the Yankee facility.
11 MR. DOSTIS: Are these announced inspections, or 12 do you ever do sneak attacks?
13 MR. NICK: We typically have currently a policy of 14 announcing all our inspections, but we do reserve the right 15 to do surprise inspections.
16 I don't think that we've had a surprise inspection i
i 17 at the Yankee facility for quite a period of time.
18 Sometimes they're short notice, but they're typically 19 relayed to the licensee so they know and have the proper 20 people prepared for us to give us the information that we 21 need.
22 We've found that it's an efficiency matter for the 23 most part, and we typically have not seen any variation in )
24 the inspection results on whether it was announced or not 25 announced. !
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45 1 MR. DOSTIS: All right. So no cover-ups that you
()
'2 know or anything like that?
3 MR. NICK: We hope not. We haven't found any yet.
4 MR. DOSTIS: Okay. Here comes the real question.
5 When you're on the site, do you drink the water?
6 [ Pause.]
7 MR. DOSTIS: Honestly, Joe. Honestly.
8 MR. NICK: I'm trying to remember. I don't --
9 well, I think I have drank from their water fountains in the 10 past, yes.
11 bl. DOSTIS: You think?
12 MR. NICK: I don't remember. I don't have any 13 qualm about drinking the water, let me put it that way. But 14 if I have, it's certainly not memorable, let me put it that O .
k ,) 15 way. It didn't taste bad. I didn't avoid it on purpose, 16 either.
17 MR. PITTIGLIO: Let me provide just a little bit 18 more background regarding the question on inspections and 19 specifically talk about just for about a minute what we did 20 related to the Ft. St. Vrain project related to the final 21 surveys, because I think that's probably maybe what you were 22 getting at.
23 Not only was the inspector there, but we went out 24 with an inspection team. We conducted four inspections in 25 the last year on the final survey with teams that varied A
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46 1 from seven to nine people. So it wasn't simply one person ,
rN l 2
() on the site for 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
In addition, when we put the inspection plan 1
3 4 together, we identified areas and notified the licensee 5 where we would be taking measurements. We went out where 6 the licensee was taking measurements and took side-by-side 7 measurements, and then when we got to the site, especially 8 in what we call contaminated areas, unannounced, we elected 9 to say let's go into those areas and take side-by-side 10 measurements.
11 So I didn't want to give you the impression on the 12 final survey that it's one man for 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> once a quarter. ;
13 What will happen due to the uniqueness of the final survey, 14 it will be a team of NRC people with a significant amount of i
'\_s! 15 survey background as well as the use of our survey l 16 contractor that will go with us for -- and we'll look at 17 instrument calibration, check in and check out of 18 instruments, we'll take side-by-side measurements, we'll 19 resurvey areas.
20 So even though we're not resident on site, we will 21 devote a significant amount of time over the next year or so 22 in the phase survey approach.
23 MR. DOSTIS: And at Shoreham, that cost $30 24 million?
25 MR. PITTIGLIO: The Shoreham final survey, the r
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47 1 licensee side of it cost $12 million. The Fort St. Vrain
,n
(
x_/
! 2 licensee side of it cost $20 million. It was between the 3 two of them that the total survey costs were over $30 4 l million.
5 MR. FAIRTILE: I would like to add a little more 6 to what Joe and Larry said about inspections. Not only are 7 there Region I-based inspections that Joe takes care of, but 8 also people from headquarters, typically the project 9 managers, they go out to the plants also on a periodic 10 basis.
11 MR. DOSTIS: And everybody drinks the water.
12 MR. FAIRTILE: I've had no qualms -- I've been 13 drinking the water at the Yankee site for years, I had 14 coffee there. It doesn't bother me a bit. So far.
(7 is ,/ 15 Any other questions?
16 MR. DOSTIS: And you're what? Twenty-two years 17 old?
18 MR. FAIRTILE: Twenty-two, 23.
19 MR. WEISS: Let me make a point, then. Today is 20 Mort's 75th birthday. ;
21 [ Applause.]
22 MR. FAIRTILE: Sy is turning red and I'm turning 23 red. He's blushing and I'm blushing. )
i 24 Yes, ma'am?
25 MS. SLOAN: Can you repeat again how many ANN RILEY & ASSOCIATES, LTD.
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48 1 different measurements --
(m) v 2 MR. COUNCILMAN: Would you identify who you are?
3 MS. SLOAN: Sorry. Peggy Sloan. How many 4 different measurements will be taken and what percentage of 5 those will be checked or side-by-side measurements taken?
6 MR. PITTIGLIO: Well, the licensee indicated that 7 they were taking approximately 250,000 measurements. They 8 also have committed in their final survey plan to do about a 9 5 percent remeasurement of those areas.
10 Now, as far as the amount of side-by-side 11 measurements, it's hard for me to tell you the exact number.
12 I right now anticipate over the next year probably going out 13 with a team four different times of seven or eight people.
14 I'll use the ORISE Institute, they'll come in with
/-
k ,s) 25 technicians, so there will be four -- generally we have j 16 three or four of those people with us as well as I bring QA l 17 specialists. John Buckley and myself wrote quality 18 assurance procedures.
19 So we'll be looking at a whole lot of different 20 things. I can't tell you the number -- I can't even tell 21 you, even though we did it, the actual number of 22 measurements that we took for both Shoreham or Ft. St. Vrain 23 as far as a number. I mean, it was obviously significantly 24 less than 5 percent, but it was enough to give us a high 25 level of confidenta in the instruments and the procedures (n
\"'
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l 1
1 49 1 that they were using.
() 2' 3
MS. SLOAN: Would-you also explain how the NRC prepares the site release criteria and reviews the-4 termination plan in terms of how many different soil samples 1
5 -are taken, whether or not you coordinate with other 6 environmental agencies? Exactly what is the process for 7 determining what the acceptable' site release criteria are?
8 MR. PITTIGLIO: Well, currently the lice,nsee'is CR 9 going to be using the guidance provided in NUREG p"$ 4?)
oe.49,-~
l 10 which is our guidance document, that dictates per survey .
l 11 unit the number of measurements that need to be taken '
12 depending on what the classification of the survey unit is.
13 In addition to that, when we go do confirmatory J
14 surveys, based on a lot of experience we've gained from the
() 15' two plants, when we walk the site for soil samples, as an 16 example, at the Ft. St. Vrain plant, we had a good feeling j 17 for where the direction of runoff might be and where, if I 1
18 there was any contamination -- I call it bias, but what it 19 is is a best guess of -- not a random measurement. We go j 20 take additional samples in addition to taking split samples ;
21 from -- with the licensee to ensure that we're getting an 22 accurate reading and that their laboratory work is also 23 correct.
24 MS. SLOAN: So are there other agencies that were 25 involved in preparing the site committee's criteria or is it-() ANN RILEY & ASSOCIATES, LTD.
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50 1- pretty much --
(v ) 2 MR. PITTIGLIO: No. TLe NRC is the;only agency 3 that was involved with the final survey, the radiological 4 surveys,-even though occasionally we had people from the 5 states come out to-observe what we were doing and to gain 6 and learn some knowledge from what we were'doing. '
7 MS. SLOAN: Do you ever'have input'from like a 8 ' state. department of public health in terms of areas that 9 they would like to see sampled, or.take that type of input 10 in as you're going through your final. testing?
11 MR. PITTIGLIO: No, we don't do that because we're 12 -- what we're trying to do is to validate the validity of 13 the licensee's samples, so we use our technical expertise in 14 our own labs, and we feel confident with that. We. don't 15 have any calibration for an external source to -- whether 16 they even have appropriate lab procedures or whatever. I 17 would be somewhat reluctant personally to just give sources t
18 to another group.
19 There's an elaborate set of procedures that need 20 to be followed on the analysis of the data to assure that 21 you're getting an accurate representation of the data, and 22 that's why we take our samples and use our labs as an 23- independent check.
'24 MS. SLOAN: I was thinking more-in terms'of if a l 25 department of public health wanted you to take some
]
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51 1
- 1. additional samples based on their knowlecge of the --
~2 MR. PITTIGLIO: Well, I mean,.we're not objecting 3 to that, and the fact is that if.they come out and do that, 4 that's fine. But, you know --
5 MR. FAIRTILE: Let me.
6 In the past, we have cooperated with various state 7 agencies in Massachusetts and Connecticut in that regard.
8 But getting back to the first part of your question about 9 independence, I would like the licensee to say a few 10 words about how they handle their samples and verify their 11 instrumentation. 'en you address that a little bit, maybe 12 to help Peggy out?
13 MR. PITTIGLIO: Let me say one thing first.
14 For, example, with the Ft. St. Vrain, and Sy
- 15. brought up a good point that I didn't mention to you, the 16 State of Colorado came to us and said, we have some concerns 17 about tritium.
18 Now, they went out and did some independent --
19 came on site, took some independent samples and some 20 analysis on tritium, and we did the same thing. Then we 21 looked at the results of all of them. It turned out to be 22 that all of them were -- resolved the p:.oblem. But again, )
23 the state said they want to do it, they came out and did it, 24 the licensee had no problem with it, we didn't either. !
25 MR. HEIDER.: I'll come all the way up here to give ANN RILEY & ASSOCIATES, LTD.
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52 1- the question to somebody else. Guys, get on deck.
)) ~2 3
In terms of independence,- I've already talked a little bit about that this evening in that we have our own 4 quality assurance program, and that could be argued as being 5 probably not very independent in that_they are Yankee Atomic 6' employees,.but they do have an independent oversight role at 7 the plant and a different reporting chain at the plant. In 8 fact, they report up and eventually come back to Yankee 9 Atomic Electric Company.
10 Our laboratories that we use, which are Yankee 11 laboratories, are also cross-checked by other laboratories 12 in the country, and it's part of the EPA lab cross-check-13 program, and our equipment that we use on site is traceable 14 to the National Institute of' Standards.
() 15 Should I add anything more? That's my radiation 16 expert over here.
17 MR. FAIRTILE: Peggy, are you satisfied with what 18 you've heard so far, or do you have any further --
19 MS. SLOAN: No. I think I understand it.
20 MR. FAIRTILS: Okay. Any further -- any other 21 questions?
22 AUDIENCE MEMBER: Yes, I have a question.
23 MR. FAIRTILE: This gentleman here had his hand up 24 first.
25 MR. LOVEJOY: My name is Sam Lovejoy. I thought ,
1 ANN RILEY & ASSOCIATES, LTD.
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53 1 when you first made your presentation -- maybe you just
() 2 spoke too fast or I was hearing too slowly -- you said you 3 were going to be advertising in the National Register.
4 MR. FAIRTILE: Federal Register, yes. Yes. We'll 5 put in --
6 MR. LOVEJOY: Is this because you're trying to-7 decide whether to hold a Subpart G hearing or a Subpart L I 8 hearing or you're not considering either kind of hearing?
9 MR. FAIRTILE: No. The notice has nothing to do 10 with the type of hearing. The notice is just to give the 11 public an opportunity to make comments or request a hearing. !
12 The type of hearing will be decided in the future, or if 13 there will even be a hearing. You may request a hearing and 14 there'may not be a hearing granted for various reasons.
() 15 You can talk to Ann about that. l 16 MR. HEIDER: If I could just follow up with a 17 response a little bit, we, of course, we have worked with 18 the state in the past in terms of having independent 19 oversight of some of our measurements. In fact, releases 20 from the site, liquid releases from the site, we have a 21 program where the state does come in and periodically 22 monitor those releases alongside of us and take side-by-side 23 measurements. Of course, we would have no difficulties at 24 all in working in concert with both the NRC as well as the 25 state in that regard.
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1 54 1 MS.'NEWINGTON: My name is Nina Newington. I'm a ]
() 2 resident of Buckland and a member of the Citizens Awareness 3 Network.
4 I hava a number of questions for you. One is, 5 what have the NRC inspectors discovered about the extent of l
6 tritium contamination from the ion exchange pit and also the 7 extent to which that tritium contamination has reached 8 groundwater?
9 MR. FAIRTILE: The data that we have to date is 10 that the groundwaters at the site meet the EPA drinking 11 water limits, which is j pretty low level of concentration of 12 tritium, l
13 MS. NEWINGTON: What level have you actually j 14 discovered?
10
( ,/ 15 MR. FAIRTILE: Larry?
16 MR. HEIDER: What --
17 MR. FAIRTILE: She wanted to know what the actual 18 . level of tritium -- of tritium is in the site waters. Do I i
19 you all have that information?
i 20 MR. HEIDER: It's presented in our license '
21 termination plan. For those of you that are following i i
22 along, on Table 2.4 of our license termination plan, we have 23 recorded several values of tritium on site, and the EPA I i
24 drinking water standard is 20,000 and the unit on that is !
I 25 picocuries, pCi, per liter, and the value -- again, the '
I l
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l 55 1 limit is 20,000, and the maximum value for Yankee Rowe's
/ \
( ) 2 site is measured down gradient of the spent fuel pool 3 building, which is where you would expect that measurement 4 to be made.
5 f>une 1 The leakage that she's referring to is thatpearly 6 in the 1960s when the ion exchange pool or pit was first l 7 filled up with water, there was a leak in the bottom of that 8 pit. It was discovered that some of the water leaving the 9 site had high tritium measurements in it in the '60s, early 10 '60s, and the leak was -- the pool was subsequently emptied,
! 11 repaired, refilled with water, but that tritium did 12 contaminate the groundwater supply on site.
13 The current maximum value that we've mer.Jured 14 right now is 8,000 picocuries per liter, which is less than rx k ,)
m 15 half of the EPA drinking water standard near the water 16 systems for radioactivity.
17 Once it gets out to the river, which is where the 18 Sherman Spring is one of the predominant means for the water 19 to leave the site, it's about 300 picocuries per liter.
20 Sometimes it's undetectable, depending upon the flow of 21 water on the site. That's below the level of detection for 22 the instrumentation that's used. So it's a very small 23 fraction of 20,000.
24 On table 2.4 is the information. If you want to 25 see me afterwards, we can get your name, I can send you a ANN RILEY & ASSOCIATES, LTD.
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56 1 copy of that, if you would like.
() 2 MR. TITTIGLIO: It will be about two more weeke or 3 so before the license termination plan appears on the 4 . microfiche in the local public document room, but the 5 licen' tee has committed to put a hard. copy of the license 6 termination plan in the local public document room tomorrow.
7 MS., NEWINGTON: Okay. How much cobalt-60 and 8 cesium-137 have you discovered in any' area around or on the 9 site?
10 MR. HEIDER: Is that question addressed to Yankee?
11 MS. NEWINGTON: It's to anybody who can -- you're 12 both supposed to have been doing some inspecting; perhaps 13 you both have answers to that.
14 MR. HEIDER: Okay. I can answar from Yankee's
(_) 15 perspective, and the answer is that there are many different 16 values that have been discovered in and around the Yankee 17- ' site, and as part of our extensive surveying program 18 on-site, we've looked specifically for cobalt-60.
19 Just for people's reference who may not be as 20 familiar with radiological issues, cobalt-60 is one of the 21 radionuclides that comes from the site. It comes from when 22 steel corrodes in products, circulate through the main 23 coolant system on-site, and that one of the components of 24 steel is cobalt and that becomes irradiated in the reactor, 25 and then once that water reaches other systems on-site, it
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57 1 may deposit in systems or it may spill on-site or otherwise
() 2 contaminate areas'on-site. Cobalt-60 is a predominant 3 nuclide.
4 Cesium-137 is a little bit different. It comes 5 .from two different sources, one from the plant and the other 6 from weapons testing.
4 Let's focus -- focusing on cobalt-60,1we have, 8 again, many different values that are presented in the 9 license termination plan. I would ask you to review that to 10 be able to see all the values. Really, that's the subject 11 of our final status survey, is to be able to demonstrate 12 that those values meet the site release criteria and that 13 the soils are cleaned up.
14 MS. NEWINGTON: Can you tell me what the half-life 15 is of cobalt-60 and cesium-137? ;
i 16 MR. HEIDER: .The half-life for cobalt-60 is 5.27 !
17 _ years, and the half-life for -- j 18 MR. CAVANAUGH: Cesium-137 is a little bit over 30 l
19 years, 30.2.
20 MR. HEIDER: By the way, this is Greg Cavanaugh, 21 and he is the radiation protection manager at Yankee Rowe.
22 MS. NEWINGTON: So you have also found cesium 23 on-site; is that what you're saying?
24 MR. HEIDER: That's correct.
25 MS. NEWINGTON: I've got one remaining question
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58 1 for.you. Was I correct in gathering that although'you were
( 2 not intending to leave the site with any more than 15 3 millirem, in fact the regulations would allow you to leave 4 up to 25 millirem if it was later designated as a restricted 5 use site. Is that correct?
6 MR.'HEIDER: That's not quite correct. Let me 7 speak to our criteria first and then I'll turn it over to l I
8 the NRC so that they can discuss or clarify the regulation {
9 for you.
10 Yankee is asking for approval of 15 millirem per 11 year. That's the value that we selected. That's the value 12 we will stay with in our decommissioning plan.
13 Mort, if you would you like to clarify the 14- regulation?
() 15 MR. FAIRTILE: Larry will clarify that using one 16 of our regulatory guides, but I want to make a point. I 17 want te back up a little bit.
18 In discussing license termination plan that was 19 issued on May 15th of last year, that plan, I understand, is 20 available in the Greenfield Community College library. The 21 licensee subsequently filed a December 18th response to some 22 NRC questions and some more data on the plan. That is the 23 document that may not yet be available in the local public 24 document room at Greenfield Community College, and that's 25 the one -- Jane, correct me if I'm wrong -- that you
(-
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h 59 1 committed-to get to the-PDR?
2' MS. GRANT: Yes.
3 MR. FAIRTILE: Okay. Jane said yes 4 Jane Grant is the manager of decommissioning for
, 5 Yankee Atomic.
l l 6 Larry, you want to --
7 .MR. PITTIGLIO: With regard to the 25 millirem, i
8 that is the allowable limits that has been established by 9 the Nuclear Regulatory Commission under Part 20 of subpart E 10 for unrestricted release. Its set up so that if -- again, 11 we talked about when you looked at the slides where there 12 were also some restricted release scenarios where they could 13 go up to 100 millirems, and it was a 25 millirem with 14 restrictions, and if the restrictions failed, so forth and
) 15 so on. So the 25 millirem for unrestricted release was what 16 NRC believes is a number that assures protection of health 17 and safety of the public,' and that's what the 25 mil.iirem is 18 under new Part 20.
19 Again, the new Part 20 does allow flexitility for 20 sites to go to a restricted release scenario where with 21 restrictions, they have certain limits, and then when the 22 restrictions fail, they have other limits. It also has a 23 flexibility under the new rule to even come in with an 24 alternate criterion for a unique case where the licensee can 25- come in and bring forth something different than the 25/100 i
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60 1 millirem. Whether it would get approved or'not would have a 2 lot to do with the conditions and the assessments that they 3 do to demonstrate compliance.
4 MS. NEWINGTON: Thank you.
5 MR. FAIRTILE: The gentleman in the back? Oh.
6 Behind -- oh, is that your hand?
j
'i MS. STREETUM: I have had my hand up a long time.
i 1
8 MR. FAIRTILE: I'm surry, i
9 MS. STREETUM: I would like to go back to -- l 10 MR. FAIRTILE: Would you identify yourself? j 11 MS. STREETUM: I'm Sandra Streetum. I'm a member i
12 of the Citizens Awareness Network. l 13 I would like to go back to the inspections 14 process. If I understand what's been going on, the reason 15 they're closed down is because after 28 years of 16 inspections, no one knew that their safety systems didn't 17 work. With that kind of a record, how are we supposed to 18 feel confident in inspections that the NRC is doing? j 19 MR. FAIRTILE: Anybody else?
20 AUDIENCE MEMBER: You don't want to answer that?
21 MR. FAIRTILE: I have no answer to that, no.
22 AUDIENCE MEMBER: Why not?
23 AUDIENCE MEMBER: What about Millstone?
24 AUDIENCE MEMBER: Wait a minute, Mort. You've 25 been with the agency for how many years, and you don't have ANN RIaEY & ASSOCIATES, LTD.
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Il 61 1 an answer to that? Is there anyone here that is more 2 qualified to answer that question?
3 MR. FAIRTILE: You're asking --
4 MR. COUNCILMAN: Excuse me, folks. We do have a 5 requirement that you identify yourselves for the purpose of 6 preparing an accurate and complete record.
7 MR. MASNICK: My name is Michael Masnick. I'll 8 take a stab at that question. ;
9 We have an inspection program that we have been 10 conducting for quite a few years, and there have been in the 11 past occasionally some criticism as to some of the findings, 12 but I think overall, the agency does a pretty good job in 13 providing --
14 MS. STREETUM: I disagree.
15 MR. MASNICK: -
providing that oversight. I 16 don't know what else to tell you.
17 MR. PITTIGLIO: You know, and I would provide for 18 you, if you're really interested in what we do related to 19 the final survey, since the local public document room does
- 0 have the mic ofiche, you can go back in under 1996,
[m'M 21 under the de v 6/24[
^
, ant number 50-267, and look at the four 22 detailad inspections and the supporting inspection reports q
23 that were really one of the main reasons why we released the 24 site for unrestricted release, and if you really want to see 25 what we did, the number of people involved, and the amount ANN RILEY & ASSOCIATES, LTD. -
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
62 1 of-information, it's right down here in the local public
() 2 document room in the file under the docket of 50-267.
3 MS. STREETUM: I've been to the document roota 4 quite a bit, and it's very hard to look that information up, 5 and a lot.of it is missing.
6 MR. PITTIGLIO: Well, that's why I say the way to 7 look at -- we were just down there, there is a manual. If 8 you go back under the docket of 50-267, they'll provide you 9 an eight- or nine-digit number reference, and you can go in 10 and pull the inspection reports up on a microfiche. It's 11 not the easiest system in the world, but it is there because I checked it today, and there are four or five inspection i
12 13 reports that are several pages long with information related 14 to recent inspections. If you really want to see -- your
/^\
(m,/ 15 question was what kind of confidence will you have, I think 16 this new in-process approach that we took to demonstrate 17 compliance with the criterion is an-excellent example, and-18 it is -- you know, it is in the docket and it is there for 19 you to take a look at, if you're interested.
20 MS. STREETUM: Well, I just want to register that 21 I'm very disappointed to see the same people here tonight -l l
22 that are doing what they're doing in Connecticut and we're '
23 being told we have to accept that. Well, I'm sorry, I l
24 don't. '
25 MR. WEISS: Let me talk a little about j
()
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I 63 !
)
1 Connecticut, and I think I said the same thing when I was in }
wl 2 Connecticut in a talk there.
\
3 What we have found in Connecticut has been some ;
4 radioactive. contamination that was in soil that the plant {
5 gave to townspeople to use as fill. We found some 6 radioactive contamination on some construction blocks.
7 The licensee has gone back, the state has been l
8 involved, the IRC has been involved, and the doses that were
'Mo 9 found were really minimal. They would have bu. impact on the 10 health and safety of the public, but they shouldn't have 11 gone out, period.
12 MS. STREETUM: Do you realize how many times 13 you've made that statement, that there's no impact to the 14 health.and safety of the American people, and it's crap.
()
(h 15 MR. WEISS: It is not. We have worked with the 16 governor -- l 17 MS. STREETUM: Yes, it is.
18 MR. WEISS: We've worked with the gcVernor and the 19 public officials in Connecticut, and I think everybody is in 20 agreement that --
21 MS. STREETUM: No.
22 MR. WEISS: -- that the issue is not significant.
23 Next question, please. Yes? Debbie?
24 MS. KATZ: I have a couple of questions. One of 25 the concerns that we have had in Connectic"t and potentially ANN RILEY & ASSOCIATES, LTD.
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64 1 here is the issue of the inability to keep radioactive waste
() 2 on-site. I mean, that's really the~ issue, what happened at 3 Connecticut Yankee, and also potentially at Millstone since 4 they had fills that left the site and shouldn't have done 5 so.
6 I mean, I just want to talk about this issue of 7 the tritium that leaked from the ion exchange pit, because 8 we're talking about 8,000 picocuries now. But what were the 9 picocuries in the '60s on its way while it was migrating 10 down into the Deerfield River, and how long did that go on 11 since the '60s, and how much tritium was released over --
12 we're now talking approximately 30 years. So that's one 13 question I have.
14 MR. WEISS: Well, let me ask Yankee to respond to
(_j/ 15 that question before we go on.
16 MR. HEIDER: Thank you for the question, Debbie.
17 [ Laughter.]
18 MS. KATZ: It's a really tough question.
19 MR. HEIDER: I don't have all the data with me 20 here this evening. We have had a leak, as I said earlier 21 this evening, from our ion exchange pit back in the early 22 1960s, and it released a certain amount of tritium to the 23 environment. The amount of tritium that was released from 24 the ion exchange pit was a small amount of tritium compared 25 to the amount of tritium that was released as part of our O ANN RILEY & ASSOCIATES, LTD.
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l l
65 1 license release on site.
() 2 I'm sure-you are aware and many other people in 3 the audience are aware that the release permits for Yankee 4 Rowe that are issued by the government and monitored by the !
5 NRC, F.mong others, allow us to release radionuclides into 6 the river. One of those radionuclides is tritium, which is 7 a radioactive form of hydrogen that's actually found in the 8 water molecules and gets released as part of the day-to-day l
9 release from'the site in operation.
10 If you look at the total amount of tritium that we 11 released, which is measured in a un'.t called curies, and you 12 take the ratio of what went out from that exchange pit 13 compared to the water that was released during operations, ;
14 it's a small fraction of that. i 15 The actual tritium concentrations -- I don't have 16 them with me this evening, but if you go back to the 17 decommissioning plan for Yankee Rowe, you'll find a plot 18 that presents that information in it.
19 MS. KATZ: Well, I'm just wondering, because you 20 know, originally, Yankee said they estimated it was 21 somewhere around 200 curies, but if we're just down to 8,000 22 picocuries at this point, then I'm just wondering how, over 23 30 years, what it was when it started in terms of 24 picocuries. Maybe you can supply that information. But
~25 this is all.about radiological control. I realize you don't ANN RILEY & ASSOCIATES, LTD.
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l 66 l 1
l' have that answer, but maybe --
.-q
( j 2 MR. HEIDER: Right.
3 MS. KATZ: -- we could talk about that.
4' MR. HEIDER: As I said, the answer is available in -
i 5 our decommissioning plan in terms of the number of l 6 picocuries per liter concentration of that. I
~7 MS. KATZ: I'm also interested in the issues of 8 how much deteriorated fuel -- you know, you have 40 million 9 curies of fuel assemblies in the pool, and I wondered how 10 'many of those fuel assemblies in fact have deteriorated and, 11 you know, were in deteriorated condition and how you're !
12 going to deal with them in terms of transfer. What is the I 13 process involved? !
(
14 MR. HEIDER: Well, we have 533 fuel assemblies 15 that are stored in our spent fuel pool. That's about-half 16 the amount of fuel assemblies that we operated with during i 17: the entire life of the plant The balance of them were 18 reprocessed prior to the government stopping that process in 19 the 1970s.
l 20 I don't have the exact number of fuel assemblies 21 that may have a failure, what we would call a failure. It's 22 certainly an issue that we have to address if we intend to br 23 move the fuel.out the dry cask storage facilities. It's 4
24 also an issue that we have to address if we want to move 25 fuel to the Department of Energy through their cask systems.
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l 67: l l
1 That's something we're working on'right now.
t We're
().
~
2 designing the containers that wi 1 look very similar to fuel 3 assemblies to contain those damaged rods from the fuel 4 . assemblies.
5- Each fuel assembly has a couple hundred rods which 6 are'just basically seven or eight feet long., stainless -- 1
'7' sometimes they're stainless steel. They're a fairly small 8 diameter and contain nuclear fuel. Some of them may have !
l 9 pinhole leaks in them, and those have to be treated'special !
i 10 when they're shipped to the Department of Energy. They'll l 11 be placed-into containers that look similar to fuel j i
12 assemblies, but they'll.be slightly wider in diameter.
13 [ Pause.)
14 liR . HEIDER: I'm asking Rick Williams. Rick 15 Williams is the plant manager, by the way -- or, actually, 16 I'm the plant manager. He's the plant superintendent. The 17 difference is that I work for Engineering Services and. Rick 18 is still at Yankee Atomic Electric Company.
19 MS. KATZ: How do you decide who gets to work for 20 whom?
21 MR. HEIDER: Who gets to work with whom? It's a 22 cooperative arrangement.
23 [ Laughter.)
24 MS. KATZ: You know, I read Russ Mellor's -- he 25 came out with an abstract on the process of spent fuel ANN RILEY & ASSOCIATES, LTD.
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68 1 storage, and one of the things he raises in terms of the
[
.v} 2 reason to go to dry cask storage is to save money, 3 basically, and what you would save are 33' workers' jobs.
4 That's some concern to us, because then certainly 5 if the fuel pool stays there, then 33 people would stay 6 employed in Franklin County monitoring the fuel and watching 7 the progress, and that's the only difference he found in 8 terms of going over in terms of money, that that's what 9 Yankee would save in switching over to monitoring. So as a 10 good neighbor, it would seem better to keep the jobs in this 11 poor rural community.
12 MR. COUNCILMAN: Excuse me, gentleman.
13 We're at a point where we have just about an hour 14 and ten minutes left in our schedule. We have 20 people who
) 15 are registered to speak. If you folks wouldn't mind, I 16 would like to get started with that process. If we were to 17 average something in the order of 3 minutes or less per 18 individual -- if I might make the observation, many folks ;
19 who have already asked questions or offered comments are, in 20 fact, on the list. Perhaps we will have sufficient time for 21 those individuals who wish to comment or ask additional 22 questions.
23- As I mentioned earlier, it's important for us to 24 be careful to identify ourselves before we speak. Many 25 people on this list, I migb': note, I recognize, and I'll ANN RILEY & ASSOCIATES, LTD.
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69 1 make my best attempts to spell your names. If you're r\
i 2 concerned about the spelling or if I pronounce it in an
\~.) _
3 unusual fashion, please feel free to correct me.
4 If you're concerned ultimately about the way your 5- name might appear in the transcript, I~would suggest that 6 after the meeting, check in with the gentleman who's the 7 reporter, who I'm sure will set things straight.
8 Mr. Dostis, you're you're number one on-the list.
9 MR. DOSTIS: Yes. John Dostis, Salem.
10 I would like to give my three minutes up for 11 questions because I think that we're being very productive.
12 So my three-minute statement will go to someone out here 13 asking questions.
14 MR. COUNCILMAN: Thank you.
A i ,)
s 15 Mr. McCollum, you're second on the list.
16 MR. DOSTIS: Well, would you give my three minutes 17 to someone to ask questions, please.
18 MR. COUNCILMAN: I assume, in the circumstances --
i 19 MR. DOSTIS: Okay. I'd like to take my three ;
20 minutes, sir. I would like to take-my three minutes.
21 Okay. Who has a question for me? You can ask it.
22- Go ahead. i 23 MR. BLOCK: Yes. My question --
24 MR. COUNCILMAN: Excuse me, sir. Would you 25 identify yourself?
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70 1 MR. BLOCK: I just did. You were talking, so you ji
() 2 didn't hear me. John Block. l 3 Would you compare the EPA limits of exposure to 4 the new Part 20 limits? You could probably do it as well as !
5 the NRC could. You could probably do it as well as the NRC 6 could.
7 MR. DOSTIS: Yes, but is there someone from the l
8 NRC who would like to answer that? j 9 MR. COUNCILMAN: This is not a Q and A, so I would !
i 10 just like it to be a statement.
I 11 MR. DOSTIS: Do you want to make a statement, Mr.
12 Block?
L 13 MR. BLOCK: Yes. I think the EPA has much tighter l 14 limits than the NRC in their Part 20 limits, and that we're 15 getting weak enforcement here. We could be getting much 16 stronger enforcement.
17 MR. DOSTIS: Okay. Is that it? Anybody else have 28 a question?
19 Okay. I have a statement.
20 With all of the monitoring around Yankee Atomic, 21 it seems like a pretty ridiculous thing because all of the 22 nuclides have been shifted down to South Carolina. I want 23 to know what kind of monitoring is being done around 24 Barnwell.
25 MR. COUNCILMAN: Mr. Leffond, you're second on the ANN RILEY & ASSOCIATES, LTD.
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71 j "1 list.
() 2~ MR. LEFFOND: Thank you. My name is Lenny 3 Leffond, I'm.the chairman of the board of selectman from the 4 town of Rowe. I'm speaking for the board of selectmen and 5 also for the board of health of the town of Rowe.
6 Before I begin, I would like to say that in the 7 past, officials from the town of Rowe were very apprehensive ;
8 to get up here and speak in favor, against Yankee or in 9 favor of Yankee because you all know that we had a lot of i 10 people _in Rowe that worked for Yankee and we also collected 11- a lot of taxes from them.
12 Well, most of the jobs that people had in Rowe 13 have gone and our tax base has really suffered since Yankee ,
14 shut down. So with that, you can't accuse me of saying I'm
\_,/ 15 up here trying to protect our taxes or protect our jobs.
16 What I want to say is I would like to go on record 17 and support Yankee's plan for license termination, and why i
18 I'm saying that is 40 years ago, we watched Yankee come into 19 our town, and I did, and they built a plant, they built a i
20 plant and they ran it, they ran it for 31 years and they ran l 21 it safely, and then they said they're going to tear it down, 22 much to our chagrin, and they started tearing it down, and 23 sure, they're going to finish it, but they need to be able 24 to finish it, and we think that they will finish it.
25 So I think I would just like to ask the NRC to ANN RILEY & ASSOCIATES, LTD.
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I-L 72 1 approve their plan, and I look at it this way too, is where 2 'else or what other industry could you have that comes in, 3 cuts all the trees down, builds a plant, runs it for 40 4 years, clos'es it down, and then says it's going to clean the
- 5 plant up or clean the' site up and put it back the way that 6 they started? If that happened around Franklin County, we 7 wouldn't have all of the messes that we've got around here. l l
8 So with that, thank you. !
9 MR. COUNCILMAN: Is there a member of the town of I
10 Rowe select board present? I have a letter that I have been l l 11 asked to read, it's directed to Mr. Fairtile of the NRC.
12 It reads, "
Dear Mr. Fairtile,
we the select board 13 of the town of Monroe support the Yankee Nuclear Power. Plant l
[ 14 of Rowe, Massachusetts, in its license termination project.
15 We ask that the United States Nuclear Regulatory Commissior-16 approve the license termination application. Thank you foz- i 17 your consideration on this matter." It's signed by Helen q 18 Oats and Larry Furson.
19 Speaker number four, Paul Blanch? Did I pronounce i
l' 20 that properly?
21 MR. BLANCH: Thank you. My name is Paul Blanch.
22' I'm not sure whether this is a question and answer session, I l
l- 23 but I reside in Connecticut. I'm an energy consultant I l' ;
l 24 have more than 30 years experience, and I'm presently ;
25 employed as an energy consultant for the Millstone Nuclear ANN RILEY & ASSOCIATES, LTD.
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73 1 Power Station and have been very active in many of the NRC 7 i hearings.
(G 2.
3 In response to a statement a lady made, and I've 4 mad.e the same statement to many of the regulators, I never 5 'aant to hear this no danger to the health and safety of the l 6 public because we get that an awful lot. However, I've 7 reviewed the data at Connecticut Yankee, and I don't know 8 how else to state it --
it is so low, it's almost i
9 immeasurable, but that's not why I'm here, but I did want to 10 clarify that.
11 I reviewed the licensing termination plan, and I 12 have some technical questions, and seeing as this is not a 13 question and answer session, I guess I'm going to turn them 14 into statements.
/'~ ;
(_)T 15 Again, it's clearly stated that the site is going j 16 to be remediar.ed to 15 millirem per year, which means that a 17 person, a resident on the site, from all sources, from food, l
18 from direct expo 3ure, from drinking the water and living 19 there 365 days a year in a tent or whatever, on the ground, 20 will not receive more than 15 millirem per year.
21 Now, I go on into the license termination plan and 22 also the slide that was put up there by the gentleman from 23 Yankee Atomic, and I see numbers of 10 microrad per hour.
24 Now, I don't have a quality assurance program, and 25 the NRC doesn't have a quality assurance program, but Yankee (n)
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74 1 Atomic does have a quality assurance program, but my numbers l'%
(u s) - 2 say that 10 microrad per hour would relate to an exposure of 3 about 87 1/2 millirem per year. Am I. wrong in that number?
4 I.think that's the right conversion. There's 8,700-some 5 hours times ten. It turns out to be 87 millirem per year.
6 This is a big discrepancy, and if it is, in fact, 7 'true, then there has to be restrictions on the use of that 8 land.
9 It's a very, very basic question.I have, and I 10 just truthfully don't have an answer, and I'm seeing similar 11 stuff at Connecticut Yankee.
12 MR. COUNCILMAN: Let's pause for a moment. We 13 believe there is a ready answer to the question.
14 MR. DOSTIS: Oh, you're going to answer some Q' 15 questions and not answer some others? Is that how you. guys 16 do it?
17 MR. COUNCILMAN: Mr. Dostis, we can move along.
18 Hopefully there will be time for you to make further 19 statements after we've worked through the 20 people.
20 MR. DOSTIS: I don't think so.
21 MR. BLANCH: If you don't want to answer it, just 22 take it back and -- I mean, it does appear to be a very 23 significant discrepancy in the licensing termination plan 24 and what was presented.
I 25 Ken, do you want to say something?
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75 1 I do have another minor --
r\
.( f 2 MR. HEIDER: What I would like to say is that I'd 3 like to collect the. questions as they come along during the 4 discussion, and.I can respond to them maybe afterwards.
5 MR. BLANCH: Okay.
6 My second. concern here is that, according to the 7 termination plan, that the Part 50 license is going to 8 remain in effect'through the entire decommissioning, 9 - including the long-term storage of spent fuel and also 10 including the conversion to dry cask storage.
11 This is totally inconsistent with the intent of 12 the regulation. 10 CFR Part 72 is designed for the 13 long-term storage of spent fuel, and from my knowledge, I 14 think, of Prairie Island and some of the other plants who 15 have gone to dry cask storage, they have actually converted 16 to a Part 72 license which in the regulations, in Part --
17 well, 10CFR, 41 pages long, very detailed regulations, it 18 appears as though the NRC is endorsing Yankee Atomic's 19 continuance of the Part 50 license.
20 As Dave Lockbaum says, it's like if you have the i 21 Department of Transportation licensing both airplanes and 22 buses, and all of a sudden, you're going to take the 23 airplane, take its wings off and make it into a bus and 24 drive it down the local streets here and still call it an 25 airplane and it has to comply with the regulations that j
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I 76 1 airplanes have to complyEwith.
() 2 It is just totally inconsistent with the intent of 3 the regulations. The NRC does not want to impose the 4 requirements of Part 72. I think it absolutely -- if you're 5 going to have a high-level waste dump or waste storage 6 facility there, you need to impose the requirements of Part
.7 72, whether it's wet storage in the spent fuel pool .cn: j 8 whether it's dry storage in the dry cask storage.
9 Thank you.
10 MR. COUNCILMAN: Mr. Laipson.
11 MR. LAIPSON: My name is Adam Laipson. I'm the 12 current chairman of the Franklin Regional Planning Board, 13 which is made up of members of the select boards and' 14 planning boards of the 26 towns in Franklin County as well 15 as 18 other members voted in at large and the executive 16 committee of the Franklin Regional Council of Governmente 17 Our overall mission is to promote sustainable 18 economic development, protect public health, safety and 19 welfare, and to preserve the natural and cultural resources 20 within our region.
21- Over these past several months, we have been 22 involved in studying Yankee Atomic Electric Company's 23' license termination plan for the Rowe Nuclear Power Station.
24- Yankee has made a presentation to our board and we are very 25 grateful for the responses to the questions and comments i ANN RILEY & ASSOCIATES, LTD.
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I 77 1 that we made to them in early December. ;
-( ) 2 I would like to submit for the record of this 3 meeting copies of our letter and Yankee's responses. I'll 4 pass this on-a little bit later.
5 Yankee has also been eager _to meet with our board 6 to address additional concerns. We would like to thank them 7 for their willingness for dialogue and we look forward to 8 continuing this type of positive communication in the 9 future.
10 Although we greatly appreciate Yankee's public 11 information efforts, our volunteer board, representing a 12 region of very small rurul towns with very limited staff 13 resources, does not have the expertise or experience to 14 adequately address the complexities of terminating the
' 'N_,/ 15 license of a nuclear power facility.
16 We continue to have concerns regarding technical 17 evaluations,' surveys and sampling criteria and regulatory 18 procedure. As we have developed a basic understanding of 19 the issues involved in this plan, we realize a need for 20 independent technical advice to help us evaluate the 21 implications of this license termination plan.
22 There are several fundamental issues that seem to 23' be outside the purview of the licensee to respond to that we 24 feel must be addressed in a public forum, and these issues 25 include,-one, a meaningful local public participation in
(*}
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l 78 j 1 this licensing process.
(v) 2 We agree with the NRC's strategic assessment plan 3 goal to, quote, " provide the public with clear and accurate 4 information about.and a meaningful role in NRC's regulatory 5' program so that there will be respect for and confidence in 6 that program." Unquote. ;
7 We acknowledge the importance of public j
- 8. participation in this process. Unfortunately, as a result i
9 of our lacking expertise, our questions and comments are 10 somewhat limited in scope; therefore, we'are seeking 11 independent expert review and verification of technical 12 information as well as of logistical planning for site-13 transition from an operating facility to a temporary safe 14 storage facility to.a condition of unrestricted use.
(, 15 In our desire to be informed and to be 16 knowledgeable participants in this public process, we are l 17 pursuing technical assistance funding for this purpose.
18 To the NRC, I address: your assistance in 19 this matter is most critical and would signify your 20 commitment to a meaningful role for the public in this 21 process.
22 We also request that final decisions regarding the 23 license termination plan be postponed until an adequate
- 24. independent review can be performed to help identify and 25 address the public's concerns.
r~
- ( ANN RILEY & ASSOCIATES, LTD.
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79 1 Two. The q"estion of approving the license (o) 2 termination plan before final or interim decisions are made j
3 about spent fuel storage. We would'like to know exactly i
4 what will be implemented in regard to the spent fuel and
)
5 other high-level waste.
6 Exactly, what storage system will contain spent 7 fuel if not in the existing spent fuel pool? We are ,
8 perplexed by the intricacy of licensing a dry cask storage 9 system under 10CFR Part 50 versus Part 72. Does the Part 50 10 license terminate when the spent fuel pool is decommissioned 11 or when all spent fuel is removed from the site? Does the 12 licensee transfer to a Part 72 license when the spent fuel 13 is transferred to a dry cask storage system? Can the 14 greater than Class C waste be held under a Part 72 license?
15 Given the apparent difficulty of establishing a 16 permanent national high level waste storage facility, and 17 given that the NRC Office of the Inspector General has 18 identified areas for the NRC staff improvement to include 19 formal training in dry cask storage design, construction, 20 quality assurance and operation, we find it premature and 21 imprudent to approve the license termination plan with i
22 on-site spent fuel storage issues left unresolved. i 23 As new dry cask storage technology is developed, 24 design improvements and safest handling procedures will be i
25 established. We hope to benefit from proven systems. We do j
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80 1 not necessarily want the Rowe site to be a testing ground
(/
w 2 for new high-level waste storage technology.
3 (Applause.]
4 MR. LAIPSON: What guarantees of design and 5 construction adequacy for the type of storage system to be 6 implemented will be provided to the public? What types of 7 redundancy safety systems will be in place in the event of 8 "an event"?
9 These and other questions regarding short- and/or 10 long-term storage should be answered before approval'of the 11 license termination plan.
12 I had a third issue that we wanted to discuss 13 involving independent site analysis and I appreciate the 14 NRC's description of what their criteria and independent 15 testing and verification processes were for that, and.that 16 ' explained quite a bit that we hadn't previously been aware i 17 of or been informed about, and thank you for that 18 information.
19 These questions and concerns are only some of the i
issues raised in our study of the termination plan.
20 We hope 21 that you will not rush to decisions that can impact our 2F communities for many years to come. We trust that you too .
23 have the desire to see the Rowe site left in as clean a ]
24 condition as possible. Achieving that goal is a long-term i 25 endeavor in which we are all deeply invested.
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81 1 Please-allow adequate time for flow of information
() 2 and proof of compliance to convince the public that its best 3 interests are being protected.
4 Thank you.
5 (Applause.]
6~ MR. COUNCILMAN: Mr. Olchowski.
7 MR. OLCHOWSKI: My name is Ch -lie Olchowski. I 8 too am a member of the body with Adam Laipson. My questions 9 and comments ~are probably more pointed than his 10 representations.
11 The first I don't believe is within the purview of 12 the NRC because it's nonradiological material that has been 13 spilled on the site, and my questions involve the fact.that 14 there were questions that we posed to Yankee Atomic Plant, 15 and they were very forthcoming in their answers, but my 16 questions are still that there were four instances that they 17 reported as to nonradiological spills. I'm wondering if 18 those matters have finally met closure with either DPA or 19 the EPA and are they really brought to any finality at all, 20 and maybe Ken can answer that question later.
21 There's also -- one of the answers they presented 22 to us is that I was curious as to the composition of the 23 oils that were in the transformers, regulators and the oil 24 circuit breakers that were used, and whether you will verify 25 that that oil was received by an approved disposal facility.
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82 1 My other question goes to plant-related
(~%j 2 radionuclides, and that was brought up by I believe Debbie 3 Katz earlier. It was regarding the cesium and cobalt-60 and 4 perhaps other radionuclides that were produced or discharged 5 by'the plant into the Deerfield River.
6 In their answer, theystatedthatthedamfs 7 themselves are flood control mechanisms that will prevent 8 those compounds from going further downstream, but I assure 9 that a one in 100 year storm or a one in 1,000 year storm 10 certainly could have enough turbulence to cause some of 11 those materials to be released downstream closer to the town 12 of Shelburne and other villages further downstream.
13 The Fitebrook Dam itself, which is fairly new the 14 Sherman Pond outflow, is a bottom release dam, which would
(~h
\_ ,/ 15 not give me assurances of the fact the sediment would be 16 staying behind that particular impoundment.
17 I would certainly encourage that core sampling be 18 done behind the dams below Sherman Pond to determine the 1
19 presence of any of these compounds because within a 40-year 20 period, the dams along Deerfield were re-commissioned for 21 another 40 years or ran a license that long, and part of 22 that license is the decommissioning process that will occur 23 perhaps when those dams go out of operation, and at that 24 time, the compounds and the sediments behind those .
l 25 impoundments will have to be addressed as to what their
)
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i
83 1 composition is.
() 2 I think it would be incumbent on the producer of 3 those compounds to provide that information to the dam 4 operators who happen to be the same people.
5 As Adam stated, I again felt some assurances this 6 evening about the testing aspect of this whole process, but 7 I would still feel more confident that some independent 8 studying be done of the monitoring and testing and the 9 review of data, on at least a casual basis, because no 10 matter how much report integrity the applicant may have, 11 it's always suspect when self-testing occurs in this whole 12 licensing process.
13 Further, I encourage that a third party be funded 14 to help assist the county in reviewing the filings,
() 15 documentation, and all aspects of the termination plan.
16 MR. COUNCILMAN: Mr. Pearlman.
17 MR. PEARLMAN: Hi, I'm Bill Pearlman. I'm a 18 selectman in Ashfield, a member of the planning board and a 19 member of the executive committee of the Council of 20 Governments.
21 I just wrote this statement a little while ago 22 when the lights were out, so it may be a little hard to 23 read.
24~ But in an effort to be -- I'm making the 25 assumption that all the parties involved are -- their O ANN RILEY & ASSOCIATES, LTD.
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1 I
84 1 integrity is absolute, and the problems that we are facing
() 2 are within a historical context, and in my attempt to be
~
3 fair to the parties involved, I'll probably'end up insulting 4 all of them, but those who have w>rked with me before will 5 realize that's not unusual.
6 [ Laughter.]
7 MR. PEARLMAN: The history of the nuclear industry 8 has not been without its problems. Certainly the 9 government-run facilities like Hanford are now reaping the 10 radioactive fruits of their refined plutonium seeds sewn 11 under the unsupervised guise of national security.
12 The public is still convinced that it does not 13 know the full extent of the Three Mile Island instance, nor 14 numerous emergency shutdowns of plants across the country.
) 15 Stories of corner-cutting by construction contractors still 16 abound, and supposed state-of-the-art plants like Shoreham 17 never produced a single watt of electricity.
18 This cloud of doubt also obscures the' fact that 19 untold megawatts of electricity have been generated by 20 operating plants since Rowe went on line, and this is 21 certainly a tribute to the electrical utility industry.
22 But now Rowe is closing and has acquired, through 23 no fault of its own, the legacy of years of misinfonmation 24 and doubt about its plan.
25 These doubts are understandable. In an t: ort to
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85 1 allay these doubts and to help this community put its mind i
O( j 2 at ease, I again ask for some funds to be made available to 3 us through the planning board to hire some independent 4 consultants to verify for us the adequacy of the licensing 5 termination plan as put forward by Yankee.
6 Assuming the integrity of the plan, Yankee tan 7 only benefit by independent confirmation of.the adequacy of 8 the pr6posals.
9 Among many other reasons, the NRC was created to 10 protect the health and populations of the adjacent 11 communities to nuclear power plants. Some impediments to 12 help is fear, fear stemming from lack of information and 13 misunderstanding. j 14 Again, independent confirmation of the adequacy of fh (m,) 15 the NRC oversighL of this plan will go a long way to help 16 preserve the health of our communities. ,
i 17 For the last several weeks, I have been listening ,
18 to un-trusting and uninformed colleagues debating as to how ]
l 19 to solve these questions. To this end, I ask both Yankee 20 and the NRC to help us fund these independent consultants I 21 needed to calm the fears of the community.
I 22 Thank you.
23 IApplause.]
24 MR. COUNCILMAN: Ms. Walker.
25 MS. WALKER: I'm Gisela Walker. I'm a member of
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86 1 the Franklin Regional Planning Board and I only had a very im
( ) 2 specific point to ask. I wasn't aware that we were not v
3 supposed to ask questions in this section. That specific 4 point had to do with the radiation inspection monitoring in 5 case we have dry cask storage on site.
l 6 Maybe I just didn't understand quite how that is 7 going to be part of the overall vigilance of the NRC while 8 the fuel rods are still on site, but it says in the letter ,
9 of responses that we got from Rowe Yankee -- and it's i
10 appreciated -- that in case there is dry cask storage on the 11 site, radiation levels will be indistinguishable from i
12 background radiation. And I know trust is good and I 13 appreciate that we get a product or technology that do have 14 high levels of trust in, but were you planning to have r^x '
k_s) 15 long-term monitoring around the dry cask storage -- I assume 16 you do, but I don't quite understand how -- as long as the j 17 fuel is on site, not just at the very erd when it's a matter !
18 of releasing the site, but while this technology is there 19 and the fuel rods are there?
20 I just wondered what your inspection program will 21 be and whether -- not just radiation inspection and air, but 22 whether the monitoring route will be open or what else 23 you're going to do?
24 So at some point, I would appreciate some 25 information about. Thank you.
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87 1 MR. COUNCILMAN: Ms. Katz.
q l i 2 MS. KATZ: Hi. I'm Debbie Katz. I'm president of
\_/
3 the Citizens Awareness Network. We're now a regional group 4 with about 1200 members, and I always carry a lot of papern 5 up and I then I wind up realizing I don't even know why I 6 carried them. So I'm going to put them down. I'm going to 7 try again.
8 What I want to do is thank everyone for 9 participating tonight, because I think one of the things 10 we're working on here is democracy, and there's a way that 1
11 things have really changed from the time the Rowe reactor 12 came in, which is that suddenly, people are really concerned about the site and what's left there and what's going to 13
\
14 happen, and they're concerned about the regulators, and l
) 15 there's a kind of, you know, innocence we all had, or in my 16 case I feel it was a sort of stupidity that I could leave it 17 in the hands of Yankee or the NRC and it was all going to be 18 all right. Somehow that didn't prove to be the case and it 19 hasn't proved to be the case in a lot of places.
20 So the ability for us to all participate and ask 21 hard questions is really important in this, and I think we 22 ask hard questions and we want democracy to work in terms of 23 nuclear technology because our children's lives are at stake 24 in this process, and their children.
25 There's a way in which what Yankee has presented, f
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88 1 it looku really good, and the NRC looks really good, but you I)
\ /.
2 p
5uys have been in trouble, and you haven't done things so 3 ) well, and this whole process of decommissioning is 4 experimental, and yet it's never talked about that way.
5 Everyone sort of boasts about all the decommissioning 6 they've done. Two reactors. One only operated for 100 7 hours. Ft. St. Vrain was shut down early by the State of 8 Colorado because it.was such a bad reactor, and it's not 9 like these reactors at all.
l 1
10 So this is a whole new game plan, and'the NRC has, 11 in fact, certified casks that haven't worked. You guys know 12 that. There are problems with vector casks, there are 13 problems with other casks, but nobody talks about this.
14 Everyone presents this as if it's a really easy situation to 15 get through, and it's the hardest situation that Yankee Rowe 16 is going to face, that we're going to face.
17 When they talk about that fuel getting out of 18 there, you know, it's not going anywhere for 15 or 20 years 19 even if they get interim storage. That's the truth of it.
20 And if we could get to the truth of it, then we could figure 21 out how to do it right for everyone, but it's not fully 22 dealt with that way.
l 23 So we're talking about 20 years. Well, what do we I 1
24 do with it for 20 years? Do we keep the fuel in the pool 25 for 20 years? Will the pool really hold up for 20 years?
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89 1 Will the NRC really tell us? They've licensed pools for 100 p' 2 (d years, but they really didn't want them to run for 100 3 years; they wanted the fuel, as Yankee did, continuously 4 being taken out because they didn't want it in the pool that 5 way. So it's not clear that it should stay in the pool.
6 'But the casks are experimental and the casks 7 they've made, the vector casks are breaking down already.
8 There's a leaky cask in Michigan that they cannot even put 9 back in the fuel pool to reload because they don't know how 10 to do it. There are problems with the casks in terms of 11 basically explosions that took place and shutting the lids 12 on them in fuel pools that the NRC never foresaw.
13 These are the realities of what we are facing, and 14 yet, in a certain way, citize. are continually treated with
(_,) 15 contempt, as if if everyone says it in a nice way to us, 16 we'll go home and not think about it again, and then you'll 17 struggle it out alone.
18 That's not acceptable anymore. We got to be cut 19 into figuring out what's the best, because those casks might 20 be here for 50 years. They might be here for 100 years.
21 And they're only good for 20 to 30 years. That's the truth, 22 gentlemen.
23 This monitored multi-purpose cask has never been 24 used before. It's an experiment. It hasn't happenet.
)
25 We'll be the first ones to use it on site, and all the other
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I 90 1 reactor sites that have used canisters and casks are
() 2 3
operating reactors where there is a resident inspector.
There'will be no resident inspector here. There will be no 4 work force here. And if Yankee pulls the fuel pool out, 5 there will be hardly any workers here, and that's 33 jobs
'6 for the county gone to save money for Yankee, but not for 7 our community necessarily. And I understand why they want 8 to save money, but it's not necessarily the safest thing to 9 do.
10 Now, Yankee's talking about over-packing their 11 cask. That's their idea. It's sort of like the -- you know 12 those Russian dolls they have? You put a doll in a doll in 13 a doll in a doll, and you get a bigger doll. Well, this has 14 never been done before. It's a nice idea, good thinking, s 15 but we don't know if it works. '
16 We don't know how heavy it's going to be, e don't 17 know how it's going to be transported. If they have a leaky 18 cask on site and they go to over-pack it, are they going to 19 build an over-pack that's goir.g to sit there so when it's 20 leaking, they'll immediately be able to put it on? I doubt 21 it. Are there going to be other kinds of problems?
22 All of this is part of this process and needs to 23 be raised for us to think about, and yet it doesn't come up.
24 Ken has about 50 questions that we're submitting, and what 25 we're asking for are a number of things.
[
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91 1 One is that we have more meetings to really go
( ) 2 into this and open this issue up so we can discuss it and v
3 figure out what's the best way, and if what you want or it's '
4 an honorable situation, we can do that. l 5 The other is that the Franklin County Co G 6 commissioners, or the 40a now, I guess it is, be able to set 7 up a citizen advisory board as has happened at Connecticut 8 Yankee, as has happened at Maine Yankee, so there is at 9 least the ability for information to get out to citizens 10 about what takes place, because this one meeting is not 11 enough.
12 The third thing I want to say is that we will 13 probably ask for a hearing on some of the health and safety 14 issues that are involved that are not being presented here x_,/ 15 and not being addressed as health and safety issues.
16 So thank you.
17 [ Applause.]
18 MR. COUNCILMAN: Mr. Gunter.
19 MR. KATZ: Hello. My name is Fred Katz. I'm from 20 Rowe, Massachusetts, and I actually was going to read --
21 MR. CO'UNCILMAN : Excuse me, sir. I asked for Mr.
22 Gunter.
23 MR. KATZ: Yes, I'm speaking for Mr. Gunter. I'm 24 explaining. He is not here. He wasn't able to get here.
25 He's from the Nuclear Information and Resource Service in ANN RILEY & ASSOCIATES, LTD.
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92 1 Washington, D.C., and he submitted a four-page statement, 2 which I'll give to you for the record.
1 3 Now, who'should I give that statement to? -To the
{ l 4 NRC or should I'give it to Mr. Yankee? Oh, Mr. Weiss. Very
]
5 good. I'll hand it to you. Because I'm sort of confused --
6 MR. WEISS: You can give a copy to Yankee.
7 There's nothing wrong with giving Yankee a copy also if you 8 have two' copies. I
- 9. MR. KATZ: Hey, that's what I was just going to ,
i 10- say, that when I'm talking to the NRC, I may as well be 11 talking to Yankee, or when I'm talking to Yankee, I may as 12 well.be talking to the NRC,~because this proceeding is 13 rather humorous in a way, that citizens are asking questions 14 and then a team of NRC and Yankee Atomic comes and does a 15 really nice little tap dance. So I want to address the 16 lawyer. How do you do?
17 I think that you participated in legal proceedings 18 and I want you to look at this one,-and I think you'll agree 19 with me that in no way does this satisfy the needs that an 20 adjudicatory hearing was supposed to fulfill for the 1
21 purposes of constitutional democracy, so that I put that '
22 before you. This is notwithstanding the beautiful work that L O (7 23 the Franklin County N has done, which is very heartening )
24 to us; that'this is second rate.
i 25 Thank you. I ANN RILEY & ASSOCIATES, LTD.
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93 1 [ Applause.]
2 MR. COUNCILMAN: Mr. Block.
3 MR. BLOCK: Hi. I'm Jonathan Block. That's 14 B-1-o-c-k for the record, J-o-n-a-t-h-a-n, initial M. I'm 5 from Putney, Vermont. I'm an attorney for Citizens 6 Awareness Network since approximately '93, '94, and I wanted 7 to make a few observations on the plan as submitted.
8 I guess I have quite a different feeling than 9 Debbie does, and I offer this with all due respect, because 10 I understand that although Yankee has tried hard from the 11 use of the language in the plan, I would say there must be a 12 number of things that were really difficult to answer, 13 because I found the language to be in the conditional form, 14 and that means that they don't really have final decisions ;
O) l, s 15 yet about what they're going to do in certain areas.
16 I think that others have already clearly addressed ;
17 what those areas are, but my concern is in the context of 18 what I believe Mr. Katz was trying to say on his own and Mr.
19 Gunter's behalf.
20 I'm really disturbed that there is a 21 misunderstanding in the NRC, not in Yankee Atomic, about l 22 what's necessary to meet what I believe has been called the '
23 minimum requirements of due process: notice and an l l
24 opportunity to be heard; where the public is not only given 25 notice, but in the sense of an opportunity, that if you were ANN D.ILEY & ASSOCIATES, LTD.
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94 1 speaking on a particular subject, that all the final facts
'O 2 j be put before the public for their consideration before the 3 subject is addressed.
4 Otherwise, what you're giving them in nct a 5 meaningful opportunity. In other words, it's not a~real 6 opportunity. 'In other words, it doesn't satisfy the minimum
.7 requirements of due process.
8 When you tell the people that information that was.
9 provided by Yankee is not yet in the public document room 10- for them to see, and that somebody from Yankee will come and 11 put it in at a later date, then you're holding a meeting 12 before all the facts are in.
13 And since you have a plan that in many places is 14 in the conditional form, it seems to me that unlike the 15 previous problem we had with Yankee Rowe, that this time 16 we've sunk to an even lower level, that while the public 17 awareness apparently, based on the statements of the members 18 of the new Franklin County body, has gotten higher, that the 19 understanding of the NRC has sunk lower, that you really i
20 think that the people who are here and who have been 21 involved in this process are not going to understand that 22 .w hen you hold a meeting before all the final information is 23 assembled and available completely for inspection for at 24 least 30 days in the public document room, that you haven't 25 really complied with the minimum requirements of due
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95 1 process, and that really does concern me quite a bit.
v)
( 2 I think that what the NRC needs to do, as Debbie 3 was indicating, is to consider this meeting number one, and 4 30 days from now, or actually 30 days after Yankee has 5 answered all of the questions-that the NRC had and placed 6 that material in the public document room for public 7 inspection, that then people will be able to begin to ask 8 intelligently the kind of questions that they have~a right 9 to ask.
10 Also, I would like to add.that I think that given 11 some of the-statements-that Mort had made about the kind of 12 . hearing that might be offered or might not be offered, that ,
1 13 I would suggest that Franklin County, to its body, that you 14 get real specific. You want to ask them for a Subpart G ')
15 type hearing. That's a full adjudicatory hearing. You 16 don't want to be shuttled into their Subpart L.
17 This is like a Subpart L hearing. You get to come 18 and ventilate. They'll-take it all down in a transcript, 19 and then they can flush it down the toilet. So you don't 20 want that.
21 You also want to be sure to check in the Title X, 22 part 2, in their case law to get a real good handle on what
]
23 .their notion of standing is, because you're going to have to 24 get experts and you're going to have get local people and 25 you're going to have to make a showing of imminent harm and !
1 l
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96 1 a number of other things that you'll be able to clarify by 2 looking at their case law in order to ever even get your 3 foot in the door to get what they'll give you, which will be 4 kind of like a pre-conference to see if they can kind of 5 knock you out before you even get to really get down to the 6 nitty gritty.
7 So I want to suggest that, again, it's somewhat 8 gratuitous to even mention a hearing and, you know, I'm glad 9 that Mort was sincere and honest enough to sort of tap dance 10 around it and say that there might not really even be any 11 hearing at all, and I think that you want to be sharp here.
12 And oh, by the way, while I'm not sure I'm the 13 right one, there are probably others, probably the Franklin 14 County body ought to get itself a good environmental lawyer, 15 and you might want to look for somebody that is even more 16 experienced in this than I am, because the NRC is real 17 sharp, and I can guarantee they will do whatever they can to 18 make sure that you never do have that hearing.
19 [ Applause.]
20 MR. COUNCILMAN: Mr. Mangiagli.
21 MR. MANGIAGLI: Good evening. My name is Sal 22 Mangiagli and I'm with the Citizens Awareness Network, and I 23 live in Haddam, Connecticut, a mile from the Connecticut 24 Yankee reactor.
25 I would really like to say that the contamination ANN RILEY & ASSOCIATES, LTD.
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97 1 in the Haddam area is -- might be insignificant as far as
( ) 2 quantity goes, but as far as the concerns it has raised v
3 among the people and the citizens of Haddam, it's highly 4 significant, and even though the doses were low, it had 5 nothing to do with what Connecticut Yankee did or with what 6 the NRC did. It was just kind of like good luck that it 7 wasn't more contamination that left the site.
8 The contamination has not even all been found.
9 The concrete blocks that were contaminated had smearable 10 contamination on it, which can be tracked around. People 11 built patios and walkways out of these blocks. Maybe little 12 children have tracked this all over the house, to their 13 neighbors, and it's very significant to us.
14 As far as the track record of the NRC goes, it's
.F';
( ,/ 15 poor to say the least. The issue of Millstone Unit 1 16 off-loading fuel illegally for its entire life of 28 years 17 while the NRC was there only opened up a can of worms that 18 as you inspected each of those units, they all went down.
And then Connecticut Yanke was inspected, and it went down.
20 Millstone Unit 3 had over 2,500 problems to fix 21 before they were in compliance with their license. This is 22 with NRC there. So the NRC's track record is very poor.
23 The General Accounting Office has also done a 24 study on this and found that they can't fulfill their jobs.
25 At Connecticut Yankee, they'rebeginningtheyhd[
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98 1 decommissioning process, and we had a representativeLof r\
- 2 -Barnwell, South Carolina, come up and give a presentation to 4
3 .the citizens, and one of the things that he mentioned was 4- that the Barnwell is leaking radioactivity, and when he was 5 asked how large of a leak-it is, because he was saying, you 6 know, "this'small~ leak" all throughout his presentation, and 7 when he was asked, he said that the surface area of the 8 plume or tritium that is leaking from underneath that dome 9 is 100 acres.
10 I'm wondering if, you know, if you guys care, if 11 the NRC cares or if Yankee Atomic cares, and what kind of 12 measures, if you do care, are you going to take to make sure 13 that there is on more leaking coming out of this dump?
14 That's all I have to say.
15 (Applause.]
16 MR. COUNCILMAN: Ms. Russell.
17 MS. RUSSELL: I'd like to pass my time to Keith 18 Snow.
19 MR. COUNCILMAN: Well, Keith Snow is also on the 20 speakers' list.
21 MS. RUSSELL: Fine.
22 MR. COUNCILMAN: Ms. Hamilton.
23 MS. HAMILTON: I'm going to pass my time.
24 MR. COUNCILMAN: Mr. Snow.
25 MR. SNOW: I'm not going to pass my time. Let me m
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99 1 take a deep breath. And I'm going to try to speak to the
( ) 2 people here with compassion, because I've had a poor record 3 doing that in the past. I tend to get angry, get upset, 4 lose my temper, and be very unfair, and I don't want to do 5 that.
6 AUDIENCE MEMBER: Who are you?
7 MR. SNOW: My name is Keith Snow, and I'm not 8 affiliated with any organizations. I am independent 9 investigative journalist.
10 I was formerly employed by General Electric 11 Corporation in a very technical role working on Star Wars 12 weaponry. I would like to ask, are there any other 13 newspapers heta? Which one? Could you please identify 14 yourself?
<3
(_) 15 AUDIENCE MEMBER: Greenfield Recorder.
16 MR. SNOW: Greenfield Recorder. Thank you for 17 coming.
18 My first concern is that the newspapers have 19 stopped, for the most part, from my perspective, covering 20 the issue of Yankee Atomic even though it's a very local 21 issue, and I'm talking about local newspapers like the Daily 22 Hampshire Gazette.
23 When you do see an article in the Daily Hampshire 24 Gazette, it's picked up by the AP, which is a subsidiary of 25 the New York Times, which I find very disagreeable as far as (x ANN RILEY & ASSOCIATES, LTD.
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1 100 1 any kind of independent journalism or reporting, and that's
() .2 something I will address later.
3 The person who brought up the subject of Cobalt-60 4 and Cesium-137 -- am I'too loud? Somebody was too loud for 5 me. Am I too close? I 6 Somebody brought up the issue of Cobalt-60 and 7 Cesium-137 and it was kind of glossed over. I feel it was j 8 glossed over. And I would like to know specifically and see 9 this answer for the communities and the select boards and 10 the various commissions from the communities that are here i 11 regarding specifically the Cobalt-60 and the Cesium-137 in l 12 Sherman Reservoir at the reactor outpipe which Yankee Atomic 13 ' Electric Company has identified in its decommissioning l 14 environmental report.
N
\s / 15' Cesium-137 and Cobalt-60 are, in my perspective, 16 very deadly radionuclides and I don't believe that'there's
'17 any chance that the 30 , 40-year cumulative sedimentation ;
18 that's collected at the outpipe could possibly, in any sense i
19 of the word, even from a radius of, say, ten meters, i
20 represent the kind of levels that you're defining to be safe i 21 for site release criteria defined by the NRC. I disagree !
22 with that completely, thoroughly. )
23 I don't believe there is going to be any effort to 24 remove that sludge, and I cannot fathom how you intend to 25 defend the public from that sludge.
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101 1 Someone brought up the issue of turbidity. In 2 fact, the only recent information I could find on turbidity 3 studies were done by Yankee Atomic in 1989 and the only 4 tables that I could find look only from November to April.
5 I'm sorry. From April to November. There's no data 6 anywhere I can find on turbidity studies in particular from 7 November'to April, only from April to November. ;
8- What you see.in the trends and the statistics and 9 the numbers, which Yankee Atomic is very fond of crunching, 10 is that they seem to rise, there seems to be significant 11 changes over the winter, but I don't -- there's only half 12 the data, which is a complaint that I have. The data that 13 is offered is often very selective, very selectively chosen.
14 I would like to see a graph of the background 15 radiation levels over time, beginning prior to start-up and 16 today.
17 Amongst all of those millions of datapoints that 18 someone mentioned will be collected and all of the plots and 19 charts and graphs that someone else said would be created --
20 we have the technology -- Yankee Atomic is capable of taking 21 a picture of Yankee and removing it and showing the two side 22 by side. In the Greenfield scenario, with our modern 23 technology, I'm sure they can come up with plots like that 24 which show what happened to the background levels over time, 25 and it obviously will have to be done at a bunch of ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
102 1 statistical datapoints, not just at the outpipe, which I
() 2 think is the most important point at this point, because it 3 will be left there, but 200 yards away, or 400, or all the 4 various -- and I-feel that they are very selectively chosen, 5 but there is no independent organization to verify that they 6 are selectively or not selectively chosen, because the NRC 7 does not do that.
8- So that's my first major question.
9 There is no public notification of planned 10 affluent fluid releases, as far as I'm concerned. There 11 were releases in:1997 -- correct me if I'm wrong -- from the 12 recent information that I saw at the public document room, 13 and I think the public should be notified about that. I 14 think that was very unfair.
15 I consider the decommissioning procedure 16 completely illegal from start to finish. I consider that 17 the propaganda pursued by Yankee Atomic with the local 18 newspapers is a significant problem, and that's the reason 19 why you find so many people attending the basketball game 20 and not attending this, which is really where their 21 children's future lies.
22 Safe from start to finish -- I find it's just --
23 it's an outrage -- as well as the logo -- it's an outrage 24 that you can say safe from start to finish. It's not 25 finished. How can you say it's safe from start to finish?
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103 1 How can you say that?
( 2 In Prairie Island recently,.within the last year, 3 they were loading spent fuel into casks. Somebody knows the 4 details;-I don't, but I can get them' and I would be happy 5 to provide them to the local boards of health and select 6 boards. In.the-casks, there was an explosion, blew-the lid 7 off the cask, and there was a release of radioactivity.
8 Of course, the most -- Mort's shaking his head, l 1
9 but Mort in an interview once told me that 40,000 curies is J 10 not a very significant amount of radiation. When he said 11 that, I went back and I thought about it, and I said well, 12 Morton -- I'm going to call you Mort because I've noticed
(
13 there's a tendency to use the familiar names of people, 14 especially executives, now, like Madiline Comyde is now 15 Mandy.
16 Madiline Comyde is the one who rejected the 17 request for-the documentation that's taken into schools 18 where children are educated about radiation by Yankee 19 Atomic. A citizen requested that information. It's in the 20 public document room, and Madiline Comyde rejected that 21 information. I think that should be given. If there's 22 nothing going on, there's not -- if it's true, why isn't 23 that information being provided to the people whose children 24 are being educated by special interests with a lot of money 25 and power?
f r
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104 1- Rising background levels, I mentioned. That's a
( 2 problem. I have a real problem with that. As an 3 investigative journalist who cannot publish on the subject l 1
4 of what Yankee Atomic is doing, I would like to read a 5 couple of short sections from what I have written that has 6 not been published and I don't expect to see published'in 7 the near future.
8 Yankee Atomic's Kelly Smith responded to a-certain j 9 letter in the NRC's public document room about Yankee's i
10 deliberate pollution of the democratic process through i 11 misleading advertisements and scare tactics which is 12 something that Jonathan Block wrote in a letter to the NRC. !
13 Kelly Smith said members have gone on record at 14 public meetings and in local newspapers calling-for the
() 15 Yankee Atomic plant to be placed in storage for 50 to 60 16 years and advertisement cannot be misleading if it contains 17 information that has been publicly expressed.
18 Well, the advertisement is misleading. It's a 19 case of twisting the information around just enough to make 20 it appear as if they are calling for a high level, long-term 21 nuclear waste storage facility on site, which is not, in my 22 understanding, what I heard from that organization.
23 Actually, Yankee Atomic was part of a document 24 produced in 1993 which found that on-site storage and decay 25 is the safest method of decommissioning. And I'll read:
)
l 1
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105
-1 "While nuclear wast e, the reactor spent fuel and sludges are f~ j
(]s 2 contaminated by isotopes like Nickel-59, Niobium-94 and !
3 . Iodine-129 with half-lives of 75,000, 20,000 and 15 million 1
4 years'respectively, the NRC decommissioning looks only 60 I I
5 years into the future, if'that. Still, technical documents
]
6 clearly articulate the advantages of on-site storage and 7 decay over rapid dismantlement, shipment and burial."
l 8 One document, Aging Nuclear Power Plants, Managing i l
9 Plant Life and Decommissioning, produced by the Office of I I
10 Technology Assessment, which was eviscerated and closed by 11 the Republican Congress within the last two years, it was ,
e 12 reviewed by over 76 industry, NRC, academic and financial 13 experts. It was virtually the only comprehensive j l
14 decommissioning study to date and it was completely ignored "
A V 15 by Yankee in its process of decommissioning.
16 Yankee went ahead with its accelerated 17 decommissioning, which strips and ships. There's no on-site 18 storage'and decay, which Yankee's own Donald Edwards 19 contributed to and said, that --
this is what -- Donald l
20 Edwards contributed to this document. The document said i 1
21 that on-site storage and decay was the most significant 22 thing that should be done.
23 The NRC public document room in Greenfield holds 24 significant evidence that Yankee has consistently undermined 25 both democratic process and public sentiment, altering ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
106 1 course to suit the economic climate and optimize the )
/~s
( ).
- 2. corporate spreadsheet at public expense. I'm talking about 4
3 documents which lay this out for.someone who's capable in 4 today's climate of going in and looking at that. j 15 I'm not talking about the person that goes in more 6 interested in'the basketball game, I'm not talking about the 7 . person that's sitting down at their television trying to get 8 through the day, trying to get through their - trying to 9 feed their family, trying to suffer everything that's coming I j
.10 down on them, including global warming, local health crises, i i
11 trying to make it through the day,'that kind of thing.
12 I'm talking about anybody who could rationally go 13 in and look at it, you could figure out that Yankee has been 14 interested only in optimizing the corporate spreadsheet, 15' from my perspective. I think it's dangerous, extremely 16 dangerous.
17 The primary -- I'm going to skip all this stuff 18 about the removal --
1 19 MR. COUNCILMAN: Excuse me, Mr. Snow.
20 MR. SNOW: Yes?
21 MR. COUNCILMAN: You've spoken for just a bit over 22 ten minutes now. I was wondering if you wouldn't mind 23' foregoing your remarks in deference to the three remaining 24 speakers so we'll have some time later on for some 25 questions.
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107-1 MS. GUTSHALL: I have three minutes. I'd rather p - -2 listen to Mr. Snow 3 MR. SNOW: I'll take that three minutes right now.
4 MR.. COUNCILMAN: Your name?
5 MS. GUTSHALL: Jennifer Gutshall.
j 6 MR. COUNCILMAN. Okay. Carry on, Mr. Snow, for 1 7 three additional minutes.
l 8 MR. SNOW: Somebody said copies are -- Morton, it
]
9 was you -- Mort -- you said copies are expensive. We hate 10 to see more trees cut down. I really would like to believe 11 that you seriously are concerned about trees. I really 12 would like that.
13 I was in Niger recently, and the people in Niger 14 are suffering every kind of suffering you can imagine,
() 15 including military dictatort ,
6: 3r is one of the 16 poorest countries in the t In tact, it's the second or 17 third poorest country in the we' ..
1 1
18 You know what Niger has that makes them so poor? l l
19 Who knows? Come on, somebody in the front row. Uranium.
20 International Atomic Energy has been pumping uranium out of l 21 Niger for 35 years. Why are they so poor? Whose monitoring 22 the uranium sediments in the desert, in the Sahara?
23 I'll close with a little poem. These are all the 24 thoughts that I just wrote down quickly. I actually was 25 going to write something for tonight because I'm so bad at ANN RILEY & ASSOCIATES, LTD.
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i 1
108 1 pulling my thoughts together on the spot, but I read in the
() 2 3
newspaper last night that Ashfield is pursuing a program of spraying the sidesLof the road with -- what is it? --
j l
4 Monsanto's Roundup. It's nasty and. deadly, and corporate 5 interests have made sure that Roundup has become licensed by 6 the EPA and allowed, and it's the same problem, it's the 7 same thinking. And I didn't get a chance to pull together 8 my thoughts more coherently. I at least feel that I have 9 not outright insulted people for a change 10 AUDIENCE MEMBER: That's too bad, i 11 [ Laughter.]
12 MR. SNOW: Manipulation of data. Selective use of 13 data. Narrow definitions and narrow scope. Economics of 14 predatory capitalism. The pathology of specialization.
()
15 Intentionally disorganized, at least historically.
16 Advertisement of forecasts and suppression of reality. l 17 Superficial public presentations. Information presented l
18 about possible scenarios. Language intentionally obscuring. l 19 Broad platitudes expressing hope and optimism. Confidence 20 with our own laboratories. Exorbitant executive salaries, j 21 public subsidies, taxes and penalties. Shiny brochures and !
22 glossy color photos. Failed microphones and lights for the 23 slides. Misinformation and disinformation. Optimization or 24 accentuation of the positive aspects. Suppression or 25 elimination or exclusion of the negative. Limited life
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-109 1 perspectives defined by limited life experiences. ' Industry
.( ) 2 mirrors the tobacco industry, only it's much more deadly.
3 The selective fielding of questions. Public relations think 4 tanks. The average citizen at home in front of the TV.
5 -Tested by your own labs. Tactics specifically designed to 6 mislead, exclude and silence. Cozy executive associations
{
7 with local regional media. Vested interest. Legal 8 subterfuge, legal intimidation, legal exclusion, legal 9 cooperation. Lawyers. Scientists. Scientists prostrate to I 10 the god of science. Incomplete assumptions. The arrogance 11 of humanism.
12 I would like to ask that if Yankee and the NRC i
13 were sincerely interested in the public interest in any l 14 sense, shape, manner or form, that they appoint and work
() 15 with -- that they don't appoint anybody. Sorry. That 16 somebody organizes it so that there is a community group 17 which works directly with Yankee Atomic on all of the 1
18 aspects of site release, and the importance, I think, is to I 19 the future of decommissioning in this country.
20 To close, I would like to remind you that I 21 consider the potential for Chernobyl, USA, to occur at any 22 particular moment from the operating plants that are -- from 23 the plants that are currently operating, and the breach of 24 responsibility that's related to that,. including the current 25 status with respect to overloaded spent fuel pools and the ANN RILEY & ASSOCIATES, LTD.
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i i
110
,1 potential'for an explosion there.
p '
Q 2 Thank you.
-3 [ Applause.] !
4 MR. COUNCILMAN: Ms. Newington.
5 MS. NEWINGTON: Well, I've been to a number of l 6 these gatherings here abouts and over in New York State when !
7 there once was a hearing on the effects of transporting l i
8~ high-level waste through other communities, and I always 9 have as the talk begins a strange sense of entering hall of ;
10 tr'rrors, because things happen to language.
11 The first thing that drew my attention to that j 12 this evening was Mr. Heider describing simply the process of l 13 cleaning rooms and cleaning the site at Yankee Atomic, and I 14 thought about that, and I realized that that somehow implied i 15 to me that you cleaned by just sweeping it all together, 16 putting it in a garbage bag and getting rid'of it, that i
17 somehow the contamination was disposed of, i 18 But what wasn't addressed is where that 19 contamination goes, because the nature of radioactivity is .
20 that you can't get rid of it in that fashion. If you leave i 21 it on site and let some of it decay, you get rid of some of 22 it that way, but otherwise, when it's taken from Yankee 23 Rowe, it is transferred to another place.
24 So really we should be talking about the transfer 25 of contamination, not the cleaning of the site, but the !
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(202) 842-0034 I i
111 I i
1 . transfer of contamination fr. a one place to another. l
~
) 2 In the case of Yankee Rowe, primarily that 3 transfer has been to the site at Barnwell where, as we heard 4 earlier and, you know, this is not news, there has been, 5 over an extended period, leakage of tritium into the 6 groundwater. The plume, I gather, is now 100 acres in area. I 7 That's pretty stunning.
8 That was waste not entirely from this site, but 9 nonetheless I personally witnessed the transfer of large ;
i i
1
.0 quantities of waste, most recently in the form of the '
11 storage cask, from Rowe to Barnwell.
12 So let's not talk about-cleaning. Let's talk '
13 about moving waste. Let's talk about moving contamination 14 and transferring contamination, because then we'll be a 15 little closer to reality. And we don't have a shot at !
16 dealing with this if we don't use language to take us to l l
17 reality and not away from it.
18 I don't mean -- all of us have this problem now.
19 It's not I can walk away from it and say you guys made it, 20 it's your problem. It's not. It's my problem. It's a 21 problem of everyone. We're all here, we have to deal with 22 it together, but we can't do that if we don't talk about it 23 in a way that makes sense.
24 Now, I was not exactly comforted to be informed that the amount of tritium that had been leaked from the 25 ANN RILEY & ASSOCIATES, LTD.
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112 1 ionizing pool was relatively minor compared to the amount of 2 tritium that had been released into the river in the course 3 of the operation of the plant. This did not actually cause 4 me to feel ch, no big deal. This caused me to feel, " Wow, I 5 see." So, you know, this is true -- a considerable amount 6- of radioactive material has been released into the river 7 with the approval of the-Nuclear Regulatory Commission over 8 the operating life of the plant and, in fact, has continued 9 to be released since the decommissioning of the plant, and 10 necessarily so. It's part of the ordinary operation of the 11 plant.
12 Now, in Canada recently, there has been a 13 classification of tritium _as a dangerous envirotoxin, but 14 when we were first told about-tritium by the NRC, it was 15 kin'd of like a sort of sissy radionuclide, you know? It 16 disappeared pretty quickly, didn't really have any effects, 17 it wasn't a big deal.
18 Well, come to find out maybe the human body i
19 actually is particularly susceptible to low-level radiation d 20 because it doesn't kill the cell that was damaged by it 21 because it doesn't notice that the cell was damaged by it, 22 and cells that are damaged by low-level radiation are, in 23 fact, then going to be possible sources of cancer.
24 So simply to take a numerical attitude and say, 25 well, if it's high-level radiation, then that's dangerous, ANN RILEY & ASSOCIATES, LTD. ;
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i
113 1 butalow-level stuff really doesn't matter, don't worry about
't 2 it, it's okay, good people, don't worry, we the NRC are here 3 to make sure that the noble company of Yankee does not bring 4 any harm -- I can only echo Sandy's words. This is not 5 true.
6 That takes me to the second area of doublespeak 7 that I heard tonight, which was there was reference, 1
8 specifically actually from the chairman of the board of 9 selectmen of Rowe, to the notion that Yankee Rowe had 10 operated safely for the 31 years and, indeed, we know the 11 slogan: Safe from start to finish.
12 Now, I'm sure that it's true that as a 13 corporation, Yankee has been pretty honorable and 14 punctilious and has made a real and truthful effort to
() 15 operate this plant safely; however, the end result of the
-16 operation of this plant in the Deerfield River Valley, 17 according to a recent study by the Department of Public 18 Health, is that now, we're not saying this is all from '
19 Yankee Rowe, but nonetheless, mysteriously in the Deerfield 20 River Valley, in the towns bordering the Deerfield River 21 into which Yankee has been releasing tritium and other 22 radionuclides, there has been an epidemic of disease. There 23 are significantly elevated rates of breast cancer, also 1
24 _ multiple myeloma, whose primary known risk factor is 25 ionizing radiation.
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l
114 1 In addition, the incidence of Down's Syndrome in p
Q 2 the Deerfield River Valley is ten times the national 3 average. The CDC is currently looking into this.
4 Now, it's perfectly possible that this is not all 5 the product of radiation, that it's combined with exposures 6 to PCBs, to dioxins, to'other chemicals that have been in 7 the area, but it seems really pretty premature to me to say 8 to a community where this happened and is happening and will 9 continue to happen, because this exists.among us, that this 10 plant has operated safely. I 11 This is not the way to gain my trust, that I 12 should say, oh, good, I'm really happy I can leave this in 13 the hands of the NRC and Yankee Atomic. It's not there. It 14 doesn't work like that. Don't tell me it's been safe. Tell j 15 me you're really concerned, that you really regret that you )
16 didn't instantly start a health study whenever the first 17 idea was proposed so that there would be some idea of what i
18 the health in the area had been prior to Yankee Atomic. But l l
19 no, that wasn't really important.
20 This is an experiment. It's been an experiment 21 all the way along and there's no reason to believe that it 22 has stopped being an experiment now. In fact, we know that 23 it is still an experiment, because we don't know what to do 24 with the waste.
25' We talked -- people also talked rather kind of
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i 115 l
1 referentially about finding, you know, where there was a
(
( \) 2 high-level waste site in order to be able to remove the fuel
-3 rods from Rowe. What that means is choosing a place in this 4 country to subject to the most extreme form of radioactive l 5 contamination that we can imagine, to choose a place in this 6 country and make it contaminated for at least a million 7 years. That's what we're talking about. -
l 8 We're not talking about taking the fuel rods and i
9 putting them somewhere else in the filing cabinet; we're 10 talking about finding another place to contaminate. And we 11 should be clear about that.
12 We're also talking about transporting those rods I 13 through other communities, with the possibilities of 14 accidents, because we know that, being human, or we should I
("'T !
(_,/ 15 know that, being human, we're fallible, and in my opinion, I 16 being fallible, we shouldn't have anything to do with this 17 stuff because we're not up to it. But that's my opinion; at 18 the moment, we have to deal with it.
19 MR. COUNCILMAN: Excuse me, Ms. Newington.
I 20 MS. NEWINGTON: Yes.
21 MR. COUNCILMAN: You've been speaking for almost i
22 seven minutes. Would you close, please, so we can get to 23 Mr. Katz?
24 MS. NEWINGTON: I will wind up, yes. I certainly 25 will.
p).
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116 1 So my remaining request is that the thing that 2 really irks me is the notion of the green field thing left 3 behind, and I would like to propose that instead of a green 4 field, it be made into a memorial field on which could be 5 erected gravestones and other memorials for those who have 6 died and suffered as a result of the nuclear experiment in 7 Franklin County, in Massachusetts, perhaps in the whole 1
8 country, although I would like to see this happen at all the 9 sites. So let's not talk about green fields. Let's talk 10 about memorials for the people who s'1ffered.
11 Thank you.
12 (Applause.)
13 MR. COUNCILMAN: Mr. Katz.
14 MR. KATZ: Okay. I don't have much to say. I 15 didn't think I would be up again, 16 I would just like to say that my presence here, 17 and I think I speak for other people, in no way should be !
j 18 construed as my participation or collusion with this as any 19 replacement for a necessary constitutional process.
20 Thank you.
21 [ Applause.)
22 MR. COUNCILMAN: Well, we've reached our appointed 23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> of closing. I'd like to take this opportunity to thank l
24 everyone for their attention and cooperation and patience.
25 I would like to thank the school for the use of their ANN RILEY & ASSOCIATES, LTD.
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117 1 facilities, and I would like to turn the meeting over to Mr.
(F 2 Fairtile from the NRC to close.
3 MR. FAIRTILE: I just want to add to what Brad 4 said, thank everybody for their attendance and thanks to the 5 high school for letting us use their auditorium, and 6 goodnight, everybody.
7 [Whereupon, at 10:04 p.m., the meeting was 8 concluded.)
9 10 11 i
12 13 14' 15 16-17 I
18 19 20 21 22 23 I 24 25 ANN RILEY & ASSOCIATES, LTD.
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings
() before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: PUBLIC MEETING -- YANKEE NUCLEAR POWER STATION LICENSE TERMINATION PLAN DOCKET NUMBER:
PLACE OF PROCEEDING: Shelbourne, Massachusetts
(
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to t
typewriting by me or under the direction of the court
! () reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
4 l l
V Doug dwift U
Official Reporter Ann Riley & Associates, Ltd.
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l ,
Statement of Paul Gunter, Dirvctor of the Reactor Watchdog Project January 13,1998 Densrv tlse NereIcar Regulatory Cornmisslots P' blic Meeting on the Termination of the Yankee Rowe License
(
Moteawit Valley Regional High School Auditorium
! Huckland, Manachusetts I would i ke to thark the Nucicar Regulatory Commission for this opportunity to address the license temiin stion of the Yankee Rowe nuclear generating station.
However, my op rning remark must be framed as a criticism of the NRC's overal) effort to circumvent mear1 ;ngful public involvement in the decommissioning process. My organization recognizes that t date, the NRC has actively subverted the public interest in discovering the true ,
and potential ime et ora major ciecommiasioning operation at Yankco Rowc by thwarting the r3 public's right to d heanng with discovery process and the cross exammation of thc licensee as V required under tf- : National Environmental Protection Act, the Administrative Procedures Act, and the Atenic1 nergy Act.
It is our view tin l the NRC originally abandoned its decommissioning regulations and then '
rewrote its law tI ; accommodate the economic interests of Yankee Atomic E1cetric Company by expediting the de bmmissioning procen. Tids view is bolstered by the remarts ofJudge Ponser in the Springfield Federal Court and the Erst Circuit Appellate Court decision in CAN vs NRC.
It is now jur concern that at the behest of Yankee Atomic Electric Company, the NRC is accking to exped c the removal of the Yankcc Rowc nuclear powcr station irradiated fuc1 pool through dry cask ptorage of the reactor's high level radioactive waste and the demolishing of the irradiawl fuel pop 1 and building. There are several issues that NIRS seeks to address before Yankee proceedgwith this plan.
Central t< our concerns is that the NRC has bankrupted its credibility for effective regulatory oversi Lht of the cask certification program 4-Long star ding problems with two cask designers and vendors have demonstrated that the federal regulator has failed to adequately oversee Quality Assurance and Quality Control in the certification and i mplementation of the Sierra Nuclear Corporation VSC 21 (vertical storage modules) dry ca5 i system and the VECTRA Technologies Inc. NUIIOMS-52 B (horizontal l u
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2 N storage modules dry ca* system. NIRS beheves that the NRC failed its regulatory and oversight (G furwtlon as a res it ofattempting to accommodate the nuolene in<funty's interests and schedules in >
such areas as ret l ming operationni ucxibility (i.e. the ability to have full core ofiload.)
Specifically; e On August 21,1 61, the NRC exempted and permitted Sierra Nuclear Corporation to build eight -
VSC-24 Dry Shi 'ided Casks (concrete casks) and 3 metal storage baskets for the Consumer Power's Palisade > nudcar generatiug stadun hefme design nuuruvid was insun). The excruption ' -
was granted by ? 'RC stating that approval was given "at vendor's own risk".
By April,1992, J TRC inspections identided quality corrtml/ quality assurance problems with Sierra Nuclear VSC-24 constmetion involving inadequate design control and control of subcontractors and by May 28, 992 issued a Notice of Violation. The following day, May 29,1992, Michigan %
Consumers Pow' r directed Sierra Nuclear to cease all construction of cash being built under the exemption proce s at Palisades.
In December 19! 2, the Michigan Office of Attomey Generai requested that NRC hold a public ;
hearing on the P< lisades dry ca* storage system winch the agency then dcased.
On May 7,1993 theNRC certified the VSC.24 design for five nuclear power stations without requiring site sps :ific studies, an Environmentaf Impact Statement, and barring a pubfic hearing . I process at any ol se reactor k> cations. )
p On May 11,199, ,, Consu'mcrs Power loaded its first VSC-24 cask. That same month, a consuhing firm t< ' the NRC, The Center for Nuclear Waste Regulatory Analyses of San Antonio Texas, comment' d on dry cask storage policy stating " dry crwironment has the potential of producing such r ~ohlerns as further fuel cladding oxidation, cladding stressing, and creep delbimation as a f ewit urintesual aud paessuse."
In February,199 f, an NRC soil cxpert visited the Palisades dry cask storage site which is located .
in a "high risk cri 'sion site" just 150 yards from the shore ofLake Michigan Dr. Ross Landsman found that the laa k of site specific studies under the NRC licensing policy was seriously flawed and could lead tr " catastrophic consequences."
l InJune,1994, ar (NRC inspection report finds continued QA/QC problems at Sierra Nuclear and determmed that ! tierra Nuclear has "a lack of management conunitment."
l On August 2,19h4, a Corwumers Power initiated indiograph finds weld flaws on a VSC-24 cask alreadyloaded w th highly irradiated fuel. A subsequent meeting between the licenscc and the NRC on August t5.1994 at NRC Headquarters intmduced problems with unloading faulty casks where introducin L 400 degree F. fuel to 100 degree F. fuel pool water will result in a radioactive steam flash and t crmal shock to irradiated fuel in the dry cask This issue introduces problems with the unloadh g, offaulty casks O
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T By March,1995I Consumers Power identified fmther multiple cracking in the closure welds on (O the VSC-24 shie :D lids. This will not be acLuadc4gc,i until an NRC inspection March 17 -27, 199 J identifies c ncking at a VSC-24 cask at Wisconsin Eicctric Power Company's Point Beach
' reactor.
On May28, .I99 '. while loading irradiated fuel into a VSC-24 cuek at Wiscotrsin4 Point Beach nudear generatir g station, borated water from the fud pool dectro-chenscally interacted with the rinc liner ofI w VSC-24 design generating hydrogen gas. The hydrogen gas detonated when an arc wdded un 4 to seal the cask tid ignited the gas 11ning the 3 ton shidd lid into the air setting ;
it upright on top af the cask. He accident initiated an NRC Office of the Inspector General .
investigation intc NRC staff criteria for safety evaluations and the vendor certification and review process.
In June,1996, C 'nsumets Po% canceled its preparations to unfond the faulty cask at Palisades '
because of theis ue of hot radioactive fuel coming in contact with cooling waterin the fud will' '
create a steam fla sh and simuhancously generatci more explosive hydrogen gas.
On July 5,1996 pC ordered a halt to any furtherloading of casks at reactors as a result of the galvanic acaction and hydiogen detonation at Point Beach.
On October 18, 996, the citizen's group Dont Waste Michigan submitted a petition to the NRC requesting anint spendent review of the VSC-24 design through theNational Association of Corrosion Engin ; cts. Dr. Rudolph Hausier submits a report in support of the petition identifying '
that flaws in but1 .the utilitics' and the NRC safety evaluations of the VSC-24 design and construction, int; iding the lack ofexperimental verification for temperature calculations and heat O trans" assessma nis, all of which have potential adven,e impact on the public health and safety, h., NRC rejecte I the petition as lacking suflicient merit to warrant emergency enforcement action. Dr. Haw !cr states that NRC is "stunningly ignorant on certain aspects the chemistry of metals."
1 In an NRC inspe tion report dated March 17-21,1996, cracking is observed in the closure welds
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on 1nner and outi k shields of fuel loaded VSC-24 casks at Palisades, Point Beach, and Arkansas Nuclear One unil 6. The inspection identifies the root cause ofcracking to involve tmauthorized weld repairs, the r,ask design, the welding environnu:nt and pruwdures.
1 To date. NRC ar j the industry have not resolved the issue of what to do with faulty casks where cracking of closu e welds is observed on the loaded casks at these three nuclear power stations The NRC and th industry remain in a quandary witi.ou . a strategy to unload irradiated fuct fiom fhlling casks. Th< x are currently 19 VSC-24 casks loa hi at reauors. Sicua Nuc! car und tim licensees remain nder NRC Confumatory Action Letters with regard to any further loadina, of the VSC-24 desii n. 4 Nuclear Informa1"on and Resource Service assetts that these problems and similar QA/QC 1 problems with th r VECTRA Tec!mologies Inc. NUIiOMs-52D dry cask system can be attributed to thelack ofNF C aggressive ovenight and enforcement ofits regulations and a ngorous I j o i
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01/13/98 05:20 TX/RX NO.5271 P.003 l
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J44-33-1993 38 06 FROM NJRS-156HJNGTON,IC TD 14233393769-22 P. 04 1 ,
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/~ cestification pro ess. Enentially, NRC has deferred it regulatory resrxxudlidities to the industry G} that it is suppost 4 to be regulating. NTRS catttions the NRC, the licensee and the atikcted communities to 1 ot allow the these identified problems or similar problems to be repeated at the Yankee Rowe si e.
Therefore. NIfu ' submits:
i) The NRC mu: I be required to obtain an independent and reputabfc third party review (such as timNatlunal Ass >ciation of Cossosion Engineers) of all dry cask design systems as pan ofits .
certification pro < :ss.
- 2) The curmnt h RC licensing process fbr dry cask storage must be resended to require site specific reviews it aH potential sites with a complete Eiwironmental Impact Statement and that such process wif ;h opened to the sight to a pubfic heniing with thff adjudicatory review.
- 3) Yankee Aton1 c Electric Company must retain fuff fiability for its nuclear waste gene'r'ated at -
Yankcc Rowe an d that both a wet storage and hot-cell capability be provided for the full '~..
retrievability ofi radiated fuelin the event that a duly certified dry cask develop problems, l
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I TOTAL P.Gt 01/13/98 05:20 TX/RX NO.5271 P.004
vitizenS W a re n e s s N e t w o rk e.. es. sm.,emm. ,.,,.. A D43TD p . s CT 860-345-8431 NH. 603-772-3439 V MA 413-339-5781/ 4374/ F: 339 8768 VT.802-387-2646/ F: 387-2667 QUESTIONS FOR NRC AND YANKEE ROWE ON YANKEE ATOMIC'S SITE RELEASE PLAN CLEAN UP OF CONTAMINATION: l I
o WHAT IS THE EXTENT OF TRITIUM CONTAMINATION FROM THE lON EXCHANGE PIT? {
o GIVEN THAT THE TRITIUM CONTAMINATION HAS REACHED THE GROUND WATER AND MIGRATED TO THE DEERFIELD RIVER OR SHERMAN POND, HOW DO YOU INTEND TO CLEAN THIS UP?
o GIVEN THAT TRITlUM IS A DANGEROUS ENVIRO TOXIN WITH A HALF LIFE OF 12.5 YEARS, HOW LONG DID THE j TRITIUM LEAK OUT OF THE lON EXCHANGE PIT o HOW MUCH COBALT 60 AND CESIUM 137 ARE IN THE SOIL AND SEDIMENT IN THE DRV?
o HOW MANY CONTAMINATED TEST WELLS HAVE BEEN LOCATED? HOW DEEP DOES THE CONTAMINATION GO?
e WHY WAS CONTAMINATED WASTE STORED AND TRANSFERRED ON SITE?
FUEL POOL o BESIDE THE MILLION CURIE BAFFLE, IS THERE ANY OTHER ABOVE CLASS C WASTE IN THE POOL 7 o HOW CONTAMINATED ARE THE PUMPS, FILTERS, SCREENS , AND TUBING USED TO RUN THE FUEL POOL.
o HOW HOT ARE THESE COMPONENTS?
o ARE THEY CONTAMINATED WITH TRANSURANICS?
o WHAT WILL YOU DO WITH THE ABOVE CLASS C7 o WHAT IS THE LEVEL OF CONTAMINATION UNDER THE FUEL POOL 7 FUEL POOLS, CASKS AND DRY CASK STORGE l
o HOW MANY FUEL ASSEMBLIES HAVE DETERIORATED OF THE 40,000,000 CURIES IN THE POOL. DESCRIBE HOW YOU WILL ISOLATE AND PACK THIS DETERIORATED FUEL.
. .SINCE THE ONLY DIFFERENCE IN COST BETWEEN REMOVING THE POOL AND KEEPING THE POOL INTACT IS I MONEY-THE EMPLOYMENT OF THIRTY THREE PEOPLE, WHY NOT HELP OUR POOR COMMUNITY THROUGH j l
CONTINUED EMPLOYMENT OF WORKERS? YOU WOULD ONLY SAVE TWO MILLION DOLLARS A YEAR WHICH IS 1%
' i OF YOUR DECOMMISSIONING COSTS WHILE PUTTING 33 SKILLED WORKERS OUT OF WORK GIVEN YOUR PRIMARY CONCERN WITH SAFETY?
o WHAT WOULD A GOOD NEIGHBOR DO? HOW MANY FUEL POOLS HAVE BEEN REMOVED WHERE FUEL HAS BEEN TRANSFERRED TO AN ON-SITE LOCATION?
o WHAT'S WRONG WITH THE POOL?
o SINCE LIMITING CASK USAGE IN AND OVER THE IRRADIATED FUEL POOL IS ESSENTIAL BECAUSE OF THE DANGERS OF A CASK DROP, WOULDN'T IT BE SAFER TO LEAVE THE FUEL IN THE POOL 7 o HOW MANY CASKS WILL BE NEEDED?
( o FOR HOW LONG?
-[
o
o THE FUEL POOL IS NEEDED TO TRANSFER LEAKING CASKS. WHY ARE YOU REMOVING IT? lSN'T THE ONLY REASON MONEY SINCE YOU WILL DE ABLER TO FIRE 33 WORKERS AT A COST SAVING OF HOW MANY MILLIO DOLLARS?
. HOW CAN YOU EXCLUDE THE REAL POTENTIAL FOR HEAVY LOAD DROPS, ONTO OR INTO THE FUEL POOL OF FU TRANSFER SHUTE?
e HOW WILL YANKEE PREVENT WHAT HAPPENED AT PRAIRIE ISLAND WHERE A CASK DANGLED IN THE AIR FOR I
OVER 16 HOUR, HOVERING OVER THE FUEL POOL?
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MULTI-PURPOSE CANNISTERS
. HOW MANY MPCS HAVE BEEN CONSTRUCTED THROUGHOUT THE COUNTRY
. HOW MANY MPCS HAVE BIEN CERTIFIED BY NRC?
e HOW MUCH WILL THE CASK AND ANY OVER PACK WElGHT? GROSS WElGHT OF THE CASK IN OVER PACK )
I e HOW MAY LAYERS OF CONCRETE IN THE PACK 7 IN AN OVER PACK, IF NEEDED?
. HOW LONG WILL IT TAKE TO MAKE AN OVER PACK? HAS ANY MPC OR OVER PACK RECEIVED CERTIFICATIO FROM NRC?
e WILL AN OVERPACK BE KEPT ON SITE AS A PRECAUTION FOR A LEAKING CASK?
THE FUTURE e SINCE THE FUEL MAY REMAIN ONSITE FOR DECADES IF NOT LONGER, WILL YANKEE WORK WITH THE FRANKLIN COUNTY COUNCIL OF GOVERNMENT TO CREATE A COMMUNITY ADVISORY BOARD TO MONITOR THE DEVELOPMENT OF A HIGH LEVEL WASTE MPC FACILITY?
e FROM THE BEGINNING OF YANKEE CONTEMPLATED CLOSING, YANKEE COMMITTED ASAP. IS THIS NEED TO CLEAR THE SITE DRIVEN BY THE SITE'S VALUE AS A SECOND GENERATION NUCLEAR FACILITY AS YOU SAID I YOUR REACTOR TOUR IN 1991?
e IF THERE IS A DECISION TO SELL THE SITE TO A NUCLEAR GENERATION CORPORATION, WHAT IS THE l
LIKELlHOOD THAT THE REACTOR WOULD USE ENRICHED PLUTONIUM AS FUEL 7 DOES DUKE POWER HAVE A INTENTION TO CREATE A SECOND GENERATION NUKE ON SITE? WHO OWNS THE PROPERTY, YANKEE ATOMIC OR DUKE OR ARE THEY THE SAME ENTITY?
e AS A PIONEER IN THE NUCLEAR FIELD, WILL THE YANKEE SITE IN ROWE BECOME THE " PIONEER" SITE FOR ESTABLISHING A NEW NUCLEAR SITE WITHOUT ANY PUBLIC PARTICIPATION?
TRAINSPOTTING
- HOW MANY FUEL ASSEMBLIES WITH BE TRANSPORTED IN EACH CASK 7
. HOW MANY CURIES WILL BE IN EACH CANNISTER?
. HOW MANY CANNISTERS ON EACH RAll SHIPMENT?
. ARE THE CASKS TRANSPORTED ON DEDICATED TRAINS OR POTENTIALLY MIXED WITH FOOD PRODUCTS OR EXPLOSIVE CHEMICALS?
e
THE RADIOACTIVIST hu4 SERVING NEW ENGl.AND J ANUA RY.1998 web site: www nukebusters org DRY CASK STORAGE OF ther problem scenarios: weight of the cask in the ver pack for eventual shipping, leaking of the cask HIGH LEVEL RADIOACTIVE WASTE on-site while over pack is built, exposure of workers, etc. At an NRC meeting with utilities, High Level waste (HLW), primarily . irradiated fuel negotiating the creation of an interim high-level rods from the reactor core, is intensely radioactive. waste site in Utah, the only solution the utilities After several years in a core, the rods are a million could conjure when queried about leaky casks, was times more radioactive than when loaded. Each to return the cask to the utility that sent it!
fuel cycle (every 18-24 months) one quarter to one third of the rods are removed and transferred to the Movement of casks is problematic and pose a fuel pool. Unshielded rods are lethal. They remain threat through error or equipment failure to workers deadly for thousands of years. Disposalis and the public. Dropping a cask in the fuel pool problematic and controversial. Originally waste building could severely damage the fuel pool and disposal was to occur through reprocessing and fuel creating the potential for an accident. In 1995, recychng into weapons grade materials. a loaded cask- over 240,000 lb. dangled over the Reprocessing sites are seriously contam.inated as fuel pool for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> at Prairie island. NRC had the process, itself, created additional radioactive granted a waiver for reviewing cask-load waste. Deep under ground burial of HLW at a procedures. Durability of the casks is limited and single national site is politically controversial and must be reviewed every twenty years. Some cask technically daunting. have deteriorated within a few years of installation.
Presently waste is stored on site in fuel pools. Many 3 utilities consolidated storage racks to increase pool DRY CA8K STORAGE : AN EXPERIMENT (V capacity. The nuclearindustry and the Nuclear . Casus ARE IN THE DEslGN STAGE Regulatory Commission developed a dry cask , g,,,,,,,,,,7,,,,,,,,,,,,L7,,,,
storage system or Independent Spent Fuel Storage installation (ISFSI) to expand on srte storage
. Casus ARE LEAMING AND DEMAIORAMNS capacity. Eight reactors, having reached fuel pool
. LAcu or merecTive emoceDunes oR expeRiaNce capacity, installed on-site dry cask storage. These cxperimental casks of concrete and metal, have IN UNLOADING AND RELOADING OF LEAKING OR had no full scale testing before installation. Loaded DETEn10 RATING CASKS 1r casks weigh in excess of 100 tons. Once loaded, the cask is pumped dry and inerted with helium.
Radioactive fuelinside the cask is 400 degrees F. DRY CASK STORAGE: A CHAPTER IN DEMOCRATIC MELTDOWN LEAKING CASKS:NO SOLUTION A provision in the Nuclear Waste Policy Act allows Unloading of leaking casks is problematic. Once NRC to use a "generallicense" policy for dry and inert, hot fuel can not come in contact with development of a specific site. This permits utilities Cither oxygen or water which could lead to a fuel to engage in expenmental techniques for temporary fire or a radioactive steam flash. A cask at Lake storage of HLW without public oversight or Michigan is leaking into the Lake, one of the largest participation. No specific environmental fresh water systems in the nation. The utility has assessment is required and no adjudicatory been unable to either transfer the cask back into heanng process is available to citizens or state or the pool or over-pack it for over two years. local authonties to hold NRC and the utility accountable. In Michigan, NRC approved a site O over-necximo or cesxe- e notemt>ei soietiee 1"etthe touicaioen oenerimeetor "et#<eiaesoerces I::aking casks in which the cask is inserted into a determined was a "high risk erosion zone" within larger cask, in the design stage, presents 150 yards of Lake Michigan.
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HOW MUCH FUEL ARE WE TALKING ABOUT?
DRYNNNEEN Yankee Atomic, % through its illegal dismantlement
- 1. no stra sPaceric issues Ana coNsio Rao N EVALUATING CASK stTING of Yankee Rowe, has over 40,000,000 curles of fuel on site. Yankee's engineers (now Duke Power 3 (
- 2. HEARINes AND PUBLIC PARTICIPATION ARE and Light), intend to capture the cask market with W {
sWMINATED another experimental process- its intention is to l
- 3. NO ENVIRONMENTAL IMPACT STUDIES ARE l create a multi purpose cask (MPC) for storage and neeUsaas I transport for Warehousing fuel and eventual
- 4. No CONsassaATION OF ALTERNATIVES AND NO transport to a national disposal site. MPCs are cost /sawaPir AnAtysis is Raousmus experimental- compromising safety - lighter to allow Although monitored Retrievable Storage may be transport by having fewer shielding layers. Yankee cheaper for the corporation over maintenance of an wants to remove its fuct pool to cut comers-I intact fuel pool (this has yet to be demonstrated), compromising safety. All other ISFl occurred at m iw rurpo cost cutting for the corporation may eventually ^
jeopardize workers and the public. It will certainly sp.ra wa..,
ru.t u mm, cost jobs. Since this new technology is already cxperiencing setbacks and design flaws, it could pose a threat to communities and the environment.
cwr u =a.. - -
BACK TO THE DRAWING BOARD! S Tr = pars ti o cui CERTIFICATION OF CASKS: NRC FAILUREl in May,1996, at Point Beach nuclear power station
!" Pact Limitet experienced a
- hydrogen ignition event" i.e. an operating reactor sites where on going NRC explosion while loading a VSC-24 storage cask. oversight is required. Not so at decornmissioning The explosion had enough force to Irft a 3 ton tid sites under NRC s "new rule . There is no longer several inches in the air and turn it on its side. The any requirement for resident i,nspection. Th,s i VSC is made by Sierra Nuclear Corporation, and experimental process creates a precedent which received certrfication from NRC in May,1993. The could have grave consequences for reactor explosion was caused by an electro-chemical communrties If NRC permits th,s i gambit,it will interaction of the cask's nickelliner and the acidic streamline the process, removing accountability of water in the reactor fuel pool. The reaction the industry and regulator to the people. There generated hydrogen gas which ignited when it would be no due process available to impacted came in contact with the welding torch used to seat communities " nuclear fuel" communities forced to the lid. The accident was unanticipated and baby-sit the industry's monstrous waste problemi unanalyzed by NRC or the manufacturer 16 casks have been loaded nationally before the AsouT CAN: is a grassroots, volunteer regional group cxplosionf. Each VSC cask contained the curie concerned with environmental pollution and health equivalent of 240 Hiroshima bombst After the consequences from toxic exposure. The scientific fact, an investigation of the manufacturer revealed community and nuclear industry have undermined confusion, inadequate testing, and poor quality citizens' confidence in their ability to understand atomic power. CAN seeks to demystify these issues, with the l control. Problems that have since been uncovered j ct other cask fabricator's sites. In 1997 delayed goal of enabling citizens to reclaim democratic control over their environment and develop strategies for the l cracking in the shield lid's welds were discovered at prevention and elimination of pollution. CAN's focus is Palisades, Point Beach, and Arkansas Nuclear nanonal, regional, and locat. It is rooted in our ;
One reactors. The VSC 24 casks are already expenen e in a poor, rural community hosting tw_g deteriorating! Serious problems are emerging in nuc am ww statons W Wes apan amoxin other dry cask systems. Casks at Davis Bessie "
- reactor in Ohio sited on Lake Erie without are real and immediate to us. We oppose the pollution environmental assessments or public participation. of our land, and contamination of other communities.
were built below technical specification standards.
O if you have any questions, want to make contributions or donations, or Join Us,
Contact:
Citizens Awareness Network Box 83, Shelbume Falls, MA 01370 413-339-5781/ 4374/ CT 860-345-8431/
1-4
'QQ:ggyMG FRANKLIN REGIONAL Executive oirector oar oieucchi ,
c i
pOUNCIL OF Director of Finance + Camlyn Of oireci<,r ,r eannina and oeveionmer.t ecysy sioan V
GOVERNMENTS Main Tel 413-77L3167 Finance Tel 413-774-4804 Main rax emn69 erannins Fax man <e fMWES$$5232 Community Heahh and Educuion Data Management
- Engineering 425 Main St. Greenfield. MA 01301 Municipal Assistance P:anning and Development
- Purchasing Mr. Donald Davis Chief Executive Officer Y.ankee Atomic Electric Company 580 Main Street Bolton, MA 01740 December 4,1997
Dear Mr. Davis:
Thank you for the opportunity to review the License Termination Plan for the Yankee Rowe Nuclear Power Station as part of your public participation precess. The O decommissioning of the: Yankee Rowe Nuclear Power Plant and storage of spent fuel presents significant potential public health and safety risks to the region's environment and residents. The issues related to the Termination Plan, including spent fuel storage, have been presented and discussed at several meetings of the Franklin Regional Planning Board (FRPB). At the October meetings of the Franklin Regional Planning Board and Executive Committee it was decided that a lener should be sent expressing our questions and concems with regard to the decommissioning of the Yankee Rowe facility and storage of high level spent fuel. We understand that a public meeting of the Nuclear Regulatory Commission (NRC) is scheduled for January. and that we may ask questions at that meeting. In the interest of moving the process forward it seems logical to raise our concerns and questions now so that your organization has adequate time to prepare responses for the public meeting to be held by the Nuclear Regulatory Commissicn.
This letter will outline some of the issues of greatest concern to the FRPB. Many of the individual questions we have heard from our members are specifically technical in nature, such as how the parameters and methodology were established for site assessment work.
However, we would first like to address the larger issues raised during our discussions related to the Termination Plan and decommissioning of this facility. Accordingly, we have organized our conunents into two sections, General Issues and Technical Questions.
Finally, this letter should not be construed to represent all of the issues which currently exist or the questions which may develop in the future.
m aa:rr: , ~,
Generalissues
- 1. We are very concerned with the recent sale of the nuclear services division of Yankee Atomic Electric Company (YAEC). Please explain how the sale affects the current management team's authority and responsibility for the decommissioning of the plant and spent fuel storage. Ilow will discussions, descriptions, and general assurances that we are being given by current management be impacted by the ownership changes' What can we expect in terms of:
e changes in corporate philosophy and willingness to maintain open dialogues and discussions with the general public; contintu , of the existing management team and employees familiar with the facility in contrast to replacing those permanent jobs with contract workers or new employees unfamiliar with the plant; and corporate commitment to strong safety standards, public policies, and reporting procedures?
- 2. What is the current ownership structure of YAEC and what are its financial assets including insurance that will provide for sufficient funding and personnel to complete decommissioning, ensure the long term maintenance of the spent fuel storage system and guarantee financial coverage for remediation in the event of accidents? According to the Termination Plan (Table 6-2), approximately S235 millien of funding remains for decommissioning between 1997-2018, including a deferred contingency fund ofS18.7 g
million. What corporate entity will be responsible for any shortfalls which arise during this period if the contingency amount is insufficient? What happens after 2018 if the spent fuel is still being stored on site? Are amounts still being collected from ratepayers to fund future decommissioning costs? What is the expected financial impact of the deregulation of generating facilities in Massachusetts upon YAEC and its owners?
- 3. What are the plans for the future use of the site? Will YAEC hold it in perpetuity, convey it to another utility, or is there a plan to sell or re-use the site (notwithstanding the issues of the possible presence of a dry cask storage system or spent fuel pool)? Will there be a deed restriction or other permanent notation that the site has elevated levels of contaminants?
- 4. The FRPB has great concems about the construction of a dry cask storage system since the technology is new, accidents associated with loading the spent fuel into the l
storage system have already occurred at other locations, and systems constructed have l
! been in operation for only a few years. In addition. the estimated life span (20 years) of l
the dry cask storage system is relatively short in comparison to the potential time frame the fuel may remain on-site since neither a temporary nor a permanent site is available at the federal level. The decision between selecting a dry cask storage system or i
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L maintaining the spent fuel pool should not be based primarily on econornics, but rather on g which approach best protects public safety and welfare.
V Please compare and contrast the safety, cost and life expectancy between the dry cask and spent fuel pool storage systems. In particular please describe which dry cask storage system is being considered for Rowe, its capital cost to design and construct, the life expectancy of the facility and the cost savings such a system would provide in comparison to the continued operation a 'nd maintenance of the spent fuel pool. What fail-safe procedures are proposed to prevent the problems that have occurred elsewhere?
YAEC's decision to build a dry cask storage facility or continue operations of the spent fuel pool are also dependent upon the outcome ofpending federal legislation to build a short-term centralized storage facility. Please describe what YAEC action (s) and timetables will be, given all the possible scenarios that exist right now with regard to future storage of the spent fuel and other contaminated materials including:
if short-term storage in a centralized off-site lccation is approved; if short term storage is indefinitely postponed or canceled; or if spent fuel is kept in a pool rather than moved to dry cask. under either of the ftrst two scenarios.
If short term storage in an off-site location is approved, it may still take many years to construct the new facility before YAEC spent fuel can be sent there. Assuming that the spent fuel must be held on-site until the new facility is ready, what factors will decide whether YAEC decides to maintain the spent fuel pool for the interim or pursues on-site dry cask storage? If a dry cask stcrage facility is constructed, does YAEC intend to store the fuel within the " Owner Contro!!ed Fence" area? What security will be provided to protect against sabotage? What levels of radiation will be emitted by the dry cask storage !
facility? If new technologies for safer storage. transportation and disposal of spent fuel become available, what process will the company use to reconsider its plans?
- 5. Please describe the difference between an NRC Public Hearing and an NRC Public Meeting. We expect that one meeting will be not be sufficient to fully address issues raised by all interested parties. The decommissioning of the Yankee Rowe Nuclear Power Plant and potential long tenn storage of spent fuel has public health and safety implications which deserve a full, open and detailed discussion and it is highly unlikely this will be fulfilled in one three hour meeting or hearing.
1 1
- 6. The Franklin Regional Planning Board requests that grant funds be made available to j l the Franklin Regional Council of Governments to allow them to hire an independent
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consultant to review and comment on the technical aspects of the tennination plan and the l
storage of spent fuel. Is YAEC able to contribute funding for this resiew?
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- 7. According to the Union of Concerned Scientists, it would be more appropriate to design, construct and license a dry cask storage facility under 10 CFR Part 72 which the g
NRC promulgated speci5cally to address the safe storage ofirradiated fuel rather than W under the 10 CFR Part 50 regulations intended for power plant operations. Since the plant is no longer in operation, as the reactor vessel has been removed and shipped to South Carolina, what is YAEC's view of handling the storage ofirradiated fuel according to the requirements of 10 CFR Part 72 regulations which are speciScally designed to address the threat to public health and safety? If the dry cask storage system is licensed under 10 CFR Part 72, would YAEC be required or allowed to accept irradiated fuels from other nuclear power plants?
Technical Questions
- 1. The NRC says that t' . average radiation exposure to a person in the United States is 360 Millirem (MR) per year. If the background level at Rowe after clean-up is 75 MR per year (comprised of 60 MR background radiation levels and 15 MR residual from YAEC operations), what will the average dose per year to a resident of the area be when all other sources of radiation such as natural radon emissions, medical diagnostic procedures, and average air travel is factored in? How far beyond the site will the extra
, 15 MR per year elevated exposure. or some percentage ofit, extend? What is the formula for calculating exposure vs. distance from a source of radiation? What impacts will the elevated exposure to radiation have on plant and wildlife habitat? What would be the cost to YAEC to clean up the site to background radiation levels (60 MR) given the g
already high level in comparison to other areas in the region (Brattleboro background levels reported to be 18 MR per year)?
- 2. Most of the radioactive contaminants found on site bind to soil particles. Different soil layers can have ve:v different physical properties. For the site evaluation, how were the parameters determined which dictate how deep to test, spacing between borings, and distance from the plant? We understand that the methodology that was employed sampled fewer areas as the distance from the plant increased until contamination was no longer signi6 cant, and then no testing was done beyond that point. Since very few samples were taken outside of the " Owner Controlled Fence," what consideration was given to the possibility of contamination at isolated and more distant points due to stack e '.ssions, windbome contaminants, or other singular or infrequent events? Sampling mults appear to be based on the " average contamination" in an area. Are there areas more highly contaminated than others in the " average contamination" zone? How are exposure and health risks impacted by smaller areas of more highly contaminated materials within the averaged zone?
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- 3. The sampling and testing according to the Termination Plan is self monitored.
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Similarly, laboratory testing is reported to be conducted by the YAEC laboratory without specific provision for independent sampling, quality control or verification of the results. I What, if any, independent verification is provided for the sampling, monitoring and testing program?
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- 4. Other contaminants exist on the site which are regulated by the Massachusetts
{
Department of Environmental Protection rather than the NRC. Please disclose and
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discuss any incidents or situations such as spills or clean-ups vhich may involve hazardous materials such as asbestos, PCBs, lead, and similar materials. How are these materials being handled in the decommissioning work? What will be the status of the site following decommissioning with regard to hazardous materials regulated pursuant to M.G.L. Ch. 21E?
- 5. The Radiology Department of the Massachusetts Department of Public Health is responsible for monitoring radioactive exposure levels and related activity. Please describe the role they have played in the decommissioning activity to this point, and what their continued role will be as radioactive materials are removed and the facility is decommissioned.
- 6. We imderstand that YAEC is considering leaving tritium contamination in the sediments of the Deerfield River and the Sherman Pond reservoir. Please present your
] analysis of the advantages and disadvantages of removing contaminated sediments versus leaving them in place in terms of radiation exposure to the environment. How will severe stonn events and flooding impact the sediments and radiation exposure to the environment? Please list the half-life of tritium and specify when it can be reasonably assuined that the amount of tritium will fall below detectable levels? What other contaminants, such as PCBs and other radionuclides, occur in these sediments?
- 7. What short and long term water quality monitoring will be conducted for groundwater, the Deerfield River and Sherman Pond? The termination plan reports that groundwater levels are relatively close to the surface beneath most of the plant buildings because of an impermeable layer ofsoil. Why were observation wells placed below known groundwater levels at a depth 6.1 to 9.1 m rather than reported groundwater levels of.9 to 6.1 m which is the area where contamination from the buildings would most likely be detected? Are there plans to instcIl shallow monitoring wells?
n U
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9 We appreciate your request to convey our concerns and questions regarding the Termination Plan. We look forward to receiving your responses at the NRC Public g
Meeting to be scheduled in January 1998. Please do not hesitate to contact me or Peggy Sloan, Director of Planning & Development - Franklin Regional Council of Governments W
(413-774-3531)if you have questions concerning this letter.
Sincerely, ,
/
ha frn Adam Laips i Franklin Regional Planning Board O
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cc.: Mr. Morton Fairtile, Nuclear Regulatory Commission Franklin Regional Council of Governments Executive Committee O
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Telephon (S08) 568-2233 Facsimile (508)568-3703 YANKEEATOMICELECTRIC COMPANY e~ ~ ~ r. ~ ~
h 580 Main Street, Bolton, Massachusetts 01740-1398
, ANKEE DON K. DAVIS CHIEF U VE FRCER '
Mr. Adam Laipson, Chair Franklin Regional Planning Board 425 Main Street Greenfield, MA 01301
Dear Mr. Laipson,
Thank you for your letter of December 4,1997 regarding the License Termination Plan (LTP) for the Yankee Nuclear Power Station. Yankee has prepared the attached responses to the Planning Board's questions presented in that letter, and we trust that you will find these responses informative and helpful.
Yankee appreciates the opportunity to discuss the decommissioning of the Yankee Nuclear Power Station with the Franklin Regional Planning Board and Council of Governments. We look q forward to following up on the attached responses in person at the NRC public meeting on O January 13,1998 and at subsequent meetings with members of the Planning Board and Council.
Ms. Jane Grant, Decommissioning Manager, will contact you in the near future to discuss meeting dates.
Sincerely, YANKEE ATOMIC ELECTRIC COMPANY Don K. Davis W -
President and CEO Yankee Atomic Electric Company c: Brad Councilman, Council of Governments Morton Fairtile, NRC i
YAEC RESPONSES TO FRANKLIN REGIONAL COUNCIL OF GOVERNMENTS QUESTIONS ON YNPS LICENSE TERMINATION PLAN GeneralIssues GeneralIssue No.1: We are very concerned with the recent sale of the nuclear services division of Yankee Atomic Electric Company (YAEC). Please explain how the sale affects the current management team's authority and responsibilityfor the decommissioning oftheplant and spentfuel storage. How will discussions, descriptions andgeneral assurances that we are being given by current management be impacted by the ownership changes? What can we expectin terms of:
changes in corporatephilosophy and willingness to maintain open dialogues and discussions with the generalpub.*:c; continuity of the existing management team and employeesfamiliar with the facility in contrast to replacing thosepermanentjobs with contract workers or new employees unfamiliar with theplant; and corporate commitment to strong safety standards, publicpolicies, and reporting procedures?
Historically, Yankee Atomic Electric Company (YAEC, Yankee) was comprised of the Nuclear Services Division and the Yankee Nuclear Power Station (Yankee site). On December 1,1997, the Nuclear Services Division was sold to Duke Engineering and Services (DE&S). This sale is a Os positive development for the Yankee site and will have no detrimental impacts on decommissioning. The sale of the Nuclear Services Division does not change the ownership structure of YAEC, nor does the sale affect YAEC's ownership of and responsibility for the Yankee site. Furthermore, there is no change in the funding or ownership of the decommissioning trust fund as required by the Nuclear Regulatory Commission (NRC) and as approved by the Federal Energy Regulatory Commission (FERC).
As part of the DE&S acquisition, Yankee awarded DE&S a services contract to assist Yankee in completing the decommissioning of the Yankee site. This contract requires DE&S to implement Yankee policies and procedures as they pertain to the safe decommissioning of the Yankee site.
The overwhelming majority of the staff that will be providing these services will be former Yankee employees who have accepted employment with DE&S. The new relationship between Yankee and DE&S will enhance Yankee's ability to accomplish its primary mission of safely decommissioning the Yankee site. Experienced Yankee personnel, who might have felt compelled to seek alternative employment opportunities as the conclusion of decommissioning draws nearer, now have the option of" completing thejob" with reasonable assurance of ongoing employment as members of the DE&S team. Also, if the need arises, Yankee will be able to take advantage of the additional resources afforded by one of the world's leading architect-engineer companies.
The authority, responsibility, and composition of the current management team at YAEC and the 1
Yankee site remains the same as that prior to the Nuclear Services Division sale. For example, Ken Heider, who is now employed by Duke Engineering and Services, continues as the Site Manager. In that capacity, Ken will continue to be responsible for the day-to-day management of decommissioning at the Yankee site. Also, Rick Williams, Plant Superintendent, will remain a Yankee Atomic Electric Company employee. In that capacity, Rick will continue to manage the security of the site and the safe operation of the spent fuel pool. Approximately 30 Ther individuals at the plant will remain employees of Yankee. We anticipate no significant changes in the personnel who have successfully brought the decommissioning of the plant to its current status. Yankee Atomic Electric Company will continue with our historical commitment to strong safety standards and open communication with the public. Our contract to DE&S will only enhance that commitment as DE&S also regards strong safety standards and open communications as critical to success.
GeneralIssue No. 2: What is the current ownership structure of YAEC and what are its i financial assets including insurance that willprovidefor sufficientfunding andpersonnel to complete decommissioning, ensure the long term maintenance ofthe spentfuelstorage system andguaranteefinancial coveragefor remediation in the event ofaccidents? According to the Termination Plan (Table 6-2), approximately $235 million offunding remainsfor decommissioning between 1997-2018, including a deferred contingencyfund of$18. 7 million.
What corporate entity will be responsiblefor any shortfalls which arise during thisperiod sf the contingency amount is insufficient? What happens after 2018 sf the spentfuelis still being stored on site? Are amounts still being collectedfrom ratepayers tofundfuture h decommissioning costs? What is :he expectedfinancialimpact ofthe deregulation of i generatingfacilities in Massachusetts upon YAEC andits owners?
Yankee Atomic Electric Company is owned by the following ten sponsoring utilities:
% Ownershio New England Power Company 30.0 The Connecticut Light and Power Company 24.5 Boston Edison Company 9.5 i Central Maine Power Company 9.5 Public Service Company of New Hampshire 7.0 Western Massachusetts Electric Company 7.0 , l Montaup Electric Company 4.5 Central Vermont Public Service Corporation 3.5 Commonwealth Electric Company 2.5 Cambridge Electric Company 2.0 The power contracts under which YAEC supplied power to the utilities identified above obligate the same utilities to pay the full cost of decommissioning the Yankee plant. These decommissioning costs include all costs to operate, maintain, and dismantle the spent fuel storage facilities -- even costs beyond the 2018 date by which all spent fuel is assumed to be off site.
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1 Decommissioning funds are currently being collected in accordance with a FERC settlement dg approved April 10,1996, which allows YAEC ' ) collect S39.4 million annually during the period November 1995 through June 2000. The current FERC settlement also requires an updated decommissioning cost estimate to be submitted by January 1,2000. Aay future adjustments in costs and/or collections reflecting the need for funds beyond those currently approved by FERC 1 would be made through the FERC rate case process.
l It is impossible to determine what effect deregulation will have on Yankee's individual utility owners. However, whatever the circumstances, the YAEC power contracts will remain in place I and the ten sponsoring utilities will remain contractually obligated to pay the full cost of decommissioning. If the ownership structure of any of the sponsoring utilities changes in the future, these contractual obligations will remain in place and either be retained by the old utility or assumed by the new owner of the utility's assets. Deregulation is, therefore, not expected to negatively impact Yankee's decommissioning funding.
l Please note that issues concerning the funding assurances of the Yankee site decommissioning f were evaluated and settled in two 1996 NRC decisions (CLI-96-1 and LBP-96-2). These decisions were elements of the approval of the Decommissioning Plan, and they are not expected to be re-opened as part of the NRC's consideration of the License Termination Plan.
Also note that the NRC, in proposed miemaking dated September 10,1997, is proposing to modify the regulations in response to deregulation concerns and in response to questions q pertaining to funding assurance and their financial mechanisms. The actions proposed will require V periodic reporting on the status of funds and on any changes in the external trust agreements.
Periodic re-estimates of decommissioning costs and adjustments to the rate of collection would resolve concerns with potential shortfalls.
Although the occurrence of an accident resulting in significant damage or the release cf significant amounts of radioactivity is highly unlikely due to the reduced quantity ofradioactivic on site and the elimination of mechanisms that could initiate an accident, Yankee is required by tac l regulations to maintain financial protection for such events (10 CFR 50.54(w) and 10 CFR 140).
This financial protection is provided by property and liability insurance policies issued by a private l insurer, and by an indemnity agreement with the NRC. Yankee carries $100 million in nuclear liao:lity coverage and has a $560 million indemnity agre: ment with the NRC to protect the public in the event of an accident. Yankee will continue to meet the NRC's financial protection ,
requirements until all spent fuel is removed from the site and the license is terminated. l 1
GeneralIssue No. 3: What are theplansfor thefuture use of the site? Inli YAEC hold it in '
perpetuity, convey it to another utility, or is there aplan to sell or re-use the site (notwithstanding the issue of thepossiblepresence of a dry cask storage system or spentfuel pool)? Will there be a deed restriction or otherpermanent notation that the site has elevated levels ofcontaminants?
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Yankee intends to complete decontamination and dismantlement of the plant facilities, remove O spent fuel from the site, and terminate the NRC license. A comprehensive final status survey, subject to verification by the NRC, will be performed to demonstrate that any remaining plant-related radioactivity is below NRC-regulated levels established for unrestricted use of the site.
These levels will within the natural variability of background radiation in the area of the site. As described in the response to Technical Question No. 4, Yankee will also comply with all federal and state laws and regulations regarding the disposition of non-radiological contaminants.
Yankee will record a notice in the chain of title to the site so that all persons are put on notice of l the prior use of the land as a site of a nuclear power plant. However, in the event of a sale of the l site, it is Yankee's expectation that when decommissioning is completed there would be no deed restriction associated with the site property due to federal and/or state-accepted residuallevels of radioactive, hazardous, or toxic materials.
After the release of the site due to termination of the NRC license, Yankee intends to restore the !
site to a " green field" condition. Site restoratio" costs are included in the decommissioning estimate approved by FERC and are associated with demolishing site structures, backfilling foundations, grading, and landscaping. In addition to the NRC license, other permits such as the National Pollutant Discharge Elimination System (NPDES) permit will also be terminated in accordance with federal, state, and local regulations. Following site restoration, the site will remain Yankee's property. At the moment, there are no specific plans regarding future use or sale of the site.
GeneralIssue No. 4: The FRPB has great concerns about the construction of a dry cask ,
storage system since the techrslogy is new, accidents associated with loading the spentfuel l into the storage system have already occurred at other locations, and systems constructed have l been in operationfor only afewyears. In addition, the estimated hfe span (20 years) ofthe dry cask storage system is relatively short in comparison to thepotential timeframe thefuel may remain on-site since neither a temporary nor a permanent site is available at thefederal \
level. The decision between selecting a dry cask storage system or maintaining the spentfuel pool should not be basedprimarily on economics, but rather on which approach bestprotects public safety and welfare.
Please compare and contrast the safety, cost and hfe expectancy between the dry cask and spentfuelpoolstorage systems. In particular, please describe which dry cask storage system is being consideredfor Rowe, its capital cost to design and construct, the hfe expectancy of the facility and the cost savings such a system wouldprovide in comparison to the continued operation and maintenance ofthe spentfuelpool Whatfail-safeprocedures areproposed to prevent theproblems that have occurred elsewhere?
YAEC's decision to build a dry cask storagefacility or continue operations of the spentfuel pool are also dependent upon the outcome ofpendingfederallegislation to build a short-term l
centrali:ed storagefacility. Please describe what YAEC action (s) and timetables will be, given allpossible scenarios that exist right now with regard tofuture storage of the spentfuel and i 4
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other contaminated materials including:
O e ifshort term storage in a centralized off-site location is approved; e
ifshort term storage is indefinitelypostponed or canceled; or e
ifspentfuelis kept in a pool rather than moved to dry cask, under either ofthe first two scenarios.
Ifshort term storage in an off-site location is approved, it may still take manyyears to construct the newfacility before YAECspentfuelcan be sent there. Assuming that the spent fuel must be held on-site until the newfacility is ready, whatfactors will decide whether YAEC decides to maintain the spentfuelpoolfor the interim orpursues on-site dry cask storage? Ifa dry cask storagefacility is constructed, does YAECintend to store thefuel within the " Owner Controlled Fence" area? What security will beprovided toprotect against sabotage? What levels ofradiation willbe emitted by the dry cask storagefacility? Ifnew technologiesfor safer storage, transportation and disposal ofspentfuel become available, whatprocesses will the company use to reconsider itsplans?
The Nuclear Waste Policy Act of 1982 gave responsibility for the disposal ofhigh level radioactive waste and spent nuclear fuel to the U. S. Department ofEnergy (DOE).' The N. ulear Waste Policy Act requires the DOE to begin taking spent fuel by January 1998 and provides for priority acceptance of spent fuel from permanently shut down nuclear reactor sites. However, the DOE has yet to develop a permanent repository. Because the DOE has the capability to accept
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Yankee spent fuel and high level waste and currently accepts and stores spent fuel from 41 foreign countries, Yankee continues to press the DOE to accept the Yankee spent fuel and high level waste at its existing storage locations.
Legislation currently before the Congress would require the Department ofEnergy to begin the construction of a centralized interim storage facility to accept spent fuel from domestic licensees.
Prior to acceptance by the Department of Energy, storage of spent fuel is the responsibility of the individual NRC licensee. Therefore, Yankee must consider other storage options unless it can persuade the DOE to accept its spent fuel and high level waste.
Most reactors in the U.S. store spent fuelin water filled pools. Currently,10 reactor sites also store spent fuel in dry storage facilities consisting of metal and concrete casks. Yankee is ,
presently storing spent fuel in its spent fuel pool and is studying both wet and dry long-term storage options. A decision on spent fuel storage is not expected until at least mid-1998, however, Yankee is currently involved in the design and certification of a transportable dry storage system because of the long lead time associated with such activities.
There is no significant difference in overall safety between storing spent fuel in a spent fuel pool and in a dry storage facility. More than 40 years of experience at commercial nuclear reactors has demonstrated wet storage in spent fuel pools to be a safe technology. The NRC performed an inspection at the Yankee plant in 1994 to specifically evaluate spent fuel storage at Yankee. The O s
i f NRC found the existing facilities and programs adequate to ensure continued safe storage in the !
V] spent fuel pool.
Spent fuel has been stored in dry storage facilities at commercial reactors since 1986. Dry storage involves sealing spent fuelin airtight steel and/or concrete containers or casks that provide both structural strength and shielding. The spent fuel is surrounded by inert gas inside the casks. All casks are passive designs that involve no mechanical devices for cooling and ventilation. To date, dry spent fuel storage systems have performed adequately to protect the health and safety of the public. However, there have been some problems associated with the design and manufacturing of systems by certain vendors. Such problems have included small flaws in welds and the ignition of hydrogen created by the reaction of acidic water with corrosion inhibiting coatings.
Subsequent dry storage system design and fabrication activities have addressed these issues.
The dry storage system presently under consideration for use at Yankee would be a multi-purpose system which incorporates lessons learned from earlier systems. This system would consist of transportable stainbs steel canisters which would contain the spert fuel and would be sealed with welded, double lids. Because stainless steel would be used, there would be no need for corrosion inhibiting coatings of the type used in previous systems, thereby eliminating the potential for hydrogen generation and ignition. The canisters would in turn be stored in vertical heavy-walled reinforced concrete storage casks. An advantage of this multi-purpose system is that it would be designed and licensed for both on site storage and eventual transportation off site, thus minimizing the amount of handling required. Loading of the casks would be performed with a crane whose !
design is approved by the NRC and which would prevent a load drop even in the event of a failure ;
of any single component. The same rigorous adherence to procedures, attention to detail, and !
concern for safety that contributed to the success of recent major projects, such as the removal of the reactor vessel from the site, would be applied to all dry storage activities. Yankee has and will I continue to maintain an intimate role during the design and fabrication phases of the dry storage project to ensure that there are no unresolved issues which could lead to quality and/or materials '
problems that have occurred elsewhere.
The cask system would be a highly robust system which is designed to meet or exceed all NRC and International Atomic Energy Agency requirements for storage and transportation. This includes design for many unlikely sceriatios, including the impact of a 4,000 pound automobile at a tornado-driven windspeed of 126 miles per hour, submergence in over 600 feet of water, and a 30 foot drop onto concrete. Other conditions include maximum hypothetical earthquakes, temperature extremes, lightning strikes, fires, and blocked air vents. The primary dry storage site under consideration is within the current " owner controlled area." Radiation levels outside as a result of the dry storage facility would be indistinguishable from background radiation at the site boundary.
If constmcted, the dry storage facility would be subject to the physical security requirements ,
imposed by the NRC under its regulations applicable to the storage of spent fuel. Yankee would continue to maintain a round-the-clock securit;, .taff onsite, and the facility design would include i
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double fences, intrusion detection equipment, and a back-up electrical generator to provide
/ redundant power. In addition, the 77-ton dry storage casks (consisting of 3 % inches of steel and 21 inches of reinforced concrete) would provide significant protection against sabotage to the canisters and the spent fuelinside.
No finite life expectancies have been established for either wet or dry spent fuel storage systems.
An independent spent fuel storage installation is issued a 20-year renewable license under the provisions of 10 CFR Part 72. The period of the license, however, is not related to the life expectancy of spent fuel storage systems. In fact, the NRC has concluded that spent fuel can be stored safely and w;thout significant environmental impact in either wet or dry storage for at least 70 years (1990 Waste Confidence Decision Review,55 FR 38474). With continued maintenance, the life expectanc/ of both wet and dry systems is indefinite.
It is incumbent upon Yankee to select a safe spent fuel storage approach (i.e., either wet or dy) that is also cost effective. Key factors in Yankee's choice of a method for fuel storage are the outcome of ongoing litigation with the DOE to accept Yankee's spent fuel and pending federal legislation to construct an interim centralized storage facility prior to a permanent repository. If the DOE is ordered to accept Yankee's high level wastes at an existing facility, or ifinterim storage in a centralized location is approved and it appears likely that the DOE will expeditiously remove spent fuel from the Yankee site, Yankee would most likely maintain the fuel in the spent fuel pool because of the large capital expense of constructing a dry storage facility (approximately
$20 million). Ifit appears that Yankee must keep spent fuel on site for an extended period of time O because federal off site interim storage is significantly postponed, Yankee would most likely build V a dry cask storage facility because it would allow for more prompt decommissioning of the spent l fuel pool and related plant systems and stmetures. Additionally, if spent fuel were to be stored on site until 2018, overall dry storage costs would be approximately $31 million less than the wet storage option because oflower operating and maintenance costs. Finally, moving spent fuel to dry storage in transportable canisters would make the spent fuel " pre-packaged" and ready for shipment to a DOE facility.
Yankee is intimately involved in industry initiatives to handle, store, transport, and dispose of
, spent fuel and high level waste. Should an improved technology become available, it would be in Yankee's interest to consider such alternatives. Yankee would apply the same ebods that are routinely employed in all other similar decision making processes. .
Plea:e note that Yankee already possesses a general license for dry cask storage under 10 CFR 72.210 (see response to General Issue No. 7). Because approval of the License Termination Plan does not grant Yankee any additional authority to move spent fuel from the spent fuel pool to dry cask storage, the issue of wet vs. dry storage is not within the scope of the License Termination Plan approval proceeding.
General Issue No. 5: Please describe the difference between an NRC Public Hearing and an NRC Public Meeting. We expect that one meeting will not be sufficient tofully address issues O 7
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n raised by allinterestedparties. The decommissioning of the Yankee Rowe NuclearPower V Plant andpotentiallong term storage ofspentfuel has public health and safety implications l
which deserve afull, open and detailed discussion and it is highly unlikely this will befulfilled in one three hour meeting or hearing.
A public meeting is a pre-noticed meeting held by the NRC in which the public is invited to attend and participate. At such a meeting, the public may comment, ask questions, and make requests of the NRC or any other participant. The meeting itselfis often transcribed. The NRC may respond formally to the public comments and will consider them in its subsequent decision-making process.
l A public hearing is an adjudicatory process and involves presenting sworn testimony by qualified witnesses before a presiding authority, review board, judge, or panel ofjudges. A simplified description of the hearing process is as follows. First, contentions are formally filed and acted on ,
using legal mies of practice. If a contention is determined under the pertinent legal rules to be l
" admissible" and " supported by sufficient basis," a period of discovery typically follows where l information penaining to the contention may be exchanged through written interrogatories, depositions upon oral examination, and/or reproduction of documents. A proceeding may follow where oral testimony and/or documentary evidence is presented and cross-examined. This procedure generally leads to a legal decision or action by the presiding officer. Several types of hearings and their specific procedures are described in the NRC's regulations (10 CFR Part 2),
with certain types being more informal.
O V As we have indicated previously, if, following the NRC public meeting, the Planning Board and Council would like to meet further with Yankee, we would be pleased to do so.
GeneralIssue No. 6: The Franklin Regional Planning Board requests that grantfunds be made available to the Franklin R~ional Council of Governments to allow them to hire an independent consultant to review u., comment on the technical aspects ofthe termination plan and the storage ofspentfuel. Is YAEC able to contributefundingfor this review?
The number and type of questions asked by the Franklin Regional Planning Board suggests that the Planning Board has done a very capablejob of reviewing both the broader and technical aspects of the License Termination Plan. Yankee is pleased to answer these and any other .
questions the Planning Board may have. As always, the NRC is available to address questions and/or concerns. The Commonwealth of Massachusetts Department ofPublic Health and Department ofEnvironmental Protection also have technically qualified personnel. Both Departments have piovided oversight of decon missioning activities at the Yankee site. It is Yankee's understanding that personnel from these Depanments are available for independent advice to you and others. It is Yankee's hope that the Planning Board and Council ot' Governments will avail themselves of these resources. Should there be any remaining areas of concern following interactions with the NRC and/or Commonwealth officials, Yankee is willing to discuss support for an independent, recognized expert in the field of health physics and/or health 8
p studies to help resolve those remaining concerns.
V GeneralIssue No. 7: According to the Union of ConcernedScientists, it would be more appropriate to design, construct and license a dry cask storagefacility under 10 CFR Part 72 which the NRCpromulgated specifically to address the safe storage ofirradiatedfuelrather than under the 10 CFR Part 50 regulations intendedforpowerplant operations. Since the plant is no longer in operation, as the reactor vessel has been removed and shipped to South Carolina, what is YAEC's view ofhandling the storage ofirradiatedfuel according to the requirements of10 CFR Part 72 regulations which are specifically designed to address the threat topublic health and safety? If the dry cask storage system is licensed under 10 CFR Part 72, would YAEC be required or allowed to accept irradiatedfuelsfrom other nuclear powerplants?
The licensing process for the storage of spent fuel is described in the NRC's Technical Issues Paper (TIP) 15- Dry Cask Storage of Spent Fuel, which may be found on the world wide web at http://www.ntc. gov /OPA/gmo/tip/tip9715.htm. We quote from TIP 15:
"The NRC is responsible for reviewing proposed cask designs to ensure that they will safely confine the fuel and prevent fuel cladding (metal rods around the fuel) from degrading. NRC regulations cover the design, testing, manufacture, and maintenance of casks used in dry storage. The NRC approves spent fuel dry storage systems for independent spent fuel storage installations (ISFSIs) under the Q
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agency's regulations in 10 CFR Part 72. An ISFSIis a complex or stmeture designed and built for interim storage of spent fuel before final disposal. An ISFSI can be located on the same site as a licensed nuclear facility or separately.
NRC approval for an ISFSI is provided through one of two processes. The safety i
requ rements for both processes are the same, but the procedures are different. The fire. process provides for a one-step, site-specific license for construction and c peration of a dry storage facility. Receipt of a site-specific application is t nnounced in the rederal Register, and an opportunity for public hearing is provided. As part of the application, an applicant must submit an environmental report. The NRC publishes the results ofits environmental review in the Federal Register. The NRC also conducts a safety review. If results of both the safety and environmental review are satisfactory, a renewable license, with a term of 20 years, is issued.
The second process involves the use of a general license. The Nuclear Waste Policy Act directed the NRC to establish procedures for the generic approval of storage containers for spent fuel 'without, to the maximum extent possible, the need for additional site-specific approvals.' As a result, the NRC added general license provisions to 10 CFR Part 72 in a 1990 public rulemaking. Under these prosisions, any nuclear power reactor licensee can store spent fuel on its reactor O
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r,ite provided it uses an NRC pre-approved cask and performs written evaluations l O establishing that it can meet the conditions for use. l j
After the NRC's review of a spent fuel cask design application, a proposed rule is published to amend 10 CFR Part 72 to add the design to the list of approved casks.
A renewable certificate of compliance, with a term of 20 years, is issued for the cask when the rule becomes effective. Casks that are approved through this rulemaking process must be suitable for use under a range of environmental conditions sufficiently broad to encompass the majority oflicensed nuclear power plants in the United States, without the need for further site-specific approval by j the NRC." i l
Concerning the appropriateness oflicensing a dry cask storage facility using NRC-approved casks under the general provision ofPart 72, the NRC states the following in their Dry Cask Storage Fact Sheet found at http://www.nrc. gov /OPA/gmo/tip/ cask.htm:
"While the argument is made that the lack of a site-specific approval is a defect, it could equally be argued that the NRC cask-approval results in a better cask than one tailored to one specific site alone. The NRC knows of no safety or environmental reason why a site-specific analysis is required. I i
Use of NRC-certified dry storage casks at a reactor is included within the envelope {
of the previously approved nuclear power plant site, with all the seismic studies, environmental evaluations, security plans, etc applicable to the nuclear plant."
It should be noted that, of the ten reactor sites in the U.S. that store spent fuel in dry storage i facilities, five sites store spent fuel under site-specific licenses while the other five sites utilize generallicenses.
Because Yankee already possesses a generallicense for dry cask storage under 10 CFR 72.210, approval of the License Termination Plan will not grant Yankee any additional authority to move I spent fuel from the spent fuel pool to dry cask storage. The issue ofwet vs. dry storage is, therefore, not within the scope of the License Termination Plan approval proceeding. In addition, Yankee is not allowed by its license to accept spent fuel from other sites for storage in its spent fuel pool or in dry cask storage.
Technical Questions TechnicalIssue No.1: The NRC says that the average radiation esposure to a person in the UnitedStates is 360 millirem (mrem) peryear. Ifthe background level at Rowe after clean up is 75 mrem peryear (comprised of 60 mrem background radiation levels and 15 mrem residualfrom YAEC operations), what will the average doseperyear to a resident of the area be when all other sources ofradiation such as natural radiation emissions, medical diagnostic (N
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procedures, and average air travelisfactored in? Howfar beyond the site will the extra 15 mrem peryear elevated exposure, or somepercentage ofit, extend? What is theformula 'or calculating exposure vs. distancefrom a source ofradiation? What impacts will the elevated exposure to radiation have on plant and wildhfe habitat 7 What would be the cost to YAEC to clean up the site to barkground radiation levels (60 mrem) given the already high levelin comparison to other areas in the region (Brattleboro backgroundlevels reported to be 18 mRemperyear)?
We are constantly exposed to background radiation from several sources, or pathways: !
a direct exposure to cosmic rays and naturally occurring radioactive materials in soils and rocks; e
ingestion of food and water that contain naturally occurring radionuclides; e
inhalation of airborne radioactivity emitted from the earth (including radon);
exposure to man made sources of radiation, such as medical x-rays, diagnostic and therapeutic treatments, and fallout from past nuclear weapons testing.
The radiation dose we receive from each pathway is variable and can depend on many factors, including geographicallocation, time of year, and the weather. Human activities can also affect our dose from background radiation. For example, taking a continentai airline flight or moving to a higher altitude, such as Denver, Colorado, will increase a person's dose from direct exposure to t
cosmic rays.
l O Data from the Yankee Radiological Environmental Monitoring Program (REMP) can be used l
with data from the National Academy of Sciences / National Research Council (published in the 1990 BEIR V Report) to estimate the total average annual dose in the Rowe area:
66 mrem /yr from direct exposure in Rowe .trea to cosmic rays and radioactive materials in soils and rocks, including a small amount of fallout from past weapons testing (Yankee REMP data) 39 mrem /yr from ingestion of food and water that contain naturally occurring radionuclides (BEIR V data) 200 mrem /yr from inhalation of naturally occurring radon gases (BEIR V data) 53 mrem /yr from medical sources (BEIR V data) ,
358 mrem /yr total average annual radiation dose in Rowe area These average annual doses are quite variable in both time and specific location. For example, the annual dose from background direct exposure (66 mrem /yr average) has been measured to range from as low as 47 mrem /yr to as high as 83 mrem /yr within several miles of the Yankee site.
Annual doses from other pathways (ingestion of food and water, inhalation of radon, etc.) show similar variations. Background radiation levels and their variation in the Rowe area are comparable to other areas in the northeast United States. For instance, the NRC maintains a direct radiation monitoring network which indicates that the annual average direct dose rate in O 11
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,q Brattleboro, Vermont is about 72 mrem /yr. The NRC publishes the results of their monitoring V network in NUREG-0837 on a quarterly basis, and the background level of radiation referred to in the question appears to be the auarterly average dkect dose rate of 18 mrem / quarter (or 72 mrem /yr). 1 The NRC requires that the dose from residual plant-related radioactivity be less than 25 mrem /yr for unrestricted release of the site. In the License Termination Plan, Yankee has committed to '
limit the dose from residual plant-related radioactivity to less than 15 mrem /yr. This dose adds to the dose received from background radiation, and includes all exposure pathways. For example, if a person were to build a house on the Yankee site, farm the land, and draw drinking water from his or her own well, that person's dose could not be any more than 15 mrem /yr above what he or l
she already receives from background radiation (i.e.,358 mrem /yr). In fact, most of the 15 mrem /yr or less dose could only be obtained by standing on the ground at the site because most of the dose derives from direct exposure to the ground surface. For individuals living beyond the I affected area of the former reactor site, no detectable increase in exposure above the 358 mrem /yr background average would be expected to occur because the effective range for direct exposure is only several meters from the ground surface containing the residual radioactivity. The i I
correlation between exposure and distance is complex and highly dependent on the geometry of the radiation source, but in general, exposure decreases with distance from the source. Because the level of residual radioactivity committed to by Yankee (15 mrem /yr) is within the normal l variability of the direct background radiation (47 to 83 mrem /yr, or a difference of 36 mRemlyr), ,
no detectable impacts on the local plant and wildlife habitat are expected. l M
(O NRC regulations only require that site cleanup activities remove radioactive material down to an incremental level distinguishable from background. Yankee has performed an analysis which determined that the costs of remediating areas with residual radioactivity at dose levels less than 15 mrem /yr are not justified by the associated benefits (see section 4.4 of the License Termination Plan). The NRC performed a generic analysis of the costs and impacts of cleaning up sites to very low levels (NUREG-1496). This report concluded that " expenditures made to reduce impacts to a dose criterion of 0 mrem /yr above background may be very large." They also concluded that "there is not necessarily a further health and safety benefit in establishing a return-to-background attemative that is in the order of 0 mrem /yr above background." The .
NRC's conclusions are consistent with the analysis contained in Section 4., of the License Termination Plan, which shows that costs become greatly disproportionate to the benefits ,
achieved by remediation at successively lower levels of residual radioactivity distinguishable from background.
Technical Question No. 2: Most of the radioactive contaminantsfound on site bind to soil particles. Different soillayers can have very differentphysicalproperties. For the site evaluation, how were thepararneters determined which dictate how deep to test, spacing between borings, and distancefrom theplant? We understand that the methodology that was employed sampledfewer areas as the distancefrom the plant increased until contamination was no longer sigrdficant, and then no testing was done beyond thatpoint. Since veryfew O 12
samples were taken outside of the " Owner Controlled Fence," what consideration was given to thepossibility ofcontamination at isolated and more distantpoints due to stack emissions, .
windborne contaminants, or other singular or infrequent events? Sampling results appear to be based on the " average contam! nation"in an area. Are there areas more highly contaminated than others in the " average contamination" zone? How are exposure and health risks impacted by smaller areas ofmore highly contaminated materials within the averagedzone?
The distribution of radioactive contaminants with soil depth is dependent on many factors. The most important of these are the physical and chemical properties of the soil, and the amount that the soil has been disturbed following a contamination event. At the Yankee site, the majority of contamination has been found in the top 6 inches. This has been determined through soil borings up to 31 feet deep and shallow (0-12 inches) incremental samples excavated in areas of known and suspected contamination. Radioactive contaminants found deeper than 6 inches have generally been in areas where the soil has been disturbed, and in these cases the sampling depth is based primarily on information regarding the depth of the disturbance. Where significant sources of contamination have been found, systematic sampling has been performed in an iterative fashion to bound the depth and extent of contamination.
Surface and sub-surface soil sampling has been performed at over 300 separate locations on and near the Yankee site, and individual in situ gamma spectroscopy measurements have been performed at over 140 locations. Each in situ measurement detects radioactivity in an area with O an approximately 15 foot radius. As part ofinitial scoping surveys, the surface samples and in situ measurements were systematically distributed over the site based on a grid system.
Subsequent samples were targeted at areas having known or potential contamination based on the initial scoping surveys and a knowledge of site history. Many other areas, such as low lyir,g drainage areas, were sampled based on their potential to accumulate contamination from other areas.
It is important to realize that the objective of the site characterization activities to date has only been to classify areas of the site according to their potential for contamination. No part of the site will be released based solely on data from site characterization surveys. Instead, more extensive final status surveys will be performed in the systematic manner described in the License '
Termination Plan to demonstrate that the site release criteria have been met. The types of ,
surveys, frequency of measurements, and statistical interpretation of data from the final status smveys will be in accordance with NRC guidance and will demonstrate that the site release criteria have been met to a very high degree of confidence. In all, it is estimated that over 250,000 individual measurements will be taken as part of the final status surveys. These surveys will extend at least 20 meters (64 feet) beyond the Owner Controlled Fence or any area of the site designated as "Affected."
Consideration has been given to the possibility of plant-related radioactivity at isolated and distant points from the plant. Yankee has evaluated this issue and determined there is no reasonable O l a.
q potential for significant plant-related radioactivity to exist outside of the Owner Controlled Fence.
V This determination is based on site characterization data and a review of the site history. Since the submittal of the License Termination Plan in May 1997, additional soil samples have been collected beyond the Owner Controlled Fence as part of ongoing site characterization activities.
The locations of these samples were based on a meteorological evaluation and were selected to detect radionuclides potentially deposited from stack emissions. These samples contained no '
plant-related radioactivity. In addition to the soil sampling data, aerial photos, interviews with longtime employees, and historical plant documents were used to determine which areas of the site were disturbed by past activities. All areas of the site disturbed by past plant activities areas have been or are under investigation for the presence of plant-related radionuclides.
In addition to the soil sampling performed in direct support of decommissioning, much environmental data exists from Radiological Environmental Monitoring Program (REMP), which has been in operation since 1958 (approximately two years before the plant began commercial j operation). Recently, this has included the annual collection of over 1,000 samples, including i ground water, river water, storm drain water, sediment, fish, locally grown food products, mixed vegetation, maple syrup, and milk. In addition to these samples, the air surrounding the plant is sampled continuously and direct radiation levels are measured continuously. Data from the REMP is compiled annually and submitted to the NRC. Yankee has also provided the reports to the Massachusetts Department ofPublic Health. In all cases, the possible radiologicalimpacts associated with emissions from the Yankee site have been negligible with respect to the exposure already received from natural background radiation.
l D
(V The site release criteria contained in the License Termination Plan have limits for both average and maximum levels ofresidual radioactivity. This approach is consistent with NRC guidance and recognizes that residual radioactivity is often distributed non-uriformly. The average level of residual radioactivity in a given area is actually an area weighted average, so that the larger an area of elevated residual radioactivity is, the lower the maximum level of radioactivity is permitted to be. This approach ensures that there is no additional exposure or health risk associated with non-uniformly distnbuted residual radioactivity in which small areas exceed the average limit.
Technical Question No. 3: The sampling and testing according to the Termination Plan is self-monitored Similarly, laboratory testing is required to be conducted by the YAEC laboratory without specific provisionfor independent sampling, quality control or verification ofthe results. What, if any, independent verification isprovidedfor the sampling, monitoring and testingprogram?
There are several provisions for independent verification of the radiological surveys and sampling conducted at the Yankee site. For example, final status survey procedures require regular analyses of soil, water, and sediment samples by an independent third party. Yankee's primary laboratory, the Duke Engineering and Services Environmental Laboratory (formerly the Yankee Atomic Environmental Laboratory) also participates in programs with the U.S. Environmental Protection Agency, the Department of Energy, and the National Institute of Standards and 14
Technology to cross check the consistency and accuracy of radiological analyses performed at O iaborateries acress the coe#1rr. rineiiv. the sac wiii verrerm its ewn independent veriricetien ef Yankee's fmal status surveys. This will be accomplished by replicate surveys performed by the NRC or its contractor, inspections of Yankee's survey practices, and audits of Yankee's survey procedures and data. The NRC must accept Yankee's survey results prior to release of the site.
Technical Question No. 4: Other contaminants exist on the site which are regulated by the Massachusetts Department ofEnvironmental Protection rather than the NRC Please disclose and discuss any incidents or situations such as spills or clean-ups which may involve hazardous materials such as asbestos, PCBs, lead, and similu.~ materials. How are these materials being handledin the decommissioning work? W7 tat will be the status ofthe site following decommissioning with regard to hazardous materials regulatedpursuant to M.G.L Ch.21E? !
I While non-radiological matters are not within the scope of the NRC'sjurisdiction or the 1.icense Termination Plan, as part of the decontamination and dismantlement activities at the Yankee site, soil, sediment, and groundwater monitoring is being conducted to determine whether non-radiological cor.taminants are present as a result of power operations. Parameters being evaluated are based on historic use and storage in and around the various structures and components of the site. As a basis for investigation, the Massachusetts Contingency Plan (310 CMR 40.0000) as promulgated by the Department of Environmental Protection under M.G.L. Ch. 21E, provides the framework for hazardous materialidentification and remediation standards.
Yankee historically utilized materials similar to other power generation facilities in the operation and maintenance of the facility. This includes fuel oil for the Auxiliary Boilers, lubricating oils, degreasers, water treatment chemicals such as caustics, acids and hydrazine, and laboratory chemicals. In addition, other materials were used in the construction and operation of the facility.
]
These included asbestos in insulation materials, mercury in instrumentation, lead for shielding, lead acid batteries, lead paint, and dielectric fluids in transformers containing mineral oils and in a few cases PCBs. Some painted surfaces also contain a PCB component as a plasticizer (commonly used in paint prior to 1979).
I As part of decommissioning, an assessment of the use, storage and disposition of these and other i hazardous materials was initiated to identify and remediate hazardous and toxic material as required by the Department of Environmental Protection and the U.S. Environmental Protection Agency.
To ensure control ofwaste materials generated from decontamination and dismantlement activities, Yankee has established two programs to prevent discharges of pollutants to the environment. First, a Spill Prevention Control and Countermeasures (SPCC) plan has been established in accordance with federal regulations (40 CFR 112) to control and manage potential discharges of oil. Second, specific EPA guidance was utilized to develop a storm water pollution prevention plan (Storm Water Pollution Prevention for Industrial Activities, Developing Pollution A
15
n Prevention Plans and Best Management Practices, U.S. EPA, September 1992). This program V identifies the sources of potential pollution that may be reasonably expected to afTect the quality
)
of storm water discharge associated with Yankee decommissioning activities. The plan also ensures implementation of measures and controls to prevent and mitigate contact between storm water and sources of pollution. These include oils, fuels, industrial chemicals, and eroded soils.
Historically, four spills of oil to the environment have occurred at the Yankee site. The first, in 1980, involved the release ofless than a quart of oil from the Screenwell House to Sherman Pond.
The oil was immediately cleaned up with the deployment of an oil boom and hay. A second spill to a paved area occurred in April 1981 when approximately fifteen gallons of oil was accidentally spilled. Oil was contained through the construction of a sand dike and was immediately cleaned up. No oil reached the storm drainage system. The third spill occurred in May 1981.
Approximately 100 gallons of fuel oil was inadvenently discharged to the ground, the storm drainage system, ar.d the Deerfield River. Oil was recovered to the extent possible. EPA and the Commonwealth cfMassachusetts were notified upon identification of the spill. The fourth spill occurred in April 1988 when an estimated 100 gallons of diesel fuel leaked from a storage tar &
The released fuel discharged to a drainage swale and entered the Deerfield river. Oil booms were deployed and contaminated soil removed. The EPA, National Response Center, and Commonwealth ofMassachusetts were notified of this event.
With the exception of a few smaller units, all station transformers, voltage regulators, and oil circuit breakers used in the transmission of generated power have been decommissioned, drained
/ and transponed offsite to an approved disposal facility. All underground storage tanks that C] contained fuel oil, gasoline, or waste oil have been removed. No releases to the environment have been identified. A number of the above ground oil storage tanks have been removed and plans are in process for the dismantlement of the remaining above ground tanks when no longer needed, including the onsite 30,000 gallon fuel oil storage tank. No releases have been identified from these units.
Prior to 1979, paints requiring thermal expansion properties commonly contained a PCB component as a plasticizer. An extensive review of soils, sediment and groundwater around the site was conducted to determine whether PCB-containing paint had entered the environment.
Sampling identified a small area of soil and sediment under the Vapor Container (reactor containment sphere) that contained low levels of PCD-containing paint chips that had flaked off the stmeture. The area of PCB-contaminated soil was remediated under the guidance of a Licensed Site Professional through a Limited Removal Action as specified within the Massachusetts Contingency Plan in 310 CMR 40.0318. Additional soil monitoring has documented that no further PCB-containing paint exists in the remediated area. Yankee continues to investigate for the presence of PCB-containing paint in the environment. Yankee will remediate all painted surfaces containing PCBs in accordance with an EPA-issued permit.
Asbestos was utilized during the construction of the Yankee plant as an insulating material on piping and plant equipment. As part of the dismantlement vocess, asbestos was removed from O 16
I plant equipment in advance ordismantlement operations in accordance with State and Fedcral
() regulations. The majority of asbestos has now been removed from plant systems and no incidents of release have occurred. All abated material has been transported to a regulatory-approved landfill for disposal.
Lead has been utilized on site as a radiological shielding material throughout the life of the plant.
A limited portion has been disposed of as waste at a regulatory-approved facility, however, most has been recycled either as shielding at other nuclear facilities or has been sent for reclamation.
Remaining shielding material will be disposed ofin a similar manner. In addition, two areas of the site were utilized as shooting ranges in support of the on site security force. The soil in these areas was tested for the presence oflead from discharged bullets. Following a determination that lead levels exceeded Massachusetts Contingency Plan levels, the areas were remediated under the direction of a Licensed Site Professional. Contaminated soil was transported to an approved facility for disposal.
As stated, the Yankee site is being evaluated in accordance with the Massachusetts Contingency I Plan. In addition, a site characterization team meets routinely to review data and make recommendations on investigation activities during decontamination and dismantlement. With regards to hazardous materials regulated pursuant to M.G.L. Ch. 21E, based on the historic management of materials and current investigations of soil, sediment, and groundwater, Yankee will continue to remediate hazardous and toxic materials in a manner that will ensure that EPA and DEP regulatory limits are met. l (J' Technical Question No. 5: The Radiology Department of the Afassachusetts Department of Public Health is responsiblefor monitoring radioactive exposure levels and related activity.
Please describe the role they haveplayed in the decommissioning activity to thispoint, and what their continued role will be as radioactive materials are removed and thefacility is i decomndssioned To date, the Massachusetts Department of Public Health (MDPH) has monitored the offsite environment to assure that there is no impact on the health and safety of the public. Their activities have been focused in the following areas:
- 1. Monitoring radioactive waste shioments - Details of radioactive waste shipments have been transmitted to the MDPH prior to the shipment. The information transmitted included the contents of the shipment and the radiation levels associated with the packages. Representatives from the MDPH were also present during large shipments such as the steam generators and the reactor vessel.
- 2. Sampling environmental media - Samples of environmental media around the site have been collected by the MDPH and analyzed in the State Laboratory. The MDPH also participates with the NRC in a direct radiation measurement program around the Rowe site.
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- 3. - Sampling licensed releases to Sherman Pond - The MDPH has performed O i aege ae t irses er- ter s moies eeiieetea t tae aisen <8e vei t te sher- -
Pond during licensed releases of water.
In addition to the above, all reports of radioactive effluents, environmental monitoring, and decommissioning activities that are submitted to the NRC have also provided to the MDPH. The MDPH has also received a copy of our License Termination Plan.
Technical Question No. 6: We understand that YAECis considering leaving tritium contamination in the sediments of the Deerfield River and Sherman Pond reservoir. Please presentyour analysis of the advantages and disadvantages ofremoving contaminated sediments versus leaving them in place in terms ofradiation exposure to the environment.
How willsevere storm events andflooding impact the sediments and radiation exposure to the environment? Pleaselist the half-life oftritium andspecify when it can be reasonably assumed that the amount of tritium willfall below detectable levels? What other contaminants, such as PCBs and other radionuclides, occur in these sediments?
Tritium is an isotope of hydrogen (halflife of 12.3 years) that typically is found in the environment as part of the makeup of a water molecule. Throughout its operational life, the Yankee plant routinely released small quantities of tritium as part ofits licensed discharges of water. Tritium was also released to the environment by a leak from the plant's ion exchange pit in the 1960's. Environmental monitoring of Sherman Pond, the Deerfield River, and groundwater during operations have confirmed the presence of tritium, but at concentrations well below the O EPA's maideline for drinking water. Tritium is still found in groundwater, however, concentrations have been steadily decreasing since well before the permanent shutdown of the plant in 1992. Because tritium moves through the environment as part of a water molecule, it does not tend to attach itself to sediments. Since the permanent shutdown of the plant,_nu detectable tritium in either Sherman Pond or the Deerfield River has been measmed by the Radiological Environmental Monitoring Program.
Other plant-related radionuclides that have been detected in river sediments (mainly Sherman Pond bottom sediments) are Cesium-137 and Cobalt-60 (halflives of 5.3 years and 30.2 years, respectively). The presence ofCo-60 is primarily the result oflicensed plant discharges, and has been documented in the plant's Radiological Environmental Monitoring Program reports that are submitted annually to the NRC. In addition to licensed plant discharges, a significant portion of the Cesium-137 detected is also the result of fallout from past nuclear weapons tests. The concentrations of all plant-radionuclides in sediments are below levels established for the unrestricted release of the site. There is no advantage in removing these sediments because their radiological consequences are insignificant. Unlike tritium, both Cobalt-60 and Cesium-137 exist primarily as particulates or ionic species that are strongly held in sediments and, therefore, tend not to be reintroduced into the surface waters once deposited. Samples of fish in the Deerfield River have also shown no significant uptake of plant-related radionuclides from sediments.
Overall, the exposure pathways from these radionuclides in sediment are extremely limited.
O Is
n Nevertheless, sediment containing plant-related radionuclides will be included in calculating the V dose from all residual plant radioactivity. As described in the response to Technical Question No.
1, the dose from all residual plant-related radioactivity will be less than 15 mrem /yr in addition to the exposure from background radiation.
Migration of sediments due to high river flows caused by storm events is greatly limited by the presence of the dams on the river. Although the primary purpose of these dams is power generation, they also provide significant flood control, reducing erosion from Sherman Pond under all river flow conditions. This is confirmed by the absence of significant down river deposits ofplant related radionuclides over the 3 decades of Yankee plant operations that include many periods ofhigh river flow.
Current site characterization studies include the search for possible other non-radiological contaminants that might be present in river sediments due to plant operations. Their disposition will be handled in accordance with all federal and state regulations.
Technical Question No. 7: What short and long terrn water quality snonitoring will be conductedfor groundwater, the Deerfield River, and Sherman Pond? The terrnination plan reports that groundwater levels are relatively close to the surface beneath rnost oftheplant buildings because ofan impertneable layer ofsoil. Why were observation wellsplaced belme known groundwater levels at a depth 6.1 to 9.1 rn rather than reportedgroundwater levels of
.9 to 6.1 rneters which is the area where contarninationfrom the buildings would snost likely be detected? Are thereplans to installshallow rnonitoring wells?
O)
L The evaluation of groundwater, Sherman Pond, and the Deerfield River has been part of Yankee environmental monitoring programs since 1958. A more extensive groundwater monitoring program began in 1994 as part of site characterization for decommissioning. A total of 20 groundwater monitoring wells on site are currently sampled on a quarterly basis. Water samples are tested for the presence of radionuclides and compared to the EPA National Primary Drinking Water Standards (40 CFR Part 141). The amount ofradioactivity in the water samples has been well within the EPA standards, and this will lead to a reduction of testing frequency in 1998.
Long-term monitoring ofgroundwater after completion of the final status survey will not be necessary because all significant sources of plant-related radioactivity will have been removed from the site. Furthermore, what radioactivity exists in groundwater will be included in calculating the dose from the low levels of all residual plant radioactivity. Again, as described in the response to Technical Question No.1, the dose from all residual plant-related radioactivity will be less than 15 mrem /yr in addition to the exposure from background radiation.
~
As described in section 2.4.5 of the License Termination Plan, ground water levels in observation wells across the site range from depths of 0.9 m (3 ft) to 6.1 m (20 fl). Yankee has followed standard practices in constmeting monitoring wells approximately 10 feet deeper than the top of the groundwater. These monitoring wells are designed to draw from the top of the groundwater
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as well as from the bottom of the well. This may involve drawing water from more than one soil O layer and includes the collection of shallow groundwater.
Monitoring ofwater from the Deerfield River and Sherman Pond is done through the Radiological Environmental Monitoring Program. Reports containing the data from this program are submitted annually to the NRC, and, as with groundwater, all samples have consistently been within the EPA National Primary Drinking Water Standards for radioactivity.
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4 Telephons(508) 568-2233 YANKEEATOMICELECTRIC COMPANY 22YL ' @ '-
U, , 7L"g? N S80 Main Street, Bolton, Massachusetts 01740-1398
,Yaux,me DON K. DAVIS December 18,1997 csics EtTofriv*tTrricca Mr. Adam Laipson, Chair Franklin Regional Planning Board 425 Main Street Greenfield, MA 01301
Dear Mr. Laipson,
Thank you for your recent letter of December 4,1997 regarding the License Termination Plan (LTP) for the Yankee Nuclear Power Station. Yankee is developing responses to the Planning Board's questions and anticipates a written response to the Planning Board and Council of Governments by the end of December 1997. We believe that many of the questions simply require clarification of what is described in the LTP while some issues raised may benefit from face-to-face discussions.
j p Yankee Atomic Electric Company appreciates the opportunity to discuss the decommissioning of the Yankee Nuclear Power Station with opinion leaders in Franklin and Berkshire counties, including the Franklin Regional Planning Board and the Council of Governments. Many i members of both the Planning Board and Council have accepted invitations by Yankee to tour the Yankee site and observe for themselves the process that Yankee is implementing to retum the site to a green field condition. We encourage those on the Planning Board and Council who have been unable to observe decommissioning first hand to tour the site prior to the NRC public meeting so that they too can observe how Yankee is implementing decommissioning in accordance with NRC, EPA, OSHA, and State requirements. Stanley Gawle or Mandy Comai ;
can be contacted at the Yankee Visitors Center (413-424-2394 or 413-424-5498, respectively) to !
make the necessary arrangements. l In Questions 1 and 2 of your letter, you expressed a concern regarding the impact of the sale of the Yankee Nuclear Services Division (YNSD) on the decommissioning process at the Yankee !
site. I want to reassure you that the sale of YNSD to Duke Engineering & Services (DE&S) will have no detrimental impacts on the decommissioning of the Yankee site. First, the sale of YNSD .
does not impact the ownership structure of Yankee Atomic Electric Company; the funding of the ;
decommissioning trust fund as required by NRC and as approved by FERC; or Yankee Atomic Electric Company's ongoing responsibility as licensee for the Yankee site. I have attached a letter that Yankee recently sent to the NRC in which we informed NRC of the sale and confirmed Yankee's ongoing licensee responsibility.
p
d g Mr. Adam Laipson, Chair Q December 18,1997 Page 2 l
As part of the DE&S acquisition, Yankee awarded DE&S a contract to assist Yankee in completing the decommissioning of the Yankee site. This award will enhance Yankee's ability to accomplish decommissioning safely and effectively. DE&S is recognized as a premiere engineering services company in both the nuclear and energy industry. Yankee will now have access to both former YNSD employees who have contributed to Yankee's decommissioning success to date, and to an additional pool of highly skilled ana knowledgeable engineering resources within the DE&S organization.
I would also note that the management team at the Yankee site remains the same as that prior to the YNSD sale. For example, Ken Heider, who is now employed by Duke Engineering &
Services, continues as the Site Manager. In that capacity, Ken will continue to be responsible for the day-to-day management of decommissioning at the Yankee site. Also, Rick Williams, Plant Superintendent, will remain a Yankee Atomic Electric Company employee. In that capacity, Rick will continue to manage the safe operation of the spent fuel pool. Approximately 30 other individuals at the plant will remain employces of Yankee. We anticipate no significant changes in the personnel who have successfully brought the decommissioning of the plant to its current !
status. Yankee Atomic Electric Company will continue with our historical commitment to strong l safety standards and open communication. Our contract award to DE&S will only enhance that Cq commitment as DEAS also regards strong safety standards and communications as critical to success.
As you are aware, NRC's schedule for a public meeting is the evening of January 13,1998. As noted in your letter, NRC's schedule may not afford parties such as the Planning Board and l Council sufficient time to ask questions and discuss issues of concern. Given the circumstances, I suggest that it may be beneficial if Yankee and as many members as possible of the Planning Board and Council meet during the week of January 5,1998. A meeting prior to the NRC public meeting would ensure that the Planning Board and Council members have sufficient opportunity to discuss questions and concerns in preparation for the NRC meeting. Also, there may be facets of decommissioning that because they are long term in nature and are not affected by approval of the LTP (e.g., long term storage of spent fuel) are more amenable to a meeting subsequent to the NRC meeting. We are prepared to suppon a meeting prior to and/or after the NRC public meeting. We would also open such meetings to other opinion leaders in the vicinity of the Yankee site who might not be represented on the Franklin Regional Planning Board or Council of Governments.
In your letter, the Planning Board also solicits Yankee's support for funding of an independent review of the LTP. I would like to comment that even though the Planning Board suggests the need for an independent review of the LTP, the number and type of questions suggest that the Planning Board has done a very capablejob of reviewing both the broader and technical aspects lh of the LTP. As you are aware, the NRC is available to address questions and/or concerns that
Mr. Adam Laipson, Chair
( ) December 18,1997 Page 3 you may have. In addition, the Commonwealth of Massachusetts Department of Public Health and Department of Environmental Protection have technically qualified personnel. Both Departments have provided oversight of decommissioning activities at the Yankee site. It is our understanding that personnel from these Departments are available for independent advice to you and others. I hope that the Planning Board and Council will avail themselves of these resources.
Should there be any remaining areas of concern following interactions with NRC and/or Commonwealth officials, Yankee is willing to discuss support for an independent recognized expert in the field of health physics and/or health studies to help resolve those remaining concerns.
J 1
I look forward to meeting you and discussing Yankee's decommissioning activities. Ms. Jane j Grant, Decommissioning Manager, will contact you in the near future to discuss meeting dates. '
Sincerely, j o, a n {. <
Don K. Davis President and CEO Yankee Atomic Electric Company c: Brad Councilman, Council of Governments Morton Fairtile, NRC
E ATOMIC ELECTRIC COMPANY "'fAllll.g*]o%f,*g"'
r j}@m,- 580 Main Street, Bolton, Massachusetts 01740-1398
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- BYR 97-060 i December 5,1997
- )
United States Nuclear Regulatory Commission )
Document Control Desk l Washington, D.C. 20555 Attention: Mr. Morton B. Fairtile Senior Project Manager Non-Power Reactors and Decommissioning Directorate l Division of Operating Reactor Support
Reference:
(a) License No. DPR 3 (Docket No. 50-29) l (b) Yankee Nuclear Power Station FSAR, Section 502
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l (c) Yankee Nuclear Power Station FS AR, Section 501 I (d) Letter, H.T. Tracy (YAEC) to Document Control Desk (NRC).
Decommissioning Funding Assurance Report and Certification, 7/25/90, BYR 90-102 (e) FERC Docket No. ER 95-835-000 (April 10,.1996)
Subject:
SALE OF YANKEE NUCLEAR SERVICES DIVISION ASSETS
Dear Mr. Fairtile:
On December 1,1997 the assets of Yankee Atomic Electric Company's (YAEC) Yankee Nuclear Services Division (YNSD) were acquired by Duke Engineering and Services (DE&S).
The subject transaction between YAEG and DE&S will not affect the continued existence of Y AEC nor YAEC's ownership of the Yankee Nuclear Power Station (YNPS). YAEC will continue as the licensee for YNPS and will ensure continued compliance with all conditions of its lic.ense and the. applicable provisions of Title 10 of the Code of Federal Regulations. Consistent with the information provided in the YNPS Final Safety Analysis Report (Reference ib)),
o u m u n nm u rn i
United States Nuclear Regulatory Commission December 5,1997 Document Control Desk Page 2 p)
Don Davis will continue as the Chief Executive Officer and President of YAEC, the YAEC corporate officer responsible for YNPS nuclear safety. Mr. Davis remains empowered by the YAEC Board of Directors to take any measures necessary to ensure. the safe storage of spent fuel )
at YNPS and the safe and efficient decommissioning of YNPS. Mr. Davis also retains the ultimate authority to direct day-to-day activities. The on-site decommissioning organization continues to be directed by the YNPS Site Manager / Manager of Operations, who reports to the Decommissioning Manager, who in turn reports directly to the President.
DE&S has been retained by YAEC to provide certain project management, quality assurance, engineering suppon, procurement and other related technical and administrative ;
support services. All work performed by DE&S under the terms of this agreement will be l performed in accordance with the applicable YAEC programs and procedures, which will remain in effect. The overwhelming majority of the staff whch will be providing these services will be former YAEC employees who have accepted employment with DE&S. The YAEC/DE&S ,
agreement identifies key personnel by name to assure the maximum degree of continuity in the l YNPS decommissioning effort.
The new relationship between YAEC and DE&S will enhance the ability of YAEC to l
accomplish its primary mission of safely decommissioning YNPS. Experienced YAEC personnel '
who might have felt compelled to seek alternative employment opportunities as the conclusion of '
Q V
YNPS decommissioning draws nearer now have the option of " completing the job" with reasonable assurance of ongoing employment as members of the DE&S team. Also,if the need arises, YAEC will be able to take advantage of the additional resources afforded by one of the world's leading architect-engineer companies.
The YAEC Operational Quality Assurance Program (Document No. YOQAP-1-A), will remain in effect and will apply to vork that is safety-related and/or" requires QA." Effective December 1,1997, Nuclear Service Divisionresponsibilities defined in the YAEC QA Program have been delegated to DE&S. As 'the President of YAEC, Mr. Davis will retain the final management authority for assuring that the QA Program is appropriately implemented within the scope of services provided by DE&S. Organizational responsibility for the continuing review and audit of the YAEC Operational QA Program has been assigned to DE&S Quality Services.
The sale of YNSD assets to DE&S in no way impacts the financial assurance provided to NRC that all decommissioning funds as approved by the Federal Energy Regulatory Commission (FERC) will be collected. As described in the YNPS FSAR (Reference (c)), YAEC is currently collecting decommissioning funds through its Power Contracts. The collections are deposited in an independent and irrevocable trust at a commercial bank, with the principal and interest used to discharge decommissioning obligations as they are incurred. This trust was determined by NRC to be in compliance'with 10CFR50.75(eXikii) and a copy of the trust document has been provided to the NRC (Reference (d)). The Power Contracts obligate the utilities that were
, , ,mm,m ,
. .., 7 United States Nuclear Regulatory Commission December 5,1997 Docurnent Control Desk Page 3 x'J I purchasers of power generated by YNPS for the full costs of decommissioning YNPS, including the disposition of the facility's spent fuel. The FERC orders received by Yankee acknowledge the continuing obligation of the purchasers with respect to the full cost of decommissioning YNPS.
Thus, the acquisition of the assets of YNSD by DE&S will have no effect upon the technical or financial qualifications of YAEC to complete the decommissioning of YNPS. The l information provided in this letter has been reviewed by legal counsel to YAEC. If you have any questions please contact me at (978) 568-2112.
Sincerely. .
YANKEE ATOMIC ELECTRIC COMPANY J
6, 0 ,{.~ % (
Ja e M. Grant D ommissioning Manager i m l
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D ento.wa w rn
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v United States Nuclear Regulatory Commission December 5,1997 Document Control Desk Page 4 bc: D. K. Davis K. J. Heider B. W. Holmgren J. A. Kay j D. K. Kowalski J. M. Oddo J. D. Sutton J. K. Thayer N. A. Byrne/ File 1
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