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Collapse of a Pyramid Scheme

Rituals of Evasion

Table of contents:

  1. Introduction

  2. A. Historical Background
    B. Collapse of a Pyramid Scheme
  3. Public Safety Issues

  4. A. Radioactive Waste Inventories
    B. Safety Issues and Recent Events
    C. Whistleblower's Letter
    D. A Summary of Safety Concerns
    E. Public Safety Bibliography
  5. Economic Issues

  6. A. Introduction
    B. Decommissioning Waste Inventories
    C. Decommissioning Scenarios
    D. Economic Issues Bibliography
  7. Legal Issues

  8. A. Introduction
    B. Legal Issues Bibliography
    C. Brief to the US Attorney for Maine Jay McCloskey
    D. Request for an Investigation by the FBI
    E. A Letter of Inquiry to Shirley Jackson
    F. Summary Notice for a Petition for Indictment
  9. Decommissioning Debacle

  10. A. Introduction
    B. Decommissioning Chronicle: August 1997 - September 1998
    C. Patterns of Noncompliancethe newest CBM report
    D. Unresolved Issues
    E. Decommissioning Chronicle Continued: January - December 1999
    F. Decommissioning Chronicle Continued: January 2000 to May 8, 2000
    G. Decommissioning Nightmare <= the latest developments
    H. Decommissioning Debacle Bibliography
Note that NRC generated reports published after mid-1998 that do not relate directly to MYAPC will be cited and annotated in RAD11: Anthropogenic Radioactivity:  Major Plume Source Points:  Part 4 U.S. Nuclear Power Plants.


The Maine Yankee Atomic Power Company (MYAPC) is a pressurized water nuclear electricity generating facility located in Wiscasset, Maine. It was issued a Nuclear Regulatory Commission (NRC) operating license on September 15, 1972 for a power level of 2,440 Mwt (megawatts). The Maine Yankee Atomic Power Company first came to the attention of the Center for Biological Monitoring, the sponsor of RADNET, in the early 1970's, as Maine's principal potential source point of biologically significant radionuclides. (See RADNET, Section 16 for more information about the Center for Biological Monitoring). The MYAPC facility was previously the subject of two Center for Biological Monitoring publications: A Review of Radiological Surveillance Reports of Waste Effluents in Marine Pathways at the Maine Yankee Atomic Power Company at Wiscasset, Maine -- 1970-1984: An Annotated Bibliography, (Brack, 1986) and Legacy for Our Children: The Unfunded Costs of Decommissioning the Maine Yankee Atomic Power Station: Maine Yankee as the Model for the Dilemmas of Dismantling any Nuclear Power Facility. (Brack, 1993). MYAPC is currently RADNET's model for analysis and evaluation of the variety of problems associated with an operational nuclear power plant. The issues pertaining to MYAPC as a bioregional source point of anthropogenic radioactivity, as well as a paradigm of the twilight of the nuclear area, fall into 3 general categories: safety, economic and legal issues. Each of these is discussed in more detail in the following sections of RAD 12. Citations, some of which are annotated, of the most relevant publications follow each sub-topic in this section of RADNET. The bibliographic citations following the discussion of the safety issues are preceded by the copy of the whistleblower's letter and a link to CBM's December 1995 report "A Summary of Safety Concerns, Steam Generator Sleeving Project, 1995." The discussion of the legal issues pertaining to the Maine Yankee Nuclear Power Company is followed by links to a selection of CBM reports, briefs and correspondence related to these controversies.

Safety issues pertaining to the operation of Maine Yankee Nuclear Power Company (MYAPC) are grounded in a widespread concern about the subtle deleterious health impact of low-level (liquid and gaseous) radioactive emissions resulting from routine plant operations. Safety concerns and controversies have rapidly escalated with the discovery and subsequent repair of circumferential cracking in steam generator tubes. Concerns were further heightened by the revelations in an anonymous letter (referred to as the whistleblower's letter and reprinted at the end of this sub-section of RAD 12) documenting fraudulent emergency core cooling system (ECCS) and containment analyses which resulted in an illegal but lucrative power up-rate. Follow-up NRC inspections, as well as subsequent equipment failures have revealed a whole new set of safety questions which are summarized in a review of events in 1996 and early 1997 at MYAPC in the Public Safety Issues Section of this report. Confidence in the reliability and accountability of the NRC has been further shaken by the disclosure that Peter Atherton, a former nuclear engineer working for the NRC until fired in 1978, had raised many of the current cable related safety issues almost two decades ago.

The discussion of economic issues focuses on the generation of high-level wastes and its relationship to the cost of electricity produced at MYAPC. This is followed by a brief summary of the decommissioning issues previously addressed in "Legacy for Our Children." The economic basis for the decline of the era of nuclear power, including the impact of deregulation and the high costs of updating plant safety systems, is briefly addressed.

The last component of the discussion of MYAPC in the twilight of the nuclear era pertains to the legal issues arising from the plant operations. A brief summary of the long-standing legal issues involving waste disposal and decommissioning costs at MYAPC are followed by a glimpse into the Pandora's box of allegations and illegal activities uncovered by the whistleblower's letter. A selection of CBM reports and correspondence follows the annotations at the end of the last sub-section of this part of RADNET.


Recent events provide graphic evidence that the twilight of the nuclear era in Maine has arrived just a few years after the end of the Cold War. The arms race provided the fundamental impetus needed to sustain what is now an antiquated technology. With the end of the Cold War, the nuclear energy industry, its unfortunate footnote, is in inevitable and irreversible decline. This decline was first signaled by nuclear accidents at Three Mile Island and Chernobyl.

The whistleblower's letter issued Dec. 1, 1995 and the cascade of events that followed in 1996 represented the opening of a Pandora's box of MYAPC-related issues which also symbolize the predicament of the nuclear industry as a whole. The unraveling of the lies and deceptions pertaining to the safety, the economics, and the NRC licensing requirements of this enterprise provide a lesson about the unreliability and untrustworthiness of both federal and state representations about this facility. The folly of generating nuclear electricity by creating nuclear wastes, nuclear dangers, nuclear debt, nuclear bureaucracy and nuclear proliferation can no longer be evaded; the unsafe conditions of an aging and uneconomical facility speak for themselves.

Many have long worshipped at the shrine of nuclear electricity at 2.7 cents per kW/hr. The systemic evasion of waste storage and disposal costs which this mythical cost symbolizes have been highlighted by an entirely new cluster of criminal activities: the fraudulent Emergency Core Cooling System (ECCS) and containment analyses by the licensee (Maine Yankee Atomic Power Company (MYAPC)) and its principal co-conspirator the Yankee Atomic Electric Company (YAEC). (See: NRC Confirmatory order suspending authority for and limiting power operation and containment pressure, 1/3/96; NRC Office of Inspector General Event Inquiry, 5/8/96; CBM, Brief to the U.S. Attorney, 12/95.) The illegal power up-rate which followed the implementation of the inadequate computer codes not only endangered public safety in Maine, but completed the cycle of evasions which began with the avoidance of waste disposal and decommissioning funding. That the latter evasion of funding was based on a failure of federal oversight may have provided grounds for the illusion that no one would notice the implementation of the fraudulent computer codes. The many safety issues and design flaws which NRC investigators inadvertently discovered as a result of the review which followed the whistleblower's letter are the symptoms of the obsolescence of an aging and antiquated reactor (see NRC ISA team report, Oct. 1996). The primary characteristic of this decline is denial: a denial of danger, a denial of the existence of economical alternatives to nuclear electricity, a denial of long term waste disposal and decommissioning costs, a denial of aging and microdegradation-related safety issues, and, most especially, a denial that criminal activities are implicit in the power up-rate scandal. The reports and publications reviewed in this annotated bibliography graphically illustrate these denial mechanisms. The startling willingness of the State of Maine, including the governor, attorney general, legislature, public advocate, and state nuclear safety advisor, to participate in these evasions exemplifies the strength and the duration of the iron grip of the nuclear energy pyramid scheme in Maine.

A second component of the nuclear energy pyramid scheme is that manifested in the investigation of wrongdoing and violations of NRC regulations by the NRC itself. Following two reports finding the licensee culpable for the fraudulent manipulation of data essential to the safe operation of the plant, the NRC presented its findings to the Department of Justice, indicating grounds for criminal prosecution of MYAPC and YAEC for violation of federal law. No component of federal government, however, is a more complaisant participant in the evasions and deception of the generation of nuclear electricity or more representative of a culture of complacency than the FBI and the Department of Justice (DOJ) as manifested in the Office of the US Attorney for Maine. Now that the NRC has made a presentation to the DOJ providing evidence of criminal activities at MYAPC and YAEC, it is extremely unlikely that successful prosecution of the licensee will follow. The Department of Justice does not have the resources and experience with nuclear technology necessary to successfully formulate such a prosecution. The FBI and the DOJ also have a long-standing conflict of interest about the vigorous investigation and prosecution of activities which have been sponsored by the government they represent. The FBI has, prior to the presentation of the NRC's third report to the DOJ, Office of US Attorney for Maine, asserted in a letter to the Editor of RADNET that there were no grounds for prosecuting the MYAPC and the NRC for evasions of waste disposal or decommissioning funding or for violations of federal law implicit in implementation of the fraudulent computer codes. (See Brief to the US Attorney in Part 4-C of this Section). The NRC's presentation of evidence of wrongdoing by MYAPC and YAEC to the Department of Justice puts the federal government in the unenviable position of having an obligation to prosecute a pyramid scheme and its related illegal activities that the government itself has sponsored, nurtured, encouraged and directed. The resulting +/- 100 million dollar windfall obtained by the licensee and its sponsors in the power up-rate scam is the largest and most lucrative criminal activity ever to have occurred in Maine. It is also the subject of an intense ritual of evasion, as any and all federal and state officials, politicians and other pyramid scheme beneficiaries exhibit a pathology of denial that such activities occurred or that they are in any way illegal. Since few in the media wish to discuss the criminal implications of MYAPC's fraudulent power up-rate, but many will willingly report the safety implications of these misrepresentations, will the criminal component of these activities evaporate as quickly as the tritium releases from routine plant operations?

The twilight of the nuclear era in Maine is best summarized as two complementary rituals: a ritual of propitiation and a ritual of aversion. The ritual of propitiation is manifested in the blind quest for profits which accrue to the few at a cost to many. The ritual of aversion is the frenetic denial of the predacious social and economic effects of an industry which generates 1 curie of high-level waste for every twenty dollars in sales.

The MYAPC will undoubtedly reopen for a period of time in late 1997. The MYAPC cannot afford to close - the nuclear energy pyramid scheme must continue in order to avoid the unmasking of the economic impact of a defacto high-level radioactive waste repository in Maine. Resumption of reactor criticality at this aging facility, an act of desperate recklessness, will be the result of the frantic race to postpone and to evade the huge costs of closing and decommissioning the Maine Yankee Atomic Power Company.

The driving force of the nuclear industry is now no longer the profits to be generated from the production of radioactive wastes, but the costs to be avoided by maintaining production of these wastes. In an era of energy deregulation, privatization, dwindling public resources and increased competition, how long can the nuclear energy pyramid scheme be maintained?

This is the era of a pledge of allegiance to a new flag, that of the Snake and the Dollar Sign, embraced by "independent" politicians whose totem is money. The twilight of the nuclear era is characterized by a manic ritual of propitiation: of, by, and for profit. The accompanying rituals of evasion have one objective, avoidance of both the loss of these profits and the costs implicit in a permanent shutdown. No topic is more avoided than the discussion of who pays for the storage and disposal of huge inventories of radioactive wastes which are now the entitlement of whoever loses the current game of nuclear waste musical chairs. In this Darwinian nuclear debacle, the one likely occupant of the last chair are those few powerful owners of the MYAPC who continue to have guaranteed profits and who can pass on the costs of the liabilities of the MYAPC to the citizens of Maine. It is the ratepayers and the taxpayers of the State of Maine who must bear the burden of the radioactive waste "entitlements" (including obligations incurred by out of state MYAPC customers) along with the safety risks of this aging reactor and the social impact of a defacto radioactive waste storage facility.

Up until recently, the majority of voters in Maine have expressed enthusiastic advocacy for the MYAPC nuclear energy pyramid scheme, as expressed in three referendums supporting this enterprise. The whistleblower's letter opened a Pandora's box of safety and legal issues; not only does the MYAPC pyramid scheme involve blatant criminal misrepresentations of the adequacy of computer codes essential to safe plant operations, the ensuing NRC investigations have dropped an inexorable bombshell on Maine media, politicians and ratepayers. The MYAPC operation is an unsafe pyramid scheme; no amount of money spent on upgrading the aging reactor or on public relations blitzkriegs will be sufficient to counteract the microdegradation mechanisms in the MYAPC plant labyrinth. The most significant detail in the collapse of the MYAPC pyramid scheme is the uncovering of numerous safety defects pertaining to the allegedly "safe" plant operations of the past. Even more startling is the revelation that the intensive NRC inspections triggered by the Whistleblower's letter involved only 4 of the 42 safety systems. Closer scrutiny ("escalated enforcement") of the remaining 38 safety systems will uncover additional design defects and safety issues, the rectification of which will continue the cascade of expensive repairs, upgrades, and equipment replacement. The NRC has a clear conflict of interest in executing additional safety analyses at the MYAPC since such escalated scrutiny could permanently postpone reactor restart. The Maine Yankee Atomic Power Company pyramid scheme is not only unsafe, it is now uneconomical even without payment of the waste disposal and decommissioning costs. The collective impact of MYAPC as a safety, economic and legal debacle is a subject stubbornly evaded by the citizens, the media (including MPBN) and the politicians of Maine.

The compilation, citation and annotation of reports in this publication constitutes one small step in the documentation of this painful process. Only a few of many relevant NRC inspection reports and other documents are reviewed in this brief summary of the literature pertaining to the unraveling of the nuclear energy pyramid scheme. In this era of rapid technological change, there are many other messengers. The obsolete edifice upon which nuclear electricity is built is now under siege. This is a lose - lose situation; there will be no victors in the twilight of the nuclear era. Maine citizens will feel the impact of the activities of the Maine Yankee Atomic Power Company not for a generation or two, but for centuries.



Public safety considerations require documentation of Maine Yankee Atomic Power Company and other reactor inventories of radioactive wastes. These inventories serve not only as a forewarning of future potential safety hazards but also portend the environmental, economic, and social impact of any operational or decommissioned nuclear electricity generating station. The Maine Yankee Atomic Power Station is expected to be decommissioned beginning in the year 2008. Considering the rapidly changing situation in Wiscasset and elsewhere, 2008 may come sooner than expected. The following inventories of radioactive wastes at MYAPC may serve as a model for estimating waste inventories at other nuclear generating stations, for alerting concerned persons to the potential safety hazards of a nuclear facility, and for estimating the decommissioning costs inherent in returning the MYAPC reactor site to unrestricted use.


The total of radioactive waste inventories at the Maine Yankee Atomic Power Company at any time during reactor operations must be divided into two components: operating reactor vessel inventory and the current spent fuel pool inventory. The MYAPC reactor vessel contains 217 fuel rod assemblies, 10% of the total number of fuel rods accumulated by the time of decommissioning in 2008. The nuclide inventory of an operating reactor vessel at one hour cooling has a radically different composition than a reactor vessel after two years of cooling. Public safety considerations mandate close attention to the total nuclide inventory of an operational reactor vessel due to the dangers posed by either a quick release accident (QRA), or one form or another of a loss of reactor coolant accident (LORCA). The following is an approximate nuclide inventory of the MYAPC reactor vessel during criticality; this estimate excludes the several hundred million curies of radioactivity in the spent fuel pool.


RADNET: Source term estimates excluding spent fuel:

Fuel rod assemblies, 217 (HLW) > 20,000,000 curies
Reactor vessel components, (GTCCW)  > 6,000,000 curies
Short lived nuclides: (1/2T = > 1 yr.) > 150,000,000 curies
Reactor vessel components, (LLW): > 100,000 curies

NRC: Generalized worst case estimates:

RADNET's source term estimate for a QRA at the MYAPC reactor vessel (hot) may be compared to the NRC's estimate of the quantity of radionuclides available for a release as listed in the EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA 400-R-92-001, May 1992, reviewed in RAD 6). The EPA manual, in listing the principle radionuclides in a "worst case" accident, indicates over 150,000,000 Ci of the ten most important nuclides would be available for release in an accident scenario. The NRC estimate does not specify if the source term estimate is for the reactor vessel only, or for an entire reactor including spent fuel radioactivity. Under any conditions, hundreds of millions of curies of radioactivity are available for release in the first few hours of a quick release accident, whatever the cause. Unfavorable meteorological conditions can maximize the radiological impact of any kind of accident.

Release Quantities for Postulated Nuclear Reactor Accidents

Principle radionuclides contributing to dose from deposited materials Half-life (days)
Estimated quantity released (Curies)
SST-1* SST-2* SST-3*
Zr-95 6.52E+1 1.4E+6 4.5E+4 1.5E+2
Nb-95 3.50E+1 1.3E+6 4.2E+4 1.4E+2
Ru-103 3.95E+1 6.0E+6 2.4E+5 2.4E+2
Ru-106 3.66E+2 1.5E+6 5.8E+4 5.8E+1
Te-132 3.25 8.3E+7 3.9E+6 2.6E+3
I-131 8.05 3.9E+7 2.6E+5 1.7E+4
Cs-134 7.50E+2 8.7E+6 1.2E+5 1.3E+2
Cs-137 1.10E+4 4.4E+6 5.9E+4 6.5E+1
Ba-140 1.28E+1 1.2E+7 1.7E+5 1.7E+2
La-140 1.67 1.5E+6 5.1E+4 1.7E+2

*SST-1 etc. refer to the five types of nuclear power plant accidents described in Table E-1 of the EPA manual, of which these are the three most serious.

This manual also includes a "consideration of the appropriate range of costs for avoiding a statistical death... Estimated incremental societal costs per day per person relocated" are reprinted in the following chart. This EPA estimate of the costs of avoiding a statistical death derives from NRC-EPA "risk assessments" and provides a startling insight into how cost effective a serious nuclear accident can be once its associated costs are distributed over a large population group, at least according to the EPA. "Loss of residence: $2.96/day" is a metaphor for a larger lack of credibility for risk assessments in general and the EPA's estimates of the per diem cost of a nuclear accident in particular.

Moving $1.70
Loss of use of residence $2.96
Maintain and secure vacated property $0.74
Extra living costs $1.28
Lost business and inventories $14.10
Extra travel costs $4.48
Idle government facilities $1.29
Total $26.55


The definitive reference for verifying MYAPC's spent fuel inventory is the database of the Oak Ridge National Laboratory. This section of RADNET currently cites Oak Ridge National Laboratory's Integrated DataBase for 1994: U.S. spent fuel and radioactive waste inventories, projections and characteristics, Technical Report DOE/RW-0006, Rev. 11, pg. 264. This report is cited and annotated in RAD 11: 3. While this database is as integrated as an Arkansas restroom circa 1935, it is the single most important source of information about radioactive waste inventories in the United States. Electronic access to the Integrated DataBase (IDB) is available at URL: http://www.en.doe.gov/idb95/ or see RAD 13: RADLINKS II D-3: DOE: Environmental Management Sites.

Projected LWR (Light Water Reactor) spent fuel inventories in 2008 are listed at 36,700 106 Ci. Using an estimate of 109 light water reactors - the total of all boiling water reactors (BWR) and pressurized water reactors (PWR) - a model nuclear power station will have accumulated 336,700,000 curies of spent fuel by 2008. The spent fuel inventory of a typical LWR including MYAPP as of Jan. 1, 1997, is 280,070,000 Ci. Note: this figure is slightly revised from our earlier reports due to the addition of two new reactors in the last several years. Table A2 in the Integrated DataBase (pg. 258-265) provides the mass, radioactivity, and thermal power of nuclides in domestic commercial LWR spent nuclear fuel at the end of calendar year 1994. A current estimate of the inventory of any particular radionuclide at any US reactor may be derived from this table. For example the commercial nuclear industry cumulative inventory of 137Cs as of December 31, 1994 is 2.31 E+09 Ci, or 2,310,000,000 Ci. Dividing this figure by 109 power plants, and keeping in mind the exact number of US nuclear power plants varies and is now on a declining trend, a model light water reactor (LWR) has an inventory of 21,192,660 Ci of 137Cs. The exact nuclide inventory of the spent fuel in any particular reactor will vary widely, depending on reactor age, fuel burnup time and capacity (megawatts). As an older facility (1972) and with a slightly larger capacity than average, a reasonable estimate of the total on-site inventory of 137Cs at MYAPC in both the spent fuel pool and in the reactor vessel is 20 million Ci. MYAPC and state of Maine reports indicate total plant liquid discharges since 1972 of about 4 Ci of 137Cs. The objective of future environmental remediation efforts at MYAPC as a defacto high-level waste storage facility will be to ensure no additional discharge of this or any other isotope occurs.


The primary function of the MYAPC is to produce heat, and thus profit, from the fission of uranium in the fuel assemblies in the reactor vessel. 239Pu ( 1/2 T = 24,131 yr.), a principal ingredient of nuclear weapons, is one of many waste products which result from this process. Using the most up-to-date technology, powerful atomic weapons can now be manufactured using as little as 3 kg. of weapons grade 239Pu. Reactor grade plutonium, such as that in MYAPC spent fuel, must either be reprocessed into weapons grade plutonium to eliminate unwanted contaminants (especially 241Pu), or larger quantities of reactor grade plutonium must be utilized to fashion such weapons.

The inventory of 239Pu at the MYAPP as of January 1, 1995, is approximately 83,333 Ci. (IDB, pg. 264). Plutonium has a specific activity of 16.5 grams per curie, so the total MYAPC inventory as of January 1, 1995, is 1,374,995 grams, or 1375 Kg., of reactor grade 239Pu. This is sufficient to create about 120 nuclear weapons without reprocessing into weapons grade fuel. This legacy of the nuclear energy pyramid scheme has significant implication for Maine citizens and ratepayers in the future. The burden of maintaining the security of this plutonium prior to its final disposal in a geologic repository is the entitlement of the "beneficiaries" of nuclear energy, none other than MYAPC ratepayers. Preventing the transfer of this plutonium to those who would value it for its weapons production potential is one of many responsibilities which ensure that this plutonium will be a costly legacy of the nuclear energy pyramid scheme.

As of January 1, 1995, the MYAPP has the following inventory of other transuranic isotopes (read "entitlements"):

Half Life
238Pu 1/2 T = 8.77 yr 539,450 Ci
241Pu* 1/2 T = 14.4 yr 22,844,000 Ci
241Am 1/2 T = 432 yr 338,532 Ci
239Np** 1/2 T = 2.35 days 3,073,400 Ci

* The daughter product of the decay of plutonium-241 is americium-241.
** The daughter product of the decay of neptunium-239 is plutonium-239.

The best argument to be made by the sponsors of the nuclear energy pyramid scheme (@ 2.7 cents per kilowatt hour) is that this legacy of radioactive wastes will create jobs until disposed of in a final geologic repository. One of many obligations of waste titleholders is to make sure nobody spills the "entitlements."


The radioactive wastes in a reactor vessel are of particular interest because they include not only low-level waste which would be disposed of at the time of decommissioning, but also greater than class C wastes (GTCC) which are too radioactive to be included in the low-level waste flow, and are also excluded from the definition of high-level waste (spent fuel only) by federal law. These GTCC wastes are known in industry jargon as "orphan" wastes, and, at the present time, they have no known destination in the decommissioning process. The DOE Integrated DataBase contains the following information about GTCC waste inventories (pg. 256) at typical light water reactors. The DOE Integrated DataBase estimates the inventories of GTCC wastes in both pressurized water reactors (PWR) such as MYAPC and boiling water reactors (BWR). A typical PWR has an inventory of 4,350,000 Ci of GTCC waste; a typical BWR has a higher inventory of GTCC wastes, 9,200,000 Ci. In the 1987 TLG decommissioning study, site-specific GTCC waste inventories for MYAPC are listed at 4,047,879 Ci (see chart below). In the latest TLG decommissioning report (1993), GTCC waste volume is estimated at 239 cubic feet. This raises the question: why would it take 101.2 shipments of GTCC waste, as noted on the TLG chart reprinted below, to dispose of only 239 cubic feet of reactor vessel waste? The answer to this question is that antiquated waste disposal paradigms (c. 1987) allowed GTCC wastes to be mixed with low-level wastes and disposed of in a landfill in Barnwell, S.C. as (Hot C) low-level waste. These GTCC wastes originally contained just under 40 curies per pound of waste (for comparison, an entire steam generator contains less than 100 curies of radioactivity); mixing reduces GTCC wastes to class C low-level wastes. By the time MYAPC is ready to actually ship out the deconstructed components of the reactor vessel, it is extremely unlikely that this disposal option will still be available. The MYAPC will also not have the luxury of the GTCC disposal method utilized in the recent partial decommissioning of the Yankee Rowe Reactor in Massachusetts. This facility had sufficient space in its spent fuel pool to accommodate the GTCC reactor vessel wastes that resulted from the deconstruction of the reactor vessel. The MYAPC has no such extra space in its crowded fuel pool and the lack of a destination for these GTCC wastes will greatly exacerbate decommissioning efforts and costs.

Maine Yankee Reactor Vessel Inventory: GTCC Waste only*
Lower Core Support Barrel
7.960K+00 GTCC
Core Shroud
8.370K+01 GTCC
Lower Core Support Plate
3.750K+01 GTCC
Total Weight: 
Total GTCC Ci:
Total: 101.20

Note: Total reactor vessel waste inventory including classes A, B and C low-level waste is 4,170,222 Ci.

*TLG Engineering, Inc., (1987). Decommissioning study for the Maine Yankee Atomic Power Station. No place of publication listed.  [We now have both scanned and transcribed more of this inventory, it is printed in Section 5: Decommissioning Debacle: October 31 entry.]


MYAPC low-level waste inventories are divided into two categories, operational and decommissioning. Day-to-day routine operations produce low-level wastes, usually in very small quantities; current estimates are that the MYAPC will produce not more than 12,000 curies of LLW prior to decommissioning in 2008. Most, if not all, of these wastes will be sited prior to decommissioning at one of two locations: Barnwell, S.C., the current destination of MYAPC LLW, or the Texas LLW repository, where construction has been postponed until at least 1999. Low-level wastes are measured not only in terms of their radioactive content (curies), but also volumetrically (cubic feet). Initial MYAPC decommissioning LLW estimates were 480,000 cubic feet. Recent advances in compaction technology now allow a decommissioning estimate of 150,000 cubic feet of LLW containing slightly over 129,000 curies of radioactivity. This decommissioning LLW is slated for disposal at the Texas repository. The primary constituents of MYAPC LLW are contaminated building products, activated concrete and other solid waste. Most of the radioactivity, however, is contained within reactor vessel components, particularly activated stainless steel, and activated carbon steel (82.9%). Processed liquid waste will also contain a significant percentage (11.9%) of decommissioning-derived LLW activity. The principle radionuclides containing significant amounts of radioactivity after 500 years of storage in a hypothetical LLW repository are 59Ni, 63Ni, 14C, and 94Nb. "All other radioisotopes have either decayed to below 1 microcurie or remain in very small quantities or concentrations." (Vanags, p. 24). This data as well as a description of MYAPC decommissioning derived LLW is contained in A Study of Radioactive Wastes (Vanags, 1992). Additional discussion of the complications and costs of decommissioning MYAPC are contained in Legacy for Our Children (Brack, 1993). Both citations are included in the bibliography in the third sub-section (Economic Issues) of this part of RADNET.



1992 MYAPC sales: $187,259,000 (model year)
High-level waste generation: 1972-2008: 341,000,000 curies (1993 estimate: see note above)
    MYAPC yearly average HLW production: 9,472,000 curies per year
    MYAPC hourly average HLW production: 1,084 curies per hour

Note: Hourly average is actually higher due to shutdowns for repairs and refueling.

SALES TO WASTE RATIO: $187,259,000 divided by 9,472,000 Ci = $20* IN REVENUES PER CURIE HLW

*Note: $19.77 in electricity sales per curie of HLW was rounded to $20

Since 50% of MYAPC electricity is sold to out of state vendors whose contracts expire prior to decommissioning, future collection of high-level waste storage, transportation, and disposal costs from these sources will be extremely unlikely. MYAPC in-state ratepayers receive a double whammy: entitlement of 1 curie of high-level waste for every $20 of MYAPC electricity purchased will effectively double to an approximate entitlement of 1 curie of HLW for every $10 of Maine Yankee electricity purchased, unless the tooth fairy can be enlisted to collect the waste costs from the out-of-state vendors.

BONUS: Reactor Vessel Greater Than Class C (GTCC) wastes at 112,441 curies per year: for every $1,665 in MYAPC electricity purchased, get a free entitlement of 1 curie of reactor vessel GTCC orphan wastes. You do want to give a home to an orphan, don't you? Sorry, no LLW bonus.


Question: If low-level waste disposal costs of 1994 were $8,350 per curie, how much will it cost Maine ratepayers to maintain a de facto high-level waste facility at Wiscasset for the storage of reactor vessel and spent fuel wastes (+300,000,000 curies) and to transport and store these wastes in a monitored retrievable storage (MRS) facility and later in a final spent fuel repository at Yucca Mountain, Nevada?


... for providing nearly a quarter of Maine's electricity at a cost of 2.7 cents per kilowatt hour, plus one curie of high-level waste for every $20 in revenues.


One of the first "official" publications to specifically address public safety issues at nuclear generating facilities is Aging Nuclear Power Plants: Managing Plant Life and Decommissioning, issued in Sept. 1993, by the U.S. Congress Office of Technology Assessment (OTA), almost two years before the extensive circumferential cracking was discovered in the steam tubes at MYAPC. "Many systems, structures, and components (SSCs) in industrial facilities, including nuclear power plants, are subject to aging degradation. For nuclear power plants, aging degradation is defined as the cumulative degradation that occurs with the passage of time in SSCs that can, if unchecked, lead to a loss of function and an impairment of safety." (U.S. Congress OTA, 1993, pg. 9).* Such has been the case at MYAPC, where no sooner had the steam tube sleeving project been completed (see our extensive comments on this topic in the Summary of Safety Concerns in Appendix A) than a whole new series of issues had been raised by the whistleblower's letter. This letter, written by an employee of the Yankee Atomic Electric Company (YAEC) and reprinted in this sub-section of RADNET, alleged deficiencies in the performance of a small break loss-of-coolant accident (SBLOCA) analyses of the emergency core cooling system (ECCS) and the use of fraudulent containment analyses, both a component of NRC license violations as well as the basis for a series of illegal thermal power increases. These illegal power up-rates not only endangered the citizens of Maine by exceeding the safe operating capacity of the plant equipment, but also resulted in a windfall of +/- 100 million dollars in additional revenues, much of it profits, for the owners of the MYAPC. These allegations triggered an extensive NRC investigation of MYAPC and YAEC which resulted not only in confirmation of the whistleblower's allegations, but also in the discovery and documentation of numerous additional safety violations, issues and design flaws, as summarized in the following listing. These issues are analyzed in more detail in the citations which ensue. The events which followed the repair of the steam generator tubes and the appearance of the whistleblower's letter serve to document both the twilight of the nuclear era and the collapse of the nuclear energy pyramid scheme. The following developments in 1996 and early 1997 manifest the progress of this debacle at the MYAPC.
*As befits all messengers in the twilight of the nuclear era, recent budget cuts have resulted in the elimination of the Office of Technology Assessment.

December 1995:

The installation of 17,000 laser-welded sleeves was completed in the partial repair of an aging steam generator suffering not only from circumferential cracking in the steam tubes but also from sludge deposits within the steam generator which could not be removed. Other unresolved safety issues include weld-induced stress damage to parent tubes, the consequences of which are unknown, as well as upper steam tube degradation. More recent developments at reactors in Arkansas and Wisconsin which exacerbate the steam generator safety controversy are the discovery of single axial cracking at the first egg crate support (Arkansas 2) and leaky laser welds at the recently repaired Kewaunee Nuclear Power Plant in Wisconsin.* (See Summary of Safety Concerns in Appendix A of this publication).
*The sleeves at this facility were rewelded.

January 1996:

The NRC issued Confirmatory Order Suspending Authority for and Limiting Power Operation and Containment Pressure (Effective Immediately) and Demand for Information. Jan. 3, 1996. This order limited plant operations to 90% of power as suggested by the whistleblower's letter.

January 1996:

The extensive NRC investigations of plant operations which began in December of 1995 in response to the whistleblower's letter continued, centering on allegations of inadequate and misrepresented computer programs for emergency core cooling system operation.

February 1996:

The plant was shutdown due to faulty valve allowing excessive water to accumulate in one steam generator.

March 1996:

Sixteen workers were exposed to radioactive gas due to a leaky valve during routine servicing.

April 1996:

Excessive radiation was discovered in a plant storage area ("the backyard") originating from the accumulation of irradiated equipment from the sleeving project, the shine from which resulted in higher than normal ambient radiation levels in nearby clam flats. This situation is discussed in detail in the NRC inspection report cited below (United States Nuclear Regulatory Commission, June 15, 1996, Maine Yankee Atomic Power Station Integrated Inspection Report 50-309/96-06.)

May 1996:

The second in a series of NRC reports appeared detailing deficiencies in plant operations as well as failure to follow federal regulations. This "event inquiry" further confirmed allegations in the whistleblower's letter.

June 1996:

The MYAPC issued its own analysis of plant operations detailing low worker morale and unsafe operational procedures. A June 15th Integrated Inspection Report documented and summarized the excessive radiation levels discovered in April, as well as numerous plant deficiencies.

July 1996:

The plant was again shut down due to a lack of pressure relief valves. This design flaw was discovered at the beginning of an in-depth NRC inspection of plant facilities, allegedly a "top-to-bottom" review of all the safety systems at MYAPC that began in July.

August 1996:

The continuing NRC inspection discovered improperly installed instrumentation cables which could be submerged in water during an accident. This was followed by a pump failure due to a circuit test failure. Unsafe plant operations over a period of 5 or 6 years were confirmed by the discovery of a severed safety system cable with 15 feet of wire missing. This cable was essential to safe plant shutdown in a crisis situation and was another example of safety deficiencies not observed by the state nuclear safety advisor or resident state and NRC safety inspectors.

September 1996:

The third and final NRC report resulting from the investigation of the whistleblower's allegations was issued but not released for public scrutiny. Instead, this lengthy NRC O.I. (Office of Investigation) was referred to the Office of the U.S. Attorney for Maine, U.S. Dept. of Justice, for investigation and possible prosecution of violation of NRC regulations and Federal law. This report was forwarded to the U.S. Attorney for Maine 6 months after CBM submitted a brief to the same office detailing our observations of illegal activity at MYAPC. (The CBM brief can be accessed at the end of sub-section 3, Legal Issues, in this section of RADNET).

October 1996:

The Independent Safety Assessment of MYAPC was published October 7, 1996. Among the most controversial reports ever issued by the NRC, this report was initially trumpeted as a comprehensive safety inspection of plant facilities, but was later revealed to be only a partial review of 4 of 42 safety systems and not the "top-to-bottom" inspection it was represented to be by the governor and the state nuclear safety advisor. Numerous previously unknown safety problems were uncovered during this inspection including several design deficiencies which had jeopardized safety since 1972. This controversial report triggered an emergency public meeting sponsored by the environmental group Friends of the Coast. The resulting FOC report issued on Oct. 19th included observations of former nuclear engineer Paul Blanch, a whistleblower previously associated with Northeast Utilities in Connecticut, and David Lockbaum, a former nuclear consultant, now associated with the Union of Concerned Scientists. The FOC report documented the failure of the NRC to address important safety issues at MYAPC and underscored the complacency of the NRC in its prior oversight activities as well as in its failure to note long-standing design flaws and other equipment deficiencies.

November 1996:

Radioactive gas leaked from the reactor vessel building into the spent fuel pool area which was currently undergoing re-racking. This incident was followed by a failure of the plant computer for 41 hours, creating the necessity for the manual operation of some aspects of plant operations and raising questions about yet another obsolete component of an aging nuclear facility. On November 9th, the plant experienced a complete loss of off-site power which then became the subject of a December 18th confirmatory action letter.

December 1996:

Discovery of a radioactive chair used by plant guards for a year or more was followed by another plant shutdown due to crossed cables. Extensive additional investigation revealed the crossed cables problem was more serious than initially thought. Other safety defects surfaced which had not been noted in the "top-to-bottom" safety inspection during the summer. The crossed cable problem had previously been documented by a nuclear engineer, Peter Atherton, in 1978. As an employee of the NRC, he submitted a 61 page report of his observations of unsafe conditions at MYAPC and was ignored, harassed and fired from his position at the NRC. (See the Atherton letter, March 1997 comments, and the review of the Atherton report in this section of RADNET.)

Plant president Charles Frizzle resigned just prior to discovery of the presence of 129I in leaking fuel assemblies in the reactor vessel.

On December 18th, the NRC issued a confirmatory action letter to MYAPC addressing the cable separation as well as logic circuit testing deficiencies.

January 1997:

As a result of the discovery of the leaky fuel assemblies, the MYAPC reactor was brought to a cold shutdown to allow a 90 ton reactor head to be removed to facilitate fuel inspection. Purging of containment gases resulted in unusually high releases of radioactive gases at the plant, raising further concerns about plant safety. At this time the plant was expected to remain shut until at least mid-February of 1997. As of January 20th, 7 leaky fuel assemblies had been discovered out of the 50% tested to date. Extensive hiring of new staff, announcements of new programs and the hiring of a controversial new company to manage the MYAPC (Entergy Inc., New Orleans, LA) characterized the attempt to invigorate the aging MYAPC nuclear power facility at this time.

On January 26th, NRC inspectors discovered a possible "reactor coolant system loop fill header/motor operated valve over pressure situation." These valves must be opened after a loss of coolant accident to allow hot leg injection; technical specifications "require these valves be operable for a hot shut down condition or higher" (Jan. 26, 1997, NRC licensee event report 31641). This is an example of a deficiency that was overlooked by the ISA team's inspection of this safety system in its summer inspection of the MYAPC facility. This inoperable motor operated valve (MOV) could have led to a loss of reactor coolant accident (LORCA); this incident bears similarities to the relief valve failure during the Three Mile Island accident.

On January 27th, MYAPC announced that the plant had found 75 leaky fuel rods; they had originally anticipated 3 - 6 leaky fuel rods.

On January 29th, the NRC added MYAPC to its WATCH LIST of reactors requiring significant NRC additional supervision; such additional scrutiny by the NRC will tend to increase both the cost of returning the MYAPP to service as well as the duration of the down time of the reactor, which is now not expected to be back on line until the late spring or early summer.

On January 30th, the NRC determined the existing off site power capability "does not meet the current design and licensing basis ... Further, the facility's current technical specifications associated with the off site power capability are not adequate to ensure the plant will operate within its licensing basis." (January 30, 1997, NRC confirmatory action letter supplement).

February 1997:

On February 4th, Friends of the Coast resubmitted to the NRC an ancient report (1978) by a former employee of the NRC, Peter Atherton, which detailed a series of problems with cable separation and other hazards at this facility. When Atherton's complaints were first submitted to the NRC, they were ignored, and he was ostracized by NRC officials who forced him to leave his job.* Approximately 20 years later, these same safety issues are now the topic of NRC inspection reports and of complaints that the licensee is not in compliance with NRC regulations. No explanation is available as to why the NRC didn't respond to the initial complaints 20 years ago. (*Letter: 11/15/96; telephone conversations: 12/96, 3/97).

On February 14th, NRC officials, MYAPC's new managers (Entergy) and MYAPC's new CEO, Mike Sellman attended a meeting in Augusta, Maine, for the purpose of briefing members of the Maine legislature about safety concerns at MYAPC. Of particular interest to state legislators was the question of who would pay for the 68 damaged fuel assemblies, the cost of replacement of which will be in the tens of millions of dollars. This issue was not resolved at this meeting; if Westinghouse can prove that the fuel assemblies were damaged by the licensee during emplacement, the licensee and its ratepayers will be responsible for not only the cost of replacing the assemblies, but also for the cost of storing and disposing of this low burnup spent fuel which was only in the reactor vessel for a few months of use. As a result of the short burnup time for these fuel assemblies, this fuel has a higher criticality than spent fuel normally placed in the spent fuel pool. The higher criticality of these damaged fuel assemblies raises additional safety questions with respect to a spent fuel pool that has been reracked on a number of occasions to increase its storage capacity. Long term storage of these damaged fuel assemblies increases the possibility of a spent fuel pool accident in an already overloaded facility. If Westinghouse accepts the return of these hot assemblies, how will they transport this spent fuel and where is its destination? If the fuel stays on-site, how will its storage impact the spent fuel pool at MYAPC?

The ongoing controversy about the safety of the repaired steam generators also surfaced at this meeting. MYAPC's new CEO Sellman indicated that Entergy will be initiating a steam generator inspection, and that during this inspection upper steam tube degradation is expected to be discovered which will result in the need to plug additional steam tubes. Sellman indicated the plant can still operate efficiently with up to 15% of the tubes plugged. The expected discovery of upper steam tube degradation at MYAPC, the discovery of leaks in the laser welds of recently repaired steam tubes at the Kewaunee Nuclear Power Plant in Wisconsin and the rupture of two tubes due to cracking at the first egg crate support on the hot leg side of the steam generator at Arkansas Nuclear 2 combine to emphasize the temporary nature of the steam generator sleeving project at MYAPC. In view of these developments, the plan to operate repaired and aging steam generators at MYAPC is a safety controversy which will continue as long as the plant is in operation. For more information about the safety of the steam generator sleeving project at MYAPC, see the Summary of Safety Concerns in Appendix A of Collapse of a Pyramid Scheme.

On February 21st, the NRC completed a special inspection (12/8/96 - 1/28/97) reviewing the status of safety issues identified by the NRC Independent Safety Assessment (ISA) Team as discussed in Inspection Report 50-309/96-16. The 16 key safety violations and the 30 unresolved issues documented in this most recent NRC inspection summarize in a nutshell the unraveling of the MYAPC pyramid scheme, at least in regard to public safety issues. This report is posted and reviewed at the end of this section of RADNET (see US NRC: 2/21/97).

On February 21st, the NRC also issued a separate event report detailing a subject not reviewed in the ISA Team report discussed above: potential for freezing temperatures in the circulating water pump house, which would thwart residual heat removal by the service water system in the event this cooling water was needed (NRC event report no. 31829).

As of late February, the MYAPC reactor facility parking lot is filled to capacity by four to six hundred contract workers hired to supplement the normal staff of 400 in a frenetic race to repair the dozens of major safety deficiencies and thousands of backlogged maintenance projects in a concerted effort to reinvigorate aging MYAPC equipment and safety systems.

March 1997:

The new management at MYAPC announces that advanced steam generator tube probe technologies will be utilized beginning in April to examine the steam generators for evidence of microdegradation mechanisms. If these more accurate remote sensing technologies uncover additional defects in the steam generator tubes, the cost of replacing these generators will result in the closing of the plant.

On March 4th, in a telephone conversation, Don Clark, the Assistant U.S. Attorney for Maine, who is handling the MYAPC inquiry indicated a vigorous investigation of the NRC Office of Investigation complaint is continuing. However, as is always the case, the Office of U.S. Attorney will not attempt a criminal prosecution of MYAPC unless it is confident of success in this effort. In the MYAPC case, the existence of the power uprate scam is as obvious as a routine bank robbery yet its successful prosecution is extremely unlikely.

On March 6th, the Lincoln County Weekly (LCW) printed a front page expose about Peter Atherton's 1978, 61 page analysis of fire hazard design flaws at MYAPC. The design flaws that Atherton noted included the lack of cable separation which resulted in the December, 1996, shutdown of the plant. At the time that Atherton discovered "redundant safety cables routed in the same trays" (LCW, pg. 12) he recommended that the plant shut down. Atherton also recommended that MYAPC as well as other plants set up a special electrical system with an independent power supply, something the NRC recommended several years later. The lengthy article in the Lincoln County Weekly provides a distressing tale of NRC harassment of a dedicated employee back in the days when most everyone thought nuclear energy was "a wonderfully safe way to produce electricity" (Rep. John Vedral, III, LCW, pg. 12). Atherton, a former nuclear engineer, worked for the NRC as a GS-13 engineer for a number of years prior to his being fired for raising these safety questions.

On March 7th, MYAPC issued the Maine Yankee Restart Readiness Plan in response to the NRC request for "Adequacy and Availability of Design Bases Information." This report summarizes most of the activities being undertaken by MYAPC in order to restart the facility in late summer 1997 and will be followed up by the submittal of a separate Restart Plan Closure Report to be issued approximately 30 to 60 days prior to the restart date. This report is noteworthy not only for the extensive qualifications within the report (if, when, generally, long-term improvement, approximately, overall, etc., etc.), but also for the revelation that the cause of leaky fuel assemblies is grid to rod fretting resulting from the abrasion of the fuel assemblies against the reactor vessel grids holding them in place. This report seems to acknowledge that grid to rod fretting is a problem to one degree or another with all fuel assemblies in the reactor vessel, but then also specifies that this ongoing degradation mechanism is particularly characteristic of fuel produced by Westinghouse. This report also indicates that the problems with crossed cables may not be entirely resolved by remediation efforts prior to reactor restart; the same observation may be made about other corrective actions not considered essential to safe reactor startup.

On March 13th, Edouard Trottier, the MYAPC Project Manager in the Office of Nuclear Reactor Regulation was charged with and pleaded guilty to the unauthorized disclosure of information pertaining to the identity of persons involved with the NRC Office of Investigations of the "alleged deliberate failure of Maine Yankee to comply with NRC requirements regarding the adequacy of Maine Yankee's emergency core cooling system." The complaint, issued by the U.S. District Court, District of Maine, at the request of the U.S. Attorney for Maine further noted that the confidential OI report which Trottier disclosed to Douglas Whittier, a Vice President of the licensee, "contained the allegations and conclusions of the NRC investigation and the identities of certain individuals with information who had been identified in that investigation, All in violation of Title 18, United States Code, Section 1905."

The disclosure of the contents of the confidential NRC Office of Investigations report by Trottier to the licensee is particularly controversial because, in providing Maine Yankee management with this confidential information, Trottier's actions may have jeopardized the investigation by the Office of U.S. Attorney into allegations of criminal misconduct which resulted from the whistleblower's letter of December 1995. U.S. Attorney for Maine McClosky is quoted in the Lincoln County Weekly (Tuesday, March 20) as saying "...that the illegal disclosure 'could have a substantial negative impact on evidence our office is able to develop'." Trottier has provided a major service to the licensee by disclosing the identities of individuals within the MYAPC-YAEC corporate community who have been cooperating with the Department of Justice investigation. This will greatly assist the defendants in this investigation in evading the successful prosecution of any charges brought against them.

The significance of the disclosures by Trottier are further emphasized by the revelation that Douglas Whittier, a key player in the whistleblower's allegations as well as a probable defendant in any DOJ prosecution (and also the representative of the licensee on the State of Maine Radioactive Waste Advisory Commission) has resigned from MYAPC but has been retained as a consultant and will be in charge of supervising and interpreting the upcoming April steam generator inspection. This raises the question: what person could the licensee appoint to supervise the steam generator inspection who could have less credibility than Whittier? The answer: nobody. MYAPC demonstrates a consistent pattern of incompetence, first spending $38 million to sleeve aging steam generators which cannot legally be returned to service and now appointing a prime suspect in a major criminal case as the supervisor of yet another safety inspection of steam generators which should never be returned to service.

On March 13th, the NRC issued Integrated Inspection Report 96-14 listing several additional violations including problems with fuel handling. This report is particularly noteworthy in that it discusses Radiological Incident Report 96-016, Discreet Particle Exposure in Chair used by Security Personnel, and provides the startling information that the chair contained .218 Ci of fission product fragments. The amount of fission products in this chair exceeded the total annual plant liquid discharges of fission and activation products during 6 out of 11 years between 1983 and 1993 as noted on page 11, Figure 13, State of Maine Nuclear Safety Report, 1995. Plant discharges in 1985 were only .02 Ci; in 1993, the last year reported, discharges were .18 Ci. The particle in question was reported to have been 3.3 years old; this raises important questions about the accuracy of radiological monitoring reports executed by MYAPC/YAEC as well as about the declining material condition of this obsolete facility.

NRC Correction

On May 9, 1997, CBM received the following information in a letter from John Zwolinski, Deputy Director of NRC Reactor Projects: "On April 8, 1997, NRC Region I issued a correction to NRC Inspection Report No. 96-14, a copy of which is enclosed. The report had erroneously referred to the discovered material as having .218 curies of activity, when in fact the material had .218 microcuries of activity." This correction reduces the significance of the particle in the guard's chair from the sensational to the routine -- the particle having one millionth of the radioactivity initially reported in the above inspection report.

April 1997:

On April 3rd, the following notice was received by Fax at the CBM office:


Neither the Nuclear Regulatory Commission nor the Maine Yankee Atomic Power Company can guarantee the integrity of aging MYAPC steam generators and thus ensure public health and safety with respect to the restart readiness of the Maine Yankee Atomic Power Plant in Wiscasset, Maine (License No. DPR-36, Docket No. 50-309). Discrepancies in the service life expectancy of sleeved tubes and stress-relieved welds vs. the service life expectancy of parent tubes at and above the first horizontal support cannot be resolved without the entire replacement of the existing steam generators (3) with new steam generators.

  1. Secondary side corrosion products, sludge deposits, tube scaling and micro-degradation mechanisms ensure anomalies in service life expectancy which are not amenable to repair or prediction by tendentious steam tube inspections.
  2. Parent steam tubing in the vicinity of horizontal tube supports numbers 1-6, upper steam tube drill plates 7 and 9, and upper steam tube horizontal support number 8 are particularly vulnerable to secondary side corrosion mechanisms and were not repaired in the sleeving project of 1995. The long term integrity of unsleeved parent tubes in these locations cannot be guaranteed.
  3. Other phenomena undermining steam generator integrity include:
    • Far field sleeve weld-induced stress in parent tubes.
    • Potential sleeving-induced displacement of parent tubes including bowing, lateral displacement, and possible tube locking at the horizontal supports.
    • Outside diameter tube scaling deposits.
    • Secondary side corrosion and sludge deposits in other areas of the parent steam tubes including degradation of upper steam tubes.
    • Other deformations associated with normal aging and microdegradation mechanisms.
    • Overall increased vulnerability of parent tubes to water hammers or other unforeseen events.
The 1995 temporary repair of the steam generators by sleeving tube areas susceptible to circumferential cracking was a licensee sponsor management decision designed to save owners the expense of replacing aging steam generators. Implicit in that mismanagement decision is the unequivocal necessity of full steam generator replacement to ensure public health and safety in the unlikely event of reactor restart.

Replacement of steam generators in no way addresses or resolves other design and license bases discrepancies, inadequacies or safety issues. Also pending are legal, ethical and operational questions raised by the ongoing NRC Office of Investigations and Department of Justice inquiries into several whistleblowers' allegations as well as unfunded decommissioning, waste storage and disposal obligations. The loss of competitiveness caused by energy deregulation and the availability of inexpensive replacement energy render purchase of new steam generators superfluous. A delay of four to six weeks is likely before plant owners, senior management and NRC supervisors acknowledge the fait acompli of indefinite plant closure.

Preliminary decommissioning activities should commence as soon as the futility of reopening MYAPC is also acknowledged.

Whistleblower No. 9

On April 3rd, the NRC participated in two meetings in Wiscasset, Maine, pertaining to the Restart Readiness Plan which is reviewed in this section of RADNET. Of particular interest are comments made by NRC staff members at the evening question and answer session at the Wiscasset Middle School which include the bizarre assertion by Charles Heyl that licensee Radiological Incident Reports are routinely available in the NRC public documents room. Heyl also asserted that the large quantity of fission products discovered in a chair used by guards (0.218 Ci, significantly more than the total release of liquid fission and activation program products in 1993, 0.180 Ci) does not constitute an additional pathway for release of undocumented plant effluents. Heyl's comments as well as the unavailable RIR's discussed elsewhere in RADNET raise the important issue of exactly how much radioactivity MYAPC releases to the environment which is not accounted for in the semi-annual effluent monitoring reports. A copy of the transcript of this meeting has been requested from the NRC and will be provided to the office of the U.S. Attorney for Maine for consideration in the on-going investigation of violations of federal laws and regulations at MYAPC.

On April 15th, an article in the Portland Press Herald provided the information that MYAPC has notified the Nuclear Regulatory Commission that 90% of the special foam seals designed to prevent the extension of a fire within the nuclear plant are defective and will have to be replaced at a total cost of 3.8 million dollars. This cost is in addition to the 38 million dollars already allocated to be spent upgrading plant safety systems prior to any proposed reopening. The fire penetration seal problem is complicated by the problem of inadequate cable separation. Until all the safety cables are separated, numerous fire penetration seals cannot be repaired and MYAPC has been forced to post special fire watch personnel. Due to ongoing repairs not all fire seal repairs will be made prior to restart. The fire seal deficiencies raise yet another non-compliance issue which is particularly complicated by the revelation (not reported in the Portland Press Herald) that the silicone foam being used to repair fire penetration seals are combustible material. This combustibility was discussed in a July 1, 1996, NRC report Technical Assessment of Fire Barrier Penetration Seals in Nuclear Power Plants, SECY-96-146 and also in NUREG-1552 Fire Barrier Penetration Seals in Nuclear Power Plants, July 31, 1996. A more detailed commentary on fire barrier issues was made available from the Union of Concerned Scientists on May 1, 1997 and is reviewed in this section of RADNET. An NRC technical paper on fire barrier issues is also available on the Internet at URL: http://www.nrc.gov/OPA/gmo/tip/tip26.htm) but does not mention the combustibility of the silicone foam being used at MYAPC.

On April 22nd, information surfaced (licensee employee disclosure) that for six years MYAPC had failed to inform the NRC that a pressure release valve essential to the safe shutdown of the reactor during a nuclear incident had been discovered to be inadequate. MYAPC had submitted information in the form of a computer analysis pertaining to the pressure release valve to the NRC, but MYAPC soon discovered that the information in the computer analysis was inaccurate. A memo written in 1996 by an MYAPC employee documented that the licensee had known but failed to inform the NRC of the inaccurate information and that the licensee had postponed repairing the valve by installing a manual bypass.

On April 28th, the Central Maine Power Company (CMP) announced that, as part of corporate restructuring in the upcoming era of energy deregulation, CMP will divest itself of its energy generating stations including its share of MYAPC, focusing its efforts solely on transmission and distribution of electricity. The objective of CMP's divestiture of generating facilities at this time appears to be the current favorable market for these facilities; comments by David Flanagan, CMP President, indicate that CMP believes delay in the sale of this component of CMP equity could result in a lower return for its properties.

The proposed sale of MYAPC raises a whole series of yet unasked questions about who will be responsible for the decommissioning and waste storage and disposal costs of the future. Dysfunctional and inadequate federal oversight of the nuclear energy industry raises the specter that the MYAPC sponsors who profited from the nuclear energy pyramid scheme in Maine may be able to escape any further decommissioning and waste storage obligations and, through the sale of MYAPC to another utility and/or energy corporation, further ensure that utility ratepayers of the future will bear the primary burden of the uncollected debits of the past. The proposed sale of MYAPC gives further emphasis to the discrepancy between nuclear energy at 2.7 cents per kilowatt hour (an illusion as well as a fraudulent misrepresentation of the past) and the huge unfunded obligations of an unsafe, uneconomical nuclear energy dinosaur of the future.

May 1997:

On May 1st, the Union of Concerned Scientists issued an important critique about fire protection problems at MYAPC following the revelation that 90% of 2,600 fire barrier penetration seals will need to be replaced, repaired or reanalyzed. The UCS report reveals that the silicone foam manufactured by Dow Corning to be used in the MYAPC repairs is combustible and therefore in violation of federal regulations. Numerous other inconsistencies in NRC fire barrier related regulations are noted in the UCS critique which is reviewed in this section of RADNET.

On May 2nd, the U.S. Nuclear Regulatory Commission Operations Center issued the following event report (32251) for MYAPC: "New engineering analysis indicates that the component cooling water pumps (CCP) could be disabled by a main steam line high energy break. ...this postulated event could disable both trains of the residual heat removal system. This condition will be addressed prior to startup."

On May 6th, the Maine Yankee Press Herald (Portland) reported the not so surprising news that "the repairs done to the cracked tubes in 1995 are holding up well." With respect to the need to replace the aging steam generators at a cost in excess of 150 million dollars, the Yankee Press Herald reports "Now that threat seems to be fading away." What the Yankee Press Herald does not report, however, is that 144,000 steam generator drill plate and horizontal support tube junctures subject to stress corrosion cracking, tube denting and thinning, pitting and intergranular attack cannot be accurately evaluated for degradation due to sludge and corrosion deposits, inaccessibility, deficiencies in the ability of existing equipment to analyze defects in these locations, and limitations in staff and resources which allowed only a partial inspection of the more accessible recently sleeved steam tubes. For additional comments on steam generator safety issues, see Robert Pollard's report on Steam Generator Corrosion in this section of RADNET.

On May 15th, the following letter was sent to Attorney General Janet Reno and is printed here in its entirety.

Center for Biological Monitoring, Inc.
Sponsor of RADNET: Nuclear Information on the Internet
World Wide Web at http://home.acadia.net/cbm/Rad.html
BOX 144, HULLS COVE, ME 04644-0144 207/288-5126
FAX:207/288-2725 EMAIL: sbrack@post.acadia.net

Department of Justice
Constitution Ave. & 10th St. NW
Washington, DC 20530

Dear Janet Reno,

With respect to the ongoing investigation of Maine Yankee Atomic Power Company I would like to bring some discrepancies to your attention which relate to a recent reinspection of steam generators which were repaired two years ago with state of the art technology. That repair was limited to sleeving the lower sections (only) of the steam generator tubes at the tube base where circumferential cracking had been discovered in 60% of the steam tubes. Not amenable to repair were an additional 144,000 drill plate and egg crate cross support junctures which hold the steam tubes in place in these aging steam generators, nor an additional 16,000 U bends in the upper region of the steam generator. Not only are these locations not amenable to repair, but due to tube scaling, corrosion and corrosion derived sludge deposits it is difficult for the licensee or the NRC to even evaluate the condition of these junctures using their new high-tech probes, which have greater sensitivity than old probes used prior to the discovery of the circumferential cracking.

I would like to direct your attention to the licensee's assertion that it has analyzed (or will analyze) 30,000 points within the steam generator tubes, and in checking the new sleeves (16,000) it has found no problems with the 1995 repair. Due to the advanced technology used in the sleeving process, and the limited time the repaired steam generators have been in service, this is not an unexpected result. I wish to point out that the licensee has discovered (as reported in the Lincoln County Weekly, 5/8/97, copy enclosed) 118 tubes that need to be plugged out of 23,452 analyses completed (out of 30,000 analyses planned) in this partial reinspection. If we subtract the 16,000 sleeved tube junctures at the steam generator tube base from 23,452, one can observe that the 118 tubes which were discovered to be inadequate and thus in need of plugging derive from inspection of only 7,452 out of 160,000 of vulnerable junctions located above the high-tech repairs at the steam tube base.

The licensee notes, as reported in this news article, that only 30,000 "points" are due to be inspected prior to reactor restart. At the rate of 118 defects per 7,542 inspections, were the licensee able to do the physically impossible and accurately evaluate the corrosion damage at each of the 160,000 vulnerable junctures above the sleeves at the steam tube base, the licensee and the owners of MYAPC would be forced to do what they should have done two years ago when circumferential cracking was discovered in 60% of the steam tubes at the steam tube base: close the facility or replace the steam generators.

A thorough inspection of the remaining 150,000+ vulnerable drill plate and egg crate cross supports and U bends would undoubtedly reveal far more than 118 defects. The licensee's ability to manipulate witless news reporters such as those at the Portland Press Herald and other media by asserting that a lack of defects in the sleeved tubes at the tube base means the rest of the steam generator is safe to operate indefinitely is consistent with the licensee's use of deceit and deception so well documented by recent NRC inspections, safety assessments and investigative reports.

The fact that the NRC as well as the Department of Justice are very receptive to this type of deceit, manipulated data, and public relations propaganda relates closely to the contents of my letter to you two weeks ago and the questions which it contained.

The conclusion that the steam generators would be safe to operate indefinitely even if there were no further defects discovered would be invalid because the evidence so clearly shows that the unrepaired internal components of the steam generators in older nuclear power generating facilities are subject to such rapid degradation that once circumferential cracking is observed at the steam tube base in any substantial quantity, the steam generators must be replaced or the facility closed. The MYAPC facility is anomalous in that it is the only nuclear energy generating facility in the world which has been returned to service with a partial repair of all 16,000 steam generator tubes at the steam tube base. The fact that defects are being discovered in areas away from the sleeved tubes (16,000 repairs with 12, 24, or 36 inch sleeves) at the rate of 118 defects per 7,452 points analyzed, with another 150,000 vulnerable junctures yet to be analyzed, indicates yet again how much restart of this reactor, which now should be permanently closed for safety, economic and legal reasons, depends on deceit and deception.

Yours truly,

H. G. Brack

cc. Don Clark Shirley Jackson Jay McClosky John Zwolinski

On May 22nd, the Lincoln County Weekly reported, in contrast to the news story in the previous issue, that 71 of the laser welded sleeves have defects which will require plugging and that additional problems were found in other areas of the steam generators so that 260 additional tubes will have to be plugged bringing the total of plugged tubes up to 6.1%. The current license allows 8.4% of the tubes to be plugged. Due to these problems the licensee announced that steam tube inspection will be expanded to 100% of the steam tubes. These developments represent a radical departure from the optimistic but premature conclusions reported in the Maine press the previous week. Further complicating the prospects of reactor restart was the discovery on May 19th that due to modifications made at the plant in the 1980's a high energy hot water and steam pipe break had been a possibility for over a decade, and that this defect had not been noted until just recently. The LCW recorded the following comment by NRC inspector Yerokun (pg. A-2) "If that had happened while the plant was on-line it would have been very significant." Controversy over combustible fire barrier repair materials continued as Congressman Tom Allen joined Edward Markey in criticizing NRC policies with respect to the use of combustible silicone foam in the ongoing repairs at MYAPC.

On May 26th, an anonymous source indicated to the Center for Biological Monitoring that some type of a mishap involving a crane and a large buried pipe had occurred as the pipe was being removed. No injuries resulted, but RADNET would be interested in obtaining more information about this incident.

On May 27th, following the final of a series of meetings of MYAPC board of directors, and of MYAPC owners, David Flanagan, President of Central Maine Power announced that MYAPC would lay off 1,000 temporary workers and some permanent staff, and discontinue all ongoing safety repairs and plant upgrades with the exception of the ongoing steam generator inspections. Flanagan clearly indicated that plant owners were not planning to reopen the facility due to the convergence of economic, safety, and regulatory problems. Flanagan indicated the plant is still for sale; it appears unlikely the facility will ever reopen unless another utility is willing to purchase the reactor and complete the extensive safety upgrades and repairs which were ongoing at MYAPC. Flanagan indicated that the current layoffs would save MYAPC owners $41,000,000 out of a total outlay of $193,000,000 since the beginning of the steam generator sleeving project in 1995.

June 1997:

On June 12th, after reviewing 5 notebooks containing information about altered problematic risk assessments (PRA) during late May, the Union of Concerned Scientists forwarded a two page cover letter containing allegations of additional misrepresentations to the NRC. These allegations pertain to risk assessments which were the basis for the Independent Safety Assessment Team's evaluation of which MYAPC safety systems were to be the subject of review in the summer of 1996. These additional allegations may be referred to the U.S. Attorney's Office and may form yet another component of the on-going criminal investigation of altered computer codes and misrepresented containment analysis. These anonymous allegations of altered risk assessments, which involved the interactions of various plant safety systems, were received by the Union of Concerned Scientists from an employee of the Yankee Atomic Electric Company and include 2,200 pages of documents and memos.

July 1997:

On July 31st, PECO Energy Co. informed MYAPC that it will not purchase the plant.

August 1997:

On August 1st, the owners of MYAPC agreed that they could not operate the reactor economically and they are moving ahead with plans for a permanent shutdown.

On August 6th, the 18-member board of directors voted to permanently cease operations. In the fall a detailed plan will be submitted to the NRC explaining the schedule and methods of decommissioning.

The post-closure chronicle of the Collapse of the MYAPC Pyramid Scheme will continue in Part 5, of this component of RADNET (Section 12). This new section of Collapse of a Pyramid Scheme will include relevant citations, reports and events which document important developments in the ongoing decommissioning debacle at MYAPC following the August 6th closing of the Wiscasset facility.

This summary of some of the most important developments in the MYAPC debacle will be updated weekly. This summary in no way includes all the radiological incidents and events that have occurred in 1996 and early 1997. 

Note on licensee Radiological Incident Reports

One important source of information pertaining to the safety of MYAPC plant operations not available for routine review and citation in RADNET is the licensee Radiological Incident Reports (RIR's). These reports are licensee derived radiological contamination event reports which contain information of safety significance and provide insight into daily operations at MYAPC. In addition, these RIR's are now of interest as background material in ongoing Department of Justice and other investigations of criminal activity at MYAPC. These RIR's are considered to contain "proprietary information" by the licensee and are not available in NRC public document facilities. Although these RIR's are available through expensive FOI (Freedom of Information) requests through the NRC, both the NRC and the Maine State Nuclear Safety Advisor have refused to provide this material to the office of the U.S. Attorney for Maine for review as a component of an ongoing investigation (as of May 2, 1997).

A June 15th NRC Integrated Inspection Report references a series of 8 radiological inspection reports (RIR's) which were filed in early 1996. Only one of these RIR's has been obtained by RADNET through a freedom of information filing and is cited and reviewed below. This single RIR, detailing 60Co contamination on the leg of a worker in January, 1996, is one of a whole series of reports which are not available to the general public and are not placed in the public documents room but which present graphic evidence of the deteriorating conditions in an aging nuclear power plant. A second important RIR (96-016) is referenced in U.S. NRC Integrated Inspection Report 50-309/96-14 (see review below) and documents radioactive contamination in a chair used by guards which exceeds plant discharges for an entire year. Additional RIR's will be posted as soon as they are available for review.

Accident Scenarios

Public safety considerations at any nuclear power plant have one central focus: prevention of the release of the huge on-site inventories of anthropogenic radioactivity contained in every plant. The complicated physical structure of a nuclear power station as well as the division of on-site inventories of radionuclides into two components (operating reactor vessel inventories and spent fuel pool inventories) create a complex aggregate of potential safety hazards and issues. The recent revelations at MYAPC illustrate how much more vulnerable this facility, or any other operational nuclear power plant, is to a major accident than has been previously admitted. Two general categories of nuclear accidents can now be postulated:

Anticipated events: not one but hundreds of events can combine in any number of sequences to create conditions allowing a LORCA (Loss of Reactor Cooling Accident). Safety analysts at the NRC and various DOE laboratories have spent years, and issued hundreds of reports, attempting to analyze the wide variety of accident scenarios which can be triggered by malfunctioning equipment, power outages, cooling system pipe failures, and other mishaps, all interacting in one pattern or another and all the subject of intense analysis by experts who spend a lifetime trying to anticipate potential safety hazards.

Unanticipated events: recent developments have made the remote possibility of an unforeseen nuclear accident much more likely. The military technology allowing a single individual to destroy a nuclear power plant has long been available in the form of surface to ground missiles, extremely powerful plastic explosives and other weapons technologies. In the post Cold War era, the proliferation of fissile materials has raised the spectra of a new type of "unanticipated" nuclear accident: the vaporization of an operational nuclear power plant, fuel reprocessing facility, or other weapons production installations by terrorists using a suitcase type nuclear weapon, or a nuclear warhead on a surface to ground missile. Other new technologies which may facilitate the same objective include laser beam weapons and top secret EMP (electro-magnetic pulse) weapons which can knock out the electrical systems of a nuclear plant without vaporizing the fuel.

The following are the 4 principle categories of nuclear accidents which could occur at the MYAPC or any other nuclear power plant.

QRA: Quick Release Accident: A quick release accident occurs when a sudden and total release of the inventory of radioactivity takes place at an operational (hot) nuclear power plant. While it is unlikely that the MYAPC would ever become the target of a terrorist armed with a nuclear weapon, this scenario is a reminder that, in the new millennium, any operational reactor is a potential target for groups which may find nuclear blackmail a useful policy. Another type of QRA which is difficult to anticipate would be that resulting from a severe earthquake. The MYAPC is, unlike many Japanese reactors, in an unlikely location for this type of scenario. Other types of unanticipated events are not correlated with geological and political factors: commercial airliner accidents, psychopaths armed with advanced technology, and other situations we cannot yet anticipate. Certain types of loss of reactor coolant and reactor vessel embrittlement accidents could result in a quick release accident, especially after pressure buildup in the reactor vessel which might originate from a series of minor mishaps.

LORCA: Loss Of Reactor Coolant Accident: the most probable form of a nuclear accident at MYAPC or any operational reactor, a LORCA results when the circulation of the enormous quantities of cooling water necessary to halt the fission process and prevent meltdown from overheating due to the accumulation of decay heat is interrupted. Loss of coolant accidents can be divided into two categories: small break loss of coolant accidents (SBLOCA), now the center of attention at MYAPC, and large break loss of coolant accidents (LBLOCA). Ongoing steam generator degradation mechanisms could play a significant role in the evolution of a loss of coolant accident. Possible LORCA precursors include rupture of the coolant intake pipe, main steam pipe break, steam tube axial ruptures, single or simultaneous failures of steam tubes due to circumferential cracking, and other types of steam generator failure due to ongoing degradation processes such as sludge accumulations in aging steam generators. In a LORCA scenario, any of these or other incidents could lead to the failure of the reactor pressure vessel to contain the extreme pressures generated by the attempt to cool the nuclear fuel. The deteriorating condition of the aging MYAPC facility makes this type of scenario much more likely at MYAPC than at a less decrepit nuclear generating station.

RVA: Reactor Vessel Accident: reactor vessel embrittlement is another ongoing degradation process which could lead to a sudden release of the nuclide inventory of an operating reactor. While the sudden and complete failure of the reactor pressure vessel is unlikely, the embrittlement of this vessel is a normal part of the aging process of any reactor. Most situations involving reactor pressure vessel failure would probably be preceded by a loss of coolant situation, but the failure of the reactor pressure vessel is a possibility during a SCRAM, the sudden manual or automatic shutdown of a reactor when the fission process is terminated by the flooding of the reactor vessel. The sudden loss of pressure in a reactor vessel is called "blowdown" and may result in a QRA if pressure vessel failure occurs simultaneously with breach of the containment building. In other scenarios, a blowdown may be followed by a LORCA which results in a more gradual release of radioactivity to the environment. Embrittlement of the fuel rods is another process which can complicate and/or enhance a LORCA or a RVA scenario.

SFPA: Spent Fuel Pool Accident: the spent fuel pool at MYAPC is located approximately fifty feet from the reactor building; spent fuel is moved to the pool through a tunnel that connects the two buildings. Any number of situations could result in a severe nuclear accident at the spent fuel pool which would occur if the spent fuel bundles were knocked together or otherwise rearranged to allow heat buildup and a return to criticality (e.g. falling aircraft, crane, or other objects). As spent fuel ages and its heat dissipates, resumption of the fission process within a spent fuel pool is increasingly unlikely. After thirty years cooling, public safety considerations require the transfer of the spent fuel to either dry casks or a multiple purpose canister (MPC) system. In the case of MYAPC the failure of the federal government to develop a spent fuel repository that would be available to MYAPC at the time of decommissioning will make it mandatory that the spent fuel pool be deconstructed, and the fuel rods transferred to dry casks as is already being done at some U.S. nuclear power plants. Even if a final geological repository is not available, it would be much more practical to utilize a multi-purpose canister system for spent fuel storage rather than utilizing obsolete dry casks which cannot be moved to a monitored retrievable storage site wherever such a site might be developed. Unfortunately, a modern multi-purpose canister system is much more expensive than dry cask storage and will cost in excess of 60 million dollars for MYAPC spent fuel. Financing for such an MPC system has not yet been approved by Congress; the fund which now exists for disposal of commercial spent fuel (12 billion dollars has been collected from utility ratepayers; 6 billion dollars remains unspent) only applies to the receipt and disposal of spent fuel at a federal repository if and when it is available. If no such repository is available, under current federal law utility ratepayers are responsible for all temporary storage and administrative costs, as well as for transportation and for financing a modern MPC system which would allow spent fuel movement from one location to another. One of many indicators of the future financial crisis inherent in the collapse of the nuclear energy pyramid scheme is the federal failure to design, construct and finance these multi-purpose containers. Public safety considerations mandate that a modern MPC system be available as soon as possible.

The potential for leakage of high-level wastes into the spent fuel pool from corroded or damaged zirconium spent fuel cladding is a danger at all times, and has already been noted in a number of DOE facilities where the spent fuel has aluminum cladding. The spent fuel pool itself then becomes a repository for uncontained radioactive wastes. Current real time data about the MYAPC spent fuel pool leakage rates are not available from either the NRC or the licensee. Radionuclides which are not filtered out of the spent fuel pool water and disposed of as "low-level" wastes could leak into the environment.

Decommissioning is another potential source of a fuel pool accident; current plans for reactor deconstruction adjacent to a fully loaded spent fuel pool provide a variety of accident opportunities including those involving cranes and other heavy equipment used in the deconstruction of the containment building.

Other Small Accidents, Incidents and "Events"

Unanticipated and anticipated events leading to catastrophic releases of anthropogenic radioactivity overshadow more common day to day events which often result in small releases of radioactivity into the environment. Such smaller releases, as well as other mishaps and "radiological events," are documented in licensee event reports (LER) and radiological incident reports (RIR). While LER's are public documents which must be filed in the public documents room, there are also many safety related incidents which are not required to be reported to the NRC. The latter incidents are often described in internal reports (RIR's) which are not usually available to the public but which further document ongoing safety issues, incidents, and/or plant microdegradation mechanisms which may be indicative of situations which could lead to more serious accidents. One such RIR is reviewed at the end of this subsection. Many other types of incidents can and do occur which result in some release of radioactivity to the environment, usually within the facility itself. Sometime these radiological incidents or "unusual occurances" result in a more substantial potential to contaminate the environment. One such incident occurred in the early years of plant operation when MYAPC experienced a significant failure of the cladding of its first group of fuel rods which had to be replaced. These defective fuel rods are now stored in the spent fuel pool and are a second possible source of waste leakage to the fuel pool and will be an additional burden during the decommissioning process. The recent discovery (January 1997) of 68 defective fuel assemblies during the current outage will further exacerbate spent fuel storage issues unless the manufacturer of the defective fuel, Westinghouse, will accept the return of these damaged fuel assemblies. A full report on the environmental impact of the earlier fuel rod failure has never been compiled nor required by NRC regulations. The cause of the recently discovered damage in the 68 fuel assemblies now being removed from the MYAPC reactor is also undetermined.

The NRC does require the filing of an LER to record any unusual incidents during normal reactor operations. The past and current problems with defective fuel assemblies are only one example among many incidents which require an LER. A compilation of all the LERs at NRC supervised reactors describing the many types and variations of minor nuclear accidents would run to many thousands of pages of documents.

Safety Issues: Relevant Citations and Reports

Readers please note this is the first of three groupings of bibliographic citations in this section of RADNET. The other two will follow the discussion of economic and legal issues at MYAPC. The following citations are those publications and reports which best document ongoing safety concerns. NRC publications are listed in the order of their date of publication; otherwise, reports are listed alphabetically by author with the exception of the first few reports cited below. This listing is subject to continual update, particularly in view of the uncertainty of the status of the MYAPC facility at Wiscasset, Maine. Additional citations and suggestions are always welcome.


Anonymous letter released to the public pertaining to falsified computer data, deficiencies in the emergency core cooling system and misrepresentation of the reactor vessel pressurization capabilities

The whistleblower's letter issued in early December, 1995, and sent to Robert Pollard of the Union of Concerned Scientists prior to its release to the general public is the single most important document pertaining to the twilight of the nuclear era among all the reports, journal articles and research papers cited and annotated within RADNET. In one short year, this revealing fragment of information has had a vast impact on public awareness about the policies and practices of the nuclear industry. The person who blew the whistle on MYAPC, YAEC, and the NRC opened a vast Pandora's box of safety issues, the ramifications of which will continue for generations. The full copy of this letter is preceded by an introductory letter by the Union of Concerned Scientists.

USCS Cover Letter


December 1, 1995

Mr. Uldis Vanags
State Nuclear Safety Advisor
Maine State Planning Office
184 State Street, Station #38
Augusta, ME 04333

Dear Mr. Vanags:

I am writing to bring to your attention a matter that is of utmost importance in determining whether operation of the Maine Yankee nuclear power plant will pose an unacceptable risk to the health and safety of the public.

I have received documentation, purportedly from a longtime employee of the Yankee Atomic Electric company, indicating that the management of Maine Yankee deliberately falsified reports to the U.S. Nuclear Regulatory Commission in order to receive approval of an increase in the reactor's maximum allowable power level. Specifically, the individual asserts that management officials manipulated computer calculations to avoid disclosing that the emergency core cooling systems at the Maine Yankee plant are inadequate to prevent overheating of the reactor fuel following a small break loss-of-coolant accident. The individual also asserts that the Yankee Atomic Electric Company fraudulently modified its analysis of the reactor containment building to avoid disclosing that a large break loss-of-coolant accident will pressurize the building above the pressure that it was designed to withstand.

It is apparent that this information was provided by someone who is knowledgeable of the subject matter and has access to documents that are not publicly available. It is also apparent that the person knows that it is the responsibility of the U.S. Nuclear Regulatory Commission to ensure public safety, but has concluded, as I have, that the NRC fails to fulfill that responsibility. I assume that this information was provided to the Union of Concerned Scientists because the individual wishes it to be made public. Therefore, I am distributing this letter and the individual's three-page letter to the public.

A copy of that unsigned, undated letter and copies of the other five documents that I received earlier this week are enclosed. The handwritten notations were on the documents before I received them. I trust that you will make these documents available to the U.S. Nuclear Regulatory Commission and the citizens of Maine.

I urge you to recommend that the State of Maine take the position that the Maine Yankee plant should not be permitted to resume operation until a thorough, factual investigation of the individual's allegations is completed and made available for public scrutiny. I am convinced, based on 26 years of experience, that the NRC will not conduct such an investigation unless the State of Maine demands it.


Robert D. Pollard Nuclear Safety Engineer

Washington Office: 1616 P Street NW Suite 310. Washington, DC 20036 (202)332-900 FAX: (202)332-0905
Cambridge Headquarters Two Brattle Square Cambridge, MA 02238 (617)547-5552 FAX:
(617)864-9405 California Office 2397 Shattuck Avenue Suite 203 Berkeley, CA 94704 (510)843-1872. FAX (510)843-3785

Anonymous Report of Safety Violations at Maine Yankee

Dear Sir,

I must report to you some of the flagrant violations of NRC regulations by Yankee Atomic Electric Company (YAEC). I have worked at YAEC for several years, with each passing year a belief that NRC is a nuisance as an organization and its staff technically incompetent, has become stronger at YAEC. Surely, YAEC's management has actively supported this belief and jeopardized public safety on several occasions. The disregard for public safety is manifested by the temerity with which Maine Yankee Power Plant's rated power was increased from 2630 MWth to 2700 MWth in 1989. YAEC's management knew that the Emergency Core Cooling System (ECCS) and the containment system of Maine Yankee (MY) did not meet the licensing requirements even for the pre-1989 power rating of 2630 MWth, never the less they made misrepresentations to NRC and obtained the license to operate MY at 2700 MWth. The deficiencies in ECCS and containment have still not been rectified. To ensure public safety, NRC should immediately derate the plant to 2400 MWth, its original power, and fine Maine Yankee.

Deficiencies in ECCS: As a consequence of the Three Mile Island Accident (TMI), NRC issued a set of requirements for the nuclear power plant licensees in its report NUREG 0737 (Reference 1). Item II.K.3.30 of this report required all licensees to upgrade their method (computer code) for analyzing the Small Break Loss-Of-Coolant-Accidents (SBLOCA's), and Item II.K.3.3 1 required the licensees to use the new method to assess their ECCS's performance during SBLOCA's.

To meet the requirement II.K.3.30, YAEC spent several years (1980 to 1983) to develop the RELAP5YA(PWR) computer code (Reference 2). This code was able to predict the LOFT SEMIS CALE and other experiments reasonably well. However, preliminary SBLOCA analysis of the Maine Yankee plant with this code showed that the plant's ECCS is grossly inadequate, i.e., calculated peak clad temperatures (PCTs) were higher than 2200 0F. MY management refused to even discuss the possibility of upgrading the ECCS. Hence YAEC did not submit the code for NRC review. Between 1983 and 1987, YAEC analyzed and re-analyzed these MY accidents, made modifications to the computer code, but with any reasonable code modification and input parameters the results showed that Maine Yankee ECCS is inadequate, i.e. the fuel rod cladding temperature was calculated to exceed 2200 0F during the LOCAs. As a last resort, in 1987, YAEC considered scrapping the code and approached Combustion Engineering (CE) to perform the analysis with its (CE's) new method to show adequacy of the MY's ECCS. Alter some preliminary analysis CE turned down the offer. At this point, under pressure from NRC to close out Item II.K.3.30, YAEC submitted to NRC the RELAP5YA(PWR) in 1987.

Consider the ethical bankruptcy: Knowing that once the new method is approved, it will have to be applied. The new method, at 263OMWth, will give MY, at best, very limited margins in PCT. This will eliminate the possibility of MY ever applying for power up-rate. Hence, while the new method was under review, despite the knowledge of the inadequacy of the ECCS, MY and YAEC management decided to apply for a power up-rate for MY in 1988 (Reference 3). To support this power up-rate application they used the small break analysis performed by CE in 1973, and told NRC that they were working on a new analysis, with 2700 MWth to meet the post TMI NRC requirements. YAEC staff was aware of the fact that applying for power up-rate while knowing the inadequacy of the ECCS, was dishonest. However, it was thought by the management that YAEC should get the approval for power up-rate before Mr. Pat. Sears, NRC project manager for MY, moved to a different position in January 1989. Mr. Sears was considered to be a particularly lenient person, therefore YAEC wanted to get the approval before he left. YAEC wanted to apply between thanksgiving and Christmas, when NRC staff is least vigilant. Open discussion of these considerations is indicative of a disregard for public safety. They applied for the power up-rate and got it, as planned.

In 1990, under pressure from NRC, YAEC decided to fulfill its commitment to perform a new small break analysis according to the post-TMI rules. This analysis, as expected, showed inadequacy of the MY ECCS. At this point, a new scheme was devised by Mr. R.K. Sundaram: we will do the break spectrum analysis with the Best Estimate (BE) assumptions, and perform an Evaluation Model (EM) analysis of the limiting break from the BE break spectrum analysis. Since the limiting break in the BE break spectrum analysis will not be the limiting break in the EM break spectrum, we will be analyzing a non limiting break and showing a lower PCT. The scheme was approved and put into action. It was decided that the scheme will be justified to NRC by stating that the BE analyses are useful for operator training etc., therefore, to conserve resources, the break spectrum analysis is done with BE assumptions and only the limiting break is analyzed with EM assumptions. In reality, making input changes from BE input to EM input and running the code did not take much. However, the results of this "limited EM" analysis gave PCT higher than 2200 F!

At this point, the conservatism in the decay heat and the break flow calculations were removed from the EM input deck. The decay heat was calculated by the un-approved (by NRC) 1979 ANS standard and the break flow was calculated with the RELAP5 critical flow model (not the licensing Moody Model). In calculations with these fraudulent models, decay heat was under estimated by the decay heat model, and the combination of non-licensing break flow model with the licensing assumption of one ECCS train assured that we were analyzing a non-limiting break. In fact we assured that we did not even analyze a realistic accident scenario.

The results of analysis with the above non-conservatism's were presented as 95% confidence level results. This is fraudulent, RELAPS was approved by NRC only as a licensing code (with several stipulations, indicating lack of confidence in the code). Also, the method of performing BE LOCA analysis to obtain results that are considered as 95/95, is completely different. YAEC management, specifically R.K Sundaram, clearly defrauded NRC in this regard. After completing this analysis Mr. Sundaram and other YAEC officials reported to NRC that MY ECCS performance was satisfactory, and all post-TMI and licensing requirements have been met. NRC simply acknowledged this report. The Maine Yankee plant is operating on the basis of this fraudulent analysis at 2700MWth. I hope an occasion to use ECCS does not arise.

Alter the TMI accident, nuclear industry declared that it had learned its lesson from the accident and will use the experience to improve the public safety. In case of YAEC, it was doing every thing to cover up, rather than repair, the deficiencies in the safety systems exposed by TMI.

Deficiencies in Containment System: The containment design analysis for Maine Yankee was performed by Stone and Webster Co. for a design power of approximately 2430 MWth (1970). For this analysis it was assumed that a hot leg LOCA would result in maximum possible containment pressure, and the maximum pressure from such a break was calculated to be less than 55 psi. Hence MY containment was designed for 55 psi.

In the 1970s MY applied for two power up-rates, from 2430 MWth to 2550 MWth and then to 2630 MWth. For these power up-rates, a containment analysis was performed with the help of Combustion Engineering (CE). This analysis showed that during a cold leg guillotine break the containment pressure would exceed the design pressure (55 psi). Specifically, the mass and energy released to the containment during the reflood period of the LOCAs caused the containment pressure to increase beyond the design pressure. During the reflood period a significant source of energy is the hot water contained in the secondary side of the steam generators. YAEC decided to fraudulently exclude from the calculations this energy. Additionally, the containment free volume was assumed to be highest of the estimates (lower bound, best estimate and upper bound) given by Stone and Webster Co. These tricks in the safety analysis produced acceptable results and the plant was up-rated to 2630 MWth

In 1985,86,87, preliminary analyses (performed by L. Schor) had shown that the MY containment could not safely contain the mass and energy released during a LOCA from a power level of 2630 MWth. This did not deter the YAEC management from applying for the power up-rate in 1988. The YAEC management indicated to NRC that during operation at 2700 MWth the average temperature of primary coolant was going to be maintained at the same value as it was for operation at 2630 Mwth (Reference 3). This implied that the energy content of the primary coolant was not going to change, hence the containment response to LOCA from 2700MW was going to be the same as that from 2630 MWth. Since the containment analysis was considered acceptable for 2630th it would also be considered acceptable for 2700 MWth. This would be a fair argument, if the fluid mass on the hot side of the primary system was equal to that on the cold side, and if there was some margin in the existing containment analysis. However, the public safety concerns were put aside and power up-rate was gotten.

I think these violations of NRC regulations are serious enough to derate the MY plant and to levy fines against YAEC and MY. Also, the management, particularly Mr. Sundaram who used these activities for self promotion, should be seriously reprimanded.

2. 11RELAP5YA, A Computer Program for Light Water Reactor System Thermal-Hydraulic Analysis" YAEC 1 300P.
3. Maine Yankee Power Uprate Application, December 1988.

The Peter Atherton Letter of November 15, 1996
to the Center for Biological Monitoring

A friend provided me with your RADNET nuclear information from the internet, which I personally don't yet have access to.

For your info, I blew the whistle in 3/78 on Maine Yankee within the executive branch of the federal govt. to the White House. My evaluation covered fire protection and raised safety concerns thruout the entire plant while I worked for the U.S. Nuclear Reg. Comm'n. I suggested solutions.

As a GS-13 engineer I was subjugated, my mental health was both threatened and challenged, and the evaluation never made it to the public document room after I was fired in 5/78. I checked after the 1991 fire. Maine Yankee is not my idea of a model nuclear power station. But they are not alone. If you are truly interested in nuclear safety, I could help. If you are not or you are a facade, pass this letter to a concerned group who is interested in nuclear safety. I sacrificed my job & ultimately my family for nuclear safety.



Center for Biological Monitoring. (1996). A Summary of Safety Concerns: Maine Yankee Atomic Power Company Steam Generator Sleeving Project 1995, Re: Maine Yankee-NRC Meeting of September 14, 1995 Steam Generator Sleeving Update.

A complete copy of this summary is contained in Appendix A of the hard copy edition of this publication.


The following anotated citation is the emergency response plan that would be implemented in the case of a nuclear accident at Maine Yankee Atomic Power Company. This citation is followed by two additional reports pertaining to actions implemented during a nuclear accident at MYAPC. These three reports are highly technical and our review of this literature is not easy reading; RADNET readers may want to skip ahead to the remaining NRC reports and environmental organization critiques which follow the Maine Radiological Emergency Response Plan review and which document the ongoing safety controversies at MYAPC.

Maine Emergency Management Agency. (August 18, 1995). State of Maine Radiological Emergency Response Plan, Volumes 1-9. (08/18/95, Rev. 3). Maine Emergency Management Agency, Augusta, Maine.

  • This plan is a vast nine volume compendium of directions, instructions, evacuation plans, regional and intergovernmental compact arrangements, accident assessments, notification and response activities, laboratory analyses, field monitoring procedures, protective action guidelines and other detailed directives pertaining to the implementation of emergency planning procedures in case of an accident at Maine Yankee Atomic Power Company. Circulation and distribution of this report is restricted to authorized persons on a "controlled document distribution list ... the responsibility of the Maine Emergency Management Agency (MEMA)." (Vol. 1, pg. iii).
  • Accident classification levels range from unusual events, alerts, and site area emergencies to a general emergency, with the area surrounding Maine Yankee divided into three zones:
  • PRIMARY EMERGENCY PLANNING ZONE: an area within a 10 mile radius from the power plant for which there are specific evacuation plans.
    SECONDARY EMERGENCY PLANNING ZONE: a zone beyond the primary emergency planning zone of approximately the same size where additional protective action plans may be implemented.
    INGESTION PATHWAY ZONE: "designated as the zone beyond the emergency planning zone, where protection actions are required relative to the food chain. Unless changed by rule, the ingestion pathway zone shall be a circle of a fifty mile radius, centered on any nuclear power plant." (Vol.1, pg. XV 15).
  • The two emergency planning zones are characterized by a licensee emergency operating center (EOC) at the corporate headquarters in Brunswick, a state EOC in Augusta, and eleven county and local emergency operations centers.
  • All information pertaining to the radiological impact of any accident originates from the licensee emergency operations center in Brunswick.
  • This RERP provides no description or inventory of isotopes produced at the Maine Yankee Atomic Power Company which are available for release in an accident scenario. No mention is made that 300,000,000 curies of radioactivity are available in the event of a quick release accident nor that the 100,000,000+ curies of long-lived radionuclides available for release during a major accident include millions of curies of plutonium isotopes (238Pu, 239,240Pu, 241Pu and 242Pu).
  • This report uses protection action guidelines derived from the FDA and published in the Federal Register. The first PAG is called the preventive PAG and is defined as "derived response levels for the milk-pathway preventive PAGs, with infants as the critical segment of population" (Vol. VII, Ingestion Pathway, pg. 29 excerpted from Reference: 47 FR 47073, Oct. 22, 1982); the emergency protection action guidelines (PAG) is a second "derived response level," and uses contamination levels that are one order of magnitude higher than the preventive PAGs in the following table. The emergency PAGs are reproduced in RADNET, Section 6 with additional comments as a component of the annotation of the 1982 FDA guidelines.
Preventive Protection Action Guideline for Infants: Milk Pathway
131I 134Cs 137Cs
Initial Deposition
(microcurie/square meter)
0.13 2 3
Forage Concentration
0.05 0.8 1.3
Peak Milk Intake
0.015 0.15 0.24
Total Intake
(microcurie/accident, 1-30 days)
0.09 4 7
  • Total accident intake is for a period of time not specified, but up to 30 days, at which time it is assumed that affected individuals will be evacuated and/or uncontaminated food will be substituted for contaminated food. If the total accident intake does not meet the preventive protection action guideline (PAG) total, there is no need to impose the suggested preventive action guidelines. The FDA guidelines do allow implementation of the PAG before the guidelines are surpassed, but the point of these guidelines is to specify that intake level which will result in meeting or exceeding the derived response level, at which time the effective dose equivalent is reached (1.5 rem to the thyroid; .5 rem to the whole body, bone marrow or any other organ).
  • It is important to note both the preventive and emergency PAG's are only for one pathway/5 isotopes (SR 90 and SR 89 are also included in the FDA guidelines). No consideration is given to the impact of pathway exposure from inhalation, immersion, absorption (ground shine, cloud shine), drinking water, etc., nor for the exposure to short lived radionuclides in the above pathways. These guidelines also ignore the exposure resulting from other radionuclides released during a nuclear accident e.g. barium, lanthanum, ruthenium, etc. which also tend to bioaccumulate in the food chain.
  • When ground deposition or forage and food contamination reach the above cited levels, the preventive action guidelines (PAG) suggest a number of preventive actions:
    • pasture control (use uncontaminated feed)
    • withhold milk until short-lived radionuclides decay (no mention is made of 137Cs decay time; 1/2T=30 years)
    • wash, brush or scrub vegetables, polish and mill grains, avoid use of surface water, and process other foods to remove surface contamination.
  • These are the same routine preventive actions associated with the old (1961) FRC radiation PAGs which are no longer mentioned in the current FDA-FEMA guidelines.
  • The RERP then goes on to denote emergency PAGs which are one order of magnitude greater than the preventive PAGs listed above. If contamination levels of 131I reach 150,000 pCi/liter for infant's milk and/or total accident dietary intake of 134,137Cs for an adult reach 150,000,000 pCi (150 µCi), the RERP report recommends, "isolating food containing radioactive material to prevent its introduction into commerce and determine whether condemnation or another disposition is appropriate" rather than washing and peeling vegetables and storing milk, etc., as suggested for the lower levels of contamination listed in the preventive action guideline (Vol. 7, pg. 25).
  • While these guidelines might seem reasonable to anyone not familiar with the vast literature of radioactive contamination of the environment, RADNET readers are urged to review RADNET, Section 6, Radiation Protection Guidelines. The FDA action level for radioactive contamination in foodstuffs is 10,000 pCi/kg; on May 16, 1986, the FDA issued a specific supplemental guideline for 131I in infant foods: 1,500 pCi/kg for contamination in imported foods. This new guideline was issued as a component of an ad hoc FDA response to the Chernobyl accident and expressed "levels of concern," which also included a guideline of 8,000 pCi/kg for 131I in adult foods. After the Chernobyl accident, the FDA implemented the 10,000 pCi/kg general guideline for contamination in foodstuffs; this became the effective action level even though it specifically contradicted the suggested preventive and emergency PAGs contained in the RERP cited above.
  • The extraordinary protection action guideline issued in this radiological emergency response plan (RERP) is expressed in microcuries per kilogram (millionths of curies, 10-6), six orders of magnitude greater than the usual delineation of contamination expressed as picocuries per kilogram (millionth of a millionth, 10-12). The significance of this change in nomenclature is that an infant ingesting 390,000 pCi of radiocesium-134/137 per liter of milk (0.15 µCi + 0.24 µCi = 0.39 µCi = 390,000 pCi) is ingesting radioactive contamination at a rate 39 times greater than the FDA action level which was implemented as a component of the "levels of concern" issued after the Chernobyl accident. Even at 390,000 pCi/l, the revised FDA preventive action guidelines do not suggest seizure and destruction of contaminated milk as occurred with other foods contaminated with Chernobyl derived radiocesium, but only suggests storage of and/or reprocessing of milk at this level of contamination.
  • The emergency response level listed for infants for consumption of 134,137Cs over the duration of an accident lasting not more than 30 days, at which point contaminated food is actually withheld rather than washed or processed, is an extraordinary 110,000,000 pCi (110 µCi), in startling contrast to the National Committee on Radiation Protection (NCRP) guideline mandating action at 14,500 pCi/day for adults. Assuming the maximum 30 day period for total accident intake, the emergency action protection guidelines imply infants or pregnant mothers can safely consume 3,060,606 pCi/day. For infants' milk, the emergency action guideline in the Maine RERP is 3,900,000 pCi/liter of 134,137Cs, at which point milk would be "isolated," rather than "stored" (390 times greater than the FDA "level of concern").
  • The preventive action guidelines and emergency action guidelines in the Maine RERP for 131I are even more bizarre: while the NCRP guidelines suggest routine (preventive) controls starting at a daily intake level of 10 pCi of 131I per day, and additional controls beginning at 100 pCi of 131I per day (Range III: begin emergency controls), the Maine RERP begins preventive controls for 131I for infants at 50,000 pCi/kg for food and 15,000 pCi/liter for milk, with total intake of up to 90,000 pCi of 131I per accident before washing, brushing or peeling vegetables is suggested. The emergency action level for infants (withhold the food and milk) are one order of magnitude greater: 500,000 pCi/kg of 131I in food, 150,000 pCi/liter of 131I in milk, and 900,000 pCi 131I per accident intake, 300 times higher than the threshold for emergency action listed in the NCRP guidelines for daily 131I intake by adults, assuming consumption over the duration of a 30 day accident.
RERP 131I Action Guidelines for Infants

Preventive Protection Action Guideline (PAG):
Forage concentration: 50,000 pCi/kg: 
"wash, brush or peel to remove surface contamination" (Vol. 7, pg. 24)
(50,000 pCi/kg = 1,852 Bq/kg = 111,120 counts per minute (cpm)) 

Emergency Protection Action Guideline (PAG):
Forage concentration: 500,000 pCi/kg:
"isolate contaminated foods" (Vol. 7, pg. 25)
(500,000 pCi/kg = 18,520 Bq/kg = 1,111,200 cpm) 

  • These differences in the response levels of three sets of radiation protection guidelines (FRC 1961, FDA-FEMA 1982, and FDA 1986 "levels of concern"), all essentially issued by the same official source (Food and Drug Administration), are extraordinary examples of inconsistencies which undermine the credibility of an emergency response plan for domestic nuclear accidents and is among the more bizarre anomalies in radiation protection literature. These irrational and self-serving Maine RERP protective action guidelines are only one among many reasons why this RERP has and should have zero credibility during a nuclear incident. The controversial nature of these PAGs are further emphasized by the following protective action guidelines for authorized persons (additional discussion of these "official" protective action guidelines is contained in RAD 6).
Radiation Protection Guidelines for EOC personnel:

Authorized persons entering the emergency operation centers of either the licensee or the State of Maine are considered contaminated if their total body burden (external: on clothing) exceeds 300 counts per minute above background; extensive instructions are given in the RERP as to how persons entering the emergency operations centers should decontaminate themselves.

Decontamination Guidelines for Authorized Persons Entering an EOC Facility:

Abbreviated summary: Enter personal monitoring center; scan; if contaminated above 300 cpm dispose of contaminated clothing in low-level waste storage. If showering fails to reduce contamination below 300 cpm refer to follow up program: registration, dose recording, separate exit.

  • This Maine RERP 300 cpm-above-background contamination guideline is in startling contrast to the unusual, in fact anomalous, Maine RERP action guideline that does not suggest a response for an infant consuming contaminated milk until it contains 390,000 pCi of 134,137Cs (14,444 Bq); this translates to a count rate of 866,640 per minute per liter (cpm/liter); at this level of contamination, the Maine RERP suggests milk should be withheld or stored for reprocessing. The emergency response level for contamination of infants' milk is 8,666,640 cpm/liter; only at this level of contamination is isolation or destruction of the contaminated milk recommended.
  • The following quotations, excerpts and other desiderata should help illustrate why this emergency response plan should be given little credence in light of the lessons learned from the Chernobyl accident:
    • "The predominating nuclides for the ingestion pathway on a long-term basis (up to several days) are considered to be radioiodines. This is particularly true in that as distance is increased from the plant, particulates, if any, would fall out or wash out from the plume relatively close to the sight of release." (Vol. 7, pg. 2). (The Chernobyl accident illustrated that 137Cs (1/2T = 30 years) was the predominant ingestion pathway nuclide, and that fallout was hemispheric in its extent.)
    • "The Radiological Health Coordinator may be assisted in the assessment of the ingestion pathway by two Radiological Health Specialists, one located at the State EOC and one located at the Maine Yankee Emergency Operations Facility (EOF).... The Radiological Health Specialist at the Maine Yankee EOF will coordinate ingestion pathway decisions with accident assessment personnel of Maine Yankee... the Environmental Sampling Teams will be directed by the Radiological Health Specialist at the Maine Yankee EOF." (Vol. 7, pg. 6-9). (A near total lack of a sufficient number of trained radiological monitoring specialists is an important component of the lack of credibility of the Maine RERP.)
    • "Contaminated area boundaries will be identified by field monitoring teams...environmental sampling kits will allow the teams to perform radiation surveys... the Health Engineering Technical Laboratory in Augusta will serve as a central point for receipt of all environmental and food samples collected by the sample collection teams." (Vol. 7, pg. 15-16). (A Laurel and Hardy parody best describes the radiological surveillance techniques and procedures described in the Maine RERP.)
  • Laboratory sample analysis capacity is listed as: in emergency conditions, sample analysis time: 20 minutes; 72 samples per day (24 hour emergency operation). The backup Yankee Atomic Environmental Laboratory is listed as having an emergency capacity of 96 samples per day. (Vol. 7, pg. 17). (Laboratory capacity is insufficient even for routine sampling which can take as long as a thousand minutes. For how long will the one experienced lab technician in the Maine Health Engineering Laboratory {HEL} be able to analyze one sample per 20 minutes, 24 hours per day {emergency conditions}, and what credibility does such a primitive laboratory analysis system have for providing the radiological data needed to evaluate the patterns and amounts of deposition during a nuclear accident? How long before such data is available? What impact will the conflict of interests of EOC personnel have on their interpretation of such data? {See review of the ARAC program which follows.})
  • Among the most controversial components of the RERP plan is the contention that no contamination beyond the fifty mile ingestion pathway limit is expected from an accident at Maine Yankee. This astonishing assertion is completely contradicted by the erratic deposition of the Chernobyl accident plume components and their dispersion throughout the northern hemisphere and the wide dispersion of weapons testing fallout and Sellafield effluents which also respected no such arbitrary boundary. The assumption of a fifty mile ingestion pathway limit has no more credibility than an emergency action guideline of 390,000 pCi/liter of radiocesium in infants' milk.
  • Federal accident assessment response assistance consists of two components: aircraft provided by the DOE as a component of the Aerial Measuring System (AMS) (See the review of the AMS which follows.) "ready to apply state of the art remote sensing equipment to map large areas that may have been effected by an accidental release...as well as a computer based system, the Atmospheric Release Advisory Capability (ARAC)," based at the Lawrence Livermore National Laboratory, which uses "actual weather and terrain data to predict, on a regional scale, the transport, diffusion, and deposition of any radioactivity released to the environment" from an accident at Maine Yankee Atomic Power Company. (Vol. 7, pg. 44). This would be an extremely useful computer program were accurate real-time radiological surveillance data to be available to the LLNL program. The LLNL program, however, is limited to an armchair analysis of a nuclear accident, based on regional weather data and the accident release data provided by officials in the Emergency Operations Center (EOC). In the event of a nuclear accident at the MYAPC, the only source term estimates would derive from on site monitors; the sole real-time monitoring equipment in Maine consists of seventeen State of Maine maintained telephone pole mounted dosimeters located within the immediate environment of the Maine Yankee Atomic Power Company (+/- 1 mile), as well as 77 NRC/Maine Yankee thermoluminescent dosimeters (TLD's) which provide only monthly composites of ambient radiation levels. This primitive technology, virtually unchanged since the 1950's, provides a minimum amount of information for accidents that have the potential for hemispheric impact (Since the Maine RERP Laurel and Hardy radiological sampling teams will have little or no accurate data for the ARAC computer programs and most types of plumes will pass well above the Maine Yankee Atomic Power Company controlled stationary real-time monitors, most information about an accident at the Maine Yankee Atomic Power Company will have to come from secret aerial measuring systems (AMS) sponsored by the DOE. A much more sophisticated AMS is maintained by the National Reconnaissance Office (NRO), which now sends its remote sensing data to the recently incorportated National Imagery Management Agency (NIMA). See RAD 13 RADLINKS Part II D-1: US Intelligence Community Links. The nuclide specific ground deposition data collected by these agencies, especially the NRO, is unlikely to be available in an accident scenario. In fact NRC, FEMA, and state officials this editor has spoken with seem unaware of the existence of the more sophisticated remote sensing technology used by the NRO (The DOE's AMS may be limited to ambient radiation levels expressed as µR/hr; the capabilities of the NRO include much more comprehensive nuclide specific aerial surveillance capabilities). Will such secret data be shared with the public and even with authorized EOC personnel? How accurate will this data be, and how long will it take to carry out such a survey and process, interpret and communicate the data?
  • The following quotations help illustrate the Laurel and Hardy quality of radiological surveillance which might be attempted by the poorly trained Maine RERP personnel who might be available during an accident:
    • "Dry samples with field counts greater than 500 counts per minute (cpm) should be separated from other samples." (Vol. 7, Sec. D, pg. 55).
    • "Notify your supervisor if your 0-20 R Direct Reading Dosimeter reaches 1 R." (Vol. 7, Sec. D, pg. 61).
    • "Do as much preparation outside of the plume as possible... before entering the plume for sampling, determine which direction you will go to leave the plume... change gloves often to prevent cross contamination." (Vol. 7, Sec. D, pg. 67).
    • "Ensure engine is running before connecting air sample to battery." (Vol. 7, Sec. D, pg. 68).
    • "While driving to air sampling locations, continuously monitor radiation levels en route using the E-140N with the HP-210 probe on the dashboard against the windshield. If the count rate exceeds 5000 cpm, energize the RO-2 and monitor dose rates... If a dose rate of 500 mR/hr or greater is measured, obtain approval from the Radiological Health Coordinator before proceeding further or exit the plume and await further instructions." (Vol. 7, Sec. D, pg. 69).
    • "Once outside the plume area, reconnect the air sampler to the battery and let the sampler run about 30 seconds to purge noble gases from the cartridge." (Vol. 7, Sec. D, pg. 71).
    • "Before returning to the EOC, survey your vehicle and yourself for contamination and check your direct-reading dosimeters. If contamination is found, call the team organizer." (Vol. 7., Sec. D, pg. 72).
    • "The radioactive iodine results you obtain from the silver zeolite count are very important in determining the protective actions that should be recommended for public protection. These samples should be carefully handled, accurately analyzed and promptly reported." (Vol. 7, Sec. D, pg. 72).
    • "If reading is >3000 cpm, the sample is rejected, placed in a clean plastic bag and set aside in a remote area reserved for highly contaminated samples. These samples will only be analyzed at the request of the Radiological Health Coordinator or the Chief Chemist." (Vol. 7, Sec. E, pg. 11).
  • "Individuals who have or are suspected to have received radiation doses or contamination equal to or exceeding the following guidelines will be referred for medical evaluation and treatment as soon as possible." Levels of radiation exposure requiring medical attention are listed as follows:
  • Total effective dose equivalent (TEDE): 5 Rem
    Committed dose equivalent (CDE) to the thyroid from radioiodine: 25 Rem
    Skin Surface Contamination: >10,000 cpm on a CDV-700 or similar instrument (Vol.7, Sec. D, pg. 77).
  • This RERP is based on an antiquated pre-Chernobyl conception of nuclear accidents, the effluents from which are not expected to penetrate a mysterious and arbitrary fifty mile ingestion pathway boundary. The radiation protection guidelines in this emergency plan, expressed in microcuries rather than picocuries, have a frightening disconnection from the long-standing guidelines of the National Committee on Radiation Protection, as well as the "levels of concern" the FDA issued after the Chernobyl accident.
  • Radiological monitoring is licensee controlled and limited to 17 close in, real-time telephone pole mounted dosimeters and 77 TLD's which cannot provide either nuclide specific air concentration data or any far field information about any type of nuclear accident at the Maine Yankee Atomic Power Company. The location and number of thermoluminescent dosimeters express NRC, licensee and state assumptions about the limited impact of a nuclear accident at MYAPC.
  • This radiological emergency response plan therefore involves the mobilization of hundreds of persons to staff emergency operations centers in preparation for evacuating tens of thousands of persons during a nuclear accident in which almost no accurate and reliable real-time data is available about radioactive plume size, movement or characteristics. This RERP demonstrates the near total incapacity to evaluate both near site and far field ground deposition of radioactivity; in any accident scenario, this deposition will inevitably be uneven and erratic and have the potential for contamination of any and all sections of Maine. This RERP could easily serve to increase exposure of local residents to an accident plume rather than to mitigate exposure.
  • The Maine RERP suffers from the same lack of credibility as other components of MYAPC operations. The recent repair of the steam generators serve as a symbol of the self-deceptions and evasions of the Maine RERP: state of the art resleeving of a small portion of aging steam generator tubes resulted in radical discrepancies in the service life expectancy of the resleeved steam tubes versus the parent tubes in aging steam generators subject to multiple microdegradation mechanisms. The safety and reliability of repaired units were represented (by the licensee, the NRC and the State Nuclear Safety Advisor) as equal to or superior to new steam generators, regardless of sludge deposits and corrosion damage in the unrepaired portions of the older steam tubes. The anomalies in the radiation protection guidelines are consistent with the inadequacies within the Maine RERP, waste funding evasions, phony ECCS and containment analyses, fraudulent power up-rates, negligent state and federal oversight by complicit officials within a predatory political milieu. As a result, the MYAPC fiasco is essentially an accident in progress in which everyone loses except a few wealthy investors. As the safety envelope is stretched to the extreme in the desperate race for nuclear energy profits, the chance of a major nuclear accident increases daily.
  • The recent spate of equipment problems at MYAPC as well as the results of the extraordinary not top to bottom Independent Safety Assessment Team (ISAT) inspection are the most recent manifestations of this lack of credibility. (See review of the ISAT report in this section of RADNET).
Extensive additional information about radiation protection guidelines is contained in RAD 6.

ARAC (Atmospheric Release Advisory Capability), Lawrence Livermore Laboratory, Livermore, CA.

ARAC is a key component of the Maine RERP annotated in the previous citation. ARAC computer modeling will provide predictions about the behavior, characteristics and significance of a Maine Yankee Atomic Power Company derived plume of radioactive contamination. The following information is from an unpaginated, unreferenced Lawrence Livermore National Laboratory/ARAC public relations fax and is followed by observations by the editor of RADNET:

  • Located at the National Atmospheric Release Advisory Center, ARAC's purpose is "assessment of accidents and events involving the release of hazardous material, i.e. radiological, chemical, biological, etc., to the atmosphere.... and includes the delivery of graphic dose or exposure assessments to emergency decision makers to assist in the protection of populations at risk.... ARAC maintains and operates the NARAC, a network of ~40 remote site computers and radiological systems and communication links to local, regional and global meteorological data."
  • Unfortunately, the success of ARAC computer models relies on competent collection of large amounts of accident release data (real-time air concentration data and total ground deposition data) over a very large geographical area. Other than the ARMS (Aerial Radiological Measuring System), reviewed below, and close-in licensee monitoring, the ARAC program has no reliable source of radiological monitoring data in Maine on which to base any accurate assessment of a plume derived from a Maine location.
  • Rapid, accurate radiological surveillance data collection from a number of low-flying aircraft could partially fulfill this requirement for effective ARAC plume pathway predictions, but this is extremely unlikely (See ARMS review for further comments).
  • RADNET has reviewed an existing ARAC report pertaining to the Chernobyl accident (See RAD 10); no other ARAC reports have been encountered which document radiological releases to the environment. The ARAC report is a good general overview of the Chernobyl accident plume pathway, but is limited to an assessment of 131I and 137Cs dose and dry deposition estimates for Europe and Scandinavia only, with assessment of 131I deposition in the United States a second objective. "This is an informal report intended primarily for internal or limited external distribution." (Dickerson, M.H. and Sullivan, T.J., July, 1986, ARAC Response to the Chernobyl Reactor Accident. Lawrence Livermore National Laboratory).
  • The ARAC was clearly unprepared for a nuclear accident of the dimensions of the Chernobyl release. The ARAC report on Chernobyl, which was issued just a few weeks after the accident, contains overly generalized, incomplete and often inaccurate deposition estimates which were based on the data collected at only a few far-field sampling locations with real-time nuclide specific monitoring capabilities. This data was combined with a hodgepodge of computer transport and diffusion models to make nuclear materials release estimates of a questionable nature. The resulting ARAC report, while an interesting survey of ARAC activities, illustrated that accurate information about the radiological deposition patterns and contamination levels was, in fact, not available in sufficient quantity to accurately assess the actual extent of the erratic far-field deposition patterns which the Chernobyl accident produced.
  • In the case of the Maine RERP report cited above a similar if not much more extensive lack of radiological monitoring data will impede any ARAC assessment of a radiological emergency in Maine.
  • The following quote from the ARAC Chernobyl report (1986) gives a description of a milieu which is not likely to have improved for the better since this date:
    • "Although ARAC had many of the resources necessary to address a problem of this magnitude (Chernobyl), they were not readily available (i.e., implemented in an operational emergency response system) and interfaced for calculating real-time assessments. ARAC's scope (in support commitment and resources, i.e., personnel and computers) is presently scaled to support domestic accidents on a regional scale for approximately 50 specific sites. A planned upgrade and expansion to a full response 'national' center has been planned for several years, but has not been funded. Such a center would have the resources (calculational, data-flow/data-storage, model, and staff) to effectively respond in 'near real-time.'" (Dickerson and Sullivan, 1986, pg. 1-2).
  • If little or no data is available pertaining to a Maine Yankee Atomic Power Company derived plume pathway and its isotopic components, how useful will an upgraded ARAC program be in assessing an accident at this location?
  • The Lawrence Livermore National Laboratory has been solicited for additional citations pertaining to ARAC reports on radiological releases. LLNL can be accessed through RAD 13: RADLINKS Part II D-2: US Department of Energy Laboratory Servers; however, only a few pages of sanitized literature are cited in the LLNL publications list available to the general public.
ARMS. (August 10, 1973). ARMS: Aerial radiological measuring system: Radiological survey of the area surrounding the Maine Yankee Atomic Power Plant, Wiscasset, Maine, date of survey: 23,25 September 1971. EGG-1183-1605. Las Vegas Area Operations, EG&G, Las Vegas, NV.
  • "The present survey was made as part of a continuing nationwide ARMS program started in 1958 to monitor radiation levels surrounding facilities producing or utilizing radioactive materials. This is the first such survey performed in the MYAPC area." (pg. 1).
  • "The detection system on board the aircraft collects gamma-ray gross-count and spectral data on each flight line of the survey. The gamma radiation and aircraft position information are processed by a computer into an isoexposure contour map of the area surveyed." (pg. 1).
  • "The raw data from the gross gamma count and the gamma spectral measurements are permanently recorded on paper tape, which is computer processed and analyzed to characterize the radiological properties of the area surveyed. Using an altitude-dependent conversion factor obtained from prior calibration measurements, the raw gross-count rate is converted to exposure rate (µR/hr) at three feet above ground." (pg. 4).
  • A Beechcraft Twin Bonanza was flown 9.3 hours over 530 square miles at an altitude of 300-500 feet. The survey resulted in an extremely primitive gamma exposure rate contour map; the pre-operational terrestrial data range was 2-12 µR/hr.
  • This survey also produced nuclide specific gamma ray spectral data which consisted of isotopes consistent with normal terrestrial background radiation. (Table 3, pg. 13).
  • This report includes a wonderful photograph of antique computer equipment circa 1968. National Reconnaissance Office (NRO), Defense Intelligence Agency (DIA), and DOD/DOE equipment has been vastly updated since this photograph was taken, unlike the circa 1948 NRC regulations governing radiological surveillance in the vicinity of nuclear power installations. (NRO and DIA surveillance includes high-orbit and low-orbit satellites, as well as, where possible, low-flying aircraft.)
  • This report includes only two bibliographic citations which pertain to the ARMS program, both of which follow this citation. Other citations will be posted by RADNET if and when they become available.
  • This ARMS report was obtained by the editor of RADNET as a component of a Freedom of Information request made to the NRC in January of 1996 and ends a twenty year search for an aerial survey of the Maine Yankee Atomic Power Company area. Numerous previous requests for ARMS reports were made to the NRC and the DOE including previous FOI filings. These were always met with denials that such reports existed.
  • No ARMS post-operational aerial surveillance reports are now available, nor are any known or acknowledged by NRC or state of Maine personnel queried by this editor.
  • NRO-NIMA fly-over data pertaining to the post-operational surveillance of the Maine Yankee Atomic Power Company is unlikely to be released due to the necessity of maintaining the confidentiality of other ARMS type surveys in more contaminated U.S. locations, as well as for other security reasons. An ARMS type survey could play a key role in an incident involving the Maine RERP or any other federal RERP; however, secrecy prevents an accurate assessment of either ARMS (DOE) or NRO-NIMA aerial reconnaissance capabilities, equipment, personnel and readiness.
  • In the case of a radiological emergency at the Maine Yankee Atomic Power Company, what information would these top-secret NRO/ARMS programs provide to either the general public or designated authorized emergency personnel when such data is presently such a closely guarded secret? (In fact, if the NRC will not even mandate state of the art real-time isotopic stack monitors at MYAPC, what chance is there that any other agency will provide accurate real-time data about radiological effluents which derive from this location?)
  • ARMS is only one component of a three dimensional radiological surveillance program, which, to be effective in an emergency, must include nuclide specific real-time air concentration as well as nuclide specific monitoring of the abiotic and biotic environments over a wide geographic area. The financial resources and the political mandate necessary to implement such a program are not currently available.
Aerial radiological measuring systems (ARMS) - systems and procedures employed through FY71 (AEC Report No. ARMS-71.6, in preparation).
  • Referenced in ARMS, this report will be reviewed and annotated by RADNET, if and when it should become available.
Atherton, P.J. (March 1, 1978). Maine Yankee fire protection evaluation. Prepared for the United States Nuclear Regulatory Commission, Washington, D.C.
  • "In general plant areas, redundant divisions of safe shutdown/safeguards cables are routed in the same open ladder type aluminum cable trays with an aluminum partition separator. This layout is contrary to all Nuclear Regulatory Commission safety requirements, especially those within Regulatory Guide 1.75." (pg. 1).
  • "Equipment required for safe shutdown is located in the turbine building, a non-safety related area." (pg. 1).
  • "Redundant divisions of equipment and cabling are located in the same fire area, making them vulnerable to a design basis fire." (pg. 1-2).
  • "The use of highly combustible and explosive chemicals throughout the plant appears to be commonplace." (pg. 2).
  • "A seismically qualified dedicated safe shutdown system completely independent of all plant areas outside containment is required." (pg. 2).
  • "The fire protection system within the control room is judged to be inadequate to prevent functional loss of redundant safe shutdown systems. ...the walk-through instrument tunnels and the cable tray risers contain redundant divisions of the same equipment or cables. A fire in these places if not extinguished early may prevent safe shutdown of the reactor." (Control Room, pg. 2).
  • "A design basis fire in this room would eliminate the safe plant shutdown capability. Without the low pressure safety injection pumps which also serve as the residual heat removal pumps the plant is unable to achieve cold shutdown." (Containment Spray Pump Area, pg. 1-2).
  • "A design basis fire in this room could become large enough to damage redundant divisions of electric cable and collapse the aluminum cable trays. This fire will damage cabling essential to safely shutdown the reactor." (Protected Cable Tray Room, pg. 1).
  • "Most of the combustibles are located on the ground floor. Some of these combustibles are lube oil, drums of cotton clothing and rubber wear, wood, oxygen-acetylene units, cabling, wax, wax stripper, sealant, cleaner, waste oil and hydrogen gas. ... The turbine building contains a high heat load with a potential for collapsing the building. The complete loss of the component cooling water pumps and service water pump cabling would leave no way of achieving safe shutdown." (Turbine Building, pg. 1-2).
  • This recently rediscovered report from 1978 addresses the need to separate redundant cables essential to safe plant shutdown and other safety issues. The failure of the NRC to address these issues in 1978 emphasizes the long duration of unsafe reactor operation which continued unnoticed during the recent Independent Safety Assessment Team analysis.
Atherton, P.J. (November 15, 1996). Personal communications to the Center for Biological Monitoring.
  • See the copy of this letter which follows the Whistleblower's letter above. A copy of this letter was forwarded to Ray Shadis, Friends of the Coast, who tracked down the original report and provided copies to the NRC, state officials and the press. A comprehensive summary of Atherton's observations of safety and design flaws, as well as the resulting harassment that he suffered was published in the Lincoln County Weekly, Box 1287, Damariscotta, ME on March 6, 1997. This article was written by Kris Ferrazza and is one in a series of stories on MYAPC during the last several years which in their totality provide an important record of events documenting the MYAPC debacle. No other paper in Maine has provided anywhere near the detailed chronicle of events at MYAPC as this small weekly publication.
Burson, Z.G., Boyns, P.K. and Fitzsche, A.E. (1972). Technical procedures for characterizing the terrestrial gamma radiation environment by aerial surveys. EG&G/LVAO Report No. 1183-1559.
  • Also referenced in ARMS, this report will be reviewed and annotated by RADNET, if and when it should become available.

Brack, H.G. (Ed.). (1986). A review of radiological surveillance reports of waste effluents in marine pathways at the Maine Yankee Atomic Power Company at Wiscasset, Maine - 1970-1984. Pennywheel Press, Hulls Cove, ME.

  • The first of many publications of the Center for Biological Monitoring on the Maine Yankee Atomic Power Company.
  • MYAPC was the subject of extensive research under the auspices of the Sea Grant Program, the objective of which was studying the feasibility of growing oysters in the (heated) liquid effluents of MYAPC.
  • The independent research cited and annotated in this publication documented extensive reactor derived radionuclides in the MYAPC liquid effluents which accumulated in both the abiotic and biotic environment in the vicinity of the liquid effluent outlet. This report also contains a review of NRC, state and licensee radiological surveillance reports.
  • Numerous citations reviewed in this bibliography are also annotated in this section of RADNET as well as RAD 11: Major Plume Source Points, Section 4: Nuclear Power Plants.
  • Chapter II on isotropic characterization of high level and transuranic waste in reactor spent fuel has been scanned and may be viewed online.
Christine, K. (March 8, 1997). 1978 Dangerous Year for Maine Residents. Personal communications to an unidentified journalist.
  • The following Email message from Kris Christine to a Maine journalist and the Center for Biological Monitoring is reprinted (without permission) by RADNET because it provides a concise summary of a key component of the collapse of the MYAPC pyramid scheme: the unreliability of NRC and state of Maine assertions about the past and present safety of this aging facility.
  • "I was just going through some documents and suddenly realized what an extraordinarily dangerous year 1978 was for the citizens of Maine. In March 1978, Peter Atherton identified and reported significant cable separation issues throughout Maine Yankee. Maine Yankee did not reroute these cables, coat them with fire suppressive sealant, or install the Protectowire detection system they proposed themselves.
Ford, D. F. and Kendall, H. W. (1974). An assessment of the emergency core cooling systems rule making hearings. Friends of the Earth, Inc., San Francisco.
  • This decades old publication raises important safety questions which have never been fully addressed by the NRC, and, in view of the current controversy about falsified data pertaining to the MYAPC ECCS, this review of emergency core cooling system capabilities is still current.
Friends of the Coast Opposing Nuclear Pollution. (November 19, 1996). A Citizen Review & Critique US Nuclear Regulatory Commission: 1996 Independent Safety Assessment Maine Yankee Atomic Power Station: Written Comments. Post Office Box 98, Edgecomb, Maine 04556.
  • This is a very important compilation of comments and criticisms of the NRC sponsored 1996 independent safety assessment of the Maine Yankee Atomic Power Station presented at a Nov. 19, 1996, meeting in Wiscasset, Maine.
  • Friends of the Coast provided an essential service by compiling these critiques from a number of experts with prior experience in the nuclear industry and then presenting their comments in this report as well as at the Wiscasset meeting.
  • The critiques in these written comments focus on the failure of the NRC to address the reality that the MYAPS "is not in compliance with its design and licensing basis" and "refuse[s] to even attempt to directly address the issue of compliance with regulations" (Executive Summary pg. 1). The critiques in this citizen review include the observations of the six member panel who presented at this meeting as well as those of seven other interested parties.
  • The combination of the ISAT report and the subsequent NRC briefing (see United States Nuclear Regulatory Commission, 1996, Independent Safety Assessment of Maine Yankee Atomic Power Company), and this Citizen Review and Critique provide a long overdue opportunity to begin to assess the many safety deficiencies which characterize nuclear power generation in the United States as well as the gross oversight failure of the NRC in their supervision of these facilities.
  • Participants in the citizen review included Paul Blanch (former nuclear engineer with Northeast Utilities), Robert J. Fitzgerald (nuclear system test engineer), Jonathan Block (attorney for New England Coalition Against Nuclear Pollution), Henry Myers (former senior staff member of the US House of Representative's Committee on Interior and Insular Affairs), and David Lockbaum (Senior nuclear safety engineer, Union of Concerned Scientists).
  • This critique along with the ISAT report which prompted these written comments are essential reading for any persons concerned with the current safety status of any NRC licensed nuclear energy generating facility.
  • A selection of comments from the Citizen Review And Critique:
    • Paul M. Blanch: "From my perspective, the NRC is again covering their own incompetence and embarrassment created by UCS's disclosure of falsified LOCA codes and the NRC's Inspector General's event inquiry dated May 8, 1996 ... it is clear from this report the plant [is] in noncompliance with both the design and licensing bases. The conclusion of '[C]onsidered adequate for operation' is totally unsupported by any objective evidence and is contradicted by the report itself." (pg. 38).
    • Kris L. Christine: "Contrary to Dr. Jackson's remarks she and the NRC staff are knowingly allowing Maine Yankee to operate in violation of regulatory requirements. ... the NRC flagrantly and negligently jeopardized public safety by allowing Maine Yankee to operate above 2440 Mwt for more than 20 years. Clearly the NRC cannot be trusted to enforce its own regulations." (pg. 6).
    • David Lockbaum, Union of Concerned Scientists: "1) Three of the ISA Team's findings, involving emergency diesel generator loading, off site power sources, and component cooling water capability, challenge safe operation of Maine Yankee even at its presently authorized power level. 2) The ISA team determined that several design bases issues prevented the team from justifying safe operation of the plant above 2,440 Mwt, yet the team did not address the safety implications from Maine Yankee routinely operating above this power level since June of 1978. The breadth and number of these issues represent the very real potential that the facility would have been unable to mitigate a design bases accident without incurring significant adverse public safety consequences. 3) The fact that Maine Yankee operated for 17 1/2 years at power levels with 'eroded margins' demonstrates that this utility failed to fulfill the legal and ethical obligations that accompanied its license and that the NRC's regulatory oversight provided inadequate protection of public health and safety." (pg. 39).
Friends of the Coast Opposing Nuclear Pollution. (February 4, 1997). Independent Safety Assessment Response: Written presentation before the U.S. NRC: Public meeting in the matter of Maine Yankee Atomic Power Station (50-309). Friends of the Coast Opposing Nuclear Pollution, Post Office Box 98, Edgecomb, Maine 04556.
  • "Friends of the Coast remains convinced that NRC regulation of MYAPS places excess emphasis on form and process, to what appears to be the neglect of physical condition. We urge the Commission to become pro-active with regard to settling NRC-identified material issues, such as reactor embrittlement, erosion/corrosion of main steamlines, potential deterioration of the steam generator vessel, reactor vessel and reactor vessel head penetrations together with control components, and the examination of welds, known to be defective, in the primary coolant piping. These welds were an issue raised in a Friends of the Coast 10 CFR 2.206 Petition upon which NRC took no action. ...it should be noted that many of the defective welds have no record of in-service inspection." (Summary of Comments, pg. 1).
  • "...much of the concentration of the current round of examinations and activity focuses on design flaws, flaws built-in largely by the same designers and engineers who selected many of the materials and minor components for their applications. For the most part, the designs did not age, but the materials have." (Summary of Comments, pg. 1).
  • "The unfortunate fact is that the thoroughness of the ISAT examination of select areas, and some of the team's assumptions and conclusions are being challenged by events which have occurred at MYAPS in the brief period (four months) since the ISA was completed. Among others, these events include: (1) complete loss of offsite power and (2) the recent discovery that thermal expansion of trapped fluid could render safety-related, motor operated valves inoperable in the event of a loss-of-coolant accident. It is significant that these two events involved systems 'examined' and 'signed-off on' by the ISAT. The ISAT used the historical stability of the two offsite power transmission lines to support a rationale for accepting slim performance margins on MYAPS emergency diesel generators. Yet, in blatant contradiction to the ISAT assumptions, both offsite power lines were lost when the licensee disabled one for maintenance (on-line maintenance) and a power surge knocked out the second line." (pg. 2).
  • "How can the Commission justify declaring an aging, poorly maintained, and hard-used reactor adequate to ensure public safety when what is examined is not very good, and what is hidden remains the greater portion?" (pg. 3).
  • "The ISA mission ... did not include a physical inspection of MYAPS. Even where some physical survey took place, it was largely a visual surface scan incidental to a conformance walk-down of given system. The safety assessment was, however, presented to the public as a 'nuts and bolts, top-to-bottom, physical examination.' This was stated, perhaps naively, by Governor King. The ISAT, which knew better, became complicit in propagating the misconception by not correcting the matter. This false representation of the ISA has persisted through the conclusion of the project. Following the NRC ISAT team members' briefing, Governor King emerged from his office and announced to a waiting press corps and the Maine citizenry that 'Maine Yankee had undergone the most extensive physical examination of any nuclear power plant ever, anywhere in the world, and was found to be safe.' The NRC should have immediately debunked this utter hokum." (pg. 13-14).
  • "The NRC should adopt a full-disclosure policy and subsequent full-disclosure rule which would allow the public the opportunity to examine in a timely and convenient manner all NRC business with licensees in which the public has an interest. Under this policy/rule, for example, all inspector's field reports, notes, and evidentiary material for every reportable occurrence would be available for public scrutiny. Licensee correspondence to NRC would require simultaneous service to the local public document room and to interested parties on the NRC's service list for that particular license." (pg. 13).
Hess, C.T., Smith, C.W., Churchill, C.H. and Burke, G.F. (May 1976). Radioactive isotopic characterization of the environment near Wiscasset, Maine using pre- and post-operational surveys in the vicinity of the Maine Yankee nuclear reactor. Technical Note ORP/EAD-76-3. Environmental Analysis Division, Office of Radiation Programs, U.S. Environmental Protection Agency, Washington, D.C.
  • Pre-operational surveys of field soil and sediment samples in the Maine Yankee Atomic Power Company vicinity revealed significantly higher levels of 137Cs in many samples than were found in many post-operational field soil and sediment samples.
  • Post-operational surveys of Bailey's Cove did record a significant impact from Maine Yankee Atomic Power Company derived activation products (58Co, 60Co), with peak concentrations of 58Co up to 5,620 pCi/kg near the plant outfall.
  • One hot particle was noted containing 7,700 pCi of 60Co, and had a total activity of 9,000 pCi in a mass less than 20 µg. (pg. 18).
  • Most of the extensive pre-operational nuclear weapons testing derived radiocesium as well as post-operational reactor derived radiocesium documented in this report have miraculously disappeared in later Maine Yankee Atomic Power Company environmental radiological summaries.
Holt, M. and King, E. (1988). Monitoring Maine Yankee: Report of the Citizens' Monitoring Network, 1979-1988. Citizens' Monitoring Network, Bath, Maine.
  • This report summarizes a series of unexplained alarms observed by CMN members during this time period, most of which do not correlate with any known releases from MYAPC.
  • This report may be a paradigm for a future in which citizen groups maintain and utilize monitoring equipment which is of comparable reliability to NRC licensee and state maintained TLD thermoluminescent dosimeters and which may be a major source of information in the event of a nuclear accident, at which time it appears that there will be a minimum of reliable information from official sources.
Lochbaum, David. (June 1998). A report on safety in America's nuclear power industry. Union of Concerned Scientists.
  • See comments in RAD 11-2: Anthropogenic radioactivity: Major plume source points: Safety issues at nuclear power plants.
Maine Yankee Atomic Power Company. (January 3, 1996). Radiological Incident Report. Maine Yankee Atomic Power Company, Augusta, Maine.
  • This report is actually just a form filled in to describe a radiological incident (2 pp.); this particular RIR triggered a whole cascade of paperwork beginning with a root cause analysis (2 pp.), an unusual occurrence report (1 p.), and another 13 memos, work instructions, procedure change requests, survey record form, gamma spectrum analysis (3 pp.), etc.
  • The incident that was responsible for the compilation of these documents was the contamination of the leg of a worker who triggered the gatehouse portal alarm, the contamination having been apparently missed during routine scans at the end of the work day. (The prior scans did locate some alpha contamination on the same worker's hard hat).
  • A particle of 60Co was discovered above the left knee; the initial survey indicated a count rate of 35,000 ccpm. "Decontamination for the area was accomplished using a moist cloth." Contamination was measured as .109 microcuries of 60Co (this compares with a 1981 total plant discharge of 365,000 microcuries of 60Co).
  • The significance of this RIR, which is one of a series of such reports issued in the spring of 1996 and cited in Integrated Inspection Report 50-309/96-06 June 15, 1996 (see RADNET review of this report below under US NRC), is that it documents incidents of radiological contamination, information about which is not available to the general public via the public documents room. While this and other incidents may have no public safety significance as individual events, the detailed descriptions these reports give of day-to-day operations could be very useful in providing evidence of a decline in the material conditions of the facility. Why would a worker come to have such a large fragment of 60Co on his leg, allegedly transferred from his TLD, and what is the significance of a small amount of alpha contamination on his helmet, and why didn't routine surveillance reveal this contamination prior to his exiting the gatehouse?
Maine Yankee Atomic Power Company. (February 7, 1997). Response to USNRC request for information pursuant to 10 CFR 50.54(f): Adequacy and availability of design bases information. Maine Yankee Atomic Power Company, Augusta, Maine.
  • "...Maine Yankee has determined from the evidence and assessments that the linkage between the design bases and the appropriate procedures and the plant design is generally established. However, we also conclude that the implementation of this linkage has not been consistent across all procedure and design development and modification. The extent of these inconsistencies has been assessed and we continue to maintain that the observed translation of design bases requirements into plant procedures and design implementation supports an overall conclusion of reasonable assurance of continued safe operation of the plant and adequate protection of the public health and safety." (cover letter MN-97-027 from Frizzle, C.D., President and CEO, pg. 2).
  • "We recognize that recent Maine Yankee and USNRC reviews have identified a number of specific design bases and configuration management related deficiencies which highlight the need for focused corrective actions. These actions have been, are being, or are planned to be taken to correct these identified deficiencies from both an individual and broad perspective." (cover letter MN-97-027 from Frizzle, C.D., President and CEO, pg. 2).
  • "Safety Issue Concerns (SICs), defined as nuclear safety issues for situations where the operability of components or equipment that effect nuclear safety becomes uncertain and cannot be resolved immediately ... Of the 85 SICs issued since 1990, 25 identified as being potentially related to the plant design bases configuration or implementation were reviewed. ... Eighteen of the 25 SICs which were reviewed resulted in subsequent changes to procedures." (pg. 5-8).
  • "The activities summarized above cover different types of inspections, reviews, and improvements related to consistency of plant system, structure, and component (SSC) configuration and performance with the design bases. These activities contribute to reasonable assurance that the control processes are reasonably effective. ... Consideration of these activities as a whole, including the improvements and corrective actions that have been taken, leads Maine Yankee to conclude that the level of consistency between configuration of plant systems, structures, and components and the design bases support an overall conclusion of reasonable assurance of adequate protection of the public health and safety." (pg. 6-22).
  • "Although the content and demonstrated usage of the DBSDs [Design Basis Summary Documents] is observed to be useful, progress in the rate of completion of DBSDs and Topical Reports has not been satisfactory. To date, there have been eight of the fourteen previously defined DBSDs completed. With the inclusion of risk significant systems, as defined in the Maintenance Rule implementation program, the total number of DBSDs to be developed has expanded to nineteen. [including] ...
    • Electrical Distribution (AC and DC) System
    • Emergency Diesel Generator System
    • 115 KV Offsite Power System
    • Residual Heat Removal System
    • Safety Actuation Signal Systems
    • Alternate Shutdown System / EFCV Air System
    • Reactor Protection System
    • Condensate and Feedwater Systems
    • Containment Isolation Systems"

    • (pg. 9-5).
  • Appendix A consists of a "Summary listing of the Maine Yankee design bases related commitments."
Maine Yankee Atomic Power Company. (March 7, 1997). Maine Yankee Atomic Power Company: Restart readiness plan. Maine Yankee Atomic Power Company, Augusta, Maine.
  • The Restart Readiness Plan (RRP) "...contains the activities we feel necessary to complete in order to restart Maine Yankee, and also contains provisions for short-term and long-term actions following restart which will address and resolve other outstanding issues associated with the plant." (cover letter MN-97-43 from Sellman, M.B., President, pg. 1).
  • "Although we are intent on restoring Maine Yankee to an operating condition, the RRP recognizes a substantial amount of work which must be satisfactorily completed in the next several months. Progress in completing this work, which consists of both hardware changes and programmatic evaluations, will form the basis for submittal of a separate Restart Plan Closure Report approximately 30-60 days prior to our estimated restart date." (cover letter MN-97-43 from Sellman, M.B., President, pg. 1).
  • "Restart required actions" are identified on pages 11-13 and are divided into 7 major areas, the contents of which provide a general summary of restart issues.
  • "Significant Restart Issues ... identified will be managed as individual restart projects and will be specifically evaluated during the resolution review process to assess the potential for generic implications. The action plans for these issues are contained in the Appendix to this RRP." (pg. 12-13).
  • "The current set of issues being managed in this way include:
    1. Logic Circuit Testing
    2. Cable Separation
    3. 115KV Offsite Power
    4. Steam Generator Inspections
    5. Fuel Repair/ Replacement
    6. Corrective Action Program (Learning Process)
    7. Surveillance Testing
    8. EQ Issues"

    9. (pg. 13).
  • The action plans for significant restart issues are contained in 8 appendices at the end of the report and provide an excellent summary of some but not all key safety issues at MYAPC. Of central interest are cable separation issues, about which the licensee provides the following information:
    • "Given that nearly all cable separation discrepancies discovered have involved plant modifications and that a review of plant construction records indicates significant QA effort to verify cable installation, the original construction cables and circuits are assumed to be in installed in accordance with the original design basis. Any original construction discrepancies discovered during the effort will be investigated and the scope of the project will be redefined as needed. ... The configuration of cables which are found to be in conflict with the appropriate design documents or criteria may be reconfigured to comply with the approved design. ... An engineering evaluation may be performed with discrepant cables to accept the cables as installed. This may include a safety analysis and/or a functional redundancy analysis. ... Maine Yankee intends to correct all deficiencies practicable prior to restart. There may be some deficiencies which could require completion in the post restart time period. In this situation, a safety evaluation will be performed and compensatory action(s) may be established. The long term corrective action(s) will be placed on the post restart list for implementation in the appropriate time period." (pg. Appendix B-3, B-4).
  • It may be concluded from the above quote that some, if not many, crossed cable configurations may not be repaired or replaced prior to reactor restart; this represents yet another admission that the licensee is unable to operate the MYAPP in compliance with design and licensing bases.
  • This restart readiness plan provides the following interesting information about fuel leakage:
    • "On June 12, 1996, reactor coolant system (RCS) iodine activity increased from the high 10-4 micro-curies/milliliter range to the 10-3 microcuries/milliliter range indicating fuel leakage. During the ensuing months the RCS iodine activity trends and response to changes in plant power level indicated a gradual, but progressive trend in fuel leakage." (pg. Appendix E-2).
    • "On December 6, 1996, Maine Yankee was taken off line to deal with cable separation deficiencies which had been identified. Just prior to the shutdown, RCS iodine activity was in the low 10-2 micro-curies/milliliter range. On January 2, 1997, Maine Yankee management decided to perform a concurrent inspection of the fuel." (pg. Appendix E-2).
    • "In particular, Maine Yankee wanted to establish if the cause of the leakage was grid to rod fretting which had occurred in Westinghouse fuel of a similar design in another facility." (pg. Appendix E-2).
    • "The results of the inspection identified 9 leaking assemblies containing 76 leaking rods. All of the leaking rods were within the batch of the 68 first cycle fuel assemblies manufactured by Westinghouse. Seventy five of the 76 leaking rods were in a subset of 24 assemblies located near the core periphery. Sixty six of these leaking rods were in a subset of 8 assemblies in 'half-baffle' locations. Half-baffle locations are those locations where half of one edge of a fuel assembly is adjacent to the core shroud and the other half is adjacent to another fuel assembly." (pg. Appendix E-2).
    • "The primary cause for the fuel leakage was determined to be grid to rod fretting at the mid-assembly fuel spacer grids. The cause of this fretting was determined to be related to an inadequate design of Westinghouse C14 fuel with zircaloy mid grids that incorporate a diagonal spring feature. The C14 design is the Westinghouse version of the ABB Combustion Engineering 14X14 fuel design." (pg. Appendix E-2).
    • "Assemblies were classified as having light, moderate, and heavy wear if they contained sample rods with wear between 0 and 25%, greater than 25% to 50%, or greater than 50% respectively. The sampling program involved 325 rods in 17 assemblies." (pg. Appendix E-3).
    • "The conclusions reached ... indicated that the wear problem was widespread and generally heaviest in the periphery assemblies and light to moderate in the interior assemblies. In addition, examination of the wear scars showed evidence that the diagonal grid springs were wearing completely through the fuel rod cladding in some fuel rods." (pg. Appendix E-3).
    • "Based on the wear damage to both fuel clad and grid springs, it was decided to replace all 68 Westinghouse fuel assemblies with a fuel design known not to be susceptible to a grid to rod fretting." (pg. Appendix E-3).
McCarthy, W.J., Ryder, D.L. and Antonitis, J.D. (1978). Radionuclide concentrations in New England seaweeds following the Chinese nuclear bomb test of March, 1978. Report No. 342:57-77. U.S. Department of Energy, Washington D.C.
  • See the comments on this report in this section of RADNET.
Meinke, W.W. and Essig, T.H. (April 1991). Offsite Dose Calculation Manual guidance: Standard radiological effluent controls for pressurized water reactors: Generic Letter 89-01, Supplement No. 1. NUREG-1301. Division of Radiation Protection and Emergency Preparedness, Office of Nuclear Reactor Regulation, U.S. NRC, Washington, D.C.

Osgood, C.C. (Date unavailable). Fatigue design, 2nd ed. Pergamon Press, New York.

  • RADNET has not had an opportunity to review this text, but Carl Osgood's discussions of degradation mechanisms in equipment similar to the MYAPC's steam generators have relevance for consideration of the life expectancy of the sleeved steam tubes versus that of the unrepaired steam tubes.
  • Degradation mechanisms discussed in Fatigue Design are of additional relevance because Osgood expressed concerns to the State Nuclear Safety Advisor about the steam generator repair, and the response by this office may not have fully addressed the issues raised in Osgood's correspondence.
Pollard, Robert. (December 1995). U.S. nuclear power plants -- showing their age: Case study: Reactor pressure vessel embrittlement. Union of Concerned Scientists.
  • "Embrittlement of reactor pressure vessels [from exposure to neutron radiation from the fission process in the core] is a particularly serious safety problem because no safety systems are capable of protecting the public against the consequences of vessel failure." (pg. 1).
  • "... a plant-specific analysis is needed to evaluate the magnitude of the safety hazard posed by embrittlement of the reactor pressure vessel and to estimate the remaining useful life of the nuclear power plant. ... In 1992, embrittlement of the reactor pressure vessel beyond safety limits led to the permanent shutdown of the Yankee Rowe plant in western Massachusetts after 31 years of operation..."(pg. 1).
  • "The portion of the vessel walls and welds directly opposite the reactor core --- the vessel beltline region -- receives the highest level of radiation exposure. Vessel embrittlement occurs when long exposure to radiation reduces the ability of the vessel materials to give, or stretch. As the vessel's steel plates and welds become brittle, they are more likely to fracture." (pg. 2).
  • "The chemical composition of the vessel materials is a key factor affecting the extent to which the vessel becomes embrittled by the neutron radiation. The presence of small amounts of copper and nickel in the irradiated material -- less than 1 percent by weight -- can have a marked effect on the magnitude of embrittlement degradation. For example, increasing the amount of copper in the vessel welds by just a few hundredths of a percent can reduce the time to reach embrittlement limits by several years." (pg. 2).
  • "Another factor that affects the rate of vessel embrittlement is the temperature at which the reactor operates. For a given radiation exposure, a vessel will become embrittled at a faster rate if it operates at a lower temperature. Thus, if reactors are operated at a lower temperature in an attempt to slow the rate of corrosion in other components, such as steam generator tubes, the result is more embrittlement." (pg. 2).
  • If the pressure vessel fails, "... there is no means of cooling the core and avoiding a meltdown because the emergency cooling water escapes from the vessel without reaching the core." "... the containment building housing the reactor is not designed to remain intact in the event of a reactor meltdown. Thus, failure of a reactor pressure vessel could result in off-site releases of radiation as large as, or larger than, the releases estimated to have occurred at Chernobyl." (pg. 5, 1).
  • "As more nuclear power plants approach middle age, it is becoming increasingly clear that a wide variety of degradation mechanisms pose significant economic and safety risks. The degradation of steam generators in pressurized water reactors (PWRs) is among the more perplexing problems confronting the nuclear power industry and its state and federal regulators. ... This study focused on just one age-related problem and found that the nuclear industry and its regulators are not confronting the increasing risk of reactor accidents or the economic costs arising from the continuing degradation of PWR steam generators." (abstract).
  • An excellent brief summary of steam generator safety issues including: stress corrosion cracking, tube wear, tube denting, stress corrosion cracking, circumferential cracking, and thinning, pitting, stress corrosion cracking and intergranular attack.
  • "The NRC is well aware of the unreliability of the methods used to detect degradation of the steam generator tubes. In a May 26, 1993, internal staff report (Operating Reactors Events Briefing 93-19), the NRC reported that 'there have been widespread deficiencies in [steam generator] inspection programs throughout the industry.' The NRC concluded that cracks penetrating 40 percent through the tube wall 'cannot be reliably detected.'" "... If ... tubes are cracked or degraded in locations where other metal components, such as the tube support plates, are close to the tube walls, the tube cracks can be masked by the metal outside the tube." (pg. 8, 10).
  • This document is available from the Union of Concerned Scientists for a nominal charge.
  • See citations of other articles by Pollard in RAD11 4-A: 5-a: Anthropogenic radioactivity: US nuclear power plants: reactor embrittlement.
Siegel, B. (March 1978). Evaluation of the behavior of waterlogged fuel rod failures in LWRs. NUREG-0303. U.S. Nuclear Regulatory Commission, Washington, D.C.

Union of Concerned Scientists. (May 1, 1997). Fire protection problems at Maine Yankee. Letter from David Lochbaum, Nuclear Safety Engineer, UCS to Hubert J. Miller, Regional Administrator, Region I, U.S. Nuclear Regulatory Commission.

  • This is a detailed point by point commentary by the Union of Concerned Scientists critiquing two NRC reports: Technical Assessment of Fire Barrier Penetration Seals in Nuclear Power Plants, July 1, 1996 and Fire Barrier Penetration Seals in Nuclear Power Plants, July 31, 1996 which are cited in this section of RADNET.
  • The following conclusions issued by UCS on April 15, 1997, in a preliminary discussion of defective fire barrier seals titled Fire Barrier Penetration Seals -- Union of Concerned Scientist's Position by D. Lochbaum, succinctly summarize the May 1 critique.
    • "The NRC staff's position on silicone foam fire barrier penetration seals as expressed in SECY-96-146 is inadequate due to numerous flaws and inconsistencies.

    • The NRC concluded that silicone foam is combustible. 10 CFR Part 50, Appendix R, Subpart M prohibits the use of combustible material in fire barrier penetration seals. The NRC staff's acceptance of this nonconforming condition represents wholesale discretionary enforcement without adequate justification.
      The NRC and the industry have documented numerous problems with missing and degraded fire barrier penetration seals. Risk assessments prepared by and for the NRC indicate that fire contributes up to 50% of the overall core damage frequency. Therefore, fire barrier penetration seal problems are safety significant.
      (1) Combustible material used in fire barrier penetration seals must either be:
      (a) removed and replaced with a conforming (noncombustible) material, or
      (b) accepted on a case-by-case basis following inspections that assure fire retardant overlays exist on both sides of the penetration that provide the assigned fire rating despite the presence of the combustible foam.
      (2) The NRC's internal and the nuclear industry's fire protection inspection procedures must be upgraded to include specific guidance on fire barrier penetration seals.
      (3) The NRC must develop and issue specific guidance controlling fire barrier penetration seal testing configurations comparable to the universally accepted certified listings."
U.S. Congress Office of Technology Assessment. (1993). Aging nuclear power plants: Managing plant life and decommissioning. (OTA Publication No. OTA-E-575). U.S. Government Printing Office, Washington D.C.
  • This report contains an interesting discussion of reactor vessel embrittlement and degradation processes within steam generators and was issued well before the circumferential cracking was discovered in the MYAPC steam generators.
  • This publication includes an overview of policy issues, discussion of the safety and economics of aging nuclear plants, information on decommissioning nuclear power plants including comments on residual radioactivity standards, and case studies of 9 operating plants.
  • Table 4.1 on page 119 includes a list of all retired nuclear power plants in the United States and their decommissioning status; most larger plants are in the SAFSTOR mode of decommissioning; only 4 small plants have been fully decommissioned.
  • Fig. 4.6 on pg. 137 lists the major costs for decommissioning a reference pressurized water reactor; low-level waste (LLW) disposal is noted as the greatest cost at 38%; utility staff labor is 25%; and contractor labor is estimated at 21% of the total decommissioning cost. These estimates are now out of date; there are no inclusions for greater than class C waste disposal, spent fuel storage and disposal costs, or the costs of the multipurpose canister systems needed to move the spent fuel to a monitored retrievable site or a permanent geological repository.
United States General Accounting Office. (May 1997). Nuclear regulation: Preventing problem plants requires more effective NRC action. GAO/RCED-97-145. U.S. GAO Report to Congressional Requesters.
  • A landmark document in the demise of the nuclear energy industry.
  • This report is available in Adobe Acrobat Reader format at URL: http://www.gao.gov/new.items/rc97145.pdf.
  • "...the many safety problems identified in some plants raises questions about whether NRC's regulatory program is working as it should." (pg. 2).
  • "Because of the many redundant safety systems built into the plants' designs, NRC believes that plants are safe to operate even when some of their safety systems are not working properly. However, according to recent findings in some plants, including Millstone, NRC is no longer confident that all plants are still operating as designed and is requiring all 110 nuclear plant licensees to certify that they are maintaining their plants in accordance with their approved plant designs." (pg. 2).
  • "NRC is also concerned that as nuclear plant owners pursue cost-cutting strategies to meet future competition, safety priorities may be jeopardized." (pg. 2).
  • "For some plants, NRC has not taken aggressive enforcement action to force the licensees to fix their long-standing safety problems on a timely basis. As a result, the plants' conditions have worsened, making safety margins smaller. ... NRC allowed safety problems to persist because it was confident that redundant design features kept plants inherently safe and because it relied heavily on the licensees' promises to make changes. NRC forced the licensees to correct their problems only after the licensees voluntarily shut down plants." (pg. 2-3).
  • "The conditions found at Millstone, ... have challenged NRC's confidence that it can rely on licensees to ensure that the plants are operating within their approved design basis. In 1996, NRC discovered that Millstone had been operating outside of its plant design for many years..." (pg. 5).
United States Nuclear Regulatory Commission. (date unknown). Standard review plan, Section 4.2, Fuel system design. NUREG-0800. U.S. Nuclear Regulatory Commission, Washington, D.C.

United States Nuclear Regulatory Commission. (October, 1975). Reactor Safety Study: An assessment of Accident Risks in U. S. Commercial Nuclear Power Plants. U.S. Nuclear Regulatory Commission, Washington, D.C.

  • This safety study, commonly known as the Rasmussen Report because the study was directed by Prof. Norman Rasmussen of MIT, describes estimated accident risks to the public from commercial nuclear power plants.
  • The average risk of fatality from nuclear reactor accidents (100 plants) is estimated at one in five billion compared to a risk of one in four thousand for motor vehicle accidents (per year). (pg. 83).
  • Probability of core melt is estimated at 5 x 10-5. (pg. 135).
  • Table 2 on page 157 gives the dominant accident sequences versus release categories.
  • A "fault tree" and "an event tree" methodology are used in this report to assess accident probability.
  • "Although the event trees used in the analysis of the PWR encompassed approximately 130,000 potential accident sequences, which could have conceivably involved millions of potential common mode failures at the system level, elimination of physically meaningless dependencies reduced the number of sequences of physical significance to approximately 650. The use of probability discrimination techniques among accident sequences that would produce similar radioactive releases reduced the number of potentially significant sequences from 650 to 78. Fifty-one of these sequences involve the failure of only a single system or a single element. In the 27 remaining sequences, only seven different combinations of two-system failures were involved. Therefore, of the potential millions of system-to-system common mode failures involved in the initially defined 130,000 potential accident sequences, only seven potential dependencies remained."(pg. 182).
  • In light of the accident at Three Mile Island, the Chernobyl disaster, and the recent discovery by the NRC of design and safety deficiencies ranging from soup to nuts at numerous U.S. nuclear reactors, there is an urgent need for a reconsideration of accident risks at all U.S. and foreign reactors. The one in five billion risk of death assessment in this report is now completely obsolete.
United States Nuclear Regulatory Commission. (1984). Radioactive materials released from nuclear power plants: Annual report 1981. NUREG/CR-2907 BNL-NUREG-51581, Vol. 2. U.S. Nuclear Regulatory Commission, Washington, D.C.
  • This annual report is a summary of the airborne and liquid effluent releases and solid waste production at all U.S. nuclear power facilities and contains an individual plant summary of radioactive emissions in the appendix of each publication.
United States Nuclear Regulatory Commission. (August 21, 1987). Control of hot particle contamination at nuclear plants. Information Notice No. 87-39. U.S. Nuclear Regulatory Commission, Washington D.C.

United States Nuclear Regulatory Commission. (January 31, 1989). Implementation of programmatic controls for radiological effluent technical specifications in the administrative controls section of the technical specifications and the relocation of procedural details of RETS to the Offsite Dose Calculation Manual or to the process control program. Generic Letter 89.01. U.S. NRC, Washington, D.C.

United States Nuclear Regulatory Commission. (September 1993). Boiling-water reactor internals aging degradation study. NUREG/CR-5754. U.S. Nuclear Regulatory Commission, Washington D.C.

  • This NRC report provides the following summary of degradation mechanisms in boiling water reactors and is also reprinted in the UCS's US nuclear power plants -- showing their age: Case study: core shroud cracking, September, 1995, see RAD11: Plume Source Points: Section 4: U.S. Nuclear Power Plants.
  • "BWR internal components and potential aging-related degradation mechanisms"
  • Component
    Steam dryer
    Steam separator
    Shroud head
    Shroud head bolts
    Steam separator support ring
    Top guide
    Access hole cover
    Core shroud
    OFS piece
    Core plate
    Core spray line internal piping
    Core spray sparger
    Feedwater sparger
    Jet pump
    In-core neutron flux monitor housings
    In-core neutron flux monitor guide tubes
    In-core neutron flux monitor dry tubes
    CRD housing
    Neutron source holder
    Jet pump sensing line
    Control blade
United States Nuclear Regulatory Commission. (October 12, 1993). Recent fuel and core performance problems in operating reactors. Information Notice 93-32. U.S. Nuclear Regulatory Commission, Washington, D.C.

United States Nuclear Regulatory Commission. (April 28, 1995). Generic Letter 95-03: Circumferential Cracking of Steam Generator Tubes. U.S. Nuclear Regulatory Commission, Washington, D.C.

  • These generic letters are issued to all holders of NRC operating licenses and are an excellent source of information about on-going safety issues of every description which have come to the attention of the NRC. These generic letters are available not only in the public document rooms associated with each nuclear facility but also via phone orders to the NRC public document library or via electronic retrieval (see RAD 13: RADLINKS: Part II D-5: U. S. Federal Government: NRC or Part I B: Governmental and Research Oriented Search Engines: FedWorld Information Network).
  • Generic letter 95-03 gives extensive information about the circumferential cracking of the steam generator tubes at MYAPC. "Inadequate eddy current test procedures since 1990, or earlier appear to have been the primary reason the tube degradation went undiscovered resulting in several of the tubes becoming severely degraded" (pg. 1). This seven page report continues with extensive additional information about this important safety issue.
  • Further analysis of the extensive degradation of the MYAPC steam generator tubes resulted in an additional NRC information notice 95-40 (September 20, 1995): Supplemental information to generic letter 95-03, "Circumferential cracking of steam generator tubes". This report contains additional information about the extensive degradation discovered in the transition region of the tubes as well as information about the superior performance of the recently developed "high frequency pancake coil" inspection devices which were responsible for the discovery of the cracking which had previously gone unnoticed with the use of the less accurate standard pancake coil.
  • This information notice also notes that these circumferential cracks have been observed on specimens of tubes pulled from other plants. (pg. 3).
  • These generic letters and information notices provide an important source of safety information for anyone concerned with the hazards and major accident potentials associated with the nuclear power industry. A small sampling among many NRC information notices which apply to all nuclear facilities include the following:
    • August 24, 1995 - Potential loss of spent fuel pool cooling after a loss-of-coolant accident or a loss of off-site power.
    • August 28, 1995 - Degraded ability of steam generators to remove decay heat by natural circulation.
    • September 7, 1995 - Inadequate off site power system voltages during design-basis events.
    • September 8, 1995 - Degradation of boraflex neutron absorber in spent fuel storage racks.
United States Nuclear Regulatory Commission. (December 15, 1995). U. S. Nuclear Regulatory Commission: Region I: Inspection report number 50-309/95-24. Licensee: Maine Yankee Atomic Power Company. Inspection dates: October 1, to November 13, 1995. U.S. Nuclear Regulatory Commission, Washington, D.C.
  • "Due to a series of fuel handling and operational events that occurred at Maine Yankee in October and November of 1995, the Nuclear Regulatory Commission (NRC) assigned a Special Inspection Team to review the events and evaluate their significance." (Attachment 1: Special Team Inspection of Refueling Events, November 6-9, 1995, pg. A1-1).
  • The following quotes and editors comments are from: Attachment 1: Enclosure 1: Maine Yankee refueling outage event descriptions:
    • "October 18, 1995: About 800 gallons of water was dumped into the containment spray building due to RHR drain valves being open when the header was filled. This event was caused by operators using the wrong procedure for aligning the RHR system."
    • "October 27, 1995: During upender operation in the reactor cavity, the upender was stopped by mops caught in the drive cable pulleys. The mops had been used by a contractor to clean out the upender pit. The licensee performed an extensive inspection of the FME zone and found no other debris."
    • On October 27 and 29, the refueling machine operator had problems with the fuel assembly hoist box and its interaction with the CEA (Control Element Assembly).
    • "October 31, 1995: Following shift turnover during refueling, the upender was sent back to the spent fuel pool (SFP) without removing the fuel assembly to the core side. The SFP operator then attempted to put another fuel assembly into the upender. No damage occurred to the fuel assemblies. ... Part of the root cause was poor lighting in the upender location of the SFP."
    • "November 1, 1995: The containment purge valves were found to be in the 'on-line' mode rather than in the 'refueling' mode as required by T$ 3.13.D." These mishaps during the refueling outage are significant precursors to the variety of safety problems and design flaws uncovered after the issuance of the whistleblower's letter in December, 1995.
  • This report contains a lengthy (6 pp.) refueling operations corrective action plan.
  • Attachment 2 of this inspection report includes an Engineering inspection of steam generator tube sleeve weld and post heat treatment. "The weld repair procedure was examined for metallurgical effects the procedure might have upon the microstructure of the welds. The post-weld heat treatment operation was examined for potential metallurgical changes to the heat treated welds that might result from an anomaly in the execution of the heat treatment." (pg. A2-1).
  • Attachment 2 also includes the evaluation of the effects of multiple rewelds, consideration of post weld heat treatments and a description of the ultrasonic inspection (UI) of steam generator sleeve welds.
  • "By letter dated September 1, 1995, the licensee submitted its revised sleeve installation process for minimizing the amount of tube bowing or bulging that could occur as a result of the PWHT [Post-Weld Heat Treatment] operation. Four changes were made to the sleeve installation process:
    • At least one hour will be allowed between any successive stress reliefs in a tube span.
    • Stress relief of the weld will precede stress relief (if performed) of the upper tube expansion transition.
    • Lower sleeve hard rolling will be performed after stress relieving.
    • Limit the use of 30 inch sleeves to areas with 10.5 inches of secondary side corrosion products accumulation." (pg. A2-5).
  • This report also includes a Radiological Safety Inspection (Attachment 3).
United States Nuclear Regulatory Commission. (June 15, 1996). Maine Yankee Atomic Power Station Integrated Inspection Report 50-309/96-06. U.S. Nuclear Regulatory Commission, Washington, D.C.
  • This report is a summary of a comprehensive six week NRC inspection of MYAPC facilities which ended June 15, 1996. It includes an inspection of "licensee operations, engineering, maintenance and plant support" and a review of radiological protection and controls and the radiochemical emissions program.
  • An NRC Mobile Radiological Measurements Laboratory was brought to the MYAPC site to make independent measurements to verify plant capability for analyzing radioactive effluent. All sample results were in agreement with Maine Yankee measurements (see Table 1. Maine Yankee Radiochemistry test results, pg. 37).
  • The NRC inspection included radiation measurements made along the plant site boundaries. While the licensee was in compliance with the dose limits listed in 10 CFR, part 20, 1301, higher ambient radiation levels than expected were noted at several boundaries:
    • background radiation listed as 8 microRoentgens per hour
    • ambient radiation levels along the north and south fence lines noted up to 37 microRoentgens per hour
    • "The highest protected area fence line dose rates were at the southwest, west and northwest fence lines ranging from 19 to 64 microroentgens" (pg. 18).
  • "While qualitative reviews were performed to identify the major sources that contribute to radiation doses at the protected area fence line, the actual contribution from each source had not been determined" (pg. 18). This comment is followed by a chart on page 20 which summarizes "direct radiation sources that affect radiation doses at the western protected area boundary." Sources include the LSA building, the RCA building, the RAD material bunker, the refueling water storage tank, and "transient sources such as radioactive equipment stored in the 'back yard' for periods of six months or less" (pg. 20).
  • This report also lists the radiation dose goal for 1995 (275 person-rems) as well as the actual station total for 1995 of 653.3 person-rem, as well as a listing of activities during the sleeving project which contributed to the higher than expected staff exposure (see person-rem exposure summary pg. 26). The 1996 radiation dose goal was set at 40 person-rem (pg. 26).
  • This report makes reference to a series of "eight radiological information reports initiated between the periods of 01/03/96 and 04/16/96" as well as RIR #95-023 which is summarized as a component of this report (pg. 18). RADNET has requested review copies of these radiological information reports from both the NRC and the licensee. These requests have been denied on the basis that the radiological information reports are proprietary information. The unavailability of routine radiological information reports raises the question of licensee control of nuclear information during an accident. RADNET has filed an FOI request with the NRC to obtain copies of these routine RIR reports. The NRC has sent the first of 8 reports at a cost of $43; this RIR is reviewed in this section of RADNET. RADNET would welcome any assistance in locating the remaining 7 RIR's referenced in this inspection report. The NRC has indicated that the cost of an FOI search for the remaining 7 RIR's is in excess of $400.
United States Nuclear Regulatory Commission. (July 1, 1996). Technical assessment of fire barrier penetration seals in nuclear power plants. SECY-96-146. U.S. Nuclear Regulatory Commission, Washington, D.C.

United States Nuclear Regulatory Commission. (July 31, 1996). Fire barrier penetration seals in nuclear power plants. NUREG-1552. U.S. Nuclear Regulatory Commission, Washington, D.C.

United States Nuclear Regulatory Commission. (October 7, 1996). Independent safety assessment of Maine Yankee Atomic Power Company. On site evaluation period July 15-26, 1996 and August 12-23, 1996. U.S. Nuclear Regulatory Commission, Washington, D.C.

  • An allegedly "top to bottom" safety assessment of MYAPC requested by the governor of Maine, this report is actually an incomplete analysis of some safety systems and operational procedures. Out of 40 safety systems, the ISAT report provides a detailed review of two (the emergency core cooling system and the emergency diesel generators) and a partial review of two others. This report does not include steam generator, reactor vessel or other ongoing safety controversies. The following excerpts from this report provide a partial insight into the controversial nature of this safety review:
    • "Maine Yankee was in general conformance with its licensing-basis although significant items of non-conformance were identified." (pg. v).
    • "...the design-basis and compensatory measures adequately supported plant operation at a power level of 2440 MWt. However, the team could not conclude, and the licensee did not demonstrate, that at a power of 2700 MWt the design-basis assured adequate NPSH [Net Positive Suction Head] for the containment spray pumps and the heat removal capability of the component cooling water system in the event of a loss-of-coolant accident." (pg. v).
    • "...a number of significant material condition deficiencies were noted as was a decline in material condition following the 1995 steam generator tubing outage." (pg. vi).
    • "Inadequacies in the scope of testing programs were identified, as were weaknesses in the rigor with which testing was performed and in the evaluation of testing results to demonstrate functionality of safety equipment." (pg. vi).
    • "...engineering was stressed by a shortage of resources, and there was a tendency to accept existing conditions. ... Weakness were identified in the areas of problem identification and resolution." (pg. vi).
    • "Some economic pressures resulted in limitations on resources, which impaired the licensee's ability to complete improvement projects that affected plant safety. Equipment problems were not resolved and improvement programs were not effectively implemented because the licensee perceived them to be of low safety significance." (pg. vi-vii).
    • Other comments from the executive summary include "limited available resources," "and a lack of questioning culture," "declining material conditions," "long standing deficient design conditions, such as the undersized atmospheric steam dump value," and "lack of effective improvement programs."
    • "Examples of issues which illustrate complacency and the failure to identify or promptly correct significant problems, include previously undiscovered deficient conditions of the service water and auxiliary feedwater water systems (Section 3.2.2); inadequacies in ventilation systems (Section 2.3.7); post-trip reviews which lacked rigor and completeness (Section; emergency operating procedures that may not adequately address an inadequate core cooling event and a steam generator tube rupture under certain conditions (Section; lack of a questioning attitude during test performance and evaluation that was not conducive to discovering equipment problems, but rather to accepting equipment performance (Sections 2.2.1, 3.2.2, 3.2.4); and licensee self-assessments that occasionally failed to identify weaknesses, or incorrectly characterized the significance of findings (Section 4.1). In addition, some corrective actions were not timely and others were ineffective, leading to repetitive problems (Section 4.2)." (pg. vii).
  • This report gives an important though incomplete safety assessment which provide compelling additional evidence that MYAPC knowingly as well as inadvertently operated the MYAPP at an unsafe and illegal thermal power level for approximately 17 1/2 years prior to the January 3, 1996, confirmatory order which limited the power operation at the plant to the original license power level of 2440 MWt.
  • This report can and should be interpreted as indicating the MYAPP is unsafe to operate at any power level considering the "declining material conditions of the plant ... [The] number of equipment problems identified in 1996 indicated that problems were trending upwards following the 1995 steam generator repair outage." (pg. 46).
  • This report also serves as a paradigm of official NRC acknowledgment of the non-compliance of a licensee with NRC safety regulations as well as an inadvertent glimpse of NRC complicity with this non-compliance, both in its failure to notice existing design deficiencies and unsafe conditions and its long standing failure to observe that the MYAPC was operating at an unsafe and an illegal power level.
  • The comments by the NRC calling the licensee "complacent," and exhibiting a "lack of a questioning culture" are among the most bizarre in any NRC report this editor has reviewed, as these observations are an exact and apt description of the NRC itself. Particularly egregious are the ongoing evasions of waste storage and disposal funding as well as the startling differentials of service life expectancies of the repaired and unrepaired components of the MYAPC steam generators.
  • A copy of this report can be obtained from the Governor's Office, State House Station 1, Augusta, ME 04330.
  • The issuance of this report resulted in a citizen review and critique of the ISAT findings which were presented in a meeting Nov. 19, 1996 in Wiscassett, Maine. This citizen critique is cited in this section of RADNET: see Friends of the Coast: A Citizen Review and Critique .... The comments and criticisms contained in this review constitute an important documentation of the controversies and safety issues characterizing the beginning of the decline of nuclear power production in the United States.
  • Another interesting document which derived from this ISAT review are the notes resulting from an NRC public meeting reviewing the safety assessment of MYAPC. This briefing was held at the NRC offices in Rockville, Maryland, on Friday October 18, 1996, with Shirley Jackson, NRC Chairperson, presiding. This 46 page transcript provides additional insights into NRC commissioner thinking and rationalizations about an NRC supervised nuclear power facility that even the NRC commissioners recognized as being on the brink of "inadequate," even though no such category exists in NRC lingo (NRC evaluation categories are limited to excellent, good and adequate). These revealing transcripts may be downloaded from NRC files in FedWorld: see RADNET Section 13: RADLINKS: Part I-B Governmental and Research Oriented Search Engines: (FedWorld Information Network).
United States Nuclear Regulatory Commission. (February 3, 1997). Region IV morning report, page 9, Subject: pressure test of ANO, unit 2, steam generator tubes. U.S. Nuclear Regulatory Commission, Washington, D.C. Licensee/Facility: Entergy Operations, Inc. Arkansas Nuclear 2, Russelville, Arkansas. Dockets: 50-368 PWR/CE. Notification: MR Number: 4-97-0013. Date: 01/31/97 SRI.
  • "Arkansas Nuclear One (ANO), Unit 2, recently received the results of pressure tests that were performed on two steam generator tubes (R70C98 and R16C56), which were removed from Steam Generator A during a recent forced outage to repair a steam generator tube leak (PNO-IV-96-061, MR 4-96-0128). Both tubes burst at approximately 3200 psig, which was significantly below the test pressure of 4750 psig needed to satisfy the Regulatory Guide 1.121 structural integrity criteria of three times the primary-to-secondary normal operating differential pressure."
  • "Both tubes were found during the forced outage to contain single axial cracks at the first eggcrate support on the hot-leg side of the steam generator. For Tube R70C98, analysts found the bobbin coil data showed the defect as a distorted support indication. The motorized rotating pancake coil (MRPC) examination data indicated a 1.15 inch long flaw, with a throughwall depth of 81 percent. The length of the flaw in Tube R16C56 was found by MRPC to be 1.13 inches, and the depth was found to be 89 percent by bobbin coil and 78 percent by MRPC examination. Examination of these tubes during the previous refueling outage, 2R11, which was completed in November 1995, did not reveal any degradation."
United States Nuclear Regulatory Commission. (February 4, 1997). Transcript -- Maine Yankee Commission Meeting: Briefing by Maine Yankee, NRR and Region I: Public meeting. Nuclear Regulatory Commission, Rockville, Maryland.
  • This transcript is available on the Internet at URL http://www.nrc.gov/OPA/reports/m970204.htm
  • Lengthy comments by the licensee, a representative from the Governor's Office and the head of the Maine Chamber of Commerce were followed by observations by MYAPC skeptics:
  • "MR. LOCHBAUM: Well, it gets to a point I'm making later is that going in and doing a sampling of four systems, finding problems in all four systems, and then concluding that everything else is okay just doesn't seem appropriate and it doesn't seem to be supported by the ISAT's own findings." (pg. 117).
  • "MR. LOCHBAUM: ... Unlike SALP an Unacceptable score for such an inspection is extremely necessary, especially when warranted. In fact, not to have an Unacceptable score for such an inspection makes the whole effort unnecessary. Why bother looking when the answer must be Acceptable?" (pg. 119).
  • "MR. LINNELL: They have been doing some interesting math at Maine Yankee and at Central Maine Power. Apparently they are adding their overhead costs to what they say the are paying for replacement power. If they are willing to deceive the public, I wonder why the NRC or anyone else should trust them."(pg. 125).
  • "MR. LINNELL: ... Finally, the first root cause of safety problems at Maine Yankee, economic pressure, is very likely to increase because replacement power is cheaper. ... if Maine Yankee were on line today they would paying about $1.5 million a week for replacement power, and apparently when I have engaged them in conversation they explained to me that they are taking Maine Yankee's fixed and I would submit uncontrollable costs and adding them to the cost of replacement power when they talk about the cost of replacement power." (pg. 126-128).
  • "MR. SHADIS: ... Yankee Atomic Electric ought to be a deep concern for this Commission. It has left a trail of devastation across all the power plants of New England. You are now concerned with the Pilgrim plant has some problems, Haddam Neck has some problems. And if you pry up that rock, you are going to find underneath it Yankee Atomic Electric and their involvement as a hot-shot consulting company." (pg. 132).
  • "MR. SHADIS: ... Now you have the golden opportunity. Maine Yankee is safer than it has been in a long time because it is shut down. The reactor vessel head is off. Now is the time to examine the faulty welds in the primary piping. NRC ought to do it with contractors, not rely on the sworn testimony of a company whose sworn testimony has proven faulty in the past. NRC ought to go in and take a look at the -- revisit the reactor embrittlement issue with Maine Yankee because they depended on Maine Yankee analysis and Yankee Atomic Electric analysis for the results on that issue." (pg. 133).
  • Another document in the saga of the twilight of the nuclear era.
United States Nuclear Regulatory Commission. (February 5, 1997). Region III Morning report, page 5, Subject: steam generator weld repair. Washington, D.C.: U.S. Nuclear Regulatory Commission. Licensee/Facility: Kewaunee 1, Kewaunee, Wisconsin. Notification: Wisconsin Public Service Corp. MR Number: 3-97-0017. Dockets: 50-305 PWR/W-2-LP.
  • "Discussion: Over the weekend, the licensee identified leaking tubes in both steam generators that had been repaired using a laser weld in the upper hybrid expansion joint (HEJ) sleeves above the location of the parent tube degradation. This repair method was an alternative to plugging. The weld replaces the HEJ as the structural boundary and essentially modifies the HEJ sleeve to the configuration of a conventional laser welded sleeve. The degradation of the parent tube within the HEJ (below the laser weld) would be immaterial to the structural and leakage integrity of the repaired joint."
  • "Kewaunee had completed laser weld repairs in both generators. A hydrostatic head was applied on the secondary side of the B generator, and 4 repaired sleeves were detected leaking ('dripping'http://www.nrc.gov/OPA/reports/m970204.htm). The A generator was then examined under a static head, and approximately 40 leakers (drippers) were detected. A 100 psi overpressure was then applied to the A steam generator, and approximately an additional 32 leakers were detected."
  • "Video examinations of the leaky tubes indicated that the leaks were over the top of the edge of the sleeve. Grab samples of the leakage confirmed that it was secondary fluid. The cause of the leakage is unknown at this time."
United States Nuclear Regulatory Commission. (February 6, 1997). Proposed generic communication: Degradation of steam generator internals. Agency: NRC. Action: Extension of public comment period. From the Federal Register Online via GPO Access [wais.access.gpo.gov]. 62(25) Notices pg. 5656.
  • "SUMMARY: On December 31, 1996 (61 FR 69116), the NRC published for public comment a proposed generic letter concerning the importance of performing comprehensive examinations of steam generator internals to ensure steam generator tube structural integrity is maintained in accordance with the requirements of Appendix B to 10 CFR part 50."
United States Nuclear Regulatory Commission. (February 21, 1997). Executive summary: Maine Yankee Atomic Power Company: NRC inspection report 50-309/96-16. United States Nuclear Regulatory Commission, Washington D.C.
  • "The purpose of this inspection was to review the safety concerns raised by the NRC Independent Safety Assessment (ISA) team, to provide for the proper regulatory disposition of selected issues, and to review and verify the actions taken by your staff in response to selected issues identified by the ISA." (cover letter from R. W. Cooper).
  • "This inspection and letter also brings into focus those issues and recent NRC inspection activities, the majority of which are related to the ISA team review, that are appropriate at this time to be considered for escalated enforcement. ... sixteen (16) apparent violations were identified and are being considered for escalated enforcement action ... The apparent violations were grouped in the areas of: (1) safety related equipment inoperability; (2) testing inadequacies; (3) safety review inadequacies; (4) procedure inadequacies and non-adherences; and (5) corrective actions not identified, untimely, and/or inadequate." (cover letter from R. W. Cooper).
  • "In addition, a number of items were identified as unresolved because further reviews are needed by the NRC staff to determine their proper disposition. You should expect further NRC review of these matters during future inspections." (cover letter from R. W. Cooper).
  • This NRC report detailed a total of 16 violations in key safety systems; the failure of just one system during an accident scenario could have resulted in the catastrophic release of radioactivity to the environment. In addition there are another 30 unresolved safety questions detailed in this inspection report.
  • This inspection report represents the culmination of investigations into just 4 of 42 safety systems at MYAPC which began with the Independent Safety Assessment Team inspection in the summer of 1996. The significance of this report is two fold: it represents an unraveling of heretofore hidden design defects and safety problems in a facility which had been consistently represented as safe by the NRC and the State Nuclear Safety Officer when in fact they were totally unaware of these defects and problems. Secondly, since the unforseen series of safety issues summarized in this most recent inspection report are much more serious than anticipated by even the severest critics of the MYAPC facility, a lingering question of utmost importance to the future operation of MYAPC is still unanswered: will the NRC proceed with a detailed inspection of the remaining 38 unexamined safety systems, and will any future safety inspections (prior to reactor restart) include a detailed analysis of the reactor vessel for embrittlement?
  • These findings were based on a series of 4 prior NRC inspection reports: 50-309/96-08, 96-09, 96-10, and 96-11. See RAD 13: RADLINKS Part II D-5: Other Federal Environmental Monitoring Agencies: NRC to access these other reports.
  • "A predecisional enforcement conference to discuss the apparent violations is scheduled for March 11, 1997 at your media center. The conference will be open to the public." (cover letter from R. W. Cooper).
  • This report is available on the Internet at URL http://www.nrc.gov/OPA/reports/my96-16.htm
United States Nuclear Regulatory Commission. (March 1997). Review of industry efforts to manage pressurized water reactor feedwater nozzle, piping, and feedring cracking and wall thinning. NUREG/CR-6456, INEL-96/0089, AEOD/E97-01. Safety Programs Division, Office for Analysis and Evaluation of Operational Data, U.S. Nuclear Regulatory Commission.
  • "Main feedwater line rupture is a design basis accident; its consequences include a potential for core damage. The rupture reduces the ability to remove heat generated by the core from the reactor coolant system. In addition, the resulting loss of feedwater would activate and challenge safety-related systems to cool the reactor core. A consequent transient-induced steam generator tube rupture could result in the release of significant amounts of radioactive material into the environment, bypassing the containment. Failure of high-energy piping, such as the main feedwater piping, can also result in complex challenges to the plant operating staff because of potential interactions of the high-energy steam and water with other systems, such as the electrical distribution, fire protection, or security systems. Catastrophic failure of any high-energy piping can present a safety problem for plant personnel (USNRC 1989)." (pg. 29).
  • "The characteristics of the damage caused by thermal fatigue are different than those caused by flow-accelerated corrosion. Thermal fatigue cracking generally occurs in a relatively local, safety-related portion of the feedwater piping inside the containment, whereas wall-thinning caused by flow-accelerated corrosion typically occurs, with few exceptions, in the non-safety related balance-of-plant piping outside the containment." (pg. 143).
  • "A through-wall crack caused by thermal fatigue will generally leak long before the component ruptures. However, in the unlikely event of a large overload, a pipe with fatigue cracks might fail catastrophically without any prior leakage. A component damaged by flow-accelerated corrosion loses its strength and can fail under normal operating pressure; a large fitting or pipe might fail catastrophically without any warning." (pg. 143).
  • "Sites susceptible to thermal fatigue cracking are found in those portions of the feedwater piping and nozzles where stratified flows and coolant leakage, respectively, are present; these locations are generally well identified. Sites susceptible to flow-accelerated corrosion are found throughout the feedwater system and are difficult to identify without predictive analysis because several factors are involved." (pg. 143).
  • This 186 page report also contains a description of water hammer phenomenon (pg. 76f) including a 1983 MYAPC water hammer event, as well as extensive figures containing detailed descriptions of feedwater piping and equipment. This report contains a lengthy bibliography and is one of the most comprehensive NRC publications, perhaps due in part to the participation of the Idaho National Engineering Laboratory.
  • Another NRC sponsored documentation of ongoing degradation mechanisms in aging nuclear energy generating facilities.
United States Nuclear Regulatory Commission. (March 13, 1997). Integrated Inspection Report 50-309/96-14. United States Nuclear Regulatory Commission, Washington D.C.
  • This inspection report, in addition to acknowledging "noteworthy endeavors," also cited two addition violations.
    • "The continued use of the spent fuel pool crane to move irradiated fuel without assessing or correcting recurring problems is a violation of technical specifications. Also, there was a failure to follow radiological control procedures upon exiting a contaminated area." (cover letter to M. Sellman, President from R. Conte, Chief, Projects Branch 5).
  • This report also cites unscheduled gaseous releases as well as an "unplanned worker exposure" discussed in Section R8.5.
  • Dry active waste (DAW) generation was 18,645 cubic feet in 1995, due to the sleeving project; 6,469 cubic feet in 11996; with the DAW goal of 15,000 cubic feet for 1997. (Section R1.4b).
  • The contents of the radioactive chair used by guards for several months after the sleeving project and noted in RIR 96-016 is listed as .218 Ci of a "discrete particle fission fragment" with an age of 3.3 years post irradiation contains 90Sr, 90Y, and 147Pm. (Section R8.2). See the NRC correction to this information in the section on Safety Issues and Related Events, March 1997 above.
  • Open items still unresolved are listed in the section: Items Opened, Closed, and Discussed and include:
    • Inadequate use of the Spent Fuel Pool crane.
    • HPSI pumps and valves test results.
    • Electrical cable separation issues.
    • The adequacy of Safety Related Logic Testing.
    • Contamination Control/Decontamination Program.
United States Nuclear Regulatory Commission. (May 2, 1997). Integrated Inspection Report 50-309/97-01. United States Nuclear Regulatory Commission, Washington D.C.
  • "...inspectors identified four apparent violations of NRC requirements which are additional examples of apparent violations noted in NRC Inspection Report 50-309/96-16 ..." (Cover letter from C.W. Hehl, Director, Division of Reactor Projects, NRC to M. Sellman, President, Maine Yankee Atomic Power Company).
    • "The PCCW and SCCW pump were not qualified for a harsh environment that may result in the turbine building..." (Cover letter).
    • "The installation of a 1000 gallon propane tank near the service water pump building and the installation of a temporary drain hose on a spent fuel pool system pipe, both without a safety analysis, were further examples of apparent violations related to the implementation of 10 CFR 50.59." (Cover letter).
    • "The failure to promptly assess the operability of the service water system and implement necessary corrective actions following an engineering evaluation was another example of failure to implement adequate corrective actions in a timely manner..." (Cover letter).
    • "The design vulnerability of the ventilation system in the circulating pump house could have challenged service water system operability in cold weather." (Cover letter).
  • "Additionally, the inspectors observed poor performance indicating informality in operations during shutdown conditions. This was reflected by two spills of refueling water storage tank water during testing and the movement of an incorrect fuel bundle in the spent fuel pool." (Cover letter).
  • "Maine Yankee identified the Appendix-R diesel un-expectantly running without operations knowledge. (Executive Summary: Plant Support). This water treatment pump had been inadvertently left running for four days without being noticed by plant employees.
United States Nuclear Regulatory Commission. (June 5, 1997). Integrated Inspection Report 50-309/97-03. United States Nuclear Regulatory Commission, Washington D.C.
  • "Operators were generally focused on safety and properly operated the systems required to maintain the plant in safe shutdown. However, we are concerned about a problem that occurred during the period involving an operator error during the conduct of a test. Specifically, the operator erroneously started a low pressure safety injection pump instead of a containment spray pump as required by the test procedure. While the error itself was of minor consequence, the performance of the licensed and senior licensed operators in response to the event was weak. ... Further, additional human performance errors were identified during this inspection period involving testing of the residual heat removal system valves and, control of contamination at the plant." (cover letter from C.J. Cowgill, Division of Reactor Projects, NRC to M. Sellman, President, Maine Yankee Atomic Power Company).
United States Nuclear Regulatory Commission. (September 28, 1998). Maine Yankee inspection report 98-03. Docket No. 50-309. U.S. Nuclear Regulatory Commission, Region I, Washington D.C. http://www.nrc.gov/OPA/reports/my9803.htm.
  • "Within the scope of this inspection, no violations were identified." (Cover letter from A. Randolph Blough).
  • "An onsite area of contamination was reviewed and found to be adequately controlled by the licensee.  The contamination had resulted from valve leaks in 1988.  Records describing the area were available, and the remediation of the contamination will be addressed during the decommissioning of the site." (Executive Summary).
  • "In February 1988, the licensee discovered a leak at a flange connection between the RWST siphon heater

  • return line and isolation valve CS-81. Upon discovery, the licensee contained the spilled material and repaired the leak. Surveys revealed that the ground in the area was contaminated, and the licensee excavated the contaminated area. During the excavation, a second leak was discovered at the base of the RWST siphon heater return line isolation valve CS-81. The second leak, significantly smaller than the first leak, was promptly repaired. Soil excavation continued until approximately 600 cubic feet of soil had been removed, at which point the excavation was stopped due to concerns that the foundation of the RWST was being undermined. The excavated area was then backfilled with clean soil and repaved." (Section R1.3).
  • "In a letter dated November 2, 1988, the licensee requested approval from the NRC for in-place disposal of the remaining contamination under 10 CFR 20.302(a). On August 31, 1989, the NRC granted the licensee's

  • request. This area is included in the scope of work for the decommissioning of the facility." (Section R1.3).
  • "The contaminated area will remain posted, and the licensee will cordon off and limit access to the area. The licensee will take soil samples on a regular basis in order to determine if the contamination is migrating. The licensee intends to take any precautions necessary to prevent spread of the contamination in the limited use dirt road that runs through the contaminated area." (Section R1.3).
RADNET Readers - see also RAD 11-4: United States Nuclear Power Plants for a review of additional NRC reports.

Vanags, U. (1991). Nuclear safety report submitted to the 115th Maine Legislature. Maine State Planning Office, Augusta, ME.

Vanags, U. (1993). A report to the 116th Joint Standing Committees on Human Resources on the state of Maine monitoring of radioactive effluent from the Maine Yankee Atomic Power Company. Maine State Planning Office, Augusta, ME.

  • This report presents the findings of a legislative committee which rejected upgrading monitoring equipment because "the improvement to the goal of minimizing uncertainty in detecting or measuring radiation dose is only marginal." (pg. v).
  • "The environmental information acquired from the ERM-2 system (ed. comment: the pole mounted environmental radiation monitors surrounding MYAPC), TLD's, and environmental samples provides adequate information to assess the impact to the public health and the environment from Maine Yankee effluents." (pg. iv).
  • This report includes a summary of radiation monitoring systems and programs at MYAPC and the state sponsored ERM-2 program and a lengthy series of appendices reprinting these reports. Included in appendix 1 of this report are the January 1993 records of 22 on site radiation monitoring systems presented in graph form. These monitors include the crane area monitor, spent fuel pool area monitor, pump room monitor, waste gas vent monitor, containment gas monitor, vent stack particulate monitor, waste liquid discharge monitor, and the steam generator liquid radiation monitors among other site systems. Reporting units for all area monitors are either in counts per minute or MR/hr x 12 minute segments. The introductory page notes "many down scale and up scale spikes appeared most likely from the plant shutdown" (01/14); a spike on January 12 appearing on many of the monitors "appeared most likely from the diesel generator 1-B output breaker transient."
  • The station radiation monitoring data at MYAPC or any other NRC licensed facility provide an important potential source of information for anyone seeking additional data about anomalies, incidents or radiological events at an on-line reactor. These obscure station radiation monitoring reports should be available via the public document room or from the NRC for anyone who wishes to check variations in the day to day performance. The waste liquid discharge monitor shows a consistent 12 minute average of around 1,000 counts per minute in contrast to a technical specification limit of around 20,000 cpm. No nuclide specific data can be derived from any of the station radiation monitors.
  • This report also includes the radiation monitoring system monthly report basis, State of Maine monthly report, the MYAPC 1990 environmental monitoring report, the MYAPC semi-annual effluent reports for 1992, the MYAPC gaseous release dose impact report for 1990 and a variety of other appendices on radiation monitoring issues and systems.
  • This is the most comprehensive summary of radiation monitoring programs and reports to be compiled in regard to MYAPC operations and may prove to be a useful source of information to persons concerned with effluents from other facilities where monitoring programs are not so accessible.
  • This detailed report is also significant not only for the wealth of information it provides but also for the many biological monitoring issues which it and the NRC and the nuclear industry continue to evade. This report was issued in March of 1993 before Uldis Vanag's primary function changed from State Nuclear Safety Advisor to State Nuclear Public Relations Coordinator under the attentive direction of the new independent governor, Angus King.
Vanags, U. (1995). State of Maine: Nuclear safety report submitted to the 117th Maine Legislature, 1995. Executive Department, Maine State Planning Office, Augusta, ME.
  • This brief report is a summary of the operation and performance of the MYAPC (20 pp.) and includes annual net electrical production for this facility. Average production between 1976 and 1994 was 5,000 million kilowatt hours with a peak production in 1989 of almost 7,000 million kilowatt hours. (pg. 2).
  • This report includes a summary of releases of radioactivity from the plant between 1980 and 1993: these include noble gases, gaseous halogens, gaseous tritium, tritium liquid effluents, liquid fission and activation products, the annual volume of low-level radioactive wastes, and the annual quantity of radioactivity (Ci) in low-level wastes.
    • Maximum release of tritium in liquid effluents was in 1989, just over 400 Ci. (Fig. 12, pg. 11).
    • Maximum release of gaseous tritium was in 1990, just under 20 Ci. (Fig. 11, pg. 11).
    • Annual release of liquid fission and activation products, including particulates, has never exceeded 1 curie in any years between 1980 and 1993. (Fig. 13, p. 11).
Weeks, R.W. (1983). Stress corrosion cracking in BWR and PWR piping. (Invited paper presented at the Intl. Symp. on Environmental Degradation of Material in Nuclear Power Systems-Water Reactors, Myrtle Beach, S.C., Aug. 22-25, 1983). U.S. Nuclear Regulatory Commission, Washington, D.C.

Yankee Atomic Electric Company. (1991). Maine Yankee Atomic Power Station: Maine Yankee Atomic Power Company: Annual radiological environmental monitoring report: January - December 1990. Yankee Atomic Electric Company, Bolton, MA.

  • The NRC requires all nuclear power plants to file these annual radiological reports, which MYAPC has done since 1973. The data within this report is collected and analyzed by the Yankee Atomic Electric Co. in Bolton, MA, which is the same company involved in the irregularities noted pertaining to McCarthy's analysis of Montsweag Bay sea vegetables (See Decommissioning waste inventories), as well as in the whistleblower's letter released to the public on Dec. 4, 1995.
  • See RAD 11, Section 4: United States Nuclear Power Plants, for an annotation of this citation.

Yankee Atomic Electric Company.(April 1995). Maine Yankee Nuclear Power Station: Annual Radiological Environmental Operating Report: January - December 1995. Yankee Atomic Electric Company, Bolton, MA.

  • The same antiquated annual radiological surveillance data published in an upgraded format.
  • Air samples at five locations have filters which are collected weekly and are held for 100 hours before being analyzed for gross beta radioactivity at the Maine Yankee Atomic Environmental Laboratory. The air samples also contain a charcoal cartridge which is analyzed for 131I. In 1995, gross beta measurements at all stations ranged between .005 pCi/m3 through .033 pCi/m3 with an average range of .02 pCi/m3 (750 microbecquerels/ m3).
  • Four sediment samples were analyzed for 137Cs: the range was 160 - 370 pCi/kg dry for samples taken in the top 5 cm layers of sediment. As per usual, sediment grab samples taken from the bottom of Montsweag Bay near the location of the diffuser for liquid effluents are assiduously avoided.
  • 137Cs in milk samples ranged from 1 - 4 pCi/kg, having dropped from the 1986 peak (Chernobyl) of 12 pCi/kg.
  • The exposure rate at both inner and outer rings of TLD's consistently range from 4.9 - 10 Micro-R/hr.
  • On page 19, NRC mandated reporting levels are listed in Table 4.5; NRC regulations do not require reports of radiological contamination below these levels of concentration. For 137Cs these reporting levels are: air concentration: 20 pCi/m3; for fish and invertebrates: 2,000 pCi/kg; for milk: 70 pCi/liter; for food products: 2,000 pCi/kg. The reporting level for 60Co is 10,000 pCi/kg. The significance of these high reporting levels is that substantial quantities of radioactive contaminants could be discharged from this or any other NRC licensed plant in a pattern illustrating an increasing decline in the material condition of the plant facilities without this trend being noted until contamination reached a very substantial level.
  • The presentation of data in Table 5.1 from monitoring the biotic environment (for gamma emitting radionuclides in fish, crustaceans, mussels, and clams) is presented in a manner that makes it impossible to document any trend toward increasing levels of contamination, or to interpret the location of such contamination isocurically with respect to a specific source point (the diffuser).
  • These reporting levels again remind us that the NRC, the licensee, and the Federal Emergency Management Agency are primarily concerned with levels of contamination that result in the possibility of acute health effects. Long term trends in patterns of chronic low-level emissions are of no significance to the NRC, nor are they observable at these reporting levels.
  • The lower limits of detection (LLD) used by the licensee and NRC are reported in table 4.4: air concentration of 137Cs: .06 pCi/m3; in fish and invertebrates: 150 pCi/kg; for milk: 18 pCi/liter; for food products: 80 pCi/kg; and in sediment: 180 pCi/kg dry. It is interesting to note the LLD for air concentrations of 137Cs (.06 pCi/m3 = 2,200 microbecquerels/m3). A decade ago after the Chernobyl accident, the Riso National Laboratory was routinely measuring air concentrations of 137Cs as low as 2 or 3 microbecquerels/m3 in the months after the Chernobyl accident. Peak air concentrations at the Riso Lab after the accident, a location not substantially impacted by Chernobyl fallout, had been as high as 63,608 microbecquerels/m3; see Riso R549 pages 239-247. Once the Chernobyl fallout cloud had passed over the Riso Laboratory on April 24-28, air concentrations of 137Cs dropped quickly but then showed a very erratic variability throughout the summer of 1986, finally dropping to less than 20 microbecquerels/m3 in most samples after September 1, 1986.
  • At an LLD of 2,200 microbecquerels/m3, the MYAPC is unable to document small increases of the air concentration of radiocesium which might signify a large problem; even more ominous is the LLD for airborne concentrations of 131I: .07 pCi/m3 (2592 microbecquerels/m3). During the Chernobyl accident, peak air concentrations of 131I at the Riso National Laboratory were 232,622 microbecquerels/m3 which rapidly dropped to 500 microbecquerels/m3 in late April before another pulse of Chernobyl derived radioiodine passed over Riso on May 2-8 (496,000 microbecquerels/m3 ); after this second pulse Riso Lab air concentrations dropped back down to +/-500 microbecquerels/m3. The last reading for this short-lived radionuclide at Riso was June 16-19 at 44 microbecquerels/m3. The MYAPC, FEMA, and the NRC lack the sophisticated equipment to record pulses of MYAPC derived radioiodine below 2592 microbecquerels/m3. These small pulses could be important indicators of plant degradation, including leaky fuel cladding.

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