Release Quantities for Postulated Nuclear Reactor Accidents

*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.

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"):

* 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.
 

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.
 

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.
 

April 1997:

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

NOTICE OF CLOSURE

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.

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.

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
SOURCE POINTS OF ANTHROPOGENIC RADIOACTIVITY
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
05/15/97

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 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.

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.
 

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.
 

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.
 

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.
 

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.

Sincerely,

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

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.

References:
I. NUREGO737
2. 11RELAP5YA, A Computer Program for Light Water Reactor System Thermal-Hydraulic Analysis" YAEC 1 300P.
3. Maine Yankee Power Uprate Application, December 1988.

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.

P J A

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.

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.

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:

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.

Mr. Atherton was fired from NRC. Then Maine Yankee was rewarded by NRC with a power upgrade on May 10, 1978 allowing the plant to operate at 2560 MWt. If you recall the ISAT findings, the emergency core cooling system equipment was not demonstrated to be operable at power levels above 2440MWt. So, in its mandated duty to regulate licensees and protect the public health and welfare, NRC not only allowed Maine Yankee to operate with a fire hazard [that] could wipe out primary and redundant safety-related cables, but they granted them a power upgrade allowing them to exceed the margins for the containment spray system, the high pressure safety injection system, residual heat removal, service water and component cooling water systems -- all of which are necessary to mitigate the consequences of an accident.

For nearly 19 years, NRC has allowed Maine Yankee to operate with an inadequate emergency core cooling system. They also approved and licensed this facility to operate with improperly routed safety-related cabling. Maine Yankee has posed a significant and undue risk to public safety since the first day of operation!"

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

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.

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.

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.

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.

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.

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.

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.

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.

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