· Inadequate information about the decommissioning process

· Lack of information about large component disposal procedures

· Lack of truthfulness about the option of reactor vessel disposal with GTCC internals intact

· Failure to provide description of planned liquid discharges in PSDAR (reactor containment flushing, reactor water storage tank [RWST] discharges, neutron shield tank, etc.)

· Failure to provide prior public notice of the liquid discharges in Montsweag Bay

· Lack of timely availability of long-lived fission product liquid discharge inventories (data still not available as of 9/15/98)

· Sampling of liquid waste discharges inadequate to accurately characterize hot particle contamination in tank sediments

· Minimum sampling of Montsweag Bay (site characterization process) executed prior to liquid discharges

· Post liquid discharge sampling/monitoring nonexistent following reactor decontamination flush -- issue not discussed in PSDAR

· The NRC and state of Maine nuclear safety officials unable to provide timely information about the radiological content of liquid discharges and other decommissioning activities

· PSDAR insufficient to allow continuation of the decommissioning process

· Survey packages 0100, 0500, 0900, R1000 and special survey 2501 showed extensive on- and off-site plant-derived contamination

· The leak of the reactor water storage tank only one of a series of small nuclear accidents which occurred during plant operation

· Inefficiency and ineffectiveness of the drive-over scans missed most contamination in special survey 2501 (+/-10,000 ft²)

· Laboratory analysis of field samples indicates unreliability of the drive-over scans

· MYAPC site misrepresented as clean; soil contamination undisclosed and not discussed during CAP meetings

· The data presented at CAP meetings prior to the site characterization report was misleading and deceptive

· Grossly inadequate database of plant-derived contamination in Montsweag Bay and on MYAPC property resulting from plant operations (historical site assessment)

· Inadequacy of sampling of biotic media and sediments in Montsweag Bay and Bailey Cove during plant operation and decommissioning

· DCGLs [derived concentration guideline levels] undetermined and not discussed during CAP meetings

· Site characterization report points to the urgent need of additional radiological sampling documenting the impact of plant operations and decommissioning

· Insufficient characterization of background radiation

· Maximum possible background radiation levels used as baseline; e.g. ¹³⁷Cs weapons testing derived fallout: 2,000 pCi/kg

· Insufficient database to evaluate dose-based site release criteria

· Segmentation versus intact burial issue not discussed at CAP meetings nor by NRC or licensee

· New NRC policy of concentration averaging kept secret

· State of South Carolina/Barnwell position on concentration averaging not yet clarified

· Option of use of Barnwell for RV burial with GTCC components intact unresolved

· Impact of this unresolved issue on decommissioning costs not discussed

· Inadequacy of the Texas Compact facility for receipt of decommissioning-derived large components (steam generators and reactor vessel)

· Reactor vessel internal component segmentation violates ALARA due to

a. gaseous emissions

b. worker exposure

c. the generation and release of large quantities of hot particles due to underwater welding

· Reactor vessel internal component segmentation results in huge unnecessary decommissioning costs compared to safe storage decommissioning alternative

· "Decommissioning" costs (e.g. Stone and Webster $250,000,000) only one small segment of MYAPC life cycle costs

· Large differential in cost of reactor vessel internal component segmentation versus reactor vessel disposal with GTCC internals intact

· Fixed price decommissioning contract can lead to huge wastes of ratepayer funds since actual decommissioning procedures are as yet unknown

· Actual costs of multipurpose-purpose casks not known

· Future spent fuel transportation costs unknown

· Destiny of spent fuel unknown (indefinite onsite storage versus MRS [monitored retrievable storage] or final geological repository)

· Texas Compact fees a huge waste of money for a low-level waste facility that won't be fully utilized (many other locations will be available for future disposal of class A low-level wastes)

· Texas facility design not compatible with large component disposal program (steam generators, reactor vessel)

· Texas facility too far from ocean access (Galveston) for reactor vessel transport

· Final geological repository and/or spent fuel MRS facility costs essentially unfunded: remains of mill rate collections will fund only a tiny percentage of the cost of siting spent fuel wastes generated to date

· Inadequate NRC staff resources to oversee decommissioning

· Inadequate licensee and state of Maine staff resources to oversee decommissioning

· Continued evasion of funding waste storage and disposal and decommissioning costs by FERC, NRC and the state of Maine tantamount to public corruption advocacy

· The problem of leaky fuel assemblies well known in early years of plant operation

· Hot particle discovered by Hess in Bailey Cove in 1974 not followed up by further surveys

· Grid to [fuel] rod fretting documented by NRC just prior to plant closure a potential source of hot particle contamination

· The hot particle on Bailey Point discovered during the site characterization process pre-dates the most recent episode of grid to [fuel] rod fretting; origin unknown

· Hot particle contamination may also be in the form of activation product CRUD

· Reactor vessel a major repository of hot particle contamination

· Reactor vessel dross uncharacterized by NRC during decommissioning process (e.g. Yankee Rowe) -- data not available

· Water systems another source of hot particle contamination: e.g. reactor water storage tank, neutron shield tank, decontamination flushing of reactor water systems, etc.

· Tidal flow in Montsweag Bay allows spread of hot particle contamination over a widespread area of the Sheepscot River basin

· Hot particle contamination not amenable to monitoring or remediation -- for every hot particle discovered thousands more exist undetected in sediment and biotic media

· Extensive hot particle contamination permitted by liberal NRC licensing basis regulations (see Section IV.C of Appendix I to 10 CFR Part 50) -- hot particle contamination not an NRC concern

· Spent fuel won't be removed anytime in the near future

· Offsite MRS [monitored retrievable storage] facility unlikely

· If MRS facility is available soon, MPCs [multi-purpose canisters] not available for fuel transport and storage

· Defacto high-level waste storage facility at Wiscasset an excellent location for long term storage for all state of Maine derived low-level wastes (e.g. The Jackson Laboratory, etc.)

· Low-level waste-derived revenues can partially offset cost of defacto high-level waste MRS facility at Wiscasset Maine

· Undocumented MYAPC site contamination (see surveys 0100, 0500, 0900, 1000 and special survey 2501) provides compelling argument for continued site use as a defacto radioactive waste storage area

· Failure of the news media to correct misinformation about MYAPC as a "clean" site provides an additional compelling argument for the continued development of a radioactive waste storage facility in Wiscasset (e.g. Portland Press Herald, MPR and MPBN, Lincoln County Weekly)

· Contamination in 0100, 0500, 0900, 1000 and special survey 2501 continues to be unreported by media; lack of public disclosure/exposure exacerbates potential economic impact of site contamination

· Noisy fans a metaphor for a dysfunctional, disconnected decommissioning process; poetic justice for neighbors unconcerned about the use of Montsweag Bay as an undocumented sewer

· MYAPC site a practical location for all Maine generated low-level wastes: will provide additional jobs as well as continuation of tax revenues for the town of Wiscasset

· Not enough biological monitoring data to validate dose-based site release criteria

· Inadequate historical site assessment

· Little or no information about onsite soil contamination

· Cesium-137 contamination documentation in soils not required by Off-Site Dose Calculation Manual

· Unresolved issue of how and when the existing soil contamination will be removed

· Unresolved issue of how much additional contamination missed by inaccurate drive-over scans and inadequate laboratory samples

· State of Maine split samples delayed and unavailable

· Any gas pipelines must be at least one mile from dry cask storage area or two miles from the spent fuel pool for public safety reasons

· Re-use of MYAPC site for gas-fired facility mandates monitored retrievable storage of spent fuel at another location (e.g. Chewonki Neck)

· Necessity of additional site characterization as well as soil remediation plus decommissioning delays and unresolved issues render repowering the MYAPC site unlikely

· Repowering issue a diversion from unresolved issues

· Repowering defacto high-level and low-level radioactive waste storage facility impractical and unlikely

NRC, licensee, state, public and media indifference to MYAPC-derived contamination documented in special survey 2501 as well as in surveys 0100, 0500, 0900 and 1000 provide a basis for developing the MYAPC site as a regional monitored retrievable radioactive waste storage facility. The fees and surcharges from the operation of such a facility will assist in subsidizing the high cost of a permanent spent fuel storage facility that will provide jobs and taxes to support the local economy of the future. The deflection of attention from these many unresolved issues by the NRC, licensee, state of Maine and CAP maximize the likelihood of the establishment of a deregulated and privatized high-level, medium-level and low-level radioactive waste storage facility at Wiscasset. The failure of Maine media such as PPH, MPR and the Lincoln County Weekly to report the contamination documented in the above surveys provide the most eloquent argument for the evolution of the MYAPC site as a regional high- and low-level waste storage facility.

Maine residents voted on three occasions for the establishment of a taxpayer subsidized defacto radioactive waste storage facility. The accompanying deceptions (e.g. power uprate scam), evasions, unresolved safety issues, lack of public disclosures or discussions, the failures to fund waste storage or disposal, deficiencies in radiological surveillance programs and the unwillingness to accurately document recent liquid discharges including possible hot particle contamination constitute an ongoing ritual of aversion. MYAPC is a permanent defacto radioactive waste storage facility -- get used to it.