ML19267A334
| ML19267A334 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 12/14/1978 |
| From: | Baldwin W FRIENDS OF THE EARTH |
| To: | Casey Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19263B181 | List: |
| References | |
| NUDOCS 7901080375 | |
| Download: ML19267A334 (97) | |
Text
,
FRIENDS OF THE EARTH 1:4 SPEAR SAN FRANCISCO CALIFoRNI A 94103
[413)495-4770 December 14, 1978 Dr. Clifford V. Smith, Jr.
Director, Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C.
20555 RE:
Vallecitos Nuclear Center, Special Nuclear Materials License No. SNM-960
Dear Dr. Smith,
Pursuant to 10 C.F.R. Section 2.206, Friends of the Earth hereby files a Request for Action to the Nuclear Regulatory Commission.
Specifically, Friends of the Earth requests t' hat the Nuclear Regulatory Commission order the following:
1.
suspension of all activities under License No. SNM-960 at the Vallecitos Nuclear Center; 2.
removal of all plutonium from the Vallecitos Nuclear Ce'n ter,-
3.
holding of public hearings before any plutonium is returned to Vallecitos or any plutonium handling at Vallecitos is resumed:
4.
production and delivery to F.O.E. of a complete inventory of radioactive materials at the Vallecitos Nuclear Center; 5.
production and delivery to F.O.E. of structural analyses of all VNC bui-ldings which contain radioactive material.
M108b3 lS
1.
INTRCDUCTION Cn October 24, 1977, the U.S. Nuclear Regulatory Commission (NRC) ordered the suspension of operation of the General Electric Test Reactor (CETR) at General Electric's Vallecitos Nuclear Center (VNC) near Pleasanton, California (In re GE Test Reactor, License No. TR-1, Docket No. 50-70 (Show Cause))<.
NPC ordered the suspension af ter receiving information that earthquake hazards at VNC are much more serious than previously recognized:
(1) an active fault, the Verona fault, passes across the VNC site, and (2) tha Ca:sveras fault, less than 2 air miles from VNC,
- is capable of deltvering earthquake shocks to VNC which are much greater,than previously estimated.
VNC also contains extensive facilities for the prccessing of plutonium (the " plutonium labs").
T*.ese activities are con-ducted principally in VNC Building 102, pursuar.t to NRC Special Nuclear Materials License No. SNM-960, Cocket No.70-754 SNM-960
~
acti tivies involve the use of both plutonium oxide and plutonium nitrate, both of which are in unsealed form during processing, and both of which are available for release to the environment if an earthquake damages or destroys Building 102.
Although Building 102 is approxi=ately 1000 feet from the GETR, and although Building 102 contains large quantities of unsealed plutonium, NRC did not suspend operations in Building 102.
Processing of plutonium continues today, while NRC and General Electric (GE) debate the strengths of earthquakes which could occur at 7NC.
License No. SNM-960 allows GE to possess up to 150 kilograms (330 pounds) of plutonium at Vallecitos, Typically, several kilograms of pihtonium are in unsealed form during processing.
Plutonium was not put on earth by God in measurable quantities.
It is named after Pluto, the Lord of Hell.
was discovered as a byproduct of nuclear fission and is now manufactured both for nuclear weapons and as fuel for plutonium nuclear reactors.
Plutonium is a cancer causing agent of awesome effectiveness.
Professor Gofman (Appendix 3) has cal-culated that indsled insoluble plutonium particles can theoretically 10 produce up to 2.2 x 10 (22,000,000,000) cases of lung cancer per kilogram (2.2 pounds).
Moreover, plutonium toxicity is i=mune to everything except the passage of time.
Released i
plutonium' particles will decay with a " half life" (for plutonium 1
j
- 239) of 24.000 years.
Decay to safe levels will take as much as ten half lives, or 240,000 years.
The plutonium will be available to cause lung cancer for a time into the future far i
longer than the recorded history of man.
i This Request for Action is based on several censiderations:
i (1) NRC estimates of plutonium release from the plutonium labs 1
after an earthquake are too low, (2) NRC estimates of plutonium toxicity are too low, and (3) it is inadvisable to allow the plutonium labs to remain open (a) while the NRC and GE debate the earthquake dangars at Vallecitos, (b) when the NRC admits that near-destruction of the plutonium labs including the collapse of the first floor and destruction of the bridge to the filter i
l i.
building, could be caused by a predictable earthquake, (c)
When the NRC's own estimate of the maximum possible earthquake has risen since the NRC study of earthquake effects at the plutonium
- labs, (d) When the NRC admits that an accident could carry plutonium particles into nearby towns (within 20 miles of VNC live approximately 2,000,000 people; within 50 miles live 5,000,000), and (e) after discovery of fault features next to the' labs.
NRC's basis for keeping the plutonium labs open in the face of the seismic hazards which shut the GETR is " Preliminary Safety Evaluation by the Office of Nuclear Material Safety and Safeguards, General Electric Company /Special Nuclear Material License No. SNM-960, Docket No.70-754", dated November 7, 1977
("NRC-PSE").
NPC-PSE does not demonstrate the safety of the plutonium labs in aa earthquake. NRC-PSE is deficient in light of significant new seismic information.
This new in?ormation indicates that the plutonium labs must be shut immediately.
2.
HIGHER G VALUES The NRC-PSE analysis was based on the assumption that an earthquake was possible at the plutonium labs which could produce ground accelerations of.75 g (75% of gravity).
NRC-PSE predicts limited damage to the plutonium labs resulting from this.75 g earthquake.
The amounts of plutonium predicted to escape from the plutonium labs in NRC-PSE are extremely small, based on the limited damage predicted from the.75 j earthquake.
On August 17, 1979 (released September 29, 1979) NRC staff geologists made preliminary estimates of the earthquake potential at the GETR in the course of the GETR show cause hearings i
referenced above ("Show Cause Proceeding Safety Evaluation Report Input, GE Test Reactor Site /Vallecitos Nuclear Center"
("PSER-GETR")).
PSER-GETR estimates (p. 6-7) that an earth-quake on the Calaveras fault could deliver maximum ground accelerations to the GETR in excess of 1.0 g (i.e.,
greater than the force of gravity, or strong enough to throw objects off the ground).
The Calaveras fault is approximately 10,000 feet from the GETR and approximatelv 9,000 feet from the plutonium labs.
Therefore, the NRC must assume an earthcuake potential greater than 1.0 g at the plutonium labs, and therefore the NRC-PSE accident analysis, based on.75 g, is inadecuate.
GE also prepared analyses of the response of the plutonium labs to peak earthquake ground accelerations of.58 g and.75 g
(" Advanced Fuels Laboratory Presentation to NRC at Bethesda, Md., Oct. 28, 1977 and Additional Information Supplied to NRC, Oct. 28 and 29, 1977 and Nov.
2, 1977"
("GE labs analysis")).
The GE labs analysis included GE's con-clusions that in an earthquake the bridge from Building 102 to the external filters in Building 102a could be lost, and that the first floor of Building 102 could collapse, offering no barrier to containment (GE labs analysis, Sec. IV).
The basement structure of Building 102 is assumed to not collapse in the GE labs analysis, out is reported by GF co suffer stresses of 86% of yield at.75 g (GE labs analysis, p. III-4).
Usine GE's own stress data and the NRC staff's 1.0 g earth-cuake estimate from PSER-GETR, the collacse of the basement of the plutonium labs is accarently indicated. The forces necessary
_5_
to produce a 1.0 g peak acceleration are much greater than those used by GE (.75 g) in calculating that the basement structure will sustain 86% of its' yield force.
As a preliminary estimate, scalar multiplication indicates forces approximating 115% of yield may be present in an earthquake producing peak accelerations of 1.0 g.
It is inconsistent, therefore, for NRC to assume in NRC-PSE that the basement will not collapse; in light of the PSER-GETR estimate, the assumption is mandated that the basement will collapse.
The postulated collar se of the basement negates several assumptions made in NRC-PSE which reduce the offsite doses from released plutonium. Most of the plutonium is in the basement.
3.
SURFACE FAULTING Ground rupture during an earthquake at Building 102 would be additional assurance of the destruction of the building.
No analysis of the effects of ground rupture has, to our know-ledge, ever been made by NRC or by GE or by any of GE's consultants.
None appears in NRC-PSE or the GE labs analysis.
Recent and extensive trenching has been done at Vallecitos in the GE Test Reactor Show Cause proceeding referenced above.
Fault-type features exist in trenches to the north, to the south, and adjacent to the GETR in locations indicated by the U.S.
Geological Survey's map of the Verona fault (USGS Open File Map 77-689 (1977)).
Moreover, trenches due to the north and to the south of the plutonium labs also shew fault-type features.
Ncrth of Suilding 102 (the trench kncwn as "3 extension") a clearly evident fault-type offset is present across all terraces in the
i trench (exhibit "A").
This line exhibits evidence of movement as polished clays (slickensides) along its length.
South of
[
Building 102 a similar line can be found separating orange soil i
from brown soil along a plane roughly parallel to the Verona i
fault (exhibit "B").
The line of sicht frcm fault-type features north of the plutonium labs to fault-type features south of the I
clutonium labs casses almost directly throuch the plutonium labs.
i Existence of these fault-type features near the plutonium labs 4
was confirmed by NRC geologists in a memorandum dated October 27, 1978 to Carl Stepp from J.T. Greeves and R.E. Jackson, who stated "the Southwest extension of trench 3...
i showed an apparent thrust or reverse fault of fset in the approxi-mate location of another airphoto linear."
Exhibit "A"
is a photo I
o f the Southwest extension of trench "3".
I I
Any. structural analysis of the plutonium labs which as in NRC-PSE does not assume surface ructure is therefore not conser-i vative and is unacceptable in light of this new data.
J 4.
NEW POSTULATED SEISMIC IMPACTS:
ADVANCED FUELS LAB 1
The postulated collapse of the ground ficor undermines l
the credibility of plutonium release amounts given in NRC-PSE i
i for the Advanced Fuels Laboratory in the Building 102 basement.
I r
NRC-PSE assumes that the glove boxes in the basement would not be destroyed, as they likely would be if the ceiling collapsed, and also assumes that the glove boxes would retain up to 9999/10',000 of their i
inventory even when damaged.
Moreover, in NRC-PSE the ceiling of the basement remains as a barrier to plutonium release once the I
l plutonium has escaped from the glove boxes.
If the ceiling collapses, therefore, both of the containment features in the NRC-PSE analysis would be gone.
There would be no barrier to the release of the maximum of 5.5 kilograms of plutonium oxide in process in the Advanced Fuels Laboratory.
5.
NEW POSTULATED STRUCTURAL IMPACTS-RADIOACTIVE MATERIALS LABORATORY The Radioactive Materials Laboratory (RML) is located on the first ficer of Building 102. NRC-PSE assumes that the " hot cells" in the RML will fall off their bases, and be turned over, and have their internal filters punctured.
Yet, NRC-PSE predicts that only.0000001 of the plutonium inventory of the cells would be released from the cell (NRC-PSE p. 23).
Making the generous assumption that this release fraction is realistic a 1.0 g peak seismic acceleration input worsens the situation drastically, in that not only would the forces on the hot cell itself be much greater, but the collapse of the basement could cause the hot cells to fall 12-15 feet.
Moreover, the speed with which the hot cells would impact might be exaggerated by the basement-subsoil system accelerating upward during the earthquake at the time the hot cells re-impacted the rubble.
No analysis exists to our knowledge of the behavior of the hot cells under these stresses.
A conservative assumption is that the concrete shells would be broken up and the inner liners torn open, causing a greatly higher release fraction than.0000001.
NRC-PSE does not consider the possibility of fire as a plutenium nitrate suspension mechanism.
This shortccming is discussed below.
- NRC apparently satisfied itself informally that the hot cells would fall over and not break, and that the cell liners would remain intact.
No formal anal"si c i= ci'ran
_a_
6.
SUSPENSION MECHANISMS The safety shown by NRC-PSE depends in large part on the assumption of an absence of suspension mechanisms, i.e.
driving forces which could cause plutonium particles to become airborne.
At least five credible suspension mechanisms were not considered in NRC-PSE.
(1)
Not considered as a driving force for plutonium particles is the earthquake itself.
An earthquake capable of destroying Building 102 and throwing objects off the ground would suspend essentially all the unsealed plutonium in the air, and probably throw the spilled plutonium off the ground several times,. sus-pending large quantities of small particles each time.
NRC-PSE assumes that confined areas within partially damaged glove boxes and het cells will be momentarily loaded, once, with plutonium oxide part$icles.
In addition, therefore, to the fatal optimism of the-assumption of non-destruction of the glove boxes and hot cells must be added the additional consideration that the material released from destroyed glove boxes and hot cells will repeatedly be tossed by the eart. quake like the dressing in a radioactive salad.
(2)
NRC-PSE does not consider the collapse of the basement ceiling as a suspension mechanism.
Enormous pressures will result underneath the ceiling as it falls to the floor.
The falling of the ceiling of a building typically blows out the windcws, and can sometimes blow large objects out of the building.
These pres-sures will be available to disperse the plutonium oxide powder spilled in the basement.
(3)
NRC-PSE does not consider earthquake aftershocks as driving forces capable of suspending plutonium oxide particles in the air.
Each aftershock would raise a new cloud of plutonium particles to be carried offsite by the winds.
Each after. shock would, in fact, produce the same or higher offsite doses than the original earthquake, as it would be acting, not on a structurally sound building, but on a pile of rubble coated with plutonium dust.
(4)
NRC-PSE does not consider the wind as a driving force.
Destroyed stru'ctures do not keep out the wind.
As the original plutonium dust cloud is carried offsite by the wind after the earthquake, the wind will begin to reach into the rubble pile, where it will locate plutonium dust and carry it away. High winds are not uncommon at VNC, and high or low winds at any time before the rubble is cleaned up (no plans or technology exist for the cleanup) will continue to blow plutonium out of the rubble and spread it around the Bay Area.
(5)
The GE labs analysis (p. IV.-7) considers fire to be a credible possibility after earthquake damage to the plutonium labs, and offsite doses in the GE labs analysis include fire-sus-pended plutonium nitrate.
GE does not consider the effect of the pcstulated fire on the plutonium oxide inventory.
NRC-PSE, however, dismisses without explanation the possibility of fire (NRC-PSE p.
17), ienorine GE's own references to the flammable materials in Buildinc 102 (GE labs analysis, p. IV-7, p. IV-12).
Fire as a heat source is capable of suspending a great amount of plutonium nitrate and plutonium oxica directly or through convection currents, causing great increases in NRC-PSE's offsite doses.
- I
. 7.
PRE-CLEANUP NRC-PSE assumes that all plutonium released from the rubble of the plutonium labs is released on the first day (pp.28-31).
This assumption is unrealistic.
NRC apparently believes that the plutonium nitrate and: Plutonium oxide powder, spilled and dispersed throughout the rubble of the abs, is only capable of release to the environmentin the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter the earthquake.
With respect to spilled plutonium nitrate solution, this assumption is inconsistent with the NRC-PSE assumption that spilled plutonium nitrate will dry and disperse to the environ-ment at a steady rate (pp. 14, 25, 26).
To assume both a. steady release of plutonium as aerosol plutonium nitrate following a spill, and simultaneously assume that the dispersal will stop after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not logical.
No mechanism for the cessation of the release is stated.
Further, with respect to plutonium oxide. pcwder, a
similar inconsistency exists.
NRC-PSE assumes an instantaneous-release of plutonium oxide powder at the time of the earthquake, followed by zero release (p. 28).
Not considered in NRC-PSE is the continuing release which would result frcm air currents penetrating the rubble of the labs.
High winds are not unccmmen at the site; the rubble could be easily penetrated by any wind currents following the earthquake.
Plutonium cxide powder will ride these currents out of the rubble.
NRC-PSE is possibly =aking an unstated assumption that the offsite doses after 24 hcurs will be zero because nearby cities (e.g. Pleasanton, Livermore, Frement, Hayward, Union City) will be evacuated before 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have elapsed.
If this
_ _ _ assumption is being made it should be clearly stated and clearly justified.
The contention that nearby towns could be quickly evacuated after a major earthquake which destrcys all roads, all communication, all electric power, panics the population and injures a substantial prcportion of the popula-tion is not realistic.
Moreover, if NRC is assuming that Pleasanton, Livermore, Fremont, Hayward, Union City and other nearby cities will be quickly evacuated to prevent plutonium contamination of their populations,it should notify the municipal administrations of those towns, and specify how the evacuation would be imposed, and specify how long (days, weeks, years) the evacuation would last.
8.
CLEANUP NRC-PSE does not consider the offsite radiation deses which would result from efforts to clean up the rubble of the plutonium labs. Prcsamably such an effort would be undertaken af ter the earthquake.
The only alternative would be " entombment" of the rubble of the labs with asphalt or concrete for thousands of years.
NRC could not guarantee the safe isolation of the plutonium in the entombed rubble for the time necessary for the material to decay to safe levels (as much as 240,000 years).
No technology exists to isolate materials at the earth's surface for time period of this magnitude.
A safe assumption, therefore, is that a cleanup effort will be undertaken by NRC (or a successor agency) at scme time follcwing the earthquake.
There ir no question that this effort will result in the release of plutonida offsite.
No technology exists to remove large amounts of materials (either soil or the rubble of rapidly disassembled buildings) without release of some of the materials as wrecker's dust.
The inability to clean up plutonium-contaminated soil at the Rocky Flats nuclear weapons factory in Colorado follows from this consideration:
cleanup has not been undertaken precisely because of the fear of resulting offsite plutonium contamination.
NRC-PSE also has.not addressed these questions: How will plutonium-contaminated water be contained?
How will NRC obtain the eq ipment to undertake the cleanup?
Nhere will the wreckage be put?
How will NRC convince equipment operators to undertake this possibly suicidal job?
9.
PLUTorlIUM CANCERS NRC plutonium lung cancer calculations are too low by a factor of at least 100, due to a
persistent failure to con-sider the self-siting of inhaled insoluble plutonium particles (e.g.,
plutonium oxide) in the bronchial epithelium.
The bronchial epithelium (1 gram) is responsible for approximately 90% of the cancers occuring in the 570-gram pulmonary lung.
Dr. John Gofman, Professor Emeritus at the University of California, Berkeley, and former Sicmedical Director of the Lawrence Livermore Laboratory, has shown that two factors combine to increase the relative dose to the bronchial epithelium far beyond the average dose to the entire pulmonary lung:
- The Cancer Hazard from Inhaled Plutonium, CNR 1975-1, Ccmmittee for Nuclear Responsibility, 1975; The Pluroniam Centroversy, Journal of the American Medical Association, v. 236, July 19, 1976.
. (1) the tendency of the plutonium particles to locate near the bronchial epithelium itself, and (2) the tendency of the particles to remain near the bronchial epithelium for long periods due to slow clearance mechanisms (especially in smokers, whose cilia are damaged or absent).
Retention of plutonium particles for upwards of 500 days is likely in some cases.
During this time, the plutonium particle selectively irradiates the bronchial epithelium, that small part of the lung mass most likely to cause lung cancer.
Each radioactive disintegration can produce 5000-8000 chemical disruptions in the surrounding tissues.
Disruption of a cell's reprcductive system can change the cell into a cancer cell.
Inhaled insoluble plutonium oxide particles are roughly 10,000 - 100,000 times more potent, by weight, at causing cancer than the most potent known chemical cancer agent.
Dr. Gofman has calculated the potential lung cancer doses from a 5500 gram plutonium inventory
( Appendix "3"). This amount is present in unsealed form in the Advanced Fuels Laboratory.
Dr. Gofman notes that " particle size is important in determining whether the plutonium will or will not deposit in the sites of the bronchi where it can provoke lung cancer.
However, when plutonium is dispersed in the environment, we can only guess what the ultimate dispersion will be and what particles will be-come available for inhalation.
As MarteL1 has pointed out, there is the possibility that fragmentation from alpha particle recoil can occur, so that even priticles that are initially dispersed at one size, can, with time, give rise to smaller particles that are in the right size range to produce lung cancer. Therefore, the truly meaningful number is the total number of lung cancer doses that can escape confinement, since what the final particle sizes will be in the environment can only be speculated upon, and such speculation is not a basis for hazard evaluation."
Dr. Gofman has calculated potential lung cancer doses from the inventory figures given by GE and the NRC, in terms of doses to non-smokers and to cigarette smokers, both for plutonium-239 and for fuel-grade plutonium.
He has calculated the lung cancer dose for non-smokers from plutonium-239 to be 7.3 micrograms and for smokers, 0.058 micrograms.
For fuel-grade plutonium, the lung ce.ncer dose for non-smokers is 5.6 microgr.ams, and for smokers is 0.045 micrograms.
Thus, for the fuel grade plutonium available in the basement Advanced Fuels Lab at Vallecitos, Dr. Gofman calculates the following:
Quantity of Plutenium Lung Cancer Doses 0
5500 grams 9.9 x 10 For Cigarette smokers:
1 11 5500 grams 1.2 x 10
9 The population of the earth is approximately 4 x 10 r
10.
RESUSPENSICN NRC-PSE does not attenpt to measure the continuing contamination which would be created by resuspended plutonium after its original depcsition.
At Rocky Flats, Colorado, cffsite contamination of human populations continues from this source.
Plutonium particles do not lose their cancer producing ability i
I i
once deposited.
Resuspension of deposited plutodium has occurred at Rocky Flats. Plutonium particles have been picked up by winds from the soil at Rocky Flats and plutonium contamin-ation now can be measured offsite at great distances.
Between Rocky Flats and Danver, Colorado, resuspension by winds has caused scores of square miles of land to be contaminated,with plutonium.
The supply of plutonium particles small enough to be suspended
.n air or picked up Sy ',inds is constantly renewed by alpha recoil, the tendency of plutoni?m particles to spontaneously break up into smaller particles as a result of the energy imparted to atoms in the plutonium particle by radioactive (alpha particle) decay of its plutonium atoms.
The large particles therefore tend to become more suspendable as time passes.
A conservative assumption, there-fore, is that all insoluble plutonium particles released to the environment will remain (or become) of suspendable size, and will remain available to be resuspended, inhaled, and to cause lung cancer.
Dr. Gofman (Appendix "C")
has attempted to calculate the resuspensicn hazard of deposited plutonium.
His calculations in-i dicate that accidental releases of plutonium frem the Vallecitos inventory would cause a substantial and continuing risk of lung cancer for all inhabitants of the contaminated region.
Moreover, the offsite contamination and resulting lung cancers would continue indefinitely.
Plutonium-239 has a half-life of 24,000 years.
Decay to safe levels will take at least 240,000 years (10,000 human generations).
The total number of fatalities over this period of time could be enoracus.
Decontamination i
~.
technologies are unproven, and NRC-PSE does not allude to their use.
If NRC is assuming that decontamination (e.g.,
soil and tree removal, replacement of walls and roofs, repaving of streets) is to be conducted, it should specify (a) where these operations will take place, (b) the cost, and (c) who will pay.
NRC should also notify the municipal administrations of all communities to be affected by the proposed program.
11.
WATER CONTAMINATION NRC-PSE includes no analvsis of the effect of radiation releases from the plutonium labs as contaminants of the Bay Area's water supply.
San Antonio Reservoir is within sight of VNC.
Other Bay Area water supply fa~cilities within 10 miles of VNC include the Del Valle Reservoir, Hetch Hetchy Aqueduct, and the South Bay Aqueduct.. Deposition of radioactive materials into these facilities following an earthquake could represent the permanent f
contamination of much of the Bay Area's drinking water supply system.
j Nith respect to plutonium, new evidence indicates that ingested plutonium may be thousands of times as efficient at causing cancer as previously thought.
12.
AN ALTERNATIVE TO NRC-PSE RELEASE ANALYSIS I
t In light of these many criticisms, it is obvious that i
NRC-PSE grossly underestimates the maximum potential plutonium Larsen and Oldham, " Plutonium in Drinking Water:
Effects of Chlorination on Its Maximum Permissible Concentration",
Science, Vol. 201, September 15, 1978.
9
I release from VNC after a major earthquake.
We will conserva-tively estimate, in light of all the above factors, that 55 grams, or 1% of the unsealed clutonium oxide cowder from the Advanced t
Fuels Laboratory alone (GE labs analysis p.
IV-10) could be released offsite.
This estimate does not include the additional contribution from:
(1) plutonium nitrate from the Advanced Fuels i
[
Lab, (2) all releases from the Plutonium Analytical Lab, (3) all releases from the Radioactive Materials Lab, (4) all doses due to other nuclides, (5) the resuspension dose, (6) the dose from
-clutonium-contaminated water.
i t
Usine the NRC-PSE meterolecical and dispersal analvsis and postulated exposure times gives the following results:
(1) at the site boundary, 50-year whole lung dose from two hour exposure would be 2035 rems.
Lung cancer for all persons exposed would be 1
a certainty.
(2) in Pleasanton, 50 year whole lung dose from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> exposure would be 42.3 rems.
Lung cancer for all persons exposed would be a near-certainty.
A permanent epidemic of lun.g cancers could be caused as far away as San Francisco.
13.
BUILDING 105 t
Removal of plutonium from Building 102 to Building 105 is not an acceptable solution to the seismic problems of Building 102.
The GE labs analysis (p. III-4) shows that peak ground accelerations of.75 g will cause the vault in Building 105 to sustain stressen of 81% of yield.
As an approximation, by scalar multiplication this finding indicates that the vault in Building 105 will sustain stresses of greater than 100% of yield in an earthquake delivering a peak ground acceleration of 1.0 g. Collapse of the vault is indicated.
T e
The possible collapse of the storage vault while it contains plutonium is unacceptable.
All plutonium must be removed from this structure.
14.
RELIEF REQUESTED 1.
Order suspension of all activities under License No. SNM-960.
2.
Order sealing of all plutonium at VNC and its removal from the site.
3.
Order public hearings before any plutonium is returned to VNC.
4.
Order production and delivery to F.C.E. of a complete inventory of radioactive materials at VNC.
5.
Order production and delivery to F.O.E. of structural analyses of all VNC buildings which contain radioactive material.
Respe,gtfully/hubmitted, II i.\\ Mt:.i
% L0.)L Y QL.o
\\
tj,
W. Andrew Saldwin Legal Director Friends of the Earth
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20515
E.En" October 27, 1977 c
Atomic Safety and Licensing Board Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sirs / Madams:
We,'the undersigned San Francisco Area Members of Congress, wish to express our deep concern about recent revelations of significant geologic faults near the Vallecitos Nuclear Center in southern Alameda County, California.
It is our understanding that a serious question exists, due to the recent faulting discovery, as to whether or not the Vallecitos facility would be substantially capable of incurring damage from a major seismic disturbance without concurrently sustaining a serious leakage of radioactive isotopes.
This question is of the utmost concern to us.
According to presently available information, the Environ-mental Impact Report (EIR) on the Vallecitos site indicates that a severe accident, one that might conceivably result from a major earthquake, might cause a significant release of particulate and gasious radiation such that an evacuation of nearby population centers would become a requirement.
It appears that such an evacuation would be very nearly impossible to carry out in a safe and effective manner.
It is our additional understanding that General Electric, the Vallecitos Nuclear Center licensee, has proposed to the Nuclear Regulatory Ccmmission that the license renewal for the Vallecitos nuclear reactor be granted with the condition that appropriate modifications would be made within the next five years.
Operation of the reactor would apparently continue unabated during this' period.
Seemingly, if an earthquake of near the maximum potential magnitude were to occur before the reactor modification were complete, evacuation of an area containing millions of people might be necessary.
Further, it is apparently possible that such an earthquake might also cause a rupture of the plutonium handling and storage facilities at the vallecitos site.
page two Most recently, the Nuclear Regulatory Commission 's staff has ordered the General Electric Test Reactor (GETR) be shut down because of the new geologic information.
This decision was based on information received from petitions for intervention for the relicensing of the Vallecitos Plant and on a _ study conducted by the U.S. Geological Survey.
Accordingly, in behalf of our constituents and in
, view of this new position of the NRC staf f on the safety of this test reactor, we wish to strongly urge the Atomic Safety and Licensing Board to hold kcomprehensivepublichearingsregardingrenewal
\\of the Vallecitos Nuclear Center licenses.
Sincerely, l
W-
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/ W 4-Fortney H.
(Pete) Stark Ronald V.
deElumb N
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b S.. y - Q h h Don Edwards Norman Y. Mineta
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[b; Teorge IVller Phillip Burton M
Paul N. McCloskey,fr.
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.e~. e A Report on the Lung Cancer Potential of Plutonium prepared for Mr. Glenn Barlow of Friends of the Earth prepared by John W. Gofman, M.D., Ph.D.
P.O. Box 11207 San Francisco, California 94101 September 25, 1978 9
==
Introduction:==
The question addressed to me is "What is the lung cancer potential of various quantities of plutonium, as the exide, if the plutonium is (a) pure Plutonium-239 and (b) if the plutonium is fuel-grade plutonium ?"
Let me begin by stating that I shall use the term " lung cancer dose". This term means that for one lung cancer dose distributed into the lungs of humans there will be one fatal human lung cancer.
It does not matter that an entire lung cancer dose be given and deposited in one person. If one lung cancer dose is deposited in one person, our expectation is that this person will develop lung cancer and die of it, if deposited in 10 people, then one out of 10 of the people will die of lung cancer, if deposited in 100 people, one out of the 100 will develop lung cancer. Thus, one lung cancer dose will cause one fatal lung cancer no matter how many people it is distributed into.
Next, I consider it appropriate to calculate the number of lung cancer doses available, rather than to start estimatirg what fraction of the material is in various particle sizes. To be sure, particle size is important in determining whether the plutonium will or will not deposit in the sites of the bronchi where it can
/ provoke lung cancer. However, when plutonium is dispersed in the environ =ent, we can only guess what the ultimate dispersion will be and what particles will become available for inhalation. As 4 Martell has pointed out, there is the possibility that fragmentation from alpha particle recoil can occur, so that even particles that are initially dispersed at one size, can,with time, give rise to smaller particles that are in the right. si=e range to produce lunci cancer. Therefore, the truly meaningful number is the total number of lung cancer doses that can escape confinement, since what the final particle sizes will be in the environ =ent can only be speculated upon, and such speculation is not a basis for hazard evaluation.
Fuel Grade versus cure plutonium-239 You have provided me with the datum that the plutonium at issue 239 240 has a ecmposition of major components of Pu = 86.5% and Pu= 11.3%.
I shall not consider other minor nuclides, although they will increase the hazard I calculate. In other words, I shall be calculating a 239 m4 imm ha:ard for the fuel-grade plutonium.The half-life for pu is 24,400 years, and for'40Pu it is 6,600 years. Therefore, the
fuel grade plutonium will have an increased alpha particle activity and hence an increased lung cancer potential directly related to that increased alpha particle activity. Compared to 239 Pu, the fuel grade plutonium will have an alpha particle activity of; 0.865 + 24,400 6,600
- 0.118
, where the activity of 239Pu is set at unity 0.865 + 0.437 = 1.30.
=
Any Pu will materially enhance the toxicity, but I shall neglect it here, and simply use fuel-grade as 1.'30 times.the toxici g of239 Pu.
The Lung Cancer Doses for 239 Pu and for Fuel -Grade Pu Attached to this report are four references, all papers I have written on the subject of the lung cancer hazard of plutonium.
I have had no occasion.to revise any of the estimates in those papers.
The four references are attached as Exhibits 1,2,3, and 4.
The basic numbers needed are the lung cancer doses for cigarette-smokers and for non-smokers. The lung cancer hazard of plutonium is very much higher for cigarette smokers than.for non-smokers, From the referenced.llwe have, for 239Pu, the following; Lung Cancer Dose for non-smokers = 7.3 micrograms Lung Cancer Dose for cigarette-
= 0.058 micrograms smokers Therefore, for the fuel-grade plutonium listed above, the corres-ponding lung cancer doses are the following:
Lung Cancer Dose for non-smokers = 5.6 micrograms Lung Cancer Dose for cigarette-
= 0.045 micrograms smokers We can now calculate the Lung Cancer Doses per kilogram of each type of plutonium:
239Pu Fuel-erade Pu 8
8 Non-smokers 1.4x10 Lung cancer Doses 1.8 x 10 Lung Cance:
10 10 Cigarette-smokers 1.7x10 2.2 x 10 We can now proceed to tabulate -the lung cancer doses in the verious quantities of plutonium of interest to you.
Lung Cancer Doses in Various Quantities of Pu and Fuel-Grade Pu or on-smokers:
Luna Cancer Deses Quantity of clutonium Pu Fuel-Grade Pu 8
8 625 grams 0.88 x 10 1.1 x 10 C
8 2500 grams 3.5 x 10 4.5 x 10 0
8 5500 grams 7.7 x 10 9.9 x 10 For Cigarette smokers:
0 10 625 grams 1.1 x 10 1.4 x 10 10 10 2500 Trams 4.3 x 10 5.5 x 10 10 11 550G grams 9.4 x 10 1.2 x 10
' i n c e o c.> c ~C C 9. 9
~ s.. ~
Note: If these quantities of plutonium are dispersed, the tabulated numbers provide the maximum number of lung cancer fatalities that weuld occur _if the entire quantity ended up deposited in human lungs.
The actual number of cancers, over a long period of +4-=,
that would occur after such dispersion. depends upon so many variables thac it would be speculative to try any estimates. I.believe the maximum t number is the relevant consideration.
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Some Possible Consequences of Plutonium Release from a Seismic Event at the Vallecitos Laboratory John W. Gofman for Friends of the Earth November 11, 1978 John W. Gofman, M.D., Ph.D. is Emeritus Professor of Medical Physics at the University of C lifornia at Berkeley.
M.P.O. Scx 11207, San Francisco, California 94101 w
-1 Generic Errors in the Estimation of Dose and Effect in the Document Entitled IV. Plutonium Release and Consecuence Analysis Dose versus Effect Error on page lV-19 it is stated that the dose-effect relationship utilized is that of BEIR (1972), which is Lung Cancer Deaths 1.3/10 /yr/ rem.
I have treated this question in detail in my report entitled "The Cancer Hazard of Inhaled Plutonium" CNR-1975-lR, dated May 14, 1975. I consider the value used above to be seriously in error.
The correct number, according to my analysis on page 5 of my report cited is 2.54 x 10 */yr/ rem. It is therefore to be noted that I consider the Staff report to have underestimated the lung cancer hazard per rem delivered by a factor of 2.54 x10
, or a factor of 19.5 times 1.3 x 10 NOTE: This is just the error in dose versus effect, and does not take into account the more serious error in the proper estimation of dose to the cells that give rise to lung cancer from given quantity of plutonium deposited in the lung.
The Error in Dose Itself:
The Environmental Protection Agency (Federal Register, vol. 42, No.230-Wednesday, November 30, 1977, FRL-808-5) enters an ACTION: Proposed Federal Radiation Protection Guidance. In this action it is stated explicitly that proper guidance should refer to the " Critical seement of the exposed population". This
" critical segment" is there defined (p.60959) as "that group of persons within the exposed population receiving the highest radiation dose to the pulmonary region of the lung or to the bone."
It is overt and clear, therefore, that the intent of the guidance is to describe the persons who are at the highest risk of radiation effect for a particular exposure.
In the reference of myjown cited above, I described in extenso why the cigarette-smoking male in the population is the critical segment of the population.
The reasons are the following:
(a) The dose to the critical bronchial epithelial cells (the source of lung cancer) is much higher in the smoker than in the non-smoker, per unit of plutonium
- inhaled, (b) The interaction between cigarette risk and the radiation risk in production of lung cancer.
Therefore, _. any analysis of accidents, such as seismic events at a facility working with plutonium, must necessarily consider the cigarette-smoking male as the critical seg=ent of the population.
Any other consideration is in violation of the cardinal principles of radiation protection, as stated in the Federal Register.
a
We can now turn to the magnitude of the error in dose that has beep utilized both in the General Electric and the other documents, such as the EPA document itself. All of these consider the' dose for the plutonium distributed into a lung mass of 570 grams.
But the crucial tissue for lung cancer is the approximately one cram of bronchial epithelium. The key correction that is necessary takes into account the amount of plutonium that resides for a long period in this critical bronchial epithelium compared with that which resides for a long period in the full pulmonary mass of 570 grams.
There are two corrections:
(a) Just on the basis of mass of tissue alone, a particular amount of plutonium will give the bronchial epithelium a dose 570 times as high as it will give the" pulmonary lung".
(b) The second correction has to do with the strength of the plutonium source in the bronchial epithelium versus that in the " pulmonary lung". The best estimate I could make (see my reference cited above) is that for any particular amount of plutonium inhaled, the source strength in the bronchial epithelium IS 0.18 TIMES AS HIGH as in the " pulmonary Lung".
THEREFORE, the overall correction factor for dose is (570) x(0.18), or a factor of 103 times.
So, in all the consequence analyses that have been presented,the dose estimate to the lung for the critical segment of the population, namely, cigarette-smoking males, is 103 times TOO LOW!
THE OVERALL ERROR IN EFFECT FOR THE " CRITICAL SEGMENT" In assessing the overall error in lung cancer consequence, we must take into account the cigarette-effect on lung cancer incidence and its interaction with radiation, the intrinsic error in dose-effect relationship, and the error in dose to the bronchial epithelium.
When all of these are taken into account together, it turns out that the effect on the "cr?.tical segment " of the population is low by 3517 times Ther afore,
ALL THE ESTIMATES OF CONSEQUENCES FOR A PLUTONIUM DISPEFJAL ARE TOO LOW BY THIS FACTOR OF 3517 TIMES, if we are truly going to assess the effects for the CRITICAL SEGMENT OF THE POPULATION, and this is obligatory upon us to do.
At first glance it might appear that one should correct by simply multiplying the factor of 103 above by the factor of 19.5 times. But this neglects the fact that of the population are taken as smokers and h not. It is the incorporation of the multiplying effect between cigarette smoking for the smckers And radiation that finally raises the correction to 3517 times.
The Appropriate Analysis of Consequences of Plutonium Release All kinds of assumptions can be made concerning what will happen in a seismic event, with or without fire as an accompani-ment. But the history of engineering calculations is that the unexpected has generally foiled all the assumptions of the planners.
The Titanic, for example, was not going to be sinkable.
One could expand the list ad infinitum, but knowledgable engineers realize full well that it 's what they did not take into account that has been the undoing the major disasters. Therefore, it is the simplest of common sense, instead of self-serving vested interest, to use what is commonly called a worst-case analysis.
We shall, therefore,-make a worst case analysis, for pluton-ium. release, utilizing the lung cancer hazard as the dominant hazard (though it is by no means the only hazard), and making two separate calculations; (a) The lung cancers to be 1"oduced from the initial cloud of released plutonium, and (b) the lung cancers to be produced from resuspension of plutonium that settles to the ground and thereafter becomes airborne. An appropriate calculation should consider consequences for the full period of hazard of the plutonium (many times the 24,400 year half-life).
This principle was clearly enunciated in the Vermont Yankee decision.
The Initial Plutonium Release As a base of such calculations, we have the experience cf the fallout of stratospheric plutonium from nuclear weapons testing.
We do not know, for certain, that the air-borne plutonium will get into human lungs with the same efficiency as a result of a release at Vallecitos as it did from the stratospheric fallout, but there can be no doubt that assumption of equivalence would be a reasonable worst-case calculation.
That is the real experience base, and all the hopeful calculations that might suggest otherwise are just that--hopeful calculations.
In my
" Estimated Production of Human Lunc Cancers by Plutonium from Worldwide Fallout" CNR-1975-2, July 10,1975, I estimated that for 870 pounds of plutonium (weapons grade) that fell out upon the USA through 1972, there would.be an estimated 116,000 fatal lung cancer cases produced over time, just from the initial inhalation, with no consideration of resuspension of plutonium.
Thus 870 pounds represents approxi-mately 395 kilograms of plutonium, or 395,000 grams of pluronium.
Therefore, the yield of lung cancer fatalities is of the order of (116,000) /(395,000), or 0.3 fatal lune cancers per cram of plutonium initially dispersed.
We can now make a tabulation of the fatal lung cancers for various dispersals of plutonium frem a seismic accident at Vallecitos, by considering the range of possible quantities released. See Table 1.
_g_
Table 1 Fatal Lung Cancers from Initial Dispersal of Plutonium Grams of plutonium Fatal Lung Cancers 0.1 gram 0.03 deaths 1.0 grams 0..'
'1aths 10.0 grams 3.'
deaths 100.0 grams 30.0 deaths 1000.0 grams 300.0 deaths 10000.0 grams 3000.0 deaths NOTES (1) These calculations are for respirable particles of plutonium (those less than 10 microns in diameter, approx-imately). The claim in the GE reports is that something of the order of 10% of the plutonium is in such particle size range. If this is indeed true, then, for each entry in the table, the number of lung cancers for each amount of plutonium would have to be multiplied by 0.1.
(2) The range from 0.1 to 10000 grams is presented because at the optimistic end of calculations of consequence the s" gestion has been made that less than one gram of pluton-ium would become airborne in a seismic event. This is engineering hopefulness, not to be used in a worst case analysis.
At the other extreme, the 10,000 grams, we are describing the order of magnitude of the quantity of plutonium being handled in the plant at any one time (order of several kilograms). There are all kinds of speculation that the true amount likely to be subject to dispersal is less than the 10,000 grams of the chart.
On the other hand, including all the plutonium in so-called sealed containers, the amounts on hand are well above the 10,000 grams. Therefore, for worst case analysis, it is reasonable to contemplate consequences for dispersal of as much as 10,000 grams.
Any attempt to guess where within this table the true consequences will lie in a seismic event represents hopeful crystal-ball gazing of the sort that has sunk engineers over recorded history. The public should not be taken in 5y such crystal-ball gazing.
This, of course, is only the beginning of the health consequence analysis, for it represents only the contribution of the initial dispersal. We must now consider the question of re-suspension of plutonium that is deposited outside the facility.
The Long-Term Problem of Plutonium ~ Deposition and Resuspension A primary problem associated with the deposition of pluton-inm, although not the cnly problem, is its subsequent reauspension and inhalation, with the production of bronchogenic (lung) cancer.
The hazard, through resuspension, can of course persist for time periods measured in terms of 100,000 years or more. The essence of the problem is the extent of air contamination with particles bearing plutonium, particularly those particulates in the size range expected to penetrate and be retained in the deeper-bronchial and pulmonary structures. These are the so-called " respirable" particles, with diameters under 10 microns.
The treatment of this re-suspension problem has ceen kuite.
unsatisfactory. Some have made use of the so-called "re-suspension factor", which measures the air concentration of plutonium over-a contaminated region with reference to the soil egncentration 3
of the land ( in units of activity /m / activity /m ). It is well -
known that these so-called resuspension factors can vary,by more than four or five orders of magnitude depending upon the type of' activity going on on the surface of the earth involved.
The optimists wno try to underplay the re-suspension hazard have stated that the plutonium, once settled out, tends to agglomerate, to stick to other materials and hence to become pro-gressively less available for re-suspension into the atmosphere.
On the other hand, Martell has pointed out that the alpha particle' activity of plutonium-containing particulates will continually lead to fragments of the particulates being broken off as a recoil phenomenon secondary to alpha emission. No really long-term studieu, in a large variety of soils and other surface coverings have been done that would satisfactorily tell us whether the really long -term situation is an increase or a decrease in the availability of
~
plutonium for atmospheric re! suspension, and it is this long-term availability that is all-important. It would be folly to assume the optimism of the promoters in this issue.
It is possible to avoid this entire question of an appropriate resuspension factor for deposited plutonium by approaching the problpm in a separate manner, utilizing the accumulation of insoluble particulaten in the lung tissue as a way of estimating the expected dose to be received from a given level of soil contaminatica with plutonium.
If we had conuinuous air sampling of contaminated regions, this would not be necessary since the inhhlacion of plePonium csuld be calculated from the air concen-tration. But since O__a is not feasible, we shall approach the estimate of the consequences of soil contamination in a different manner. Then we can address two questions of interest here;(1) the goodness or lack thereof of proposed guidance for soil contamination with transuranics such as plutonium and (2) the -
consequences of particular contaminations in terms of lung cancer fatality risks frem residence in contaminated areas.
An Approach to Estimation of Lung Dcre Frcm Soil Contamination Martell( 1 ) quotes the data of Lewis and Coughlin which show that about one grar c f nitric-acid insoluble particulatcc have accumulated in the..l a of men by 35 years of age. This is the result of soil anu u:ccn dusts that had beceme suspended in breathed air. Since such material dces not stay in the lung indefinitely
once deposited in the lung, we must infer that, over a period of 20 years or so (just counting' exposure beyond 15 years of age),
the average man must have deposited considerably more than the one gram found in the autopsy material referred to by Lewis and Coughlin. This amount we are in a position to estimate from the mean residence time of insoluble particulates in the lung. For highly insoluble dusts it is widely regarded as reasonable to use a Tg residence value of 500 days for the lung. The mean residence time corresponding to this T is 500/0.693, or g
approximately 720 days, which can be roundly taken as two years.
Now, if the mean residence time is two years, then the lung load turns over ten times in the 2-year period between 15 and 35 years of age. This means that a finding of one gram at any time in the lung would mean that ten times that much, or ten grams must actually have been deposited for the long type of residence (that with a mean residence time of 2 years).
But over and above that which is retained for the long-term type of residence, there is some that is retained only for a short-term residence.
The ICRP recommendations, which we shall follow here, are that 40% of the initial deposit is cleared within a couple of days. To calculate the true deposition (and that is what we need in deriving lung cancer hazard) we must correct the ten grams above by a factor of 1/0.60, which means that the true value of insoluble dust deposition is (1/0.60) x (10), or 16.7 grams of insoluble lust deposited between ages 15 and 35 years.
(The reason for starting at 15 years in such calculations is that we are calculating for the " critical segment" of the population, which is the cigarette-smoking male, who starts smoking at an age of about 15 years).
Thus we can state that the finding of one gram of insoluble dust as the steady-state load corresponds to a total deposition of 16.7 grams of such insoluble dust over the period from 15 to 35 years of age.
The Plutonium Content of 16.7 crams of Soil Dust Since our objective is to ascertain the total dose of pluton-ium deposited in the lung from resuspension of soil, it follows that we now need to learn the amount of respirable plutonium that will accompany 16.7 grams of respirable dust from the soil.
Not all the dust nor all the plutonium that beccme entrained in air are in the respirable class (some of the particles are too large to be respirable). So we new need to know what fraction of air-entrainable soil dust is in the respirable class, as well as the fraction of air-entrainable plutonium that is in the respirable class.
For the plutonium that was air-borne, deposited off-site, and resuspended offsite at Rocky Flats, Volchock,Knuth, and Kleinman ( 2 ) estimated that approximately 30% of the air-borne plutonium particles are in the respirable class. We shall utilise this figure of 30% for the fraction respirable frem off-site deposition and resuspension after a release from Vallecites.
For the soil Martell ( 1 ) has estimated that the fraction of soil re-entrained into air as respirable particles is very much smaller than for plutonium. Martell gives between 1 part
-y-in 60 to 1 part in 300 as the fraction of air-borne soil particles that are of respirable size. We shall calculate now the implications of these estimates, using both the high and the low fraction respirable that Martell suggests for air-borne soil particulates.
The sought-for datum is the amount of plutonium that will accompany every gram of respirable soil into the lung itself.
Case A: Assuming 1 part in 60 of soil particles air-borne are of respirable size.
Let us consider 1 gram of air-entrained soil particles.
Let C = the concentration in picocuries of plutonium present per gram of air-entrained soil particles.
In this case (Case A) one gram of air-entrained soil will yield 0.0167 grams of respirable soil particulates, exclusive of the plutonium. Since we have postulated C picoeuries of Pu per gram of air-entrained soil and since we are taking the Volchock value of 30% in the form of respirable plutonium, it follows that in one gram of air-entrained soil there will be 0.30C picoeuries of respirable Pu.
But this one gram of air-entrained soil has only 0.0167 grams of respirable soil particulates (exclusive of the plutonium,). Therefore, for the material that is respirable (small enough to get into the. lung), we have 0.30C picoeuries of plutonium associated with 0.0167 grams of soil. Or, we can say that for every gram of respirable soil particulates there will be (1/0.0167) x (0.3C), or 18C picoeuries of Fu in respirable form. Thus we see immediately that the concentration of Pu in the respirable material is enormously higher than in the air-entrained soil itself.
Now we can immediately calculate how much pl'utonium is deposited in respirable form if 16.7 grams of total respirable dust is taken in over the 20 year period from age 15 to 35 years.
That amount is (18C) x( 16.7), or 300.6 C picoeuries (Recall that C is defined as picocuries Pu present per gram of air-entrained soil particles).
Case B: Assuming 1part in 300 of soil particles air-borne of respiracle size.
It is self-evident that the respirab: 3 pluton'.um in this case is associated with one-fifth as much respirable soil dust, and that hence the plutonium associated with one gram of respirable 9
soil particulates will be 90C picocuries. And it follows directly that for 16.7 grams of total respirable soil deposited in the lung over 20 years there will be (16.7) x(90C), or 1503 C pico-curies of respirable plutonium deposited along with this respir-able_sgi;_gaterial._____________________________________________
Summarizing the two cases:
1/60 of air-borne soil respirable means 20 year deposition of 300.6C picoeuries of plutonium, whereas 1/300 of air-borne soil respirable means 20 year deposition of 1503 C picocuries of plutonium.
Since we do not knew which case will more nearly approximate the situation at Vallecitos in re-suspension, we shall calculate cansequences for both cases below.
Luna Cancer Risk for Various Soil Deposition Levels It is to be noted that all the calculations above are for air-entrainable soil. Since some of the soil particles are properly to be regarded as " boulders" (meaning they will never become air entrained), it should be obvious that any measured plutonium in soil in toto instead of in air-entrainable soil would mean more serious consequences than those using the direct measured picocuries of plutonium in soil in toto. So by using observed soil in toto measurements we shall be underestimating the true consequences of re-suspension of plutonium.
We shall calculate consequences for the " critical segment" of the population, cigarette-smoking males, and we shall calculate for plutonium-239.
Actually at Vallecites there is admixture of other nuclides which increase the specific activity of the plutonium, so that any calculations for a particular weight of plutonium would have to be multiplied by the specific activity ratio. Since reactor grade plutonium varies depending upon how long it has been in the reactor, we shall not do that estimate, preferring to leave the reader to multiply consequences by the appropriate factor for increased specific activity for differing reacto grade plutoniums. IT C.Vi 3E EMPHASIZED THAT ALL CALCULATlCNS FOR Pu-239 REPRESENT MINIMUM HAZARDS. HAZARDS PER PICCGRAM ARE HIGHER FOR ALL REACTOR GRACE PLLTONIUMS.
_9 The range of soil concentrations of plutonium to be considered will cover the possible contamination levels from a Vallecitos release Two specific soil concentrations will also be considered; first, the soil concentration of Pu frem weapons fallout and second, the proposed level (as we shall see to be a public health disaster) of the Environ-mental Prctection Agency.
Table 2 pe=picoeuries; pg= picograms. Conversion factor, 16.3 pg gives 1 pc.
Soil Concentration Total Pu deposited in Lung Cancer Risk lung by age 35 yrs (Lifetime) pc/g pg/g (Above spontaneous)
Case A Case 3 Case A Case B 0.05 0.81 0.92 4.61 0.000016 0.000079 0.1 1.63 1.84 9.22 0.000032 0.000159 1.0 16.3 18.4 92.2 0.00032 0.00159 10.0 163.0 194.0 922.0 0.0032 0.0159 100.0 1630.0 1840.0 9220.0 0.032 0.159 1000.0 16300.0 18400.0 92200.0 0.32 1.59 3000.0 48900.0 55200.0 276600.0 0.96 4.77 Note that for all values above 3000 pc/g, the risk of lung cancer is unity or higher for either Case A or Case 3.
Weapons Fallout 0.27 4.4 4.98 24.9 0.000086 0.00043 EPA suggested tolerance 20.0 326.0 368.0 1844.0 0.0063 0.032 Explanatory Notes: Worldwide fallout data are those of Bennett (See CNR-1975-2)
The EPA recc==endations are that 0.2 microcuries per m' rgpresents a reasonable " screening level". This translates inte 20 pg/cm', and using a 1 cm depth and an approximate density of 1.0 g/cm for soil, we get 20.0 pc/g of soil, as used in the table abcve.
Frem CNR-1975-1R we have the datum that 0.058 micrograms is "one lung cancer dose" for cigarette smokers. Since they represent the critical segment of the population, we use that value to translate dose into risk.
0.058 micrograms represent 58,000 picegra=s. To calculate the lifetime risk, the value in the Total Pu Decosited column is divided by 58,000.
What Are the Prospects at Vallecitos?
The range of consequences in the table presented above cover the bounds to be expected at Vallecitos in a seismic event. The quantity released ranges between 0.1 and 10,000 gr*~= of plutonium.
A credible value is that such =nterial could be dispersed over a 2
land area of 10 km,
9 1,
9 33 10 km represents 10- cm. And 0.1 grams represents 10-pg.
Similarly, 10,000 grams represents 10 6 picogra=s (pg).
_10 2
So, for a release of 0.1 gram spread over 10 km, we have a soil concentration of 1 pg/ gram. For a release of 10,000 2
5 grams of plutonium over 10 km, we have 10 pgfgr,,,
For the former case, lpg / gram, the lung deposition would be 1.13 pg for Case A and would be 5.65 pg for Case B. These would correspond to lifeti=e lung cancer risks of 0.000019 for Case A and 0.000097 for Case B.
5 For the latter case, 10 pg/ gram, the lung deposition would he 111:0^^ pg for Case A =.nd would be 566,000 pg for Case B. These would correspond to lifetime cancer risks of 1.95 for Case A and 9.75 for Case B. Since these risks are above unity, it means that at this level of contamination. all persons would devel;p fatal lung cancer (that is all persons of the critical segment of the population, cigarette smokers [.
IT IS NOT LIKELY THAT SUCH A RELEASE WCULD CCCUR AT VALI.EC,ITOS--
this estimate must be regarded as an upper bound calculation.
But quite a range of values in between these limits are quite credible, and as would be noted from the lifetime risks of the table above, they would certainly preclude habitation of the area without remedial action simply because the lifetime lung cancer risk would be unacceptable. The EPA suggests that a lifetime risk of about 1 per 10,000 is" acceptable".
It is clear from these estimates that resuspension is NOT AT ALL A NEGLIGIBLE RISK for credible releases from Vallecitos.
Moreover, it will not make much difference in the calculation 2
if the material is spread over seme area different from 10 km,
If the area increases, the concentration of plutonium in the soil goes down, inversely with area increase, but on the other hand, the population at risk goes up directly in proportion to area, in general, and this would just offset the concentration effect, leaving the total number of cancers the same. The risk per person goes down, but there are more persons at risk.
The EPA Standards:*A Blueprint for Disaster The EPA Guidance on the issue of permissible plutonium concentration in soil is grossly unacceptable, and will lead to a public health disaster if implemented and folicwed.
The first error en the part of EPA, and probably its major error leading to such poor suggestions of per=issible plutonium
_11-concentrations in soil, arises from a totally erroneous assessment of the risk of lung cancer per unit deposition ( in lung) of plutonium.
In FRL 808-5, the EPA states that;
" On the basis of models, it was estimated that, for a cohort of 100,000 persons followed through their entire lifetime, the e stinuous inhalation over their lifetimes of transuranium cerosols leading to an average ann al dose rate to the pulmonary tissue of 1 mrad / year per person could potentially result in 10 premature cancer deaths."
Let us examine this claim of the EPA.
I shall only count the exposure for 30 years, rather than the full 71 year average lifespan. The reasons for this are that the sensitivity is lower at advanced ages, and for the early ages where the sensitivity is high the critical segment (cigarette smokers) have not yet started to smoke. Thus, only crediting for 30 years of exposure rather than 71 years, is an approximation to correct for these effects mentioned.
Therefore, there is a total dose of 30 millirads to the pul-monary lung. Using the usual factor of 10 for high LET radiation, this amounts to 300 millirems. Now, as shown in CNR-1975-la, 1 microcurie of Pu-239 deposited in the lung leads to 2000 rems of radiation calculated on the same basis as EPA calculates, namely distribution into 570 grams of tissue. This means that 16.3 micrograms gives 2000 rems. So one microgram gives a dose of 122.7 rems. To get 0.3 rems, as calculated above for the EPA recommendation means the deposition would be (0.3)/ (122.7)
-3 micrograms, or 2.44 x 10 micrograms. But since 0.058 micrograms is the " lung cancer dose"for the critical segment of the population, the EPA rish is (2.44 x10-3)/ (0.058), which yields a risk of 0.042. The EPA says that a risk of 0.0001 is what we should anticipate from this dose (see quote above).
The EPA estimate is low by a factor of 420 times. Therefore all the EPA guidance recommendations are simply absurd.
Appendix 1 The Quantitative Relations Between Weight and* Alpha Activity 10 One Curie (by definition) 3.7 x 10 disintegrations /sec.
=
This definition holds for all types of radioactive substance, and is totally independent of whether the decay is'by alpha particles or beta particles. It is totally independent of the half'-life of the nuclide. A Curie is a defined rate of disintegrations Ob-viously it takes a much smaller weight of a substance of short half-life than of 1cng half-life to provide one Curie, provided correction is appropriately made for the mass number of the nuclide.
I mention this last point simply because we must realize that mass number enters in. Thus, if we had a radionuclide of mass number 2 and another of mass number 250, even if both had the same half-life, it would take 125 times as much, by weight, of the latter to provide one Curie as of the former.
239 230 For pure Pu 16.3 grams of Pu provides one Curie of alpha activity.
" Reactor grade" plutonium contains alpha-emitters of shorter 239 half-life and some of longer half-life than Pu
. Therefore, the alpha activity of reactor grade plutonium depends upon the extent to which such other alpha-emitters are admixed with the 239 Pu
. The extent of such admixture depends upon the length of time the reactor has been permitted to operate before the fuel is removed to isolate the plutonium.
Considered below are the fata for the separate nuclides that 239
'have shorter half-lives than Pu contrasted with the data for Pu Alpha -Emitting Half-Life in years Grams per Curie Pounds per Nuclide Curie
~4 Pu 86 years 0.057 1.26x10 39
-2 Pu 24,400 years 16.3 3.59x10 40
-3 Pu 6,580 years 4.4 9.7 x10 4
Note: Pu emits only betas. Any alphas it could congg4bute would be dgg to ingrowth of alpha. activity frem the Am daughter.
Pu' (Half-lifagjg.8x10" years) decreases the alpha activit:
3 compared to pure Pu
, because its half-liffe is over 10 times as great.
Note: These calculations neglect the slight difference in masses between 238,239,240, and 242.
Appendix.
' ~
Soecial Calculation Recuested by Andrew Baldwin Question: What is the dpm/ gram that results if one gram of reactor-grade plutoni un is deposited per square mile of land?
Answer: I shall calcuI nte this first for Pu.239. Then from this one can di *mtly calculate for any higher-specific activ.ity of reactor grade plutonium.
2 2
2 2
(1 mi ) x ( 2.56 km 7,1 ) = 2.56 km,
2 1 km x 1010,2/km2 = 1010 2
c cm,
12 One gram of plutonium contains 10 picograms.
12 10 2
So we have a contamination level of 10
/ 2.56 x 10 cm,
2 which is 39.1 picograms per em,
It takes 16.3 picograms to have an activity of 1 picoeurie, 2
so we have 39.1/16.3, or 2.4 picocuries per em,
If we use a depth of one em and a density for soil of approximately 3
one gram per em, then we have 2.4 picocuries per gram.
But one picocurie represents 2.2 disintegrations per minute.
'Therefore we have (2. 4 ) x (2. 2), or 5.3 dpm/ gram of soil as the activity represented by deposition of 1 gram of plutonium-239 per square mile.
Now, depending upon where the reactor grade plutonium comes from (that is, how long it was in the reactor), I have new seen numbers that suggest a specific activity 1.4, 5.4, and even 10 times as high as for pure Pu-239.
If one knows which of these factors really describes the plutonium at hand, just multiply these factors by t.he 5.3 to get the dpm/grms of reactor grade plutonium.
Specific Activity DPM/ gram for 1 gram spread over Setting Pu-239 at unity one square mile 1.0 (Pure Pu 239) 5.3 1.4 7.4 5.4 28.62 10 53.0
References Cited
- CNR-1975-lR and CUR-1975-2 of the author of this report are cited in the text of the report.
Other References
- 1. Martell, Edward A., " Basic Considerations in the Assessment of the Cancer Risks and Standards for Internal Alpha Emitters 99 407-457 in Proceedings of Public Hearings: Plutonium and Other Transuranium Elements, Volume 2, Proceedings of Hearings in Denver, Colorado, January 10, 1975, ORP/CSD 75-1, U.S. Environmental Protection Agency, Office of Radiation Programs.
- 2. Volchock,
H.L.,
Knuth,R., and Kleinman, M.T.,
" Plutonium in the Neighborhood of Rocky Flats, Colorado: Airborne Respirable Particles" HASL-246, Health and Safety Laboratory (ERDA), New York City, New York.-
- 3. The Lewis-coughlin reference cited by Martell is Lewis, G.P. and L. Coughlin, " Lung ' soot' Accumulation in Man",
Atmospheric Environment 7, 1249-1255, 1973.
FURTHER COCUMENTATION OF EARTHQUAKE HAZARDS TO THE VALLECITOS NUCLEAR CENTER PLUT0NILM LABS FOR THE DECEMBER 14, 1978, REQUEST FOR ACTION TO THE NRC PREPARED BY GLENN BARLOW GEOLOGY AND SEISMOLOGY In the course of the Vallecitos GETR reactor Show Cause Proceedings (Occket No. 50-70), the NRC ':taff published a Preliminary Safety Evaluation Report Input (PSER-GETR), prepared by the Geosciences Branch of the Staff on the geologic and seismk hazards to the site. Although the PSER-GETR was dated August 17, 1978, it was not released to Intervenors until early October,1978.
In the PSER-GETR, the NRC Geosciences Branch mskes the following statements:
"The seismic design hazards for the GETR site include vibratory ground motion, fault offset at the surface beneath the unit and vibratory ground motion combined with surface offset caused by postulated movement on the Verona fault. The licensee (GE) has provided an evaluation of these design hazards in reports by EDAC (1976, 1977) and has provided additional supporting discussion in a report by Earth Sciences Associates- (lESA,1978d). The staff has reviewed these reports and has taken account of the analyses and conclusions contained in them in the preparation of this testi-many. This testimony is concerned with an evaluation of the nature and magnitude of the hazards of faulting and ground motion at the site...
The GETR site is located in a complex fault environment 2.3 kilometers east of the Calaveras fault, directly over the projected surface trace of the postulated Verona fault, and within 3 kilo-meters of the Las Positas fault...
Maximum earthquakes for taese faults would have magnitudes of 7 to 7 h, 6 to 6 h, and 6 to 6h, respectively... the proposed Verona fault can be presumed to exist beyond the bounds of the area mapped by Herd and to merge with the Calaveras fault... it must be presumed that the Verona fault is structurally connected to larger faults, and that a major portion and possibly all of the 12 kilometers length could rupture during a single earthquake.
It is our conclusion, therefore, that the San Fernando earthquake of 1971 could be considered as an earthquake similar in size to a potential event on the proposed Verona fault."
(Seismology section)
The section of the P'~R-GETR entitled " Current Staff Position" says:
" Geologic data are indicative of a fault (the Verona fault) passing through the GETR site, and this fault should be assumed to exist...
The Verona fault should be assumed to be capable within the meaning of Appendix A to 10 CFR Part 100 and, therefore, to pose a potential for surface faulting near or beneath the reactor site...
2.5 meters of net slip at the surface resulting from reverse-oblicue movement alor.g a fault plane which could vary in dip angle from 10 to 60 degrees provides a reasonably conservative description of surface slip on the postulated Verona fault curing a single event...
. " Maximum vibratory ground motion at the GETR site would result from a magnituce 7 to 7 6 earthquake centered on the sector of the Calaveras fault nearest the site.
Acceleration peaks at the free-field surface could be slightly in exesss cf 1.0 g...
The horizontal vibratory ground motion at the GETR site resulting 'cm an earthquake of magnitude 6 to 6 h on the Verona fault could contain acceleration peaks as high as 1.0 g."
The following quotes are from the section entitled " Geology":
"The GETR 3ite is located in a highly active tectonic environment (Bolt and others, 1977; Lee and others,1971)... within the Liver nore syncline and the central part of the Coast Ranges structurally related to the San Andreas fault system, a trans-form fault which forms a major sector of the boundary between the North American and Pacific lithospheric plates...(Anderson,1971)... We consider the Livermore syncline and the major structural elements therein, including faults, to cwe their existence to movement across the Calaveras fault. The faults significant to cur review which we consider genetically related to the Calaveras are the las Positas fault... and the Verona fault which as interpreted is a Icw angle thrust within the southern flank of the syncline."
"The existence of a landslide near the site does not in any way preclude the exi-stence of faulting there. As discussed belcw, evidence for faulting exists in areas away frem the landslide are.
In fact, landsliding often results frem over-steepening of slopes due to fault movement and seismic shaking...
(1)... Areas to the northwest of the GETR show, both in the field and on aerial photographs,the presence of geologic features which are indicative of the exi-stence of faulting. Steeply dipping Livennore gravel beds are truncated along a linear to curvilinear topographic escarpment.
Along the base of this escarpment are a number of seeps and springs.
(2)To the southeast of the GETR the geologic log of the La Costa tunnel (California Department of Water Resources,1966) suggests low angle faulting and folding in an area through which the postulat.d Verona fault would pass if projected eastward...
(3)The relationship between the Verona fault and the las Positas fault has not been investigated and the area of the William's fault (Hall,1958) -La Costa tunnel inter-section has not been investigated sufficiently...
Areas of intersection or mergina of faults can be in a transitional stress state wnten usually leads to the develot nt of fault atterns wnicn are ceoicoically ccmolex sucn as en ecneien fauits r atner tnan a sinole cianar faul t surface.
Such ccmciex catterns are difficult to intercret witncut extensive field inves tiga tions.
Umonasis acceo)
(4)A prominent south-facing scarp and topographic break does exist in the site area.
(5) Existing geologic maos and texts of Vickery (1925), Hall (1958), Prince (1957),
URS/Blume Associates (1973) and more recently Herd (1977) supcort the existance of the Verona fault and other faults in the GETR site area and vicinity.
In addition, to the northwest of the GETR site and along the general northwesterly projection of the Verona fault is the northwest trending Pleasanton fault which is identified as a potentially active fault on the California Divisien of Mines and Geology Special Studies Zones Map, Dublin Quaarangle (Slosson, 1974). Several authors (Surkland, 1975; Judd Hall Asscciates,1977; Carpenter,1977) have assigned various lccations to
?leasanton fault. At the present time, it is reasonable to conclude that the 31easan-ton fault is a possible continuatien of the Verona fault.
(5) Recent seismological studies of earthquake fault plane solutions indicate that the Livemore Valley region is in northeast-southwest compression (Simila and Scmerville,1978) and not extension as argued by the licensee (GE-ECAC,1978).
Moreover, this indirect observation of the stress direction is consister.: with the highly active regional tectonic framework. Northeast-southwest compression would succort development of, and centinued movement along, a northeast-dipping thrust fault such as the Verena.
(8)...
The more recent geologic mapping proviced by GE contains substantially more geologic structures than :ne earlier versions, indicating more post-Liver. ore tectonic deformation than would have been ascertained from GE's earlier manping.
(9) Photolinears and the cause of seeps and ponds to the south of and in close proximity to the GETR site area have not been trenened or exclained.
In tectonic-ally active areas photolinears are often due to groundwater barriers or differen-tial erosion due to the presence of a fault."
FRIENDS OF THE EARTH'S CCMMENTS AND ANALYSIS Although the NRC's pSER-GETR report presents interesting information, it is ince=clete in analyzing the ccaplex tectonic setting of the Vallecitos Valley and the surrounding fault systems. Several faults that may intersect witn the Verona fault are not analyzed. All of these faults seem to intersect with or parallel the Calaveras fault and possibly intersect with the Las Positas fault.
These faults include the Pleasanten fault, the Williams fault, the Maguire Peaks fault, and other parallel branches of the Calaveras fault. Also not analy:ed by the NRC are the sequence of interactions during an earthquake on the Verona, Las Positas, and Calaveras faults in terms of ground motions and durations, and pos-sible surface ruptures, and how these would affect the operating plutenium labs.
All of the above mentioned faults could be branches or subsidiaries of tne pcwer-ful Calaveras fault which is a branch of the San Andreas.
If any of these faults experienced seismic activity simultanecusly with the Calaveras, what would be the effects on the reactors and labs at Vallecitos? The NRC seems to have forgotten a memo frem one of its geophysicists in the Geosciences Eranch concerning the timing of earthquakes on the Calaveras.
In his memo to Carl Stepp, John Kelleher states:
"The Calaveras fault :cne is a capable fault within the meaning of Appendix A to 10 CFR Part 100 and, at its closest point, is within one or two miles of the GETR site.
It is reascnable, in my opinion, to assume that an earthquake of magnitude about 7.0 to 7.5 could occur at any time en :nis fault and at any locaticn along the fault. Such an eartnquake, therefore, could occur at any time within one or two miles of ne plant site. The resulting grounc motion generatec at the plant site by the postulated earthquake would almost certainly be severe and ceak arcund accelerations would be among the biener cbservations to date. (emchasis accec)
- t is unlikely that extensive future investigatiens will mcdify this assessment in any significant manner."
.4.
That internal NRC Staff memo was written in late October,1177, and now in December,1978, the plutonium labs at Vallecitos are still in operation, even though the NRC PSER-GETR admits that the Calaveras could cause in excess of a one g at the site, and GE's structural analysis indicates that a one g could totally destroy the plutonium labs. This situation illustrates the risks that the NRC is willing to take with public health and safety.
Actually it is possible that an earthquake or dither the Verona or the Cala-veras faults could easily exceed one g.
Calcul u,as by a seismologist from Scripps Institute of Geophysics and Planetary Physics (J.N. Brune, Journal of Geophysical Research, 1970,1978) and by Y. Ida (Bulletin of Seismological Society of America, 1973) indicate that peak acceleration near a surface rupture can easily exceed one g.
Also, field evidence from near-epicenter damage studies (N.N. Ambraseys,1969; C.F. Richter, Elementary Seismolcav,1958) indicates that accelerations greater than one g have already been experienced.
Furthermore, according to L.H. Wight, there are " data, calculations, and observations (which) clearly indicate that accelerations approaching one g are possible in near-epicentral regions for earth-quakes of all magnitudes."
The NRC's PSER-GETR says that the Verona fault could experience an earthquake similar in size to the San Fernando quake of 1971. That quake changed the entire set of seisdalogical theories on relationships between Richter magnitudes and ground acceleration potential. That quake was the first time in history that accurate near-field ground acceleration data was collected. Based on previous records, the maximum ground acceleration possible at San Fernando in 1971 would have been pre-dicted to be 0.1 g to 0.3 g.
Instead, the 1971 quake, measuring 6.6 magnitude, caused various ground acceleration measurements in excess of one g including the Pacoima Dam record of 1.25 g, recorded at a distance of 4.4 kilometers from the epicenter. The Vallecitos plutonium labs are less than 1 kilometer from the Verona fault, and less than 3 kilometers from the Las Positas fault, either of which could cause a 6.5 magnitude quake. Thus, it is possible that either of those faults could cause accelerations at Vallecitos in excess of 1 g.
The Calaveras fault can cause a 7.5 magnitude quake with an epicenter one or two miles from *he plutonium labs. The way the Richter scale is measured, a quake of magnitude 7.5 could release more than thirty times more destructive energy than a quake of magnitude 6.5.
Thus, it is very possible that a Calaveras quake with its epicenter near Vallecitos could cause severe ground accelerations in excess of 2 g.
Another relevant quote from the NRC PSER -GETR will help to explain this:
" Numerous complexities are involved in estimating earthquake ground motions at a site. At distances greater than about 20 kilometers from the earthquake source, a fairly large set of observational data exists. At distances closer to the source, however, the observational data set is relatively small. There is,in fact, a virtual absence of records of strong grouna motion for locations close to large earthquake sources. Any estimate of free-field ground motion at the GETR site must, therefore, be considered an extrapolation of data rather than supported by direct observations. Simple sc arce theory indicates that peak acceleration near the causative fault may be proportional to the stress conditions and rock physical properties at the source, possibly independent of earthquake magnitude (see for examole, Brune,1970). Limited observational data tend to support these theoreti-cal results (Hanks and Johnson,1976)."
Following the above statement in the PSER-GETR, the NRC Staff stated that:
"Dyration of motion, including duration of high peaks is, however, a function of earthquake ma others (1972)gnitude or source size... based on the available data by Page and
... peak horizontal near-source acceleration for a magnitude 7 to 7 h earthquake could exceed I g and that the total duration of strong motion could be between 25 and 40 seconds."
Apparently, the NRC may have underestimated the duration, based on recent data from the November 29, 1978 earthquake in Mexico where a quake with its epi-center offshore some 400 miles from Mexico City, had a duration of two ninutes and 53 seconds, with a 7.8 magnitude quake. That quake was followed by five more strong aftershocks within twenty four hours. Although that quake had its epicenter about 400 mijes from Mexico City, the structural damages in that city were large.
This indicates that the Vallecitos site should be reevaluated for damages from quakes on the San Andreas fault system.
The November 29 quake and aftershocks were followed on December 7 by another major quake of magnitude 6 to 7 with two large aftershocks, that shock 3 Latin Ameri un countries.
On December 10, 1978, another quake with a 5.9 magnituc shook the Acapulco area.
That quake could have been an aftershock of the Nr.mber 29th quake.
These quakes illustrate the problems that would be 4xperienced at the Vallecitos plutonium labs if a major quake and associated aftershocks damaged the labs, spilled plutonium, and left radioactive materials exposed to resuspension from aftershocks.
Another consideration that the NRC Staff has failed to analyze is the fact that the Calaveras fault zo9 near Vallecitos is a seismic gap which is defined as any region along an active plate boundary that has not experienced a large thrust or strike slip earthquake for more than 30 years. A seismic gap has the potential to produce a large earthquake in the near future. This is especially relevant new because the earthquake in Mexico last month was predicted by geologists because the area was in a state of seismic gap. When will the next big quake stri'Ke the Calaveras fault :ene?
The NRC PSER-GETR (August,1978) failed to analyze in detail the possi-bility of an en echelon series of branch felts in the Livermore and Vallecitos Valleys. En echelon faults are very common in northern California because of lateral stresses.
If three main faults are located near each other (such as the Verona, Las Positas, and Calaveras) then there will likely be branches, spurs, or parallel offshoots between them.
It is probable that several new faults will be discovered if more trenching is done in the Vallecitos Valley.
When discussing potential earthquakes on postulated faults, it is essen-tial to understand that faults are not limited to narrow lines on a map, but are found in zones that range from 100 feet wide to several miles wide. Severe ground motions can occur several miles from the main fault trace, because the actual ground motion origi ates deep within the earth, not on the surface. The Calaveras and its branches are part of the San Andreas fault system, which is experiencing enormous tectonic stress. According to the plate tectonics theory, the San Andreas is a transform fault that is the dividing line cetween the North American plate and the Pacific plate, and those two plates are sliding past each other in a right lateral strike slip motion. The San Andreas has had two major quakes in the past 120 years that each caused surface ruptures along 320 kilometers of the fault, with offsets measuring in many meters. The horizontal displacement along that fault system has been over 50'0 kilometers since Jurassic time (COMG, 1966).
Some of the stress is transferred to the Calaveras branch which is 120 miles long. Hall (1958) estimated a vertical displacecent of at least 2,000 feet on the Calaveras fault zone and a right lateral horizontal displacement of at least 3 miles. The Calaveras has had several major earthquakes in historic times; especially notable are the quakes on June 10, 1836 (Intensity IX to X);
July 3,1861 (Intensity IX); May 19, 1889, (Intensity VI.II); June 20, 1897 (Intensity IX); March 30, 1898 (VIII), and June 11, 1903 (VIII). Many historic quakes of smaller magnitudes or less intensity have been recorded in the Livermore and Vallecitos Valleys (see epicenters maps in the report by Darrell Herd, USGS Open-file report 77-689). Some of those epicenters seemed to have been located on the Verona fault, especially during the swarm of quakes in 1943. Other epicenters were on the las Positas fault zone.
It is important to remember that in the San Andreas fault system, surface ruptures usually occur discontinuous 1y across en echelon faults. Local stress concentrations can cause a newly created en echelon fault to appear (usually parallel to a known fault zone) and to form a subsidiary fault. The tectonic stresses in the San Francisco Bay Area are particularly conducis e to this type of branching. Two branches of the San Andreas, the Hayward and the Calaveras, are among the longest faults in the state, and they each have subsidiary branches.
Block faulting between and beside the Hayward and Calaveras faults have created the Sunol Ridge (within sight of the Vallecitos plutonium labs) and the Livermore Valley. The Vallecitos and Livermore Valleys are located adjacent to the L.ablo Antiform and the Coastal Range Thrust fault system which is parallel to the San Andreas system. The Diablo Antiform is dissected by many active faults and is seismicly active. Literally hundreds of' earthquakes with magnitudes in the 4 to 5 range have been recorded there in recent years.
These fault systems have been active for millions of years and they will continue to be acti 'e long into the future. The Vallecitos Nuclear Center was constructed in one of the most seismicly active regions in the United States.
h
8-GEOLOGIC INVESTIGATIONS AT VALLECITOS Trenches are a valuable technique used by geologists to determine the exact locations of earthquake faults. The first two trenches at VNC were dug in September and October,1977 because of the publication of a new geologic map by the USGS which mapped a fault (the Verona fault) imediately adjacent to the GETR. On October 21, 1977, GE reported to the NRC that its geological consultants had ider.tified evidence of faulting in both trenches. On October 22, 1977, the NRC and the O'SGS inspected these trenches and confirmed the existence of a thrust fault which they considered capable of potentially damaging the nearby reactor. Subsequently, in December,1977 and February,1978, GE published dccuments which claimed that the fault was not really a fault at all, but that it was merely the remains of an ancient landslide.
In spite of evidence to the contrary, GE has continued to maintain its position that there are no active faults in the vicinity of VNC and that the Verona fault does not exist. The USGS and the NRC Staff have analyzed all of GE's reports and " evidence", and they both say that the landslide theory is not substantiated by the evidence and that even if there was a landslide, it could have been caused by an active fault, and that both could exist simultaneously.
In fact, in an August,1978 report, the NRC Staff stated that the faults in the VNC area could experience earthquakes causing much worse ground motions (in excess of 1.0 g) than they had believed at the time of the shutdown (.75 g). Because of that NRC report, GE decided to make a last ditch effort to save its reactor by digging more trenches. GE hoped to find a landslide and no earthquake fault. The second set of trenches were dug in September and October,1978. Four major trenches and many smaller trenches were dug.
On October 17, 1978, the NRC and the USGS visited the trenches. The NRC report on this visit confirmed that there was no evidence of a major landslide
.g.
on the site. That same NRC report (released to Intervenors in late November, 1978) stated that " Trench B which is located immediately to the west of the GETR confirmed the existence of the large thrust offsets observed in trenches 1 and 2 in the fall of 1977... The southwest extension of Trench 8, wnich had not been logged, showed an apparent thrust or reverse fault offset in the approximate location of another air photo lineation. GE is currently logging this trench and has excavated numerous parallel trenches for the purpose of
, tracing this apparent fault. We will examine these trenches in detail during our next site visit." In that report, the NRC requested that GE dig more trenches and enlarge some of the trenches that had already been dug.
The October,1978 NRC report thus describes a newly discovered " apparent thrust or reverse fault" which angles towards the VNC plutonium labs along an air photo lineation (an indication of the path of a fault). The trenches that were mentioned in that report are to the northwest of the plutonium labs. Another trench (H) hss been dug close to the labs on the southeast side.
Trench H was inspected by representatives of the Intervenors, including a geologist, in early November, 1978. This trench reveals a displacement of two distinctly different-colored beds of sediments. One bed is thrust over the other along a traceable shear surface. The angle of this displacement is parallel to the angles of thrust offset observed in trenches 1 and 2 in 1977 and in trench B in 1978 on the main branch of the Verona fault, and the feature also resembles the offset observed in the extension of trench 8 (discussed in the October,1978 NRC report). This apparent thrust fault is observable in trench H which is very close to the plutonium labs (approximately 250 feet southwest of the labs). The lineation of this fault projects towards the labs and towards the offset observed in the trenches on the other side of the labs. The existence of this fault should be sufficient evidence to imediately suspend the operations of the VNC plutonium labs. The location of this fault ra'ses the possibility of surface ruptures beneath the labs and of inc.reased ground motion during an earthcuake.
The NRC's primary legal responsibility is to protect the public health and safety from uncontrolled releases of radioactivity into the environment. Several active earthquake faults capable of damaging the plutonium labs have been discovered around the VNC site. Structural analyses have indicated that the plutonium labs will be destroyed in an earthquake. The public health and safety is endangered by the continued operation of the VNC plutonium labs. Therefore, it is important for the NRC to fulfill its legal responsibility by suspending the operations of these labs.
TRENCH H During trench inspections on December 6,1978, geologists from the NRC, USGS, ESA, TERA, and other consultants from GE and the NRC visited a trench (H) loc:sted less than 100 yards from the operating plutonium labs. Trench H was dug near the labs because features such as air photo lineations, vegetation lineaments, and an anomalous hillside structure suggested that a fault could be located there.
Trench H reveals spectacular evidence of a thrust fault where shear surfaces are seen in obvious slickensides that extend diagonally frcm the top to the bottom of the trench.
The slickensides have a remarkable consistency of direction striking towards Building 102 which contains the plutonium labs.
These slickensides are polished surfaces with a planar surface of displace-ment between two beds in which the uphill bed consists of Livemore gravels and the downhill bed consists of paleosoil, a reddish-brown colluvium. The slickensides range in dip angle frem 10 to 25 degrees and dip northeast into the hillside. The paleosoil bed is thousands of years younger than the Livermore gravels bed which is thrust up over the paleoscil.
Therefore, this displacement of t.a has taken place in recent geologic times since the famation of the paleosoil.
During the December 6th trench inspection, a discussion occured as to whether the slickensides were formed by a single episode or by multiple ep?sodes of movement.
One coment was that there was more than thirty feet of offset exposeo in this trench and that this much offset was observed in the Fort Tejon earthquake. Beccuse the Fort Tejon quake was over an 8.0 magnitude, the theory was rejected that a single event caused the offset.
Multiple earthquakes along the trench H offsets are therefore indicated.
MULTIPLE FRACTURE ZONE THEORY Ouring trench inspections on October 17, 1978, and December 5 and 6, 1978, Trenches B-2 and H revealed dramatic shear surfaces, slickensides, offsets and displacements of beds which indicate the existence of one or two new.
apparent thrust faults. Since these faults are distinguishable frem the Verona fault in Trenches 1, 2, and 8-1.
Friends of the Earth suggests that the Verona, Lake Lee, and Plutonium faults may be part of a series of thrust faults in a multiple fracture zene extending from the Verona fault to the Calaveras fault. There is evidence to support this theory. Several maps (including Blume,1973, and Herd,1977) show faults parallel to the Calaveras passing h to 1 mile east of the main trace (the Maguire Peaks fault and unnamed tr'ces). The Verona and the two new traces near the plutonium labs are approximately h mile apzrt, and appear to be parallel and somewhat similar in their angles of displacement.
All three hav'e beds of older materials thrust over younger soils.
Carrell Herd's map of 1977 (USGS Open-file report 77-689) shows three other distinct fault traces that appear parallel to the Verona and the two new traces, and are between the Verona fault and the Calaveras fault.
These three mapped fault traces are located approximately 1.4,1.6, and 1.77 miles southwest of the Verona fault.
Because the Calaveras fault zone is responsible for tectonic ccmpression in the Vallecitos and Livermore Valleys, it is theoretically possible that there could be several other thrust faults between the Plutonium fault and the three
unnamed faults to the southwest. The theory is also supported by the existence of several right lateral strike slip faults to the east running parallel to the Calaveras (the Williams, Trench A, Livermore, and Greenville faults) which were created by stress on the Calaveras zone, and which increase the compressional stresses in the area of the Vallecitos Valley.
During morning discussions on December 5,1978, GE's consultants, ESA, admitted that extensive trenches in the D, F, and G series in the hills behind the reactor revealed no evidence of a major landslide that they had predicted they would find there.
The basis for the NRC's extended delay (from October,1977, to December, 1978) in deciding if there was a thrust fault zone hazard to the plutonium labs requiring their shttdown seems to have been based on proposals by GE and ESA that the faults in'the Vallecitos area were not caused by earthquakes or seismic activity but were created by ancient landslides. This " landslide theory" was a farce from the very beginning.
The entire region is full of landslides and faul ts Many landslides have been mapped by the USGS including maps by Darrell Herd (77-689) and by Earl Brabb (USGS Miscellaneous Field Studies Map MF-519,1973),
both of which show landslides in the area from Pleasanton to Sunol. Obviously everyone involved (except the aedia and the public) knew that there are plenty of surface landslides in the hills in that region caused by historic seismic activity.
Although the USGS and the NRC both told CE and ESA that there could be both landslides and earthquake faults simultaneously, and that landslides in no way would preclude the existence of faults, GE and ESA persisted for over a year in the position that there were only landslides around Vallecitos Nuclear Center.
The NRC delayed its regulatory decisions for over a year to give GE and ESA a chance to prove their " landslide theory".
The trenches dug in September and October and
November,1978 were literally GE's "last ditch effort" to save Vallecitos with the landslide theory.
Finally, on December 5th, ESA admitted that they could not find the big landslide head scarp or any evidence of major landslides in the 24 miles of trenches that were dug. Only surface slides were found which can be caused by quakes and erosion, or subsidence and slumping.
An important point to make here is that the NRC and ESA art not new to the games they play with public health and safety. ESA was hired as consultants to "G&E for similar analyses of nuclear reactor sites at Humboldt Bay and Davenport.
In both situations, independent geologists and the USGS said that there are earthquake faults at the sites, but both times PG&E hired ESA to delay regulatory decisions by the NRC by proposing that the geologic features in question were caused by ancient landslides, not by active earthquake faults. Since faults and landslides exist side by side chroughout California, this was an easy way to fool the public and the media and to try to protect the nuclear reactor sites from any shutdowns.
In analyzing seismic hazards to nuclear reactors in California the NRC and its predecessor the AEC have a miserable list of disastrous mistakes involving nuclear reactor sites at Vallecitos, Bodega Bay, Cavenport, Point Arena, Malibu Humboldt Bay, Diablo Canycn, and San Onofre.
In all of these cases, the NRC-AEC encouraged the nuclear industry to build reactors at their chosen (and paid for) sites. Neither the consultants of the nuclear industry nor the consultants or staff of the NRC-AEC ever discovered earthquake hazards at these sites.
If it had been up to them there would now be four operating reactors at Vallecitos; five opera-ting reactors at Bodega Bay; one each at Humboldt, Davenport, and Malibu; and two giant reactors at Point Arena; as well as two monster operating reactors at Diablo Canyon with six more on the drawing boards.
Fortunately for the public's health and safety, the USGS and other independent geologists are not in the business of protecting the nuclear industry.
These independent geologists and seismologists have pain.ted out the earthquake hazards at the eight reactor sites named on the last page. For example, the Bodega Bay site for five reactors and the Point Arena site for two giant reactors are both in the zone of the San Andreas fault.
The Diablo Canyon reactors are within two miles of a major offshore branch of the San Andreas. The way the NRC-AEC seems to operate is that if the geologists and cii.1: ens can prove the earthquake hazards before constr tetion begins, then they have a chance to protect the public health and safety. But if the faults are not discovered until after the reactors are constructed or operating, then the NRC-AEC has the primary responsibility of protecting the nuclear industry's investment rather than worrying unduly about some future earthquake that may not happen until the regulators are dead and gone.
The NRC apparently has a current policy (most clearly stated at Diablo Canyon) that it is more important to protect the financial investments of the nuclear industry than to protect Californians from radioactive disasters following future earthquakes.
The Calaveras fault and its branches, including the en echelon series of thrust faults at the Vallecitos site, could experience a severe earthquake at any time.
Insurance companies still refer to unpredictable and uncontrollable earthquakes as " acts of God." Unfortunately, GE and the NRC do not have any insurance policy with God to delay the occurence of any earthquake.
In the GETR Show Cause proceedings, GE's structural consultants (ECAC) and the NRC (PSER-GETR) have admitted that the Verona fault could cause surface ruptures, ground shearing, and vertical or lateral offsets directly beneath the GETR reactor. The Verona fault is a thrust fault.
Because thrust faults angle diagonally to the surface from deep beneath the surface, they can have a surface rupture zone of up to a half mile wide.
The plutonium labs are less than a half mile from the Verona fault. Because two other " apparent thrust faults" have been discovered near the plutonium labs (in trenches B-2 and H), it is necessarv and urcent for the NPr and rJ m analvra tha notontui structural damage to the labs from surface rupture, cround shearing, and lateral or vertical offset directly beneath the labs. This tyce of analysis has not been done.
If these types of ground motions can take place beneath the labs, they could be simultaneous with and in additicn to the g values previously described, and the structural damage previously analyzed would be increased tremendously.
Structural engineers in California generally recognize that it is virtually impossible to make a structure " earthquake proof" if it is within a zone of possible surface rupture and offset or shearing. For example, the following quotes are from a book titled Peace of Mind in Earthcuake Country by Peter Yanev.
" Buildings located in fault zones are exposed to the highest possible earthquake risk. This is unequivocally a fact of life in earthquake ccuntry, and no measures--whether the most ea,thquake-resistant bracing and building materials nor the latest and soundest principles of reinforcement--can guarantee or even tentative'y propose that any property astride a fault would survive a moderate quake without severe or total damage... The greatest hazard to structures in fault zones is that they are subject to ground-surface ruptures and displacements during an earthquake, and no building can withstand this faulting beneath it. A ground shift of only a few inches (vertically, horizontally, or, most commonly, both) is sufficient to cause severe structural damage to buildings. A large quake, with its typical displacements in the fault zone of from several inches to several feet, could demolish the most well-engineered building." (page 49)
Yaney's employer is URS/ Blume and Associates who developed the AEC's Seismic Design Criteria for Nuclear Reactors in 1973. Unfortunately, the AEC had inadequate criteria for seismic hazards prior to 1973 (for reactors), and neither the AEC nor the NRC have developed any seismic criteria for the structural design of plutonium labs.
Currently, the Vallecitos Nuclear Center is a disaster waiting to happen.
If the public and its representative officials wait until after the disaster following the next earthquake, we will be faced with the problem of GE not having enough insurance t9 help pay for damages to health and property.
Because the radioactive contamination will last for thousands of years, the emergency evacuations following the e.rthquake may have to become cermanent relocations for the former residents of nearby cities. Who will pay for the enormous disruptions in the entire Bay Area's economy?
The Natural Phenomena Review Team One of the reasons for the delay in NRC decision-making on Vallecitos is the schedule for publication of a report by the Natural Phenomena Review Team. This team is a group of consultants hired by the NRC to study the earthquake hazards to the plutonium labs at Vallecitos. Tne fifteen consultants whom the NRC has hired to be on the team have obvious conflicts of interests that interfere in their objectivity. Two of them are from the same consulting firms that GE has hired in its attempts to downplay the earthquake hazards to the GETR reactor at Yellecitos. One is a structural consultant from EDAC (Engineering Decision Analysis Co.). EDAC has produced several structural reports for GE's license renewal applications for VNC.
The other team member is a seismic consultant from TERA (Teknetron Energy Resources Analysts) which has produced seismic reports for GE on Vallecitos.
The conflict of interest is so obvious that the NRC should replace these consultants with other independent engineers and seismologists.
The current review team of 15 includes 9 employees of nuclear weapons labs operated by the same federal agency (Department of Energy) wnich issues the contracts to GE for plutonium projects in the labs at Vallecitos. Eight of these nice consultants work at 3 labs wnich are directly connected by Y
-la.
contracts to Vallecitos. This indicates an inherent conflict of interest.
Perhaps the NRC's choice of consultants helps to insure predetennined con-clusions in the review teart's report.
The four remaining consultants (of the team of 15) are structural analysts frem Texas and Illinois. Two of these four, N.M. Newmark and W.J. Hall, have been used by the NRC to review seismic hazards to almost every nuclear reactor site in the nation, and as far as we know, they have never said that any site was too dangerous to have an operating reactor.
Why did the NRC not choose any independent structural engineers to analyze the plutonium labs at Vallecitos? California has thousands of qualified engineers who are experienced in earthquake analyses for structures near active fault zones. These West Coast engineers are more familiar with the specific seismic hazards and fault characteristics common to the San Francisco Say Area. Why did the NRC choose to pay certain persons frem Texas and Illinois to analyze ea,rthquake hazards to nuclear facilities in California?
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THOMAS H. BATES MEMBER oP" THE ASSEMSt.Y TwstrTM AsstMai.y casTaict December 11, 1978 Andrew Baldwin, Esq.
Friends of the Earth 124 Spear Street San Francisco, Ca 94108 D' ear Mr. Baldwin:
This letter is in response to Friends of the Earth Draft Request for Action concerning the continued operation of the plutonium laboratories at the Valecitos Nuclear Center.
The fact that the General Electric plant lies at or near three earthquake faults, as well as the discovery that i: lies on a previously undiscovered fault, raises deeply serious concerns in my judgement that the continuing operation of the plutonium la-boratory is a serious hazard to the health and safety to the pop-ulation of the Bay Area.
Accordingly, I as asking the Nuclear Regulatory Commission to suspend the license granted to General Electric to possess several hundred pounds of plutonium and uranium.
The potential da= age to the laboratory as a result of a major earthquake may endanger the lives of the few million people in the Bay Area by the release of particulate and gaseous radiation or through a rupture of the plu-
- enium handling and storing facilities a: the site.
Iq is my hope tha: the operations of the plant will be suspended until these people-who say be affected by an earthquake catastrophe can be heard at the series of public hearings planned for next year.
Sincerely, 0 >.
=
Thomas H. 3ates Member of the Assembly TH3:GM:psj cc:
Congressman Ron Dellums
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December 2, 1978 Dr. Clifford V. Smith, Jr.
Director, Nuclear Material Safety and Safeguards United States Nuclear Regulatory Commission Washington, D.C. 20555 res Vallecitos Nuclear Center, Special Nuclear Materials License No. SNM-960
Dear Dr. Smith:
I join in the Request for Action to be filed by Friends of the Earth, pursuant to 10 C.F.E., Section 2.206, asking for the suspencion of activities at the Vallecitos Nuclear Center under License No. SNM-960,
. / o;:cergly.x b a-1
/3iiirbara Shockley 1890 Sock: nan Road San Lorenzo, Ca 94580
Mas. Misot KOHN 1860 GROVE WAY CASTRO VALLEY, C.uRORNIA 94546 December 1, 1978.
Dr. Clifford V. Smith Jr.
Director,3uclear Materials Safety and Safeguards U S Nuclear Regulatory Commission Washington D.C. 20555 Re: Valleettos Nuclear Center Special Nuclear materials License Number S N u - 960
Dear Dr. Smith:
I join in the Request for Action to be filed by Friends of The Earth, pursuant to IOCFR Section 2.206 asking for the suspension of activities at the Vallecitos Ecclear Center under Licence Number SNM@960.
Sincerely, rj s [Qrd~W(
Lore Kohn
1 18313 Pepper Street Castro Valley, CA 94546 December 2, 1978 Friencs of the Earth.
124 Spear S treet San Francisco, CA 94105 Attention:
Andrew Baldwin Gentlemen:
Please adc the enclosed request to your Request for Action re suspension of activities at Vallecitos Nuclear Center.
Sincerely,
'i it/ok H. Wolch
18313 Pepper Street Castro Valley, CA 94546 December 2, 1978 Dr. Clifford V. Smith, Jr.
Director of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Sir:
I join in the Request for Action to be filed by Friends of the Earth pursuant to 10 C.F.R. Sec. 2.206 asking for suspension of activities at the Vallecitos Nuclear Center under License #SNM-960.
Very truly yours,
}$f
/ Hiram Wolch, Ph.D.
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sHERM AN 1.EWIS 2787 MILLCREST AVENUE yeC. 9, 1970, MAYWARD. CALIFORNI A 94542 sr. w11f ford o 7ELEPMC8r:. 481538 3632 m
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s:.ree cr nuclear Material anfety and Sa 'oguards Dear Dr. c-d.th Frieds of the Esrth is filing 2 Recuest for Action urder 10 C'.F.R.
Section 2.206. Thev sre asking for a suspension of activities st the Vallecitos Nuclear Center urder License No. Smi-960. I wish to join in their Request. Thank vou.
Sincerely, I
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(41f) 183-4 13 Amuco scaviers couurrrza g
e an, e-wrea November 20,1978 (4 m =*=
P",'""""*_,
Andrew Baldwin, Esq.
Friends of the Earth 124 Spear Street San Francisco, CA 94103
Dear Mr. Baldwin:
This letter is in response to Friends of the Earth draft Request for Action concerning the continued operation of the plutoniurn laboratories at the Vallecitos Nuclear Center.
Af ter a careful staff analysis of your request, including an inspection of the Vallecitos site, I am ready to join with you in this request for action. Recent evidence has served as sufficient documentation to warrant such a request.
Throughout this year, my involvement as an intervenor in the case of the Vallecitos Reactor has clearly revealed the extensive dangers to my constituents posed such a threat by the possibility of a massive earthuake at this facility. I am now convinced that the Plutoniurn Labs constitute an equally dangerous condition for the health and safety of Bay Area residents.
I have enclosed a copy of the draft letter which is acceptable to my previously stated convictions.
Sincerely, Ronald V. Dellums Member of Congress
Enclosures:
Draf t Letter RVD:ak n
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Dr. Clifford V. Smith, Director
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- Office of Nuclear Materials, Safety and Safeguards Nuclear Regulatory Commission Washington, DC 20535 Docket Number 70-754 Re: Special Nuclear Materials License Number 960 (SNM - 960)
Vallecitos Nuclear Center
Dear Dr. Smith:
Te the undersigned Bay Area Members of Congress hereby submit a formal Request for Action, pursuant to the Commission's (NRC's) Rules of Practice,10 CFR 2.206.
Te request that the NRC suspendthe License SNM - 960 which allows :he General Electric Company (GE) to possess up to 330 pounds of plutonium and over 2000 pour:ds of enriched uranium at the Vallecitos Nuclear Center (VNC), where GE operates a plutonium fuels fabrication facility and laboratories handling plutonium and other radioactive materials. The plutonium license makes Vallecitos the second larges:
privately-owned plutonium fuel plant in the United States.
It appears to us that sufficient new information has become available to justify a suspen-sion of the SNM - 960 license for Vallecitos. The earthquake faults in the vicinity of VNC could cause such severe ground motions that the plutonium labs in Building 102 would be severely damaged or totally destroyed, according to evidence presented by seismic analyses in the Proceedings that have followed the shutdown of the General Electric Test Reactor (GETR) a year agor' On October 24,1977, the NRC ordered GE to shutdown the largest of its four nuclear reactors located at the VNC site. The shutdown was ordered because at least three active earthquake faults pass very near to the site.
At the time of the shutdown, the NRC staff said that the C alaveras Fault (mapped as 2 kilometers west of the GETR) could deliver a 7.5 Richter magnitude earthquake causing in excess of.75 g in ground motion at the GETR site. The plutoniurn facilities are closer to the Calaveras fault than the GETR and both structures were built in the mid.1950's when the maximum potential ground acceleration at the site was estimated to be between.19 g and.33 g. Currently :he NRC staff has estimated in their draf t, Safe:y Evaluation Repor: Input, dated Augus: 17,1973 from the geoscience,section, that the Vallecitos site can experience ground acceleration in excess of.',,g. Documentation compiled by FCE is enc!osed.
l0
Or. Ciiflord V. Smith. Dir :ctor November 20,197S Page 2 The concern that brings us to present this Request for Action is that, based on this new evidence, continuing to allow operation of the Vallecitos Nuclear Center clearly endangers the public health and safety of the San Francisco Bay Area population. The number of people living within the 20 to 30 mile range of VNC is over 2,S00,000. Within 40 miles of VNC live over 4,c00,000 people. Within 50 miles there are over 5 rnillion people.
Te note, too, that af ter the NRC shutdown of the GETR, eight Bay Area Congressmen signed a letter to the NRC (see Appendix A) requesting the NRC to conduct public hearings before renewing the licenses for the GETR and the plutoniu:n laboratories, in that letter to the NRC, the Congressmen said, "a major earthquake rnight cause a significant release of particulate and gaseous radiation such that an evacuation of nearby population centers would become a require:nent. It appears that such an evacuation would be very nearly impossible to carry out in a safe and effective manner.... evacuation of an area containing millions of peop12 might be necessary.
Further, it is apparently possible that such an earthouake might also cause a rupture of the plutonium handling and storage facilities at the Vallecitos site." We believe that recent evidence reconfirms these concerns.
In conclusion, it is our understanding that there will be a series of 3 public hearings to be held regarding the reopening and relicensing of the Vallecitos facility which are likely to continue until at least late 1979 or even into 1930. Because of the considerable waiting period, we are even more convinced that it is necessary to suspend the operations of the plutonium laboratories.
Sincerely,yours, I
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/ Ronald V. Deilums Member of Congress t
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Nuclear Regulatbry Commission Washington, DC 20555 Docket Number 70-754 Re: Special Nuclear Materials License Number 960(SNM-960)
Vallecitos Nuclear Center
Dear Dr. Smith:
We the undersigned Bay Area Members of Congress hereby submit a formal Request for Action, pursuant to the Coanission's (NRC's) Rules of Practice, 10 CFR 2.206. We request that the NRC suspend the License SNM-960 which allows the General Electric Company (GE) to possess up to 330 pounds of plutonium and over 2,000 pounds of enriched uranium at the Vallecitos Nuclear Center (VNC), where GE operates a plutonium fuels fabrication facility and laboratories handling plutonium and other radioactive materials. The plutonium license makes Vallecitos the second largest privately-owned plutonium fuel plant in the United States.
It appeats to us that sufficient new information has becone available to justify a suspension of the SEH-960 license for Vallecitos. The earthquake faults in the vicinity of VNC could cause such severe ground motions that the plutonium labs in Building 102 would be severely
/
damaged or totally destroyed, according to evidence presented by seismic analyses in the Proceedings that have followed the shutdown of the General Electric Test Reactor (GETR) a year ago: On October 24, 1977, the NRC ordered GE to shutdown the largest of its four nuclear reactors located at the VNC site. The shutdown was ordered because at least three active earthquake faults pass very near to the site. At the time of the shutdown, the NRC staff said that the Calaveras Fault (mapped as 2 kilometers west of the GETR) could deliver a 7.5 Richter magnitude earthquake causing in excess of.75g in ground motion at the GETR site. The plutonium facilities are closer to the Calaveras fault than the GETR and both structures were built in the mid-1950's when the maximum potential ground acceleration at the site was estimated to be betseen.19g and.33g.
Currently the NRC staff has estimated in their draft, Safety Evaluation Report Input, dated August 17, 1978 from the geoscience section, that the Vallecitos site can experience ground
Dr. Clifford V. Smith, Director Page 2 acceleration in excess of 1.0 g.
Documentation compiled by F0E is enclosed.
The concern that brings us to present this Request for Action is that, based on this new evidence, continuing to allow operation of the Vallecitos Nuclear Center clearly endangers the public health and safety of the San Francisco Bay Area population. The number of people living within the 20 to 30 mile range of VNC is over 2,800,000. Within 40 miles of VNC live over 4,400,000 people. Within 50 miles there are over 5 million people.
l We note, too, that after the NRC shutdown of the GETR, eight Bay Area Congressmen signed a letter to the NRC (see Appendix A) requesting the NRC to conduct public hearings before renewing the licenses for the GETR and the plutoaium laboratories.
In that letter to the NRC, the Congressmen said, "a major earthquake might cause a significant release of particulate and gaseous radiation such that an evacuacion of nearby population centers would become a requirement.
It appears that such an evacuation would be very nearly impossible to carry out in a safe and effective manner... evacuation of an area containing millions of people might be necessary.
Further, it is apparently possible that such an earthquake might also cause a rupture of the plutonium handling and storage facilities at the Vallecitos site."
We believe that recent evidence reconfirms these concerns.
In conclusion, it is our understanding that there will be a series of 3 public hearings to be held regarding the reopening and relicensing of the Vallecitos facility which are likely to continue until at least late 1979 or even into 1980.
Because of the considerable waiting period, we are even more convinced that it 13 necessary to suspend the operations of the plutonium laboratories.
Sincerely yours,
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,ra hn L. Burton Member of Congress
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FRIENDS OF THE EARTH 124 SecAa SAN FRANctsco Caurons:A 94 og s4:5:495-4770 FURTHER DOCU:rENTATICN Cf EARTHQUAKE HAZ ARDS Arc HISTCRICAL 8ACKCROUNO CF THE VALLECITCS PLUTONIUM LASS In the course of the Vallecitos CETR reactor Shcw Cause P cceedings (Occket No. S0-70), 'the NRC Staff published a Preliminary Safety Evaluation Recort Input (PSER-CETR), prepared by the Ceosciences Branch of the Staff on the geologic and seismic hazards 4c the site. Although the PSER-GETR was cated August 17, 1978, it was net released to Intervenors until early Cctober,1973.
In the PSE R-CE TR, the NRC Cecsciences Branch reviewed all of the documents previded by CE and its censultants, reports by the USGS, and reports by other geologists and seismologists.cencarning the scismicity of the reglen and the Vallecites site.
The Staff has also conducted several site visits to inspect trenches end other geologic features. The follcwing quotes are fecm the section of the PSER-CETR entitled " Current Staf f Position" (pages 5-8):
"Ceologic data are indicative of a fault (the Verona fault) passing through the CETR site, and this fe ;1t shculd be assumed to exist...
The Verona fault should be assumed to be capabis within the meaning of Appendix A to 10 CFR Part 100 and, therefore, to pese a potential fc surface faulting near or beneath the reactor site.
2.5 meters of not slip at the surface resulting f cm reverse-cbliote movement along a fault place which could very in dip angle f cm 10 to 60 degrees provices a reasonably conservative description of surface slip en the pcstulated Verona fault during a single event...
Maximum vibratory ground motien at the CETR site sculd result f cm a magnitude 7 to 7} earthquake centerad en the sector of the Calaveras fault nearest the site. A.celeration pesks at the free-field surface cculd be slightly in excess of 1.0 g...
The hori: ental vibratory ground metien at the CETR site resulting fecm an earthquake of magnitude 6 to Si on the Verena fault could centain acceleratien peaks as high as 1.0 g."
The follcwing quotes are f;cm the section of the PSER-GETR entitled "Ceclogy":
"The CETR site is locatad in a highly active tactenic envircnment (Scit and others,1977; Lee and others,1971)...within the Live rmore syncline anc the central part of the Ccast Ranges structurally related to the San Andreas fault system, a
transform fault which forms a majcr secter of the boundary between the North Ameri-can and Pacific lithescheric pistes... (Ancersen,1971)... We censider the Livermere syncline and the major structural elements therein, including faults, to we their existence to movement across the Calaveras fault. The faults significant to our
Page Two
- review which we consider genetically related to the Calaveras are the las Pesitas fault... and the Verona fault which as interpreted is a low angle thrust within the scuthern flank of the syncline." (pages 8-9)
On pages 11 - 14, the "Caology" section continues:
"the existence of a landslide near the site does not in any way precluce the existence of faulting there. As discussed below, evidence for faulting exists in areas away fecm the landslide area. In fact, landsliding of ten results frem ove r-steepening of slepes due to fault movement and seismic shaking...
(1)... A reas to the northwest of the CETR show, both in the field and on aerial photo-
. graphs, the presence of geologic features which are indicative of the existence of f aulting. Steeply dipping Livermore gravel beds are truncated along a linear to curvilinear topographic escarpment. Along the base of this escarpment are a number of seeps and springs.
(2) To the southeast of the CETR the geologic log of the la Costa tunnel (Califor-nia Department of Water Resources,1966) suggests J aw angle faulting and folding in an area thecugh which the postulated Vercna fault would pass if projected eastward...
(3)The relationship between the Verena fault and the Los Positas fault has not
'en investigated and the area cf the William's fault (Hall,1955)-La Costa tunnel ir.cer-section has not been investigated sufficiently... Areas of intersection or merging of faults can be in a transitional stress state which usually leads to the develop-ment of fault patterns which are geolcgically ecmplex such as en echelon Faults rather than a single planar fault surface. Such complex patterns are dif ficult to interpret without extensive field investigations.
( 4) A preminent south-facing scarp and topographic break dass exist in the site area.
(5) Existing geologic maps and texts of Vickery (1925), Hall (1958), Prince (1957),
URS/9lume Associates (1973) and more recently Hard (1977) support the existence of the Verona fault and other faults in the CCTR site area and vicinity.
In addition, to the northwest of the CETR site and along the general northwesterly projection of the Verena fault is the northwist trending Pleasanten fault which is identified as a potentially active fault on tne California Division cf mines and Caolegy Special Studies Z enes map, Dublin Quadrangle (51csson,1974). Several authors (Surkland.1975: Judd Hall Associ-ates,1977; Carpenter,1977) have assigned varicus locations to the Pleasanton fault.
At the present time, it is reasonable to ccnclude that the Pleasanton fault is~a possible continuaticri of the Verona fault.
(6) Recent seismnlogical studies of earthquake fault plane soluticns indicate that the Livermore Valley region is in northeast-southwest ccmpression (Simila and Somer-ville,1979) and not extension as argued by the licensee (CC-EDAC,1978). More eve r, this indirect observation of the stress directicn is consistent with the highly active regional tectonic framework. Northeast-southwest compression would support develcpment ef, and continued movement along, a northeast-dipping thrust fault such as the Verona.
(8)...
The more recent geologic mapping provided by CE contains substantially more geologic structures than the earlier versions, indicating more post-livermore tectenic ceformation than would have been ascertained from CC's earlier mapping.
(9) Photolinears and the cause of seeps & ponds to the south of and in close pecximity to the CETR site area have not been trenched or explained.
In tectenically active areas photolineers are of ten due to gecundwater barriers or dif ferential erosien due to the presence of a fault."
On page 27 (Seismology), the ASER-CETR centinues:
"The seismic design hazards for the CETR site include vibratory ground motien, fault effset at the surface beneath the unit and vibratory gecund motion combired with surface offset caused by postulat J movement on the Verena f ault.
The licensee (CE) nas provided an evaluatien of these design ha:ctds in recorts by CCAC (1976,1977) and has provided acditional succorting discussion in a report by Carth Sciences Asscciates (1979d). The staff has reviewed these reports and has taken acccunt of the analyses and conclusions contained in them in the preparation of this testimony."
' Page Three "This testimeny is cencerned with an evaluatien of the nature and magnitude of the ha: arcs of faulting and ground motion at the site...
The CCTR site is located in a complex fault evironment 2.3 kilometers east of the Calaveras fault, directly over the projected surface trace of the postulated Verena fault and within 3 kilometers of the Laas Positas fault...
Maximum earthquakes for these faults would have magnitudes of 7 to 7 t, 6 to 6 i, and 6 to 6 i, respectively... the preposed Verona fault can be presumed to exist beycnd the bounds of the area mapped by Hard and to merge with the Calaveras fault... it must be presumed that the Verona fault is structurally connected to larger faults, and that a major portion and possibly all of the 12 kilometers length could rupture during a single earthquake.
It is our conclusion, the re f o re, that the San Fernando earthquake of 1971 could be considered as an earthquake similar in si:e to e potential event on the pecposed Verona fault."
Scre problems with the NRC's PSER-CCTR report involve its inccmpleteness in analyzing the complex tectonic setting of the Vallecitos Valley and the surrounding fault systems. Several faults that may intersect with the Verona fault are not analy:ed. All of these faults seems to intersect with the Calaveras fault and possibly with the Las Positas fault. These faults are the Pleasanten fault, the Williams fault, the Maguire Peaks fault, and the Sunol branch of the Calaveras fault.
Also not analyzed by the NRC are the sequence cf interactions during an earthquake o the Verona, Las Positas and Calaveras. faults in terms of gecund motions and duration, and possible surface ruptures. All of the above mentioned faults could be branches or subsidiaries of the powerful Calaveras fault, which is a branch of the San Andreas.
If these faults experience scismic activity simultaneously with the Calaveras, what would be the effects on the reactors and labs at the Vallecitos Nuclear Center.
Also not analyzed is the pcssibility of an en schelen series of branch faults in between and parallel to each of these other faults. En schelen faults are very commem in northern California, because of parallel stresses.
If three main faults are located near each other, there will likely be branches, sours, or parallel offshocts between It is likely that several new faults would be disecvered if more trenching is them.
done in Vallecitos Valley.
This is in fact the situa tion.
In the October 27, 1978, report by the NRC Ceesciences Branch, concerning the trench insoections of Cetoder 17 "an apparent thrust f ault" was discovered tha t is parallel to the main Verona fault and has similar characteristics in the angle of disclacement of the shear :ene.
(Cetailed discussion of this new fault is found elsewhere is our documentation.)
9 age Tcur When discusiing potential earthquakes, it is essential to understand that faults are not limited to narrew lines on a map, but are fcund in renes that range f rom 100 feet wide to several miles wide. Severs ground motions can cccur several miles frem the main fault trace, because the actual grcund motien originates deep within the earth, not on the surface. Because the Calaverss and its branches are part of the San Andreas fault system. they can be expected to respond in similar ways to tactenic stress.
.According to plate tactenic analyses, the San Andress is the dividing line between the North American plate and the Pacific plate, and the two plates are sliding past each other in a right lateral strike slip motien.
The San Andreas has had two major quakes in the past 120 years that each caused surface ruptures along 320 kilometers of the fault, with ef fsets measuring in many meters.
Surface rupture on the San Andreas usually occurs discentinuously across en echelen faults. Local stress concentratiens can cause a newly created eri echelen (parsllel) fault to branch off from the known fault zene and form a subsidiary fault.
The tectonic stresses in the San Francisco Say Area are particularly conducive to this type of branching. Two branches of the San Andreas, the Hayward and the Calaveras, are ameng the longest faults in the state, and they each have subsidiary branches.
31cck faulting between and beside the Hayward and Calave ras faults have created the Sunci Ridge (within sight of theVVallecitos plutonium labs) and the Livermors Valley.
The Vallecites and Livermore Valleys are located adjacent to the Diablo Antiferm and the Ccastal Range Thrust fault system which is parsllel to the San Andreas system.
The Diablo Antiform is dissected by many active faults and is seismicly active.
Literally hundreds of earthquakes with megnitudes in the 4 to S range have been recorded thers in recent years.
These fault systems have been seismicly active for hundreds of milliens of years, and they will continue to be active long into the future.
In fact, the Vallecites Nuclear Canter was c nstructed in ene of the ecst seismicly setive regicns in the United S tates. They could not have picked a worse place.
Sage Five The Vallecitos plutonium labs are in Building 102 which was constructed in 1955 and 1957. The Radicactive materials Lab in Building 102 began its hot cell cperatiens in June,1957.
The CETR reactor was constructed in 1957 and 1952.
The original site seismic repcrt was done in 1955 by Eyerly and Everncan.
The fellcwing are quotes frem page 42 of a CE report entitled APED-5000-A:
"The criginal design requirrnents for the CETR centainment vessel were derived f:cm a 1955 study by Byerly and Evernden.
This study showed that the CETR facility shculd be designed to withstand earthquakes similar to the Long Ee'ach, California earthquaka cf March 1933.
This earthquake was estimated to be cf mcdified mercalli IV intensity...
In Janua ry, 1958, Hausner cencluded that the CETR centainment shell eculd withstand g:cund motien twice as intense as these recceded for the Long Beach earthquake. In the same repcrt it was shown that the Long Beach earthquake produced lateral accelerations of 0.19 g.
At the time the Vallecitos Experimental Superheat Reactor was designed, an incecendent seismolegical study was made of the Vallecites site.
It was cencluded that the CVESH facilities should be designed for ground acceleratiens of 1/3 g (0.33 g)."
The same report said of the CETR, "The steel centainment shell and internal concrete support structure must be cacable of resisting sismic earth movements of 1/3 g acceleration."
Apparently the estimate at the ts' of constructicn of Euilding 102 in 1956 uns that the maximum expected earthquake for the Vallecites site would celiver a 0.19 g or modified mercalli IV.
So we assume that the original structural design for Building 102 when construction began in march, 1956 was for a Design Basis Earthquake that sculd cause a 0.19 g at the sita. Thus it seems pcssible that the plutenium labs and Building 102 cculd be damaged during an earthquake causing gecund motions abcvs a 0.19 g.
For the license renewal applicatien, CE hired a structural consultant named Kestutis Ocvycaitas.
In his June, 1977 analysis he used a maximum gecund aceslers-tien estimate of 0.56 g for the CETR and 0.56 g for Building 102 and tne plutenium
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Page Six labs. He used a higher g value for the labs because they are closor to the Calaveras fault than the Z TR.
According to his analysis, a 0.58 g at the plutenium labs site would destroy the ecmplex filter system that flows through a bridge from Building 102 into Building 102A.
In 102A, a series of ninety FCPA filters are used to filter out radioactive duest particles and gases from the het cells and glove boxes in 102.
CE has admitted to the NRC that the filter bridge, the 90 HCPA filters and the filter building (102A) would be beyond yield structurally at a.58 g.
Such a situation would leave the 20 to 25 plutenium glove boxes in the plutonium labs dependent on only 3 KPA filters and the smaller filters en each box.
These filters could also be destroyed by an earthquake. E admits that the glove boxes could be overturned in an earthquake with ground motiens of.58 g.
These are in the Advanced fuels Lab ( AFL).
2 also admits that the ground flcer Radioactive materials Lab (RML) and the Plutenium Analytical Lab (PAL) wculd be structurally beycnd yield at a.58 g.
Thus if the Calaveras, Verona or Las Positas faults deliver ground motions of.58 g to the Vallecitos site during any day that the Labs are in cperatien, the public health and safety will be endangered by the unfiltered release of radicactive materials.
G also admits that the fuel rod cladding lab in Building 105 would be beyond yield structurally at a.58 g and that the racks and stenge containers in all of.
the laba mentioned above could be everturned during ground motions of.58 g.
Unfortunstsly, Z 's structural enelysis only described the damage at.58 g (becsuse that was C's maximum predicted value for a Calaveras earthquake) but I did not indicate at what Icwer g value such damage would begin to occur. Based en the original seismic designs for Building 102, we can assume that damage would begin to cccur when an earthquake caused ground motions to exceed 0.19 g.
Secause the CTR shutdown order of October 24, 1977, was based en a NRC Staff estimate of.75 g at the CTR from an earthquake en the Calaveres fault, C's censul-tant submitted an anlysis of what camage he wculd expect to the Building 102 lacs if they experienced a.75 g.
He concluded that a.75 g would cause tne Advanced Fuels e
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Page Seven if they experienced a.75 g.
He concluded that a.75 g would cause the Advanced fuels Lab (AFL) in the basement to experience 86% of its yield.
He had said that the AFL was at 66% of its yield from a.58 g.
Thus, he calculated a 20% increase in yield for a.17 g increase in ground acceleration. Applying CE 's structural consul-tant's analysis proportionally to the new estimated g value from the NRC Staf f s PSER-GETR, a 1.0 g is an increase over.75 g of.25 g.
Thus a 1.0 g could cause the AFL to go beyond yield (116 %), and nimilarly the plutonium storage vault in Building 105 could go to 111% of its yield. See the attached table for more detail on this.
Thus, based on CE's consultant analysis, a 1.0 g could cause structural destruction of Guildin95102,102 A, and 105. This would exoose large amounts of plutenium.
If the ground motion is 1.0 g or "in excess of 1.0 g (NRC-PSER-CETR), we can assume that all plutonium glove boxes and their filters in the AFL would be damaged and that even sealed containers of plutonium would be damaged, releasing the contents of the boxes and centainers into the post-earthquake environment.
In the GETR Show Cause Proceedings, CE's structural consultants (EDAC) and the NRC have admitted that the Verona fault could cause surface ruptures, ground shearing, and vertical or late ral offsets directly beneath the CETR reactor. Since the Verone fault is a thrust fault, it can have a surface rupture zone of up to s half mile wide, because thrust faults angle diagonally to the surface from deep beneath the surface. The plutonium labs are less than a half mile from the CETR.
I Now that another " apparent thrust fault" has been disecvered near the pluto-nium labs (NRC trench report of October 27, 1978),
is is necessary for the NRC and CE to analyze the potential structural damage to the labs from surfaco rupture, ground i
I shearing, and lateral or vertical offset directly beneath the labs. This type of analysis has not been done.
If these types of ground motions can take place benetth the labs, they could be simultaneous with and in addition to the g values previously described, and the structural damage previously analyzed would be greatly increased.
I i
9
.Paga Eight Structural engineers in California generally recognize that it is almost impossible to meka a structure " earthquake proof" if it is within a zone of possible surface rupture and of fset or shearing. For example, the follcwing quotes are from a back titled " Peace of mind in Earthquake Cou'ntry" by Peter Yanov (who is employeo by URS/91ume Associates whc wrote the ACC Seismic Design Criteria). Yanev states:
[
"Sulldings located in fault zones are exposed to the highest possible earthquake risk. This is unsouivocally a fact of life in earthquake country, and no measures--whether the most eertnquake-resistant bracing and building materials nor the latest and soundest principles of reinforcement--can guarantee or even tantatively pe= pose that any property astride a fault would survive a moderate quake without severe or total damage...
The greatest hazard to structures in fault zones is that they are subject to ground-surface ruptures and displacements during an earthquake, and no building can withstand this faulting beneath it.
A grcund shift of enly a few inches (vertically, horizentally, or, most ecmmenly, both) is sufficient to cause severe structural damage to buildings. A large quake, with its typical displacements in the fault zene of frem several inches to several feet, cculd demolish the mcst well-engineered building." (page 49) c' Yanev's employer (Blume and Associates) develcped the AEC's Seismic Design Criteria for Nuclear Reactors in 1973. Unfortunately, the AEC, in the 1950's did not have any seismic criteria for the structural design of pl..tinium labs.
Because the plutenium labs at Vallecitos were designed and constructed in 1956, when the maximum expected ground actions were 0.19, the structure of Suild-9 ing 102 is inadequately designed. Because current NRC documents indicate that.the labs at VNC could experience in excess of 1.0 g end because this ground motion could be simultaneous with surface rupture, the VNC labs are endangering the public health and safety.
Therefore, all operations at the Vallecites plutonium labs shculd be suspended immediately by the NRC.
The Calaveras fault and its branches, including the erl echelen series of patsliel thrust faults at the Vallecitos site, cculd experience a severe earth-quake at any time.
Insurance ccmpanies still refer to uncredictable and uncen-trollable earthquakes as " acts of Ccd".
Unfortunately, CC and the NRC do not have any insurancs policy with Cod to delay the cccurence cf any earthquake.
- Thus, Vallecitos is a disaster waiting to happen.
If the public and its reoresentative efficials wait until af ter the disaster, we will be faced with the problem of CE not having any insurance to help pay for damages to health and preperty.
page Nine Currently, the Vallecites Nuclear Center is a disaster waiting to happen.
If the public and its rupeesentative of ficials wait until af ter the disaster felicwing the next earthquake, we will be faced with the pr:blem of CC not having any insurance to help pay for damages to health and property.
Because the radicactive contaminatien wi.11 last for thousands of years, the emergency evacuations following the earthquake have to become permanent relocations for the former residents of nearby cities.
may d
Who will pay for the enormous disruptions in the entire Bay Area's econen.y?
The Naturs1 phenomena Review Team Cne of the reasons for the delay in NRC decisi:n-making :n Vallecitos is the schedule for publicatien of a report by the Natural phencmena Review Team.
This t4em is a group of c:nsultants hired by the NRC to study the earthquake hazards to the plutonium labs at Vallecitos. The fifteen censultants who the NRC has hired to be on the team haue obvious conflicts of interests that interfere in their Objectivity.
Two of the:' <me f t:m the same consulting firms that CE has hired in its attempts to demnplay the earthquake hazards to the CETR reactor at Vallecitos. Cne is a struc-tursl censultant from CDAC (Engineering Decisien Analyiis Co.).
EDAC has pr duced several structursi reports for CC's license renewal applications for VNC.
The other team member is a seismic consultant from TERA (Teknetrcn Energy Rescurces Analysts) which has prcduced seismic reports for CE on Vallecitos.
The ccnflict of interest is so obvious that the NRC should replace these consultants with other independent engineers and seismologists.
The current team of 15 includes 9 employees of nuclear weapons labs emerated by the same federal agency (DCE) that issues the centracts to CE for plutonium pro-jects in the labs at Vallecitos. 3 of these 9 censultants work at 3 labs that are directly connected by contracts to Vallecit:s.
This seems to indicate an inherent conflict of interest. perbacs the NRC's choice cf censultants helps to insure predetermined conclusiens in the review team's report.
m
~,,'page Ten The 4 remaining censultants (of the team of 15) are structural analysts frem Texas and Illinois.
2 cf them, N. M. Newmark and W.J. Hall, have been used by the NRC to review seismic hazarcs to almost every nuclear reactor site in the nation, and as far as we know, they have never said that any site was too dangerous to have an operating reactor.
Why did the NRC not choose any independent structural engineers to analyze the plutonium labs at Vallecitos? California has thousands of qualified engineers who are experienced in earthquake analyses for structures near active fault :cnes.
These West Coast engineers are more familiar with the specific seismic hazards and fault characteristics common t3 the San francisco Say Area. Why did the NRC chocse to pay certain persons from Texas and Illinois to analyze earthquake ha:ards to nuclear facilities in California?
History of the Plutonium Labs License for VNC Projects involving plutonium began in 3 labs in Building 102 in 1957,1960, and 1962. But it was not until 1966 that CC received the Special Nuclear raterials License (5NM-960) which alleas large quantities of plutonium en the site. During the 20 years f rom 1946 to 1966, CE was the sole operator of the plutenium precucticn reactors and labs et the Hanford nuclear weapcns facility in eastern Washingten.
During those 20 years, CC lest or mufed (material Unacccunted for-muf) ever 2000 pouads of plutenium.
Then, in 1966, CC moved its plutonium fuels research and develcoment pregrams frem Hanford to Vallecitos, less than 20 miles frem San Jose.
CE's License SNM-960 was a five year license that expired in 1971 and was nveer renewed by the AEC or the NRC.
Instead of being renewed, the license was extended temocrarily from its expiration en August 31, 1971, to February 24, 1972, to July 31, 1973, and then indefinitely until new.
Apparently these extensiens were granted because of the formulation of plans for the Natural Phencrena Review 7eam, which scmehow was celayed for several years.
1$.
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