ML19338D360

Ucla Reactor Is Safe Exhibit B.Fifteen of 22 Pages

ML19338D360
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Issue date:	01/03/1980
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4Bi THE UCLA REACTOR IS SAFE A report titled, "The UCLA Nuclear Reactor -- Is It Safe?"

has been transmitted to Joseph M. Hendrie, Chairman, U.S. Nuclear Regulatory Commission. The report, prepared by a group called the " Committee to Bridge the" Gap," and the transmittal letter, are both dated October 3, 19}9.

The following abbreviations will be used in responding to the claims and allegations of the subject report:

The University of California, Los Angeles (UCLA)

The School of Engineering and Applied Sciences (SEAS)

The Nuclear ~ Energy Laboratory (NEL)

The UCLA Office 'of Environmental Health and Safety (EH6S)

The U.S. Nuclear Regulatory Commission (NRC)

The Committee to Bridge the Gap (CBG)

The UCLA nuclear reactor is operated by the NEL staff, and that staff, via a Director, is responsible to the Dean of the SEAS. The Dean, in turn, is responsible to tne Chancellor of UCLA. The licensee is the Board of Regents of the University of California acting at UCLA through the Chancellor. The Chancellor has delegated the responsibility for license admini-stration to Vice Chancellor James W. Hobson, and the UCLA-EH&S is responsible to Vice Chancellor Hobson for radiological safety concerns at, and attendant to, the nuclear reactor. This is implemented by the assignment of a Resident Health Physicist to the NEL.

The material submitted herewith has,been prepared by the Staff.of the Nuclear Energy Laboratory.

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f k,J 3 \ , 'f It is.the op' inion of the staff, that the~CBC claims and

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allegations a r e w i t ho d.t. technical substance. The CBC report

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];[~ . is v,ieved as primarily political and therefore not answerable in f.' & she technical'ip;a $ lance of scientific communication. Part I of 3 a!,. .,?

this asp,ect of . the .CBC report.

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, The CBG;does 16dicate opinions concerning two technical i - ..

studies-that have been conductid'at UCLA to measure concentrations <

L and radiationElevels attendanY to operation of the UCLA nuclear reactor. These studies, the thesis of Mark Phillip Rubin and the program of t h e rm o l, u. m, i n e s c e n t dosimetry (TLD), provide the bases of r e'c e n t NEL satements t of concentrations and radiation levels to which the general public is exposed as'a result of argon-41 releases. ,

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Bo th 's cud'ie s Post dat e the application and approval of Amendment 10 Qt0 to'the.UCLA facility license.

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5s -Ne i t h e r the work of Mark Phillip Rubin nor his conclusions have been officially commun'icated by the NEL to the NRC.

, The TLD work ~was summarized in the NEL annual report of 1978, 4

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i b'u t the accuracy question was addressed-only indirectly in relation ,

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to th6 background bias introduced by concrete. Part II, herein,

, is_a summary.of the' import of Rubin's work and also discusses the Accuracy _of TLD measurements.

As a reruit of several telephone convahsations with.the Nuclear '

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Regulatory' ;Commission, Division of Operating Reactors, UCLA has l

1 been asked to creat the roof area immediately surrounding the stack l as a restricted area. UCLA has implemented this request with I

reservatihns described in Part III of this response. j

.=,v 1 In wh'at fellows, the unnumbered pages of the CBC report will

.be identified as:S-1, 2,... 7 for the summary and T-1, 2, etc. for j

• the text that a begiss'with " Chronology of Events Regarding Argon-41 _

~ Emi s s ions ' f rom : r$,e( UCLA L rea c t o r . " The numbered pages of the CBC

._ . . , 3 v-text; start 1with 3'and that p a g e- -is here numbered T-3.

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• Part I: Factual Distortions and Allegations Made by the CBC The distortions of fact that can be identified within the CBC report include: (1) perversions of an author's intent by out-of-context quotations; (2) erroneous inversions of histori-cal sequence: and (3) the use of improper words and innuendo to

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' falsely color a situation or impute to individuals attitudes that are impossible to document.

The clearest example of out-of-context quotation is illu-strated'on page S-2 of the CBG report:

" Rubin concludes: -

'The highest exposures to the public were discovered to be within the Math Science building. This o ccu rs because a m'ain ventilator intake.for the building was found to be directly in the path of the reactor's exhaust plume.'"

The continuation, omitted by the CBC is':

"However, while this concentration was the highest found in the study, it was~ still only 11.8% of the allowable federal limit. These results seem to indicate that there is no-danger to the public from current reactor Argon releases provided that the legal limits do not yield a danger to the public."

l Thus, the' reassuring-conclusion of Rubin is entirely lost-  ;

l to the. reader;of the CBG r e p o r t'. The variety of quotations on  :

i page S-4,are, in-fact, selections that completely misrepresent  !

the import of the Rubin thesis.

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Following the excerpted' Rubin conclusion on page S-2, the I CBC continues with a, paragraph ~that is' false in almost all aspects. In entirety, it' reads: j "Nonetheless ,the NRC did'not even consider the inside of the Math Science building:in granting UCLA an exemption from  ;

normal 1 restrictions on Argon-'41 releases. In.part, .thi was

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because they had never seen Rub'in's thesis. When informed of the ventilation duct / Math Science problem and the-Rubin study,.the NRC. radiation inspector for UCLA, R.D. Thomas, admitted he knew of neither. He also expressed surprise to learn that the roof area was not restricted to the public (there are 7 open doors and 2 elevators operating on the reactor complex roof)."

7,t should not be hard to imagine the reaction of an occupant of the Math Science Building to this news. The facts are:

(1) The rooftop and ' interior occupan ts of the Math Science building were considered in detail in the Amendment application (letter of Kastenberg to Goller, November 5, 1975). (See copy attached.)

(2) The NRC had not seen Rubin's thesis because the l Rubin work did not commence until months after'the amendment had been app roved.

(3) Obviously knowledge of the ventilation duct existed at NRC Region V (the inspection report of F.A.

Wenslawski 50-142/75-01). An amendment action is conducted through the NRC licensing group in f Washington, D.C. Not all field inspectors are necessarily informed of the action. Tt e Rubin report has never been filed with the NRC.

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~(4) UCLA-NEL has never claimed that the roof areas were restricted. Any such claim _would have been totally unenforceable, and patently' ridiculous.

The same paragraph uses the words " exemption" implying

[ special' privilege and " normal"' implying the non-existence of

$' 10.' CFR'. 2 0.10 6 (b ) . This point will not be_ pursued further, but

~ note _thatSit is a repetitious. theme,. appearing in one way or -p y_

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e, o' innuendo can be found in the CBC report.

J.. More subtle forms

.On page.I-6:"However, the inspector called his superiors'and

! ;was told to permit averaging." There is nothing'in the inspection report (50-142/75-01) that-warrants the peculiar-verbiage of the CBC. The matter-is entirely in the Code of Federal Regulations, and an inspector'is not " told" to permit something that is improper.

Page T-14 attributes attitudiis to NRC inspector J.B. Baird which-the.CBG cannot-possibly document, yet which tend to discredit the very investigation they had requested.

In' closing this criticism of the CBC report, note is made of the journalistic style of-the CBG main text that juxtaposes fact 1

with colorful and fanciful interpretative commentary. In brief,  :

the staff of the NEL believes that this kind of journalis'm unduly'

. frightens people and compromises the intellectual integrity of j its creators.

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Part II: ' Experimental Determination of Plume Dispersion and Radiation Levels Attendant to Argon-41 Releases by the UCLA Nuclear' Reactor Facility The investigations to be described here, were initiated to assess actual concentrations _and radiation levels as opposed to those modelled in the application for Amendment 10 to the UCLA reactor facility license. The two studies are quite independent but are complementary and address the same essential question:

What is the radiation exposure of rooftop and interior occupants of the kathematical Sciences building? The two investigations and the conclusions are~ described in the following paragraphs.

II.A. Plume Dispersion Experiments This work was performed by a graduate student, Mark Phillip Rubin, under the direction of Prof esso r W.E. Kastenberg of the UCLA' School of Engineering and Applied Science. Releasing a non-radioactive tracer gas, sulfur hexaflouride, to the reactor room ventilation system exhaust, he measured concentrations at the stack release point and at a variety of downwind locations.

From these measurements he deduced the dilution factor for the various downwind locations.

The experiments were repeated on three different days during the summer of 1976: June 22, July 8, and July 27. All tests were performed in-the afternoon, during which time the typical southwest prevailing wind was blowing.

In ea,ch-test, the ' sulfur hexaflouride was continuously admitted to the reactor ventilation s y s ,t e m at the base of the stack and was. sampled at-half-hour intervals at the stack exit and at selected? downwind locations.. The plume dispersion (or dilution) factor is defined as the ratio of downwind concentration

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,- .to stack concentration. It is ~ a number less than' unity and will' generally become.sma'11er and smaller as the distance from the stack increases.

9 For the purpose here, the discussion ~1: limited to the dispersion factorfat locations denoted by Rubin as.D, E, F, and G. Locations D' E, and F are along the south parapet of the Math Sciences Building, overlooking, the stack.and at directions 1.. (respectisely)_ NNE, NE, and ENE from the stack. Location G is at the intake of the principal ventilation system for the west wing'of the Mathematical Scionaes building.

In order to qualitatively observe the behavior of the plume, smoke-producing flares were ignited on the grid at the stack top. Under. prevailing wind conditions these visual observations of the smoke trail can be summarized by 3 statenents.

1. To an observer at the parapet, the visual trail passes well overhead in an are toward the northeast.  ;

2.. Localized turbulence'is evident by separation of discrete puffs and rapid dissipation of plume intensity.

3. The plume center line (as estimated by. smoke density) is n.ot visible for more than 150 feet or so f rom :the ,

stack. The distance estimate is only approximate, the

, plu'me.is.quite.high and estimates will vary depending  ;

upon the viewers. perspective.

Note that the tracer gas-samples at the parapet were taken at a h eigh t - g re a t e r than the parap~et, and those at the ventilator

. intake were taken'near its mid-height on the windward side. Based on(the' visual ~ observations of the plume,: it is clear that all

samples -were obtained'ac~ elevations well below the plume center

.line.

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The concentrations measured at the stack top'were remarkably consistent from sample to sample although appreciable variations in sa'mple-to-sample concentration-at a given downwind. location were observed. Wind variations in direction and speed, as well as the turbulence witnessed by smoke flare tests, provide a sufficient. explanation for the downwind concentration variations.

sever,.if the six concentrations measured at each downwind

- location are averaged, conside~rable consistency emerges. These

" daily" averages are shown in Table A in the form of the " daily" average dilution factor. (" Daily" refers to the afternoon hours of the test period.)

TABLE A Dilution Factor versus Date and Location Location (Rubin) D E F G (Air

. Direction from Stack NNE NE ENE NNE Intake 6.99 x 10 -3 3.42 x 10' 3.15 x 10 ~3 Da'te 6/22/76 2.33 x 10

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4.15 x 10 ~3 -3 4.90 x 10 -3 7/ 8/76 4.93 x 10 7/22/76 ---

4.01 x 10 -3 3.43 x 10 -3 3.30 x 10 -3 5 Average daily dilution

-3 factor 2.33 x 10 5.05 x 10 -3 3.93 x 10

-3 3.78 x 10 -3 1.68 x 10 -3 0.97 x 10 -3

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e (3 samples) 0.87 x 10

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Ar-41 concentration ~

6.06 x 10 4.72 x 10 4.54 x 10 (relative to 1.2 x 10 pCi/ml at stack). #

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. Given the fact that the reactor operates less than 20% of.the -l daylight hours', the f o llowin g' 's t a t emen t can be made: The measure-ments indicate that the annual average' Argon-41 concentration on theiroof of the Mathematical Sciences building, during the 45. hour 1 work week, is:below MPC even if it is assumed that the prevailing' I wind exists:100% of chectime and occupancy is also 100%. This statement remains true.even if Argon-41 concentrations are conser-Lvatively estimated.as "mean value plus 3 standard deviations."

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-Argon-41. concentration at the rooftop level is not as intrinsically important as the radiation levels in that area.

The radiation depends upon the average annual plume geometry, a geometry that is neither defined nor definable by.the Rubin work. The radiation levels have been measured by TLD's and we shall discuss those results presently.

Radiation levels due to Argon-41 have never been measured within the Mathematical Sciences building. They can be inferred, howevel, from estimates of the Argon-41 concentration within the building.

1 The following calculation assumes that the plume dilution factor at the ventilation intake (Location G of Table A) is the mean value plus 1 standard deviation, or approximately 5x 10' .

There is no specific information describing the effect of wind direction upon that particular dilution factor. However, for simplicity (and conservatism), assume that the wind always blows from the ~ reactor stack toward the air intake. The reactor utilization factor is less than 20% of the 45 hour5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br />. work week; we shall take 20% for simplicity. Accordingly, the estimated

• average annual concentrations (during the 45 hour5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> work week) at the Mathematical Sciences ventilator intake is:

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(1.2 x 10-5) (5 x 10-3) (1.00) (.2)

= 1.2 x 10 Ci/mi The reactor does not operate during the remaining 123 hours0.00142 days <br />0.0342 hours <br />2.03373e-4 weeks <br />4.68015e-5 months <br /> of the week (168-45)., consequently the exposure is zero during that time. -Therefore, the true average weekly value as well as the annual average' concentration is unlikely to exceed:

-8 -9 pCi/mi

.1.2.x 10 x (45/168) : 3.2 x 10

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'This conservatively estimated concentration is 8% of the MPC.- The--November 5, 1975. supplement co UCLA's application for AmendmentL10 1 considers the interior geometry and occupancy of-

.the_Mathematica1' Sciences. vest wing. addition.- The calculated i u

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. personnel _ exposure, assuming a concentration equal to the MPC, is'2.40 person-rem per year over an estima'ted population of 454 individuals. This leads to an average expcsure per individual of about 5.3-mr/ year at an Argon-41 concen t ra tion equal to the

.MPC. _The exposure ~is ob'viously proportional to the Argon-41 concentration, and ifnas indicated above, the actual concentra-tion is-less~than-8%'of MPC...then the exposure per individual is less than 0.5 mr/ year.

The staff of~NEL and the UCLA Environmental Health and Safety-Office believe that 0.5 mr/ year is far down in the noise level of the general background and that it will never be me a s u r..b le or distingui.shable from,that background. In fact, natural background probably varies by at least + 0.5 mr/ year due to variations in

, sunspot activity.

-. The CBG criticizes the Rubin work on 2 counts: (1) the variability 4 of thaf datai and (2) failure to prove that the behavior of sulfur hexaflouride is identical to that of Argon-41. It is a'funda-mental fact that micrometeorological data always contairs statistical fluctuations under turbulent conditions, and that variability is to be. expected. However, since the data set contains 18 points per location, distributed over 3 days:under prevailing wind condi-tions, it is considered to be a statistically significant sample.

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The behavior.of unlike_ molecules, under otherwise identical l conditions, has been treated in a number of contexts. For pur-

. poses of this study we are concerned about the behavior of tracer gas molec'ules.(S'F r Argon-41) existing in a carrier gas (air) 6

.at concentrations'of affew parts per million,:and subjected to tu rb ul e n t, mix'in g . Under these conditions it is a generally accepted fact that ~ the molecular' weight or size has no effect on the behavior"of the tracer gas.

In-other words, at very low concentrations the' tracer gas-molecules behave-like the' air mole-

, culesLaround them~regardless of their molecular. weight.

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1 II.B. The Program of Thermo-Luminescent Dosimetry (TLD)

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The results of this program were reported in the NEL Annual Report of 1978. The program was initiated in March, 1976 and continued for 8 quarters (into March, 1978). Dosimeters were provided, read, and reported by the Radiation Detection Company (RDC)'of Sunnyvale, CalifornTa. The program was' funded through the NEL budget, .but was supervised by the Resident Health Physicist (EH&S).

In the first 9 months (3 quarters) of the program, environ-mentally packaged dosimeters were placed at 20 locations at varying distances from the reactor stack. These were changed quarterly, and RDC provided quarterly reports. One dosimeter location, initially chosen on the parapet 19 feet (horizontal measure) from the reactor stack, was changed to the reactor stack at the end of the third quarter. The reported net readings (mr) were based upon background observations at Sunnyvale.

The same program continued for the following 15 months  !

(5 quarters) with the addition of 2 dosimeter locations; 1 in I

Culver City and 1 within an NEL office. It was agreed that l

background was to be taken as the lower of the Sunnyvale versus Culver City backgrounds. This selection rule, introduced by .

concerns over the effect of geomagnetic latitude and local devia- I tions, did'not materially perturb the sequence; the RDC background-remained less than.the Culver City background in 4 of the 5 appli-cable quarters. It.can also be shown that the RDC background and I

the averige gross readings from the dosimeters on the roof of

. .Pauley Pavilion did not differ by more than 0.76 mr/ quarter. )

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The Committee to Bridge the Cap has questioned the reputation of TID's in general and-Ca(Dy)SO 4.TLD's in particular (CBC T-12)..

The basis of the criticism is.not cicar, but the vendor-has stated l that'when several TLD's are exposed together and the readings

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, averaged, the standard deviation in the average reading is less than 2 mr if the gross reading is less than 40 mr. If the gross reading is greater than 40 mr, the standard deviation is 5% of the gross reading.

The NEL has investigated this claim using the results of the 164 pairs of dosimeters t h a t- w e r e exposed in the 2 year TLD pro-gram at UCLA. If the standard deviation of a single dosimeter is denoted a, then the standard deviation of the difference between two identically exposed dosimeters is e /27 For the 164 dosimeters used at UCLA and reported by RDC, the standard devia-tien for the difference between two members of.a pair can be computed to be 3.27 mr. Thus e= 2.31 mr for a single dos 1 meter.

If the average value of 2 dosimeters is reported, the standard deviations in the average value will be e/.[2 = 1.64 mr. This is better than the accuracy claimed by the vendor.

The net inc remen tal rad iat ion 1evel at a location is defined as the dosimeter reading at that location corrected by subtracting a background reading. For a pair located at location X and a remote pair measuring background, the standard deviation in the incremental difference is 2 /2' = 2.8 mr (we use the RDC statement of 2 mr for each pair). If t h is is done 8 consecutive times (for 8 quarters), and the results averaged, the standard deviation

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in that average will be 2.8//8 = 1 mr. This result means that for 8 quarters of quarterly observations at a specific dosimeter location, the expected intrinsic error is on the order of 1/125 of the maximum permissib1'e exposure to the general public. The intrinsic accuracy is more than adequate.

The r'e s ul t s of the TLD dosimetry program indicate that the

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radiation levels on the rooftops around the reactor stack are:

(1) all less than 50 mr/ year, even assuming 100% occupancy and including radiation exposure contributed by concrete structures;

. and (2) the measured radiation dose at the air intake to the Math Sc i e n c e s-Eu+141 n g is approximately 20 mr/ year. The latter number EXHIBIT " b "

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~*- . is'significant1because'it can be compared to.an annual dose calculated on.the basis of'the Argon-41 concentration measurc-ments discussed in the first part of this report.

Using the calculated concentration value of Argon-41 at the Math-Sciences air intake (8%-MPC), multiplying by actual reactor operating time (approximately 50% of allowable), and subtracting dose due to betas, predicts an annual dose of 16 mr (gamma only)-

at the air intake. This. number is derived independently of any TLD measurements and agrees quite well with the TLD measurement of 20 mr/ year. This close agreement between two independent types of measurements lends considerable confidence to the data.

Finally, summarizing the results of these studies:

(a) Argon-41 concentrations on the roof of the Mathematical j Sciences building is below MPC even if occupancy is 100%,

and if the prevailing wind is realized 100% of the time.

(b) Radiation: lev,els within the Math Sciences building due Argon-41' concentrations are not more chan 0.5 me per' year.

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(c) Radiation levels on the Math Sciences and adjacent r o'o f structures that are due to Argon-41 and concrete are not j more than 50 mr per' year at 100%~ occupancy.

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, Part III: Immediate Actions As a result of'several' conversations with NRC Licensing staff, it appears that-a misunderstanding existed between UCLA-and the NRC in regard to roof area occupancy.as' discussed in the 1975 application for Amendment 10. In particular, UCLA treated the area surrounding the stack as an area of ilmited access-accessible under reasonable circumstances'only by maintenance p.ersonnel, and estimated the occupancy factor from maintanence records.

The NRC staff review of the application concluded that the a r e'a in question-was'a " restricted" area, however, UCLA had neither invoked that word nor so posted the area. However,

, because the amendment approval contained the NRC staff assump-tion, the NRC has asked UCLA to treat that area as a restricted area. UCLA has complied by posting " Restricted Area" signs and by re-keying the single access de . to the NEL off-master system.

The NRC also suggested that UCLA further amend the R-71 license, Technical Specifications, to include a stipulation that the stack area be denoted a " Restricted ~ Area." UCLA stated that their license is due for renewal and-that the question would be entertained during the preparation of the renewal application.

Pending the' resolution of that matter, UCLA would continue to treat the area as a restricted area, posted and controlled to a degree commensurate with the po:ential exposure risk involved , ,

upon entry of that area.

The' longer term reservations concerning the treatment of

.the stack area.are several f old.-

l. The TLD. data _ indicate that the area is safe, even at 100%-occupancy (less aan 50 mrem / year).

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(2) Approval of an Argon-41 holdup system will be sought within the context of the license renewal application.

Concurrently, and conditionally, an increase in reactor operating hours per year will be sought.

(3) The stack area contains air conditioning equipment unrelated to NEL activities. Twenty-four hour emergency access is required for maintenance personnel.

Provision for that access has necessarily broadened the distribution of the off-master NEL key system (C-level).

These matters are to be' addressed in the license renewal application, and are mentioned here only to show that the NEL is not acting in an arbitrary or capricious manner in regard to the interim and long-term treatment of this area.

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M'Uv!vERSITY OF CALIFORNIA, LOS ANGELES

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• DAY 33

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$Cllr Ot. Of* I:NCINrr.PINC AND A rrp.n n SCtrNCE .

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November 5, 1975- l l

Mr. Karl R. Goller

• Assistant Director of Operating .Reat tors

, Directorate of Licensing .

U.S. Nuclear Regulatory Coanission e Washington, D.C. 90545 Docket No. 50-142 4

Dear 14r. Goller:

~fhis is in response to questions raised by f4r. David Jaffcc and Mr.

Block of the, Nuclear Regulatory Cot.cnission during a tcIcphouc convcrsation with Nessors C. Ashbaugh and J. Hornor of the UCLA Nuc1 car Energy Laboratory.

. Ne underst2.nd that this conversation of Septen,her 22, 1975, invol.ed the following four icquests and/or questions:

1. That UCLA and- the Nuclear Energy Laboratory be committed to a two year environmental thermoluminescent dosimetry (TLD) program, observing a minimum' of 6 cc,mpass points sampled in various down wind directions from the stack. '

2. Describe ventilation and air conditioning intakes in relation to stack releases, and describe possible argon-41 concentrations I in these intake systems.

3. With respect to Item 2 of our August 26, 1975 response: What are the radiation exposures to personnel within the metecrological laboratory? Do not ignore immersion.

4. Jiscuss the ALAP question,10 CFR 20.106(b) an,d (c), in terms of possible reduction methods. -

items. Please advise us Pro DUPLICATE DOCUMENT Entire document previously I' g 'f-entered into system under: /

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E. Kastenberg, ActinrDLd:c.

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