ML20006F420
| ML20006F420 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 02/18/1990 |
| From: | Plotkin S SOUTHERN CALIFORNIA FEDERATION OF SCIENTISTS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#190-9921 89-594-01-ML, 89-594-1-ML, ML, NUDOCS 9002280010 | |
| Download: ML20006F420 (28) | |
Text
f February 18, 1990 L'OLKETED USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD E FEB 20 P2 :40 U.S. NUCLEAR REGULATORY COMMISSION grtCE DT SECRETARY 9
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5 In the Matter of
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Docket No. 70 M L ROCXWELL INTERNATIONAL
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CORPORATION
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ASLBP No. 89-594-01-ML Rocketdyne Division
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License No. SNM-21
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Direct case for the Southern California Federation of Scientists in opposing the license renewal application of Rockwell International to continue operating t.
the Hot Cells and Hot Laboratory at the Santa Susana Field Laboratory, SSFL.
Introduction This report is based upon the original concerns itemized in the intervener petition of November 25, 1989.
All SCFS Concerns relate to violations of 10 CFR 70.23(a) (1),(2),(3),(4),(6),(9),(10), and (11) and 10 CFR 70.23(b).
Relief sought by SCFS is denial of the Rockwell License Renewal, License No, i
R SNM-21 in all cases except where specifically stated otherwise. With these statements that address instructions to specify the relevant licensing standards and the relief sought, it was thought too burdensome on the reader to have the same phrases repeated over and over for each concern.
In view of our not possessing legal training, we presume this overall statement of the applicant's legal deficiencies are being handled properly and will be acceptable for establishing grounds for consideration of our concerns as stated below. We call attention specifically to the leeway provided the Commission in the referenced section in order "to carry out the purposes of the Act".
One direct and obvious reason for denying the license is te disingenuous nature of Rockwell's application.
R.T. Lancet, in his letter of November 2,1989 i
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to Leland C. Rouse whith modifies the original license application, states that the license period is reduced to,0ctober 30, 1990 and.that only decontamination and decommissioning of Rockwell licensed facilities will be engaged in subsequent i-to that date. in the Rockwell-Intervener private negotiations, which included L
Mr. Lancet, we requested that they commit Rockwell to a legally binding posi-
'A tion as stated.in the referenced letter.
This they declined to.do and instead responded that they hoped for a revival of nuclear power activity which would involve themselves.
Thus this modified license application may well be a p
facade to buy them time for obtaining a full ten-year license and perhaps never decontaminate and decommission the facility.
If this subterfuge were not the real purpose of the current license application, then Rockwell management should be pleased to commit themselves to doing exactly what they stated was their intention in their letter to Mr. Rouse.
Rockwell is " playing games" with both the WRC and the general public, b -
In so far as possible, the numbering of our concerns as noted by Judge Bloch in his MEMORANDUM AND ORDER of December 7,1989 will be followed,- noting that this designation scheme differs from the original petition.
-The redundant examples and rationale in what follows has been written that way.. deliberately.
The effort was made to respond to each and every concern expressed in our intervener petition, dated November 25,1989, in such a way as to make that material self sufficient, if the direct case presentation for one concern is ruled out, no other concern would be dependent upon the ruled out material, it is noted that' additional or varied examples could have been used which would make the reading more interesting. _ However, the issues involved and the information we are trying to convey remain unchanged.
It
-is probably not necessary to point out that all our work is done outside of
. orking hours by' people who are donating their services; thus the time w
2
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.i required' to thoroughly review all material that would have been had we possessed the funding to pay salaries is simply not available.
Abbre'iations used in the text are as follows:-
v Southern California Federation of Scientists SCFS
=
Santa Susana Field Laboratory SSFL
=
decontamination and deconmission E
D&D
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l Pu Plutonium
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Uranium U
a E'
Specific Concerns i
k
'1.
Specifying release of only a small part of the 6 gms of Pu in the event L
of a-worst-case. accident while ignoring the 394 gms of SNM that is admittedly contaminating the Hot Lab requires explanation.
That issue is separate from the unrealistic worst-case scenario. This small release requires perfect o
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filter operation for half the ventilation system and discounts an accident that releases-not only Pu but also damages the entire ventilation system, a rather obvious possibility.
Appendices A and B provide further discussion, r
2.
Rockwell's_ refusal to agree to a one year--limit on its license renewal-
-implies an-intent to reapply, e.g. in September,1990. The entire process appears to be. devious and disingenuous. This comment also applies to-other sections of this document.
L 3.
Since submitting our list of concerns, there have been private negotiations
- between Rockwell management and us interveners.
Rockwell explained the nature of the TRUMP-S project.
Rockwell will use metallic Pu to represent the transuranics that are contained in high-level nuclear _ waste. The TRUMP experiment is intended to determine if such transuranics might be made econo-mically to electroplate out of a molten salt solution.
Since Pu is used as a simulating material in place of all the transuranics contained in 3
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i 238 spend nuclear fuel, why in the world don't they simply use U exclusively j
h which is not hazardous and requires neither Hot Lab nor license.
This entire licensing application appears even less forthright than we originally
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- thought, In fact, TRUMP-S is a basically flawed project.
R.T. Lancet says in his December 22, 1989 consnunication to Glen L. Sjoblon of the NRC that "... the f
r TRUMP-S program is to develop... data on various actinide material so that
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I processes can be developed to separate long-lived radioactive isotopes from j
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spent nuclear fuel. TRUMP will use metallic Pu and U, whereas spent nuclear fuel generally contain these metals in oxide form. Furthermore, these oxides L
t do not electroplate. Thus the spent nuclear fuel would have to be processed j
chemically or otherwise to obtain metallic Pu, etc. in order to use a TRUMP process.
But at that point the Pu, V, etc would already be separated and any l
r need for the TRUMP process would be unnecessary, j
In other words, in order to electroplate the_ Pu and V out from the spent i
i nuclear fuel, the Pu and U have to be separated from their oxides.
Once this l
l 1s accomplished in practice, there is then no need for the TRUMP-type separation because the Pu and V are already separated.
Reference-is made to Appendices l
A,B, and - C for additional clarification of our concerns.
4.
(Concerns about Rockwell even planning to decontaminate and decommission
=the Hot Lab were denied.)
5.
(Transportation both into and out-of the Hot Lab.
Rockwell has had a
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number of transportation accidents involving the facility.)
Obviously automotive transport cannot be guaranteed safe from accident.
t Rockwell cannot guarantee there will never be an accidental release of hazardous materials in the Simi Valley resulting from some sort of transport 4
e vehicle collision or malfunction.
Accident statistics reveal that even the safest of transport conditions contains some level of risk.
The particular
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level involved depends upon a multitude of physical and human factors which will not be dwelled upon here, i
The 1989 Pennsylvania Rockwell truck accident is a good example of what t
can happen. The cause in that case was negligence. Only the most stringent of training programs can even minimize the occurrence of ^ such accidents.
In view of Rockwell not presenting any plans for enhanced training'and
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traffic control, the transport of dangerous material-into and out-of S$FL is a
" flawed" operation.
This, of course, bodes ill even more so when one considers The Rockwell Record.
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L 6.
(Inadequate measurement of radioactive materials in case of accident, Past accidents at the site have involved radiation monitors going off scale, or releases of materials for which appropriate monitors were not in place. SCFS l
No.4 - -Instrument calibration errors resulting:in-lower amounts of contamin-ates being indicated than that actually occurring. This is a common error in our experience.)
l On August 11, 1989, the California State Department of Health Services cited Rockwell with 13 violations after a three day investigation. Specifically-I of note.here is Count 13 of the violation list:
"The facility failed to submit a written report to the Department-and EPA within 15 days after determining that there had been a-
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release of radioactive waste at the sodium storage area (T209)."
An obvious-conclusion to be drawn from these rather recent revelations is I
that Rockwell-has a propensity for not releasing information regarding what they are doing or what has happened at the SSFL.
Of course, our most serious t
concern at this point is that Rockwell has both not reported and may have 5
y destroyed the records from a large number of.truly serious radioactive acci-dents. This seems the only logical explanation to explain the extensive site contamination.
7.
(Release of radioactive materials during accidents due to faulty equipment or operator error.
Such releases can be from airborne particulates or gases, liquid outflow, or solid waste disposal. Past accidents have resulted in such releases at the site.)
It is obvious at this stage of the proceedings that we lack sufficient access to SSFL accident records as well as satisfactory rationale to explain the extensive contamination for substantiation of th~;g particular concern. We need additional information and have some question regarding Rockwell's having performed thoir job well enough in the past so as to even accumulate the necessary data.
Again the August 11, 1989 California Department of Health Services report of Rockweli SSFL violations comes to the fore.- Count No 13:
"The facility failed to submit a written report to the Department and EPA within the 15 days after determining that there had been a release of radioactive waste at the sodium storage area (T209)."
indicates one unreported radioactive release, which in view of the lack of oversight over the years is indicative of not only unrepor+.ed but unrec:roed additional accidents. Assuming the Rockwell would not deliberately release
-3_.
such materials, it has to be concluded that faulty equipment or operator error-have always been the cause or causes.
8.
(No throughput limitations are included.
While only a certain amount of Pu is to be permitted at any one time, no time period is specified.
It could be as small as an hour, which could result in very large throughput of Pu, and 6
I pot'ential for very-significant releases.over a yeari)-
While concern is rather obvious, it should be added that contaminating 1394 grams of:SNM may also be there a shorter period' of time than the "one year" licensing period.
Thus it looks possible for rather large amounts of hazardous material to be at the Hot Lab far in excess of the implied 6 grams Pu and 394-grams of contaminating materials.
i M
9.
(Inadequate training of personnel.
Past accidents and contamination incidents at Atomics. International over the years revealed inadequate training L
as a key contributor.)
Mention was made with regards transport accident concerns vis-a-vis training program inadequacies.
This basic inadequacy problem is actually far more encompassing.
Basic human factor analyses of workers on company projects reveal that management attitudes and concerns are reflected directly in worker performance.
Management concerns for accidents and health hazards engender similar concerns in respor#ve workers which in turn reflects itself in low accident rates as well as smaller hazards for those accidents that do occur.
The Rockwell Record, referred to above, is quite condemning of Rockwell management on this inadequate training concern of SCFS.
10.
(Revelation of Hot Lab projects and safety considerations thereof were not spelled out when the intervention petition was submitted.)
TRUMP-S is the only project being considered for this license of several months, so the "On Site Radiological Contingency Plan for Rockwell Interna-tional Operations Licensed Under Special Nuclear Material License No.SNM-21" report of December 22, 1989 is the relevant document.
Cursory review of that 3
document brings up a number of deficiencies.
Fires are supposed to be precluded because of a maintained argon rich atmosphere of <5% oxygen.
Thus, no water is available for fire extinguishing the report states, but then later mention is made of how the water used for 7
fire extinguishing will'be monitored for radioactive content.
In private, these~ interveners were assured by Rockwell officials.that-the TRUMP experiments would have no bearing on D&D of the other three Hot Cells and v
surrounding buildings and equipment. Hot Cell operation, however,-depends upon one central 73 foot stack, powered by a 23,500 cfm blower coupled with a 12,500 cfm blower for the four Hot Cells. There are cell door interlocks with these high volume blowers along with the inert gas and negative pressure operation.
Maintenance of Hot Cell safety integrity, i.e. (5% 02 and 4000 cfm airflow out when all doors are open, simultaneously with D&D appears-impossible.
Filters are changed " frequently"; however, there is no filter testing ~
spelled out to make certain the filters don't clog up during the D&D while TRUMP-S is operating.
A truly detailed review of the Rockwell contingency plan would undoubtedly reveal additional problems.
Basically, Rockwell operation has been considered separately from D&D activity when these two activities are essentially incompatible from a technical standpoint.
Additional discussion on this subject is contained in Appendices A and B.
11.
(Adverse effects on real estate not allowed as a concern here.)
12.
(Adequate safety in the source packaging prior to shipment to and from the Hot Lab is certainly a part of these licensing considerations.
This is a separate concern from the " normal" transportation problems involved with i-transportation accidents.)
A concomitant concern with Concern No. 5 aoove, the transport accident problem, is the actual packaging of the material. As we know from the Pennsyl-vania accident the package used in that instance lacked acceptable structural 8
n
. integrity for that'particular incident.
While we do not want to belabor the Pennsylvania' accident, its mention here is used by way of a known example. -It doesn't take much imagination to postulate possible onosite accidents involving n
material packaging problems.
The bottom line with reference to TRUMP is that no specifications for material packaging are given in the documents available.
13.
(Release of radioactive or toxic materials from TRUMP.)
-l While Rockwell insists that there is no possible chance of radioactive 0
releases with TRUMP experiments because the 500 C temperature is below vaporization values, the experiments use a liquid solution with the Pu dis-solv ed.
Liquid nuclear work is certainly susceptible to spills of lesser or greater magnitude.
Our concern regarding an inadvertent radioactive release in this section cannot be separated from our concerns in the other areas as well.
Of specific concern here are the ten questions contained.in the last several paragraphs of Appendix C.
These need answers from Rockwell in some detail.
14.-
(Inclusion of community technical oversight concern was not allowed.)
- 15. (Synergistic and additive mixing of contaminates and multiple exposures from multiple sources is certainly possible and needs to be' analyzed. A simple additive example would be the exposure of a worker to three rems during his/her Hot Lab work and then becoming subjected to another three rems at the waste storage facility elsewhere on the site when delivering waste material.)
Enhanced damage or hazard because of additive effects cannot be delineated
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in a thorough manner at this time.
However, considering the example used in our original statement of concerns and extending that idea, the experiment materials have to come in and be taken out of the Hot Cell. Additional 9
x exposure _of _ workers '1s certainly possible.
,j As for the public in the surrounding communities, the synergistic-type effects can be considered from the mixing of decontamination and decommis-sioning work alongside an ongoing Hot Cell experiments like TRUMP.
Attempts to decontaminate and decommission' with all the truly significant hazards associa-ted with that activity become even more hazardous because of having to keep TRUMP operating. Note has already been make of the ventilation and reduced oxygen atmosphere problems in light of a simultaneous D&D effort.
16.
(The application itself, as amended, is deficient.)
The amended application specifies a license for 400 grams of nuclear material, whereas TRUMP specifics call for a maximum of 6.0 grams of Pu. No mention is made of why Pu _is even required rather than U which wouldn't require a license. The_ combined D&D-TRUMP problems mentioned above are further exacerbated because the entire D&D program has not yet been specified.
While 'Rockwell. is requesting a license for only a small amount of nuclear material at this time, they have insisted in private negotiations that they retain the right to submit an application at any future.date for new and expanded nuclear work. This Rockwell position is maintained in spite of the announced plans and preparation for D&D.
This implies that the _ license application is a ploy to allow Rockwell to continue the work that has already produced so much contamination. Rockwell has no intention of D&D or discontinuing nuclear-work in the Fall of 1990 no matter what the language of their license application implies.
The licensing application requires definitive restructuring to preclude Rockwell from applying for an extension or reapplication after the October 1990 ending date.
1 10
Appendices A, B, and C provide additional material regarding the deficien-cies of this application as well as reiteration of much of the material above.
17.
(EIS concern at this time was ruled premature until Judge Bloch hears from the NRC Staff.).
- 18. _ (Materials accountability.
Atomics International has a very bad record with keeping track of SNH. Scores of kilograms of SNM are listed as "MUF",
Material Unaccounted For, enough for a number of nuclear weapons.. There is no assurance that the facility would comply with the requested limits on SNM, in that their material accountability has been so poor.)
While Rockwell says they only need 6 grams, their wanting a license for 400 grams leaves lots of room for significant bookkeeping and accounting errors.
Af ter all Rockwell managed Rocky Flats when large quantities of Pu were lost.
One point of concern is the changing of personnel during the course of the work. ' A person cannot be forced to keep a job when they desire to quit for one reason or another, but then the problems of transfer of records and the specifying of accountability procedures has to be delineated.
19.
(Inadequate managerial and administrative controls.
The record at the site indicates these controls are grossly inadequate to prevent threats to
- public health and safety.)
(SCFS Concern No. 20 was not mentioned in Judge Bloch's memorandum: The request for 394 grams of Pu as contamination at the
' Hot Cell is an admission of extensive contamination-from past activities and evidence that the applicant cannot be trusted to use SNM without causing substantial contamination.)
It appears at this point that the 394 grams is simply SNM and not specifically Pu.
However, the gist of this concern is quite valid in that 11
5 Rockwell management, as evidenced by past Hot Lab operations, that they don't
+
e have much concern' regarding the contamination of the area.
The Rockwell Record with all its record keeping violations, inadequate L
training, and multitude of accidents cannot be stressed enough.
20.
(Inadequate health physics program. Radioactive monitoring is grossly deficient.
The recent EPA report, for example, calls the facility to task ~ for.
0 washing vegetation samples prior to monitoring, and. heating 500 C both vegetation and soil samples, practices that would remove much of the radio-activity present, giving erroneously low readings.
There is no assurance that' the company can demonstrate that releases will be kept to acceptable levels.)
21.
(Inadequate criticality. controls.
These controls at this site have been q
for years very poor; furthermore, the company has just been cited in a study
- done for DOE as having let very dangerous levels of Pu accumulate in areas of its Rocky Flats facility where it had denied there was any, sufficient to cause a risk of criticality accidents. Assertions of how little they may be requesting at SSFL are not determinate, because they likewise s' aimed erroneously at RF that too little would be present for such a problem. How much from past contamination is at the Hot Lab, claims to the contrary, is unknown. At any rate, 400 grams alone of Pu are sufficient for a criticality accident.)
Since submitting this concern, Rockwell has specified that the amount of
- Pu in use will be 6. grams.
This small an amount would tend to eliminate our
-criticality concern. However, because the 394 additional grams of SNM' for E
which possession is requested was not specified as to isotope content, this p
concern should not be set aside quite yet.
12
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I 22.
(The _ application does not specify the-isoto'pe of: Pu requested.- Pu238,j3 about 300X more toxic gram for gram than Pu239,)
As mentioned above, Pu does not seem to be even required for this TRUMP experiment. U238 should certainly be used initially and that would not require a Hot Cell 'or a special license.
23.
(Security is inadequate to possess Pu.
Protection against sabotage and theft of SNM are inadequate -- this is SCFS Concern N0. 34 which was not
- mentioned by Judge Bloch.)
At no place is the security system spelled out and for good reason.
However, as a general concern the interveners wish to perform an independent security system review under proper circumstances.
It should be noted that 6
SCFS assisted the intervener in this respect for the relicensing of the-UCLA reactor..Results -in that instance revealed substantial inadequacies in the security system and prompted the placing of concrete barricades around the reactor building during the Olympic Games.
24.
(The Radiological Contingency Plan is inadequate.
For example', it-doesn't even deal with TRUMP-S, and uses a ridiculously' low release fraction as the maximum-accident for its planning basis.)
'The contemplated worst-case accident release of.5x10-7 wt%/hr applies only to Pu in a particular form and under specific controlled conditions of temperature and air flow. Change those conditions in~various
" worst-case" directions and the conclusions change.
For example, let.there be 400 gm of toxic nuclear material and consider a total breakdown of the filter system rather than a partial breakdown.
The amount of released hazardous radioactivity is sufficient to contaminate 85.7 sq mi for each Ci of released radioactivity, noting that I gm of bomb-grade Pu contains about 2.;4 Ci and 13
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commercial-grade about 7.52 Ci; see Appendix A.
This calculation is based upon contamination to levels beyond what the NRC generally permit for unrestricted
- use. See, for example, Table 1 of NRC Reg. Guide 1.86 for transuranics.
A worst-_ case accident for such a facility as SSFL is almost always an I
earthquake-induced full-scale fire. As an example under this possible catastrophic scenario, let there be a 5% release from only the 6 gm of Pu.
The amount of radioactivity released (see Appendix A) would be 2.256 Ci which then results in a 193 sq mi area of contamination, i.e. a square area 13.9 mi on a side. - Addition of the SNM, i.e. 394 gm, to the radioactive material involved i
increases the contaminated area significantly.
In fact,1.0 gm or 7.52 Ci of.
j radiation contaminates an area 643 sq mi or a square area 25.35 mi on a side, i
Another criticism is that although there is a backup blower for the l
23,500 cfm, there is no automatic test program to make certain that that backup i
unit is operative as was needed at Three Mile Island.
Additionally, filters 1
are changed " frequently" or when they clog up, an unsatisfactory procedure.
3 Of particuldr note is the requirement that there be six air changes per hour with no recirculation while the air content is being constantly modified i
to provide <5% 0. Exactly how this complex atmosphere control is to be 2
accomplished needs explaining when a simple calculation reveals that a blower i
of at least 51,300 cfm capacity is required for just the Hot Cells themselves, hardly a job for a 12,500 cfm or a 23,500 cfm blower. Additionally along this i
same line, 4000 cfm minimum air flow out of each Hot Cell when their doors are open would. appear to require at least a 16,000 cfm blower, the one 12,500 cfm unit called for being inadequate.
Rockwell claims that a " Site Area Emergency " is not possible for only
- a 6.0 gm of Pu.
This is perhaps true for the limited " worst-case" scenario Rockwell assumed, but how about 394 additional grams of SNM in a realistic worst-case scenario? The license has to preclude the 394 additional grams 14 i
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as well as provide satisfactory contingency plans that deal with a realistic worst-case catastrophic accident.
25.
(Record keeping is poor, making assurance of safety hard to determine and future cleanup quite hampered.
The facility has a history of violations of AEC/NRC regulations, demonstrating that there is not reasonable assurance it can be relied upon to conduct its activities in the future in compliance with.
the regulations.)'
Rocky Flats is not the only facility Rockwell has failed to manage properly. SSFL not being as contaminated as Rocky Flats is merely a reflection of smaller quantities of hazardous material at the site, not a reflection of improved management. _That's the reason it is estimated that $9.48M will be required to D&D the Hot Lab alone.
26.
(Fire prevention and response is inadequate.
A fire involving Pu could be devastating, and fighting it is very difficult requiring serious planning, which is not demonstrated at this facility. A fire involving'SNM-contaminated materials may well be the most serious accident possible at the Hot Lab, but analysis is lacking.)
Noting the Rockwell Contingency Plan specifying 5x10-9 gm' Pu being released under their worst-case scenario for burning up of the 6.0 grams (as L
well as the additional 394 grams SNM) is an _ excellent example of the fire plan-ning inadequacies. For example, the small amount of Pu release is said to rely on perfect operation of half the filter system. A worst-case fire would certainly destroy or seriously damage the entire filter system. All this is for the 6.0 gm Pu specified for TRUMP with nothing being said about the 394 gm additional SNM requested in the license application. Furthermore, the Rockwell t
l worst-case release was based on the August 1968 reference, BNWL-SA-1735, i
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7 i
U whose experiments are seriously questioned as being applicable _ in the way j
Rockwell has used them.
See Appendix C.
Another curious inconsistency is the contention that a low oxygen H
. atmosphere, <5%, precludes combustion, so no fire prevention equipment need be provided.- Then.later there is discussion of monitoring for radioactivity the water flowing _off during fire fighting conditions. Thus there may be a water system ~ for the fighting of fires, but exactly how the water flowing off is to be collected for monitoring is not discussed. At this point we question whether there is a water system at all for the fighting of fires and whether-Rockwell has even contemplated how they are going to collect' the runoff water in order to monitor for radioactivity.
As for arrangements with local fire departments, it seems apparent from Rockwell's response to intervener Donald Wallace's comments that many loose ends still prevail with some having been established only perfunctorily many years ago. It. is doubted that the local fire departments are aware of the special nature of fires that might occur at the SSFL.
27.
(Emissions from routine operations at the site have been excessive and there is no reasonable assurance that continued operation will.not result in unacceptable emissions.)
While normal emissions from TRUMP should not exceed standards, concern is with the additional 394 grams of SNM.
Use and handling, or even purpose, of this hazardous material is not mentioned by Rockwell.
- 28. and 30.
(Safety features, maintenance, and overall safety attitude are inadequate to provide acceptable protection to workers and the public.)
Safety of workers and the public has been alluded to above. To explain now in more detail, the interveners are most concerned that the Rockwell management 16
m-simply is. not interested in safety unless publicity literally forces them to pay some attention. Mention has been made in private negotiations about the E
estimated $9.48M for D&D of the Hot Lab. The cells where hazardous' work' takes place amount to only 855 sq ft of area.
A question the interveners have is
.what-in the world has Rockwell been doing there all these,ews that requires
.many millions of dollars to clean up?
Obviously, the place is so contaminated that such gigantic amounts of money are ' required.
The only way such contamination takes place over the years is for management not to concern itself.
This has nothing to do with the meeting of published safety codes from the NRC or any other agency.
It has to do with their not adhering to " good engineering practices".
Much, if not most, nuclear work many years ago when the industry was in its infancy were not covered by any safety codes to speak of.
It was up to each working group to establish their own codes, i.e. the exercise of their own technical judgment.
Rockwell's management has demonstrated their lack of adequate safety judgment over the-years at _ SSFL.
One contributing factor occurring to these f
interveners might be the_ changing of personnel. We note that during these hearings while we have been dealing with Mr. Lancet, he is now leaving and a new face-appears -- at least new.to us. As said-before, people cannot be forced to stay at a job; however, the safety decisions to be made from one management team to the next can easily be neglected in these changeover periods.
Rockwell SSFL past safety history is sufficient by itself to justify the NRC denying this license.
29.
(Applicant has failed to adequately analyze accidents that have occurred at its facility over the lifetime of the facility, analyze common features and trends.)
Not possessing even the " minimal" accident information Rockwell has 17
L.
u 1
J precludes our satisfactorily addressing this concern.
Obviously, Rockwell has-failed to-correct the common record keeping / reporting and permit deficiencies over the' years.
Once SCFS is supplied with whatever records are available from Rockwell, this concern might be discussed within a more complete framework. Of particu-lar concern, of course, is how the deficient accident analyses have affected
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the surrounding population.
But more importantly, the D&D work to follow is potentially far more hazardous than any previous incident or activity at the SSFL. Thus this concern ~ with Rockwell's ability and willingness to provide appropriate safety analyses for specifying adequate D&D of the Hot Cell area to protect the public health is of crucial importance.
31.
(Applicant has failed to adequately analyze accidents that have occurred at similar facilities and determine whether there is _ adequate protection at its facility'to prevent such accidents. For example, its own hot lab facility at Rocky Flats has had numerous Pu fires, failures of glove boxes, and failures of HEPA filters, resulting in very substantial releases of Pu to the surrounding community, loss of property values for nearby residents and demonstrated increases in cancers._ None of this is analyzed by Rockwell in assessing potential accidents from its similar facility at SSFL, where it claims.no accident can occur that would result in release fractions anywhere near what Rockwell has already experienced elsewhere. Equipment that Rockwell has seen fail at its other facilities it claims as non-credible to fail at SSFL, yet no basis is given for this.
If fires, glove box and HEPA filter failures of the sort that occurred at Rockwell's other hot lab facilities were to occur with i
the proposed renewed licensed activities and possession authorization, very serious impacts could result, all of which is unassessed.)
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32.
(The. facility is too old-and antiquated to be ' operated safely.)
Certainly all buildings ha) > some maximum-lifetime. Nuclear reactors have lifetimes limited by contamination of the structure which reduces its strength.
Similar effects occur at the SSFL.
Yet no specification can be found for-Hot Lab lifetimes.
Judging from similar facilities which have 25 year to 30 year predicted lifetimes-(and many times operate for only a fraction of that time),
the SSFL has already outlived its usefulness.
33.
(The facility is located in a seismically active area, which can initiate l
accidents-resulting~ in radioactive releases to the environment.)
As with nuclear reactors, a severe earthquake near the SSFL could trigger severe accidents which might expose the public to unacceptable health risks.
Responsible NRC action would require moving of SSFL facilities to a remote area.
The original placement of the SSFL probably was based upon its isolation.
Today, however, that facility is no longer remote and, therefore, needs to be moved, following D&D, 34.
(Included in Bloch Concern No. 23.)
FILING DECLARATION The foregoing pleading in support of our intention that the reapplication by Rockwell International for Special Material License No. SNM-21 be denied is being filed on behalf of the Southern California Federation of Scientists by the undersigned under penalty of perjury.
W,I%o
$h oate Sneloon C. Plotkin, Ph.D., P.E.
Member SCFS Executive Board and Chair of the Rocketdyne Cleanup Coalition Task Group 19
I APPENDIX A-COMMENTS ON ROCKWELL INTERNATIONAL'S ON-SITE RADIOLOGICAL CONTINGENCY PLAN AND TRUMP-S PROJECT THE PLAN:. The Rocketdyne report has 96 pages, nearly all of which is devoted to safety measures. There are detailed discussions of emergency responso plans, sections on radiological health, assessment methods, all sorts of radio-logical contingencies, decontamination procedures, drills, data on filters and hoods, along with their air flow rates, much information on all kinds of counters (some with alarms), and even enumeration of the number of sledge-hammers and axes available.
THE EXPERIMENTS:
The maximum amount of plutonium to be brought in is 6 grams, in the metallic state. A maximum of 1 gram of this is to be.used in each experiment, which is to be carried out in an argon-filled glove _ box. A com-l munication from Rocketdyne to the Nuclear Regulatory Commission mysteriously labels the undertaking the " TRUMP-S program."
The alleged purposes of the experiments (pages 1-18 and 3-7) are described '
in~a couple of brief paragraphs. Plutonium metal (amounting to perhaps 100 mg) is dissolved in molten cadmium at 500 C and a layer of molten LiCl-kcl floats on top.
Some of the plutonium enters the salt phase as PuCl3 and some sort of unspecified electrolytic procedure is carried out.
The objective is to measure or observe a-few thermodynamic properties of plutonium, such as free energy changes, activity coefficients, and oxidation numbers.
l This information is to be employed 'in a later stage, in which spent-fuel from nuclear reactors will be processed in this way.
The objective is evident-i ly to find a way to separate the actinide elements from fission products so; that they can be reintroduced into a reactor, serving as' fuel and-as a disposal method.
These steps are extremely vague, and prompt a multitude of critical questions.
SOME-PROPERTIES OF PLUT0NIUM: The accompanying sheet gives some radiological properties of various isotopes of plutonium.
If we assume the plutonium to be used at Rocketdyne is weapons grade, each gram would be 2.14 curies, and all 6 grams would be 12.8 curies. Most of this activity arises from Pu-241, which is beta active and has a half-life of 14.4 years.
. Despite the rather small amount of plutonium being considered, it.is not negligible.
That it can escape is made clear by experience at Rocky Flats, to which no reference was made.
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i; Radiological Properties of Plutonium Specific activity (1 gram basis) 1.323 E16 dist/s c Sp~. act.
=
mass no X half-life (yr) 1 year = 3.156 E7 seconds Isotope half-life sp.act.J1grambasis) disintegrations /sec curies Pu-238 86 yr 6.462 Ell alpha 17.46 Pu-239 24,100 yr 2.296 E9 alpha.
0.0621 Pu-240 6,570 yr 8.388 E9 alpha 0.2267 Pu-241 14.4 yr 3.811 E12 beta 103.0 (0.002% alpha)
Pu-242 376,000 yr 1.454 E8 alpha 0.00393 Pu-243 4.96 hr 1.097 E13 beta 296.5 Weapons grade plutonium, based on 100 grams (Warf, J.C.,ALL THINGS NUCLEAR, p.117)
Pu-238 0.06 g 1.05 curie
.Pu-239 92.0 g 5.71
.Pu-240 5.8 g 1.32 Pu-241
_2.0 g 206 Pu-242 0.1 g 0.0004 totals ~ 99.96 g 214.1, or 2.14 curies per gram Reactor grade plutonium, based on 100 grams (franALL THINGS NUCLEAR,p. 80).
Pu-238 0.7 g 12.2 curie Pu-239 72.4 g 4.5-Pu-240 19.6 g 4.4 Pu-241 7.1' g
731 Pu-242 0.2 g 0.001 totals 99.99 g 752, or 7.5 curie per gram ALTERNATIVES:
While the chemical properties of uranium are different from those of plutonium, preliminary experiments of the type described using depleted uranium -(i.e., U-238) as a stand-in for plutonium would not only test the apparatus, but also expedite final tests using plutonium.
This choice would obviate the necessity of bringing plutonium into the site if the uranium experiments require the remaining time the laboratory will remain open (under-stood to be fall of the current year).
Another possibility is to design the
. test using much smaller amounts of plutonium, say 1 mg, in a micro apparatus.
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/42
J, E
THE MOST COMPELLING CRITICISMS:- The most vulnerable aspect of the plan is its necessity and wisdom.
If we accept the stated ultimate goal of developing a process.for spent-fuel, we must ask.whether the fuel rods are from civilian or military reactors.
Nearly all fuel consists of uranium dioxide, not the metal.
Conversion of such oxide to metal involves scores of fission products; what
-' t happens to them? The main feature which might make commercial reactors acceptable is that the dangerous fission products would be kept imprisoned in 3
their zirconium cladding; this proposed new process would negate this advantage. Assuming that a process is needed to accomplish the stated objectives, why employ a technology which requires reducing to the metal?
Why not employ the classic solvent extraction techniques?
Clearly, much more l
information must be presented by Rocketdyne before any approval of this work is even considered.
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APPENDIX B U
TRUMP S PROJECT CRITIQUE As a bit more data on the proposed experiments at Rocketdyne become avail-able, a clearer understanding of the. objectives become apparent.
Apparently.
with financing from Japan, the research is to find a way to separate uranium and transuranic elements from spent fuel rods in order to consume them by fission in nuclear reactors. Thus more energy is released, and at the same time a method of converting the long-lived heavy elements into fission products with relative short half-lives is achieved.
Eb Oroposed studies are focused on a process in which plutonium metal is dissa md in molten cadmium at an elevated temperature, and subjected to electrolysis in contact with a molten salt mixture.
The aim is evidently to transport the plutonium from the liquid metal phase to an electrode. The behavior of other actinide metals is probably also to be investigated; these might include uranium, neptunium, and americium.
By all means the great bulk of spent fuel consists of uranium dioxide.
The table below gives the approximate composition of spent fuel:
Inventory of Important Fission Products and Transuranic Elements in a Billion-watt (1000 Megawatt) Reactor (100 Tons of Fuel)
Nuclide Hal f-life Amount, kg Activity, Ci Krypton-85 10.7 years 1.5-600,000 Xenon-133 5.25 days 0.94 180,000,000 Iodine-131 8.04 days 0.73 91,000,000
~ lodine-133 20.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> 0.10 180,000,000 Cesium-137 30.2 years 59 5,100,000 Strontium-90 28.8 years 29 4,000,000 Barium-140 12.8 days 2.5 182,000,000 Ruthenium-106 1.0 year 0.83 27,000,000 Zirconium-95 64.0 days 7.5 160,000,000 Zirconium-97 16.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> 0.09 160,000,000 Lanthanum-140 40.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 0.31 170,000,000 Cerium-141 32.5 days 5.6 160,000,000 Cerium-143 33.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 2.1 140,000,000 Cerium-144 284 days 29 91,000,000 Praseodymium-143 13.6 days 29 140,000,000 Plutonium-238 87.7 years 3.6 61,000 3-Plutonium-239 24,100 years 370 23,000 Plutonium-240 6570 years 100 23,000 Plutonium-241 14.4 years 36 3,700,000 Americium-241 433 years 0.53 1,800 Curium-242 163 days 0.17 540,000 Curium-244 18.1 years 0.10 25,000 B1
7 u
' These fission products exist as various compounds or in the free elemental state.
Examples are Csl, Cs metal, Sr0, Sr metal, sri,etc.
A typical' 2
isotopic-composition of plutonium from spent fuel is given in the accompanying
-table.- The levels of radioactivity of the reactor-grade plutonium, in curies, is specified as either alpha or beta, and the sum of these is also indicated.
What has not been explained or even mentioned in the literature available is the fate of all these fission products during the proposed processing the s pent. fuel.
Before the uranium and transuramic metals can be dissolved in the molten cadmium, they must be reduced to the metallic state. How is_this accomplished? What happens to the many fission products?
Is there a chemical separation prior to the electrolysis?
If so, is it the classical Purex process?
If this is the case, then the heavy metals can be isolated without any electrolytic process at all.
In case an attempt is made to reduce the uranium dioxide-base fuel-direct-ly to the metals (U, Np, Pu, etc.), what happens to each fission product?
Is there a plan ultimately to examine the behavior of each fission product in molten cadmium and its electrolysis?
In case the process employing molten cadmium is adopted, what is left behind.in the liquid metal phase af ter electrolysis?
How is the cadmium.
separated?
Is it distilled away?
Does the high neutron capture cross section of cadmium pose any difficulty?
Cadmium is known to be a quite-toxic element.
What assurance does a referee have that this aspect is addressed safely?
The considerations mentioned above indicate that until a great deal more information is presented, defended, and justified, the proposed studies should not be authorized.
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- ON Tile OXIDATION OF PLU10NIUM METAL.
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' fIhe comnents following pertain to possible consequences of a g,
fire at; Rocketdyne's' Santa Susana Field Laboratory. Reference is:
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@% M made to the oxidation'of meta 111cLplutonium in the report by'
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IInformation from Rockwel3-[the On-Site Radiological o
_ Contingency Plan and other sourrea) indicates that six grams.of:
K}p,p, 1 Jmetallic_ plutonium will,be brought 1in for the propos i
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- ,In addition, Leone 394 grams of special: nuclear mterials,-
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presumably mostly plutonium, would also be permitted to be T.
posses, sed as the accumulated contamination from past work.
7 The Battelle workers conducted tests in which bulk plutonium _
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metal was' heated in~ air at certain ambient _ temperatures and, air.-
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The product appears to be_mostly puO. Of course,
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place is higher than the ambient temperature, owing to the h<
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~ The studies revealed that heating of small amounts of J
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'. plutonium at 410 to'650 C.in low air flow rates caused' loss of ll plutonium oxide by entrainment of-3 to 50' millionths of a per cent i 'of;the total. Agitation of the oxidizing mass increased the degree T
~ of: entrainment,i incroacing the amount air-borne to '0.03%.
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- Similar oxidation.of larger samples of plut' onium (hundreds of
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grams)?in moderate air flows. increased the proportion air borne to p<
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- 1 ;as much as 0.032% per hour. tLosses from various plutonium 3c ?
compounds,.Other than the' oxide, were considerably higher, f
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- Inexplicably,. Rockwell in'its reliance 'on' this study has claimed i
. Dit demonstrated maximum release fractions several orders of N,1
^ magnitude smaller than were the actual maximums observed in the:
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, (study.. JIndeed, perhaps the' most reasonable number to.use from the t
1 l study;is the 2.6% plutonium unaccounted lfor in one of the-Loverheating experiments. Furthermore, the study makes clear iti m
didinot: attempt to model the releases were plutonium involved in a 1
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fire such 'as -that involving burning of combustible solvents or Fq
- other petroleum derivatives. There the releases could be much Lhigher than even,the upper release f ractions found in the Battelle
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' study and ignored by:Rockwell.
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_ The possible loss of plutonium from the laix>ratory site was 4,
M further analyzed.Ln the Rockwell safety report by assuming further i i 'q reducing releasesiby two orders of magnitude. T
-!-i iup with release fractions of. on the order of 10 gus Rockwell ends l.
, a very unrealistically small level..
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C Oculd there be a credible worst-case scenario which results
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~in' greater-expocure?1 0ne porsibility would involve a vigorous fire
.following an earthquake-induced release of flamable materials.
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JAll" filters would be destroyed or bypassed under such conditions.
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- Additionally, larger anounts of plutonium than' the 6 gm mentioned (and perhaps-up to 394 grams) could be involved.- - On the order of lf
'l St or so of the pu can be justifiably assumed to be released in a worst-case accident. Under these circumstances, a fire could entrain much note particulate matter than the Rockwell report anticipated and cause much larger doses than they predict.
'Ib quantify any estinates of exposure to persons or ground water, one must do detailed calculations based on published
_ i methodology._ Because Rockwell did not reveal most of their assumptions or methods, only their conclusions, it is difficult to
_ erform a satisfactory independent audit of the calculation.
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the two areas of release fraction in fire and the assumed " worst L
case"~ accident involving one of the filter systems still working, releases orders of magnitude lower than those possible have been y
assumed.' Public. health linpacts could thus be conceivably
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-considerably worse than the Rockwell re[ ort enLimated in Section 3-3.
_Perhaps experience involving plutonium loss at the Rocky r
Flats site would be of use here, where substantial plutonium releases have resulted from. plutonium fires and failure of the filter systems.
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O. S. NOCLEAR 'REGUIATORY C0tNISSION uv 90 FEB 20 E P2 :40 l'
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Docket No. 70-2pMth6ANCH00C filNG A SERV c1
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((Rocketdyne Division, Special
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J-Nuclear Materials License SNM-21)
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.Y CERTIFICATE OF SERVICE
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'I hereby certify that copies of: the foregoing Direct Case of the' Southern California.j,
M' Federation of, Scientists have been served upon the following persons by U.S. Mail,
' * + First Class, except as otherwise noted and in accordance with the require:nents of 10 m
CFR 2.712.
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Administrative Judge
- Office of the General Counsel i
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. Peter B. Bloch U.S. Nuclear Regulat.ory Commission
" Presiding.0fficer Washington, DC 20555 l
Atomic Safety and Licensing Doard
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' US Nuclear Regulatory Consnission Docketing & Service Section X
- Washington,tDC 20555-Office of the Secretary U.S. Regulatory Commission I
Administrative Judge *-
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.F Gustave.lA Linenberger, Jr.
1 Special' Assistant.
Prof. Jerome E. Raskin,
. Atomic' Safety.& Licensing Board 18350 Los Alimos
.t US Nuclear Regulatory Commission.
Northridge, CA 91326 Washington,'DC'20555 P.D. Rutherford *,- Manager T
EAdministrative. Judge
- Nuclear Safety & Reliability Engineering)4 Christine N. Kohl, Chairman Rocketdyne Division-Is Atomic-Safety & Licensing Board 6633 Canoga-Avenue
[l US. Nuclear..Regulat,ory Commission Canoga Park, CA 91304
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Washington, DC 20555 i
Dr. Estelle. Lit Administrative Judge
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.Howard:A. Wilber Northridge, CA 91'326 iAtomic-Safety & Licensing Appeal Board 4
US. Nuclear Regulatory Commission Donald W.'Wallace l
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Washington, DC 20555 1710 No. Cold Canyon Road 4
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Administrative Judge
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- 0. Paul'Bo11werk, III Dr. Richard G. Saxon Atomic Safety & Licensing Appeal Board Physicians for Social Responsibility i
' US Nuclear Regulatory Commission 1431 Ocean Avenue, Suite B a
Washington,rDC 20555 S nta Monica, CA 90401
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