ML20011A213

Interrogatories Directed to Armed Forces Radiobiology Research Inst.Related Correspondence

ML20011A213
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	09/30/1981
From:	Entwisle E CITIZENS FOR NUCLEAR REACTOR SAFETY, INC., ENTWISLE, E.B.
To:	ARMED FORCES RADIOBIOLOGICAL RESEARCH INSTITUTE
References
NUDOCS 8110080297
Download: ML20011A213 (12)

Text

._

. .A O

UNITED STATES 3F Af' ERICA MUCLEAR REGULATORY CO!1'1ISSIO'1 N t'

.c#<

O>'

(

9 BEFORE THE ATO?!IC SAFETY AND LICEMSING BOAR

• Vr U*g$\7  ;

RELATIO CORRrspo:DENCE N f

In the Matter of i

- del l ty \

)

AR!'ID FORCES RADICBIOLOGY ) Docket 'lo. 50-170 RESEARCH INSTITUTE )

) (Renewal of Pacility (TRIGA-Type Reactor) ) License Mo. C R-%})

/\

k. I. b OCT ? 19 8 % To INTERR0GATORIES TO AFRRI - u, ,,xun amurm Q FROM THE CITIZENS FOR HUCLEAR REACTOR SAFETY, INC. C * * '"

?

sd A

Pursuant to 10 CPR 2.740h, the Citizens for Nuclear Reacto h Safety, Inc, requests that the following interrogatories be answered fully, in writing, and under oath or affirmation by any employees or nenbers of AFRRI who have personal knowledge thereof or are the closest to having personal knowledge thereof. The person answering each question should set forth his or her name and title, and should identify any other individual who furnishes information on which the answer to the question is based.

Each question is instructed to be answered in five parts as follous:

Answer to Question  : ,

A) Provide the direct answer to the quesgion. ,

B) Identify all docunents and studies-relied upon by AFRRI, now or in the past, which serve as the basis for the answer. Any such document shal. he identified with reference to its title, the date it was prepared, its author (s) , any identifying serial numbers or filine "8110080297 810930 O PDR ADOCK 05000170 PDR 6 jl

1

.;;'. 1

- *b l

w

-2 numbers, the-particular parts thereof which are relied upon, and the places,.other.than'the offices of AFRRI, where it is known to be avail-able'for inspection. In lieu thereof, a copy of each document.and study may be attached to the answer.

C) Identify all documents and studies, and the particular parts thereof, known to exist but not relied upon, which pertain to the subject matter of the question. In lieu thereof, a copy of eacn document'and study may be attached to the answer.

D) Explain whether AFRRI, the NRC staff, or any other in-

.dividualJis engaged in or intends to engage in further research which may affect the answer. Identify such research or uork.

E) Identify the expert (s), if any, when AFRRI intends to have testify on the subject natter of the question. State the cuali-fications of each expert.

QUESTIONS:

1. State the scientific basis for your assumption in the Hazard Summary Report's (PSR) analysis of a " Fuel Element Clad Failure Acci-r.

dent," submitted with your license renewal application, thnt cladding fcilure during a pulse operation or inadvertent transient would occur o

at.e peak fuel elenent tenperature of less than 100 C.

2. State the calculations from uhich you derived your conclusion in the HSR that a contact configuration of the twelve elenents stored in;your spent fuel pool would not result in a critical nass. -

3. State the source (s) you relied on for your statenent in the HSR that-it takes approximately 67 closely packed fuel elenents to achieve criticality.

4. What basis, if any, do you have for believing that the ,

~

0 .:  ; ' l 2 ..

mu - .

ifollouihg. malfunctions of confinenent safeguards at AFRRI could not

.. occur during~-an experiment' failure:

(a) a breach of containment caused by missing or inadecuate rubber gasket sealing material on the double doors to the corridor behind the reactor control room;

.(b) failure of the reactor room ventilation dampers to close as designed; (c) failure of the lead shielding doors to stop opening at the fully opened position; (d) malfunctionlyf the reactor core position safety interlock.

5. What steps have you taken to prevent the recurrence of the following. malfunctions which have occurred at AFRRI:

(a) malfunction of Safety Channel one on '! arch 15, 1980.

-An MRC. inspection on March 17, 1980, " revealed that Safety Channel One would not initiate a scram in accordance with [ Applicant's] Technical Specifications";

(b) reactor exhaust system malfunction on August 9, 1979 caused by an. electrical fire in the EF-1 cubicle of the motor control center,

- in turn. caused by a power surge due to a faulty transformer; l(c) nalfunction of the fuel elenent tenperature sensing circuit

-caused by a "floatino signal-ground," reported by DNA on August 1, 1979; (d) malfunction of the pool water level sensing float switch caused by wear on the jacketinc around the wires leading to the switch, reported by DNA on July 31, 1979; (c) . malfunction of Radiation Monitorina Systen caused by two loose wires in the control box and resulLing in a failure of the

. reactor room ventilation danpers to close (on August 26, 1975);

(f) nalfunction.of the Puel "enperature - Automatic Scram e --

e

~

~ '

E ,

q~- ..

C

/ ~

SystenLon January 29, 1974, caused by a build-up of high resistance

' Lme terial on the nechanical contacts of the T* output meter; U -(g) malfunction of the Reactor Core Position Safety Interlock w

System on February 1, 1973, caused by a faulty de-energizing relay.

^

6. -What are the' scientific and nathematical bases for your

.. assumption that the TRIGA's negative temperature coefficient will auto-

-matically shut down the ranctor in accident situations with damaged fuel elements?

7. Do you believe the following postulated events could occur in the AFRRI reactor and, if not, what are your bases for so believing:

(a) defects in the natorial integrity of the fuel elenents; (b) an uncontrolled power excursion in the reactor core; (c) a loss-of-coolant accident; (d) sabotage, aircraft collision or natural ("act of God")

4 accident.

S. Do you believe a multiple fuel element cladding failure could result fron any o. all of the events described in question 7 and, if

-not, uhat are your bases for so believing?

9. State the scientific and mathenatical bases for your .>elief that, should an accident such as that described in your HSR as a " Loss of Shielding and Cooling Water" accident occur while the reactor core isfin the pulso node, air convection coolino vould he sufficient to prevent cladding failures resulting in fission product releases in excess of 10 f..F.R. Part 20 linits.

, 10. State the scientific and nathematical bases for your position that the following accidents could not occur in the APRRI reactor:

r 39 -

r

y ---

1 (a) power excursion accident (PEA) resulting in multiple cladding failures at an elevated temperature with reduction in the

'thermalizing effect of hydrogen, followed by an explosive zirconiun-steam interaction; (b) a loss-of-coolant accident (LOCA) resulting in nultiple cladding failures at an elevated temperature, followed by an explosive zirconium-air interaction.

11.1For each of the seven conponents (A-G) and sub-components of energency planning set forth in. Attachment A, Contention 3, "Energency plan," of the Stipulation signed'by AFRRI, NRC, and Intervonor on March 31, 1981, you have brought your energency plan into conformity with the requirements of 10 C.F.R. part 50, Appendix E. State the identity of persons, agencies, and organizations where identification of same is called for in the sub-conponent, and attach schenatics, agency directives, correspondences, and cooperative agreenents between yourself and other persons, agencies, and organizations, and any other

' documents-that pertain to the emergency planning for the AFRRI facility.

12. If you have not met the requirements of 10 C.F.R., Part 50, Appendix E, with respect to any of the components and sub-components listed in question 11, state why not, whether you plan to comply, and if so, when and how.

13. Mhat energency plannino requirenents which apply to the AFRRI facility, other than those set forth in 10 C.F.R. Part 50, Appendix E, have been proposed or adopted by the Muclear Regulatory Commission, Federal Emergency Manacement Agency, Department of Energy, Environmental Protection Agency,-Food-and Drug Administration, Division of Radio-logical Control of The Maryland Department of Health, Montaomery County Civil Defense Office, and any other Federal, state, county, or muni-

cipal agency?

14._ For each requirement referred to in cuestion 13, describe the extent to which and how you'have brought.your energency planning into. compliance. State the identity you relied on for your statement in the HSR that it takes approximately 67 closely packed fuel elements to a'chieve criticality.

15. EIf you have not met the recuirements referred to in question 5, state why not, whether you plan to comply, and if so, when and how.

16. Describe how you developed the classification systen for emergencies'(2.1-2.4) in your Emergency Plan submitted with your license renewal application.

.17. Give an example of each class of emergency referred in your Emergency. Plan (2.1-2.4), including a description of the chain of events

-leading to such an accident and the steps you would take 'a $.itigate or terminate the emergency condition.

18. For each class of emergency (2.1-2.4) state whether during

.AFRRI's' operating history any such emergencies have occurred and describe each such emergency, including the precipitating event, individuals expoaed to radiation, injuries sustained, mitigating steps taken, resolution of the emergency situation, citations and/or notices of violations fron ?.he NRC and any other Federal, state, county, or municipal agency, and. steps you have taken to preclude or reduce the probability of recurrence of such emergencies.

19. In 4.2.1 through 4.3.'3 of the Emergency Plan, describe the means by which you plan to notify AFRRI Security Officer, supervisors of the laboratories, AFRRI Director, Head of Radiation Sources Division,

and Radiological Safety Department !! cad, nFRRI staf f, M?EC personnel, weather officials,,' police, and civil defense personnel in the event wai ,.

[

of an emergency, including a description of the back-up neans of notifying the said individuals, officials, and personnel if the planned means is not feasible and the back-up persons who will be notified if_those designated are not available.

20 Describe the accident that occurred in your cobalt facility between April 22 and May 16, 1981, including a statement of the class of emergency it began as and escalated to, the precipitating event (s),

the mitigating steps taken, the extent to which the emergency plan operated as planned, who the decision-makers were (includina the person (s) who acted in the Director's absence), the individuals who were exposed to radiation as a result of the accident, their levels of ex-posure and whether the same exceeded Federal linits, the concentration levels of radiation in the cobalt storage room,.AFRRI building, and outside the buidling (in restricted and non-restricted areas), and whether these exceeded Federal levels, final resolution of the accident, steps you have taken to preclude its recurrence, citations and notices of violation from the NRC, and correspondences between AFRRI and other agencies pertaining to the accident.

21. Describe how this accident affected the operation of your reactor.

22. Describe how, in a " worst-case scenario" of the cobalt accident, the operation of your reactor would have been affected.

23. Describe the evacuation and other emergency plans, both within the AFRRI facility and in conjunction with other agencies and the public, that were put into a state of readiness and/or were actually carried out in the course of the cobalt accident.

24.. Describe the instructions AFRRI personnel uere civen durina the cobalt accident regarding protective and nitigative neasures

r 'they should take, evacuation, and the possibility that they could not

' return to work if the energency situation escalated or continued una-bated.

25. What scientific and mathematical bases, if any, do you have and what empirical data and evidence can you cite, if any, to support the position that the effects of aging including increasing brittleness and netal fatigue on the reactor parts will not reduce the

-margin of operating safety and increase the risk of malfunctions and accidents during the AFRRI reactor's proposed third and fourth decades of operation?

26. Do you.believe your environnental monitoring system (i.e.,

your equipment, nethods, and reporting system for measuring releases into the Montgonery County sanitary sewerage system and at your perimeter and offsite monitoring stations) is adequate to determine radiation dose to the public due to inhalation or ingestion?

27. If your answer to question 26 is "No," explain why not and describe the steps you have taken to make the system adequate.

28. If you answer to question 26 is."Yes," explain why the following inadequacies in your-systen, alleged by the Intervenor and cited by the NRC, do not now nor in the future, will in fact detract from your syston's ability to fully and accurately determine radiation dones to the public.

(a) film dosimetry detects only external ganna radiation.

(b) the particulate radioactivity nonitor for airborne efflu-

~ents (i.e., a pancake-probe C-M counter) is not isokinetic, and therefora cannot he used for neaningful evaluations. Applicant's only other stack effluent nonitoring system, the radioactive gas nonitor, is likewise not reliable for particulate sanplina. (See

r:

~

_9_

Environmental Release Report issued 12/14/71, covering period 1/1/70-5 '0/71, and Inspection' Report No. 50-170/77-01-03.)

(c) The Violation Motice of Gross Beta Effluent Analysis, based on an NRC Inspection conducted .Tanuary 12-14, 1977, cited

' Applicant forLcalculational omissions, nethoas for preparing and analy-zing samples, and instrunentation used. The gross beta neasurenents were made without the use of a beta self-absorption correction in the presence of significant amounts of suspended solid material. (See NRC Inspection Reports No. 50-170/77-01-02 and 50-170/77-01-03.)

(d) The " concentric cylinder set model" used by Applicant to

' derive its dose assessments to the environment, and form which it con-cludes its' effluents are within regulatory limits, is an unrealistic model.

29. Describe the system you have used and use to prepare and analyze quarterly environmental samples of water, soil, and vegetation in your "Environnental Sampling and Analysis" progran referred to in your Environmental Impact Appraisal Data Report.

30. What raw data hava you have collected fron 1970 to the present in your "Envrionmental Sampling and Analysis" program?

31. What steps have you taken to prevent the recurrence of discharge on .7anuary 10-12, 1979 of Argon-41 and other radionuclides at ground level outside the reactor building through a leak in the vent-

-ilation exhaust stack drain. pipe, referred to in NRC Inspection Report No. 50-170/79-0l?

32. Has the incident referred to in question 30 or similar 1

incident occurred on any other occasion at AFRRI? i l

33. In view of your statenent in your Environnental Impact Appraisal _ Data Report, p. 5, that the efficiency of the reactor's

E-n -

p :. ',;

cooling tower "is determined by the temperature-and humidity of the ,

,outside ambient air," what are the operating parameters of said tower's efficiency?

34. State.the names and addresses oi _11 suppliers of the fuel for your reactor. .

35. How and from where is said fuel transported to your facility?

36. Describe your procedures for interin on-site and off-site disposal of the reactor's spent fuel elements.

37. Describe any occasions on which you have incinerated or-buried nuclear waste, or directed another to do the same, including the dates and locations of said activities and the amounts of waste involved.

.38. Is there now any nuclear waste buried on AFRRI or NNMC grounds?-

39. Is it still year practice to routinely discharge radioactive effluents into the Montgomery County sewerage systen?

40. Uhat radioisotopes and in what concentrations and absolute amounts have you discharged into said sewerage systen every year from 1961 to the present?

41. What measures have you taken to prevent the recurrence of the'following' security and managenent violations that have occurred at the AFRRI facility:

(a) . Eighteen activations of the facility alarm system during

-a 34-day. period, caused by p"esonnel leaving after normal duty hours from unauthorized exits. Auditors were told by AFRRI security personnel and'other AFRRI officials that investications were not made of the activationsLand.that not enough security people were on duty to investi-t gate each time the alarm went off; ,

e-e

• c;. -

y~

(b) unauthorized people entering the facility by following l employees in'wlio.used their magnetic ^ cards to unlock the door; (c) failure to escort visitors attending weekly seminars and provide them with dsnimeters; (d) failure of employees enterina and exiting the building after hours to sign a log snowing their time of arrival and departure; (e) violations of Applicant's accounting and dispensing procedures for controlled substances such as narcotics.

42. State your reasons for believing that the reactor and related

. operations in the AFRRI facility are or are not-susceptible to sabotage and/or terrorism.

43. List- the names and locations of all other nuclear research and testing reactors in the United States where experiments such as or similar to those performed at AFRRI are or could be carried out.

44. State your reasons for believing that all or sone of the

'research and experienents performed at AFRRI could or could not be carried

.out at other reactors such as those referred to in question 43.

45. For each of the years 1975 to the present, state what percentage of AFRRI' staff time, reactor operating time, and annual operating budget

.has been spent on research and experiments unrelated to AFRRT's chartered nission, as stated below, including but not linited to hallistics and

~'~~~' forensic testing for the FBI and natorials testinc for private industry.

DOD Directive Mo. 5105.33, May 11, 1972:

II. Mission The nission of AFRRI shall be to conduct scientific research in the field of radiobiology and related natters that are essential to the medical support of the Department of Defense.

-z,.,l , ; . . .:'

' ' 9

IV.--Functions

...AFRRI shall A. Operate facilities for. conducting research on the

n. '

biological effects of ionizing radiation and disseminate the results.

l-1 l

i r

Respectfully submitted, l

l l

j .

t e [ #N r0 Coun'sel for Citizens for

?!uclea_ Reactor Safety, Inc.

I Dated this 30th day _-

of Septenber,'1981.

I

- - - , . . , - , . . - -