ML20024A546

Testimony of L Wayne,R Finston,S Aftergood,L Foster,M Kaku, B Norton,R Kohn,S Plotkin,M Pulido,D Dupont & D Hirsch,As Panel IV Re Radiation Doses from Accidental Release of Fission Products.Declaration of Svc Encl

ML20024A546
Person / Time
Site:	05000142
Issue date:	06/14/1983
From:	Aftergood S, Dupont D, Finston R, Foster L, Hirsch D, Kaku M, Kohn R, Norton B, Plotkin S, Pulido M, Wayne L COMMITTEE TO BRIDGE THE GAP
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ML20024A493	List: ML20024A492 ML20024A499 ML20024A510 ML20024A537 ML20024A546
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NUDOCS 8306170426
Download: ML20024A546 (52)

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ACCIDENT CCNSEQUENCES RADIATICN DOSES FROM ACCIDENTAL RELEASE OF FISSION PRODUCTS Fh0M THE UCIA REACTCP -

Introduction

1. Dispersion factors and dose estimates have been calculated for two classes of accidents at the UCIA reactor. One category assumes release of iodine isotopes in the quantities estimated for a fuel handling accident by Hawley, Kathren, and Robkin in their report " Credible Accidents for Argonaut Reactors"

(NUREG/CR-2079). h other category ass mes a more substantial release, the amount suggested in the American National Standard for Research Reactor SiteEvaluation(ANSI /ANS-157-1977).

2. For both categories of release the assumptions made in the Hawley report have been followed as to atmospheric conditions, duration of release, dose conversion and breathing rates, and core inventory and proportional mix of iodine isotopes. The primary diffgrence is that, whereas Hawley assumes a dispersionfactor(4/Q)of.01s/a>atanunspecifieddistancedownwindand calculates doses accordingly, we have calculated dispersion factors for a range of distances from the source.

3. Using the standard NRC Regulatory Guides for dispersion during an accident, we have determined that the p/Q used in the Hawley report is applicable at a distance of approximately 100 - 200 meters frem the reactor room. Doses closer to the reactor, therefore, will be far higher than the 43 3 rem to the thyroid estimated in the Hawley report for the fuel handling rccident.

Doses near the reactor facility boundary will be approximately 10,000 rea to the thyroid for the release presumed by Hawley. Doses will exceed the 10 CFR 20

limits out to approximately 600 meters. Tens of thousands of people are within 600 meters of the reactor facility virtually every day.

4 For the second case considered--a release of 25% of the equilibrium radiciodines, as opposed to the .2% considered in the Hawley report--doses exceed the 10 CFR 20 limits and the ANSI /ANS site criteria out to tens of kilometers from the reactor site, an area including many millions of people.

Maximum doses in unrestricted areas exceed a million rem to the thyroid.

5. The methods employed rely largely on the standard NBC Regulatory Guides for dispersion during nuclear reactor accidents. The results obtained can be scaled up or down, for example, from the figures obtained for the 25% release, to estimate maximum individual doses and the size of a required Emergency Planning Zone (EPZ) for different categories of presumed accidents.

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8306170426 830614 PDR ADOCK 05000 T

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6. These data are surprising in light of the general assumption that I research reactor accident consequences would be minimal because of the '

relatively small radioactive inventory, compared with that of big power reactors. However, the particular characteristics of the UCLA reactor ~

particularly the lack of containment structure and complete absence of an exclusion zone--significantly compensate for the smaller starting inventory.

Furthermore, the high population density with no low-population zone results in a total population dose that could likewise be quite high, were there a release of even a small fraction of the core inventory of radiciodine.

He Hawley Fuel-Handling Accident

7. H e first category of release examined is that put forth by Hawley for a fuel-handling accident involving one of the reactor's twenty-four fuel bundles. Hawley assumes that this accident will result in release of .189%

of the core radio fissionproducts. pines,xenonsandkryptons,andreleaseofnoother The release is characteri by 4.4 curies of icdine-131, and.similar quantities of four other iodines. Such a release, Hawley asserts, would result in a dose equivalent to the thyroid of 43 3 rem to an observer at an unspecified distance downwiM, assuming a one-hour release during highly stable atmospheric conditions.2/ While not specifying the location of the downwip as 10' s /m s , which he terms "an extremely conservative value."obgerver, Hawley l 8. %/Q is a relative concentration factor, a measure of the degree of dispersion of atmospheric pollutants over distance. A particular T/Q value is accurate only at a particular point downwind from a source. AparticularT/Qvalue cannot, by definition, be assigned irrespective of the distance from the point of release, because it represents dispersion over distance. Se greater the ersion and the smaller the distance fromatthe concentration thatsource, the greaterifthe point. Conversely, T disp /Q is, say, .01 at a particular location downwind from the source, it must, by definition, be larger than that closer to the source, and the concentrations thus greater as well.

1/ The NRC Staff, in its Safety Evaluation Report, p.14-9, asserts that the fission product release for a seismically-induced core-crushing incident would be the same as the release assumed by Hawley for a fuel-handling incident.

l Were this assumption correct, the doses estimated here would be applicable l for the Staff's design basis accident. However, Hawley indicates (p. 26) that a core-crushing accident would produce "some multiple of the consequences of the fuel-handling accident." If Hawley is correct, then the Staff's design basis accident would result in some multiple of the doses indicated here for the fuel handling accident.

2/ he Hawley report, in footnote (a) on page 48, indicates that the assumed release represents 2.7% of the gaseous inventory of one bundle containing 7%

of the core inventory. (.027 x .07 = .00189, or .189%.)

J/ Table 4, p. 48. Hawley report.

4/ ibid.,p.51,indicatesthatinthederivationoftheequationsusedinthe Hawley report, and reproduced in our calculations, the time of exposure " drops out."

Thus, says Hawley, "the calculations would be valid irrespective of the time base for the release, and would fit a puff of instantaneous release as well as a protracted release."

i 3

9. In order to attempt to assess the location at which the 43 3 rem dose estimate is valid, CBG submitted an interrogatory to the authors of the i Hawley, el d. study

Interrogatory 91: T/Q was determined for what distance for an observer downwind?

the study's authors): The Y Q AnswerbyR.L.Kathren(oneofwasselectedasbeingthe value of 10~

maximum credible values the downwind distance at which this value might occur is site and time specific. De report assumed that this value to occur [ sic 7 at the location of a downwind observer j irrespective of the distance of that observer from

.the point of release.

. (emphasis added) f As indicated in the proceeding paragraph, a particular $/Q value cannot be assigned " irrespective of the distance" of the observer from the point of release, because it is a function of dispersion over distance. Although the above interrogatory answer did not provide the information needed, we were able to determine the location downwind at which a %/Q' of .01 would be valid by turning to the standard NRC Regulatory Guides for dispersion during accidents.

10 Reg Guide 1.4 puts T/Q at 10-2 at a distance 200 meters from the source for a ground-level release for a time period of 0-8 hours. De Hawley assumption of a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> aT/qof10-pleasewouldfitinthiscategory.

at just under 100 meters for timReg.

UCLA Guide 1.145Se conditions. indicates University of {1erida Argonaut, in its application for relicensing, estimated a $/Q of 10' at .1 miles (161 meters) for a release less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in duration, using the NRC meteorology. Rus, the dose of 43 3 rem to the thyroid estimated in the Hawley report for a fuel-handling accident would be valid for people about 100-200 meters from the reactor, given dispersion out-of-doors (as opposed to within the building complex, which is a special case discussed elsewhere).and the standard NRC dispersion models.

11. Since Hawley indicates that the value chosen was "an extremely conservative value," it would probably be more appropriate to choose the 200 meter distance as the location at which that observe would receive that dose, but in our calculations we have used the less conservative (frcsi a safety standpoint) assumption that that dose occurs at about 100 meters, using the methodology l

of Reg. Guide 1.145

12. Reg. Guide 1.145 was then used to determine the downwind distance at which thyroid doses of 5 rem and 15 rem would occur. mese corres theboundariesforemergencyplanningforresearchreactors(5 rem)pondto and site

m a__.'.

_ , _ , _ , m , . -- - - - - - - - -

evaluation (15 rem)ofbothNRCandANS.5!

13 As seen in Figure 2, using the standard Reg. Guide (1.145), the site bourdary, emergency planning zone, and urban boundary (10 CFR 20 limit) should occur at 170 meters, 300 meters, and 600 meters respectively, for the release essumed for the Hawley fuel-handling accident. In other words, even for w, fuel-handling accident assumed by Hawley, doses in excess of the 10 CFR 20 and ANSI /ANS limits would occur out to 600 meters, a large section of the University campus containing many thousands of peopleg furthermore, an EPZ of 300 meters radius would be required, again requiring the ability

, to take emergency actions on behalf of thousands of people. This result was

obtained from use of the standard Reg. Guide for dispersion.

14 As that Reg. Guide is designed for dispersion at distances greater than 100 meters, alternative methodology must be utilized in estimating the doses closer in. This is presumably because no power reactor has an exclusion zone smaller than 100 meters, so dispersion at distances less than that are not included in most dispersion models used for nuclear accident consequence modeling. Bis appears to be the source of the Hawley error discussed above' (i.e., choice of a .01 t/q as the most conservative dispersion factor ,possible, irrespective of distance from the source.) While it is true that a t/Q greater than that is not likely in the unrestricted area of a power reactor, which begins in excess of 100 meters, that would not be the case in a research reactor accident such as one at UCIA where there are thousands of people within 100 meters and where there is no exclusion zone at all.

15 If the dose at 100 meters is 43 3 rem, the dose at the beginning of the unrestricted area must be considerably greater. How much greater can be readily estimated by several methods, each of which gives remarkably similar results.

16. The simplest method to estimate concentrations and doses at the reactor room wall is to determine the concentration within the reactor room. This will provide the enneentration at the point of leakage into public, unrestricted areas.

The rector room volume is approximately 1500 ms (Application, p. III/4-1, .4-4).

4.4. curies of I-131 (and the standard assortment of the other iodine isotopes assumed by Hawley tould produce:a concentration of approximately .003 curies /m of I-131. From Hayley (p. 48) it is determined that a plume concentration of1.2x10~)Ci/m'ofI-131willproduce217remtothethyroidfromthe iodine-131, for a total of 43 3 rem when the other radiciodines are added in.

The higher concentration within the reactor room, or at the point of leakagg into publ 1.2 x 10~ge areas,

, for would a total thus thyroid doseproduce a higher of 10,825 dose rem.at thein the ratio reactor room of 3wall. x 10->/

5/ NUREG-0849 and ANS 1516 Draft TI (Table I for both) indicates a 5 ren thyroid dose as the determinant ofthesizeoftheEmergencyPlanningZoneEPZ) for research reactors. ANSI /ANS-15 7 states that dose commitment in the event of a design basis accident to persons within the site boundary shall not exceed 15 ren to the thyroid and to persons at or beyond the urban boundary shall not exceed 1 5 rem. N site boundary is defined as the limit of the area "wherein the reactor administrator may directly initiate emergency activities." he urban boundary "means the nearest boundary of a densely populated area or neighborhood containing population of such number of in such a location that a complete rapid evacuation is difficult or cannot be accomplished within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> using available resources." he 1 5 rem dose corresponds to 10 CFR 20 limits.

17. For the purpose of a first order apprcximation of the concentrations within 100 meters of the reactor, Halitsky's " stretched string" model was utilized (Halitsky19634 cited also in Hosker, 1982, p. 36, and in Li, Eeroney, Peterka, 1982, p. 3ff). Additional results are indicated in Table 2 and graphed in Figure 2 Doses of 9020 rem to the thyroid are indicated at one meter from the reactor room wall, for the fuel handling accident release.

18. Rese in-close estimates correspond closely to other computational methods. For examIl e, adjusting the estimates contained in the UCIA 1960 Hazardsrelease, handling Analysis (and 1980 produces verySafety similarAnalysis results. Report)(for the Hawley fuel-seeFigure2).

19. Some points about the initial Hazards Analysis estimates are in order at this point. CBG has pointed to the thyroid dose estimates (e.g., 1800 rem at 15 meters) in that Analysis as part of the basis for its concerns about potential consequences of an accident. It has since been argued by the

Applicant, in withdrawing its own Analysis submitted both in 1960 and 1980, that the Hawley study supersedes the 1960 Hazards Analysis in that fuel melting is supposedly required to produce the doses estimated in the original Analysis.

l Such arguments miss the point.

20 The 1960 Hazards Analysis and 1980 Safety Analysis assumed in estimating an 1800 rem dese, a smaller radioactivity release to the environment than did Hawley for his fuel-handling accident. Hawley assumes release of 4.4 curies of I-131. The Hazards Analysis (p. C-4: or p. III/B-4 of the 1980 Application) assumesaleakof037 curies /hrofI-131toproduceaneight-hourexposure of1800 rem (p.6). In other words, the Hazards Analysis, with its 1800 rem estimate, was based on a 3 curie release of iodine-131 (0 37 curies /hrx8 hrs =

2.96 curies), whereas Hawley assumes a dose of only 43 3 rem, from a release 50 % larger. ~

21. The discrepancy is readily explained. Asshownabove,the%/qutilized by Hawley fits the standard models at a distance of about 100-200 meters from

[ the source. Se Hazards Analysis estimates doses in the range of Hawley's

! 43 rem at a distance somewhere between 152 and 302 meters. In other words, the unrealistically low estimate by Hawley is due to estimating the dose quite somedistancefromthefacility(relativetothenumberofpeoplecloserin).

UCIA's own 1960 and 1980 Analyses demonstrate, as does Reg. Guide 1.145, that Hawley's estimate of doses of 43 3 rem thyroid is only appropriate at distances greater than 100 meters, and that doses closer in, for example near the boundary of the unrestricted area, would be very much higher. The UCIA Analyses' 1800 rem estimate is for a 3 curie release at 15 meters: Hawley's is a 4.4 curie release at over 100 meters. In-close. doses for Hawley's 4.4 curie release l should be approximately 2640 rem at 15 meters (1800 x 4.4/3), and approximately 10,000 rem at the reactor room wall.

22. In summary, for the 4.4 curie release assumed by Hawley for his fuel-handling accident involving one of the reactor's twenty-four fuel bundles and representing a release of 0.189% of the assumed radiciodine inventory, maximum doses of about 10,000 rem to the thyroid are indicated, and levels inexcessof10CFR20andANSI/ANSsitecriteriawillexistoutto600 meters.

I l

TABLE 1 Distance,  %/Q total thyroid dose total thyroid dose meters sec/m3 for 60001 I-131 for 4.4 Ci I-131 release release 100 8.65 x 10-3 ,

5200 rea 38 ren 170 34 x 10-3 2000 15 300 1.1 x 10-3 685 5 600 34 x 10-4 200 15 1000 1.77 x 10-4 107 0.8 3000 6.2 x 10-5 37 o,3 6000 32 x 10-5 19 o,14 7500 2 5 x 10-5 15 0.11 10,000 19 x 10-5 11 5 0.08 20,000 9 3 x 10-6 56 0.04 23,000 8 3 x 10-6 50 0.036 30,000 6.4 x 10 -6 3;8 0.03 75,000 2 5 x 10~' 15 0.01 i

\

TABI2 2 Distance, Dilation Concentration,Ci/m3 Total thyroid dose, rea for for meters Factor 600 Ci rel. 4.4 Ci rel. 600 Ci rel. 4.4 C1 rel.

1 1.16 0 34 0.0025 1.2 x 10 6 9020 5 1.9 0.21 0.0015 7.6 x 105 5400 10 31 0.13 0.00094 4.6 x 105 3400 15 4.6 0.086 0.00063 3 1 x 105 2300 20 6.37 0.062 0.00046 2.2 x 105 1660 30 10.8 0.037 0.00027 1 3 x 10 5 97o 50 23 1 0.017 0.00013 6.1 x 104 450 e

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he 25% Radioiodine Release 23 The industry standard for research reactor site evaluation (ANSI /ANS-15 7-1977) indicates 25% of the radiciodines and 100% of the noble gases should be presumed released. This is the fraction of release assumed by the University of Florida in its 1981 Safety Analysis Report for its Argonaut reactor. And, as indicated in the testimony of the CBG panel on accidents and release fractions, a 25% radiodiodine release is a realistic estimate for several different accident scenarios at UCLA.

Indeed, there are accidents, particularly those involving fire, which could release a substantially larger fraction'than 255 (25%isapproximately 600 curies of I-131, based on Hawley's calculation that .189% is equal to 4.4 curies).

24. Using Reg. Guide 1.145, as with the 4.4 curie release, for estimating dispersion greater than 100 meters from the reactor room wall produces the results in Table 1 and Figure 1. Doses are 5200 rem at 100 meters:

an EPZ would be necessary out to 23 kilometers as indicated by the 5 rem dose at that distancer and an urban boundary should not occur until 75 kilometers from the reactor, as indicated by doses in excess of the ANSI /ANS site criteria out to that distance. As indicated, doses exceeding 10 CFR 20 criteria would extend several scores of kilometers. There are obviously millions ofpeoplewithinboththeEPZandtheANSI/10CFR20zonesbecauseofthe placement of this particular reactor in the midst of one of the largest cities in the world.

25 Dose estimates for the close-in areas of the unrestricted zone near the reactor were made for the 600 curie release in the same fashion as for the 4.4 curie release. Se results are recorded on hble 2 and in Figure 3 As is seen, doses of about 1.2 million ren to the thyroid are found about three feet from the reactor room wall, i.e. in the unrestricted public area outside the reactor facility.

26. Within the reactor room, 600 curies of iodine-131 (and the standard assortment gf the other iodine isotopes) would produce a concentration of 0.4 C1/m> of I-131, or approximately 33,000 times the concentration assumed by Eawley for the downwind observer to the fuel handling accident, said to receive 43 3 rems to the thyroid. We dose at the reactor room wall would thus be about 1.4 million rem.

27. The magnitude of these doses near the reactor boundary is confirmed by the 1980 UCLA Safety Analysis Report (and 1960 Hazards Analysis). The 1800 rem estimate at 15 meters was based on the assumption'of a 3: curie release to the environment, based on several non-conservative assumptions such as only 10% release and 10 kw instead of 100 kw operation, as now licensed. Correcting for a 600 curie release, doses 200 times higher at

, 15 meters, or about 360,000 rem to the thyroid are found. Thus, the different l calculational methods result in thyroid doses of 1.4 million rem at the reactor room boundary,1.2 million rem about three feet away, and about 360,000 rem about 50 feet downwind.

28. It is obvious that potential doses within 100 meters of the reactor room wall will be enormous because all the radioactivity will be concentrated in the localized plume volume close to the leak point. In any case, since the thyroid gland is essentially completely destroyed by the time the dose reaches 10,000 rem, it is not really very important to know precisely how high the thyroid dose might rise above 10,000 rem.

29. Doses to organs other than the thyroid could likewise be quite high.

The magnitude of the whole body doses could be of substantial concern.

Unfavorable Site Characteristics 30 Unfavorable characteristics of the UCLA reactor site contribute to the high doses estimated above and, in some cases, may make those estimates non-con-servative from 4. safety standpoint (i.e. doses may well be even higher than those estinated above). Furthermore, the urban siting makes the potential population dose extremely large, despite the zelatively small start'ing inventory.

These factors include the lack of containment', the placement of the reactor inside a large public building complex (making exposures within the building a possible exposure pathway), the closely-packed proximity of nearby buildings (creating a sheltering, or channeling effect that may substantially reduce dispersion and increase concentrations and doses), unfavorable meteorology, among others.

Unfavorable Meteorology

31. The atmospheric conditions assumed by Hawley and utilized in our calculations as well are appropriate for a conservative, generic safety analysis. Some parts

of the country have a high frequency of more favorable atmospheric conditions l than those assumed here, and it might thus be appropriate in those instances to reduce concentration and dose estimates accordingly. This would appear to be the case with the University of Florida Argonaut reactor, which, in its l 1981 Application for relicensing obtained dose estimates for it s Design Basis Accident quite similar to those identified above for the 25% release, utilizing NRC standard meteorology, and somewhat lower estimates using local, more

favorab1e meteorology.s l 32. However, the atmospheric conditions in los Angeles are perhaps the Norst in the country from the point of view of dispersion of pollutants. Los Angeles' I

famous inversion layer, responsible for the persistent and dense smog much of the year, makes for extremely unfavorable conditions for dispersion of radionuclides from a reactor accident.

33. In fact, the Advisory Committee on Reactor Safeguards recommended to then-AEC Chairman McCone in 1960 seStrding power reactor siting in Southern California as follows:

The meteorology'of the Southern California coastal strip is so unfavorable for. dissipating pollutants that this area should be avoided if it is coupled with a high population density.

(ACRS letter of March 6, '1960) l

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. __ sa . __ ,

-13 34 The ACRS gave as its reason for its recommendation the high frequency of inversion conditions in Southern California, unfavorable meteorological conditions it termed "essentir,11y unique in the United States":

Referring to the frequency of inversion conditions, the situaticn of the Southern California coastal strip (south of San Francisco) is essentially unique in the United States. The semipermanent Pacific high pressure area induces a slow, large-scale, persistent subsiding motion in the atmosphere there. Air, warmed by this descent, contacts the coastal water surface which is cold as a result of upwelling. By this mechanism an inversion is formed; and the air layer extending up to a few thousand feet above the surface becomes a trap for air pollution.

Whereas persistent poor dispersion (stagnation) conditions of-meteorology, lasting several days, may be expected on the averade once per year anywhere east of the Rockies, the frequency of such episodes in the Southern California coastal strip is of the ceder of several per month. For example, d2 ring a two-year pericd, frem July 1956 through June 1958, the Los Angeles weather was of th

" smog warning" type 164 days.

35. Los Angeles is indeed " essentially unique" in the U.S. with regards the frequency and severity of meteorological conditions unfavorable for dispersion of pollutants. Thus, dispersion under certain accident conditions at the UCIA reactor may be even less than estimated above usir4 the NRC standard meteorology, and concentrations and doses proportionately higher.

' ~

36. In sum, the uniquely unfavorable meteorological conditions associated with the UCLA reactor site add significantly to the risks to the public from accidents at the factlity. The atmospheric conditions involving wind speed and stability class assumed by Hawley and used in both his and our calculations are quite reasonable for accident analysis in the Los Angeles Basin and may indeed not be conservative enough, given the ares's unique problems with dispersion of pollutants. (It should be. noted, however, that even were one to assume atmospheric conditions far mera favorable--e.g. sind speed of 2 5 meters per second and D atmospheric stability class--projected thyroid doses would still exceed 10 CFR 20 limits many kilousters from the reactor site.)

Inhibition of Dispersion Because of Extensive Nearby Construction

37. Traditional dispersion models may not be sufficiently conservative' enough for estimating concentratiors.and doses at this site for other reasons as well. Most models assume open-country terrain. This is a rsaconable assumption for most nuclear power plant considerations, due to their exclusion zones and siting at least some distance from urban areas. However, the UCLA case is somewhat different, with the reactor placed in the center of a crowd' de urban campus.

. -14_

4

38. Extensive construction has occurred immediately around the reactor facility. These buildings would likely tend to trap pollutants between them, creating something like sheltered coves which prevent airflow and the " washing out" that accompanias it. A likely.cpnsequence of this siting is a channeling effect, in which the plume is unable to disperse as fully as it would in an open-country situation. Essentially the plume .is contained and prevented from more fully dispersing because of the limited air volume available Mtween buildings and the sheltering effect.

39 One of the most likely effluent pathways in case of accident, for example, is the single door separating the reactor room from the loading zone between the reactor building and the Engineering Building a few feet to the west.

This effluent pathway is a single tarrier consisting of an ordinary door.

To assume normal dispersion from that point of leakage would be non-conservative frem a safety standpoint, because that immediate area is essentially a wind-protected cover, with tall walls on three sides restricting dispersion.

(See the photos, attached). iThe effluent could collect in that sheltered, walled-in public area, elevating concentrations and elongating exposures, before eventually dispersing elsewhere.

40 'Ihus,,the high density of buildings in close proximity to the reactor facility could produce a sheltering and channeling effect, elevating concentrations and doses.

The Special Problem of Exposures Within the Math-Sciences /Boelter Complex

41. As indicated above, dispersion of radioactive material during an accident at the facility is complicated by the new ccustruction that has occurred at the facility. In most analyses of radioactive dispersion, a building or perhaps a cluster of buildings is assumed with dispersion being fnm the containment building to the environment. Detailed models have been developed for these conditions. But the UCIA case is far more intricate, because it is, in addition to being urban-sited, situated within an unrestricted building complex containing several thousand members of the public. Dispersion in

~

case of accident, thus, will not be solely from traditional forms of dilution of plume outside the W ilding as transported by the wind, but also within the bailding, transported by the ventilation system.

42 Tbe ventilation system provides a complex mechanism for bringing radioactive material to where the people are, and recirculating that contaminated air. Whereas once the plume has passed an indi m ual outdoors, the exposure is ended, a contamination incident involving tur . . A via a ventillatier system indoors would create the potential for subi.tulia11y higher exposures to larger numisrs of people, as the material would be largely trapped inside the building for an extended period of time. And whereas it may not be very likely that an individual would remain in the same location outdoors for several hours of exposure to a plume, the situation for hundreds or thousands of faculty, staff, and students in classrooms and offices is quite

different, keeping in mind the invisible nature of most airborne nuclear material j and UCLA's current emergency procedure of not evacuating or providing any other emergency response outside of the reactor room itself.

l

43. The additional construction that has occurred around tho'UCLA reactor, i and the interface of ventilation systems inside those buildings, considerably increases the potential magnitude of public radiation exposures in case of accident. Consider, for example, the corridors outside the Nuclear Energy ,

Iab. (See attached photos). Rose could rapidly fill up with radioactive affluent from an accident, but unlike release into open air outdoors, the j release would be bounded virtually on all sides, considerably reducing dispersion.

Concentrations would be high, and would remain elevated for. extended periods

of time. The full detailed analysis would be quite complex, because release into certain areas (like the corridor on the first floor) would produce high exposures there but restrict release to other parts of the building because that corridor has only one airvent, which provides air to the corridor. Release t to other areas would reduce maximum individual dose, but vastly increase the population dose, as the ventilation systems brought the radioactive release to people throughout the building complex. Suffice it to say that traditional accident dispersion models may not be appropriately conservative for the

, UCLA case and would likely underestimate by significant factors at least certain components of the accident consequences.

! l 1 ,

Estimate of Consecuences of Dispersal hrough the Ventilation System of I Flutonium Source

44. One of f.he accident scenarios considered is fire. Were the 2 curiep l I (approximately 32 grams) of plutonium-239 contained in the plutonium-borylium j neutron source to be involved in a fire, and the plutoniun oxide particles ,

j dispersed throughout the building complex by the ventilation systems, the <

l consequences could be extremely serious.

i 45 32 grams of plutonium-239 dispersed as the oxide, as in a fire, through a building could create lethal inhalation doses throughout 16,000 square

, meters of building and significant contamination requiring some evacuation

! and cleanup of 1,600,000 square meters. (his assumes release of the material '

l in the form of an aerosol of finely divided particles uniformly in air throughout the building and one hour exposure. By comparison, 500 square meters corresponda ,

to the area of one floor of many typical office buildings and 50,000 square ,

l meters is comparable to the entire floor area of a large skyscraper.)

, 46. These calculations are based, in part, on similar calculations made for

. a 100 gram Pu-239 source in Nuclear % eft Risks and Safeguards by Theodore

! Taylor and Kason Willrich. They correctly identify the exc,eedingly toxic ,

nature of plutonium-239 and the dangers attendant with the release in air i of even a few grams of the material We have already stated that plutonium, in the form of extremely  !

small particles suspended in air, is exceedlingly toxic. The total weight of plutonium-239 which, if inhaled, would be very like to cause death by lung cancer is not well known, but is probably .between ten and 100 micrograms (millionths of a gram). Even lower internal doses, Perhaps below one microgram, might cause significant shortening of a l Person's life. he total retained dose of plutonium that would be i likely to cause death from fibrosis of the lung within a few days is about a dozen milligrams (thousandths of a gram). For purposes of this discussion, particularly for comparisons with other toxic substances, we assume that fifty micrograms of plutonium-239 represent a " lethal" dose, i.e., the amount that would be very likely to cause eventual death if it were internally absorbed.

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)

l In terms of the total weight of material that represents a lethal dose, plutonium-239 is at least 20,000 times more toxic than cobra venom or potassium cyanide,and 1000 times more toxic than heroin or modern nerve gases. It is probably less toxic, in these same terms, than the toxins of some especially virulent biological organisms, such as anthrax germs.

The amounts of plutonium that could pose a threat to society are accordingly very small. One hundred grams (three and one half ounces) of this material could be a deadly risk to everyone working in a large office building or factory, if it were effectively dispersed.

In open air, the effects would be more diluted by wind and weather, but they would still be serious and long-lasting.

47. Taylor and Willrich correctly conclude that even a few grams of dispersed plutonium could pose a serious danger to the occupants of a rather larger office building or enclosed industrial facility. Dispersal out of doors--

and this is relevant to the previous discussion of how exposures within the reactor building complex might, be substantially higher than those outdoors as estimated with traditional dispersion models--would produce substantially greater dilution by wind and weather, but they would still be serious and long-lasting, as the Taylor /Willrich calculations indicate. "With a few dozens of grams of plutonium, however, it would be relatively easy to

• contaminate several square kilometers sufficiently to require the evacuation of people in the area and necessitate a very difficult and expensive decontamination of the area." As they indicates After the plutonium-bearing particlas settled in an area, they 4

would remain a potential hasard until they were leached below the surface of the ground or were carried off by wind or surface water drainage. As long as the particles remained on the surface, something might happen to draw them back into the air. Contamination levels of about a microgram of plutonium per square meter would be likely to be deemed unacceptable for public health. Thus, in an j urban area with little rainfall, a few grams of plutonium optimally dispersed out of doors might seriously contaminate a few square kilometers, but only over a very much smaller area would it pose a lethal threat.

l 48. Thus, dispersal indoors through the ventilation system of the building complex could pose dangers even greater than those estimated for out-of-door dispersion. And were the plutonium-berylium source to become involved in fire, the consequences could verge on the catastrophic. Plutonium metal, of course, can burn, releasing minute particles into the air, dispersed by the energy of the fire. Fire-fighting would be extremely hazardous due to the presence of the plutonium oxide in the air, and the public health implications would be awful. 2 curies of Pu-239 is by no means an insignificant amounts placed near the skin, it will cause radiation burns in a few minutes, and- as indicated above, inhalation of even microgram amounts is exceedingly dangerous. .

(Berylium, for that matter, is also quite< toxic.) A fire involving the plutonium-berylium source could thus pose substantial dangers.

~ _ _ . _ - . _ _ - _ _ _ . . _ . _ _ _ _ _ _ _

Iack of Containment Structure

49. Se risks to the public fromat accident at the reactor are substantially increased because of the lack of containment structure. he reactor room in no way represents either a confinement or a containment structure. There arenumerouspenetrationsintotheroom(quiteafewdoorways,inparticular) which leak air at a significant rate. One can put one's hands near the doors and feel a strong draft because of the negative pressure of the rgsctor room."

In an accident, with the ventilation system shut down as required , the air uculd flow through the same passages into other parts of the building or the outdcw environment. Se reactor room itself represents essentially little or no inrrier to fission product release in an accident. Given the population on the other side of the wall, the lack of effective containment substantially  !

elevates potential exposures.

50 one study (Otway, Battat. Lohrding, Turner, and cubitt) determined l that lacit6f' engine' redesafeguards e such as a containment structure tended to equalize risks to the public from a 3000 Wth large contained pressurized water reactor and an 8 Mth uncontained research reactor. The release to the atmosphere of I l31 was determined to be approximately the same (and in somecaseslarger)foraccidentsofestimatedequalprobability,duelargely to the ability of the containment structure to substantially reduce the core inventory fraction that entered the environment.

Site Characteristics Leading to Gamma and Neutron Exposure Poten_tials

51. As indicated, the reactor was originally in its own two-story building which has since been virtually enveloped on all sides by new construction, as well as construction directly above the reactor. his new construction has created additional pathways for exposure.

52. When the reactor was built, because it was in its own two-story building, no one was to be above the reactor room, so exposures in the vertical direction l were not of concern. (Forexample,theapplicatienatpageIII/4-1 indicates that the reactor room walls are 12-18 inch thick concrete, whereastheroofofthereactoris6inchesthick.) Since that time power has been increased by a factor of 10, and aloni; with it potential fission product inventory, and three floors of classrooms and offices have been added above the reactor itself. Sus there are now classes and offices above the reactor, creating new exposure pathways.

53. An additional concern is readily apparent by viewing the architectural and HEAC drawincs for the third floor " void area" or machine room. That area contains the ventilation system for the reactor facility. Air ducts penetrate the reactor room ceiling so that the ventilation equipment above can provide air to the rooms below. The air duct penetrations provide a number of openings in the concrete ceiling above the reactor. Whereas the six inches of concrete will somewhat reduce gamma and neutron " shine" through the ceiling, the air ducts provide avenues fer radiation " shine" without any of the attenuation normally offered by the concrete. His didn't matter when the reactor was first licensed and the building designed, because no one was ever to be on the floor above the reactor, except maintenance people for brief intervals. But given the relatively thin concrete floor and penetrations in it , the new construction and the tenfold increase in power, new conditions requiring a new assessment of the possible risks are in order regarding the people who take classes, work in offices, and eat in the snack bar above the reactor.

• see photos: large A i r

• • WrA_Mrh_Fh311-6 pathways in, under, and around several of the doors. _

54 It is a subject for later hearings as to whether doses during normal operation because of this and other problems are below 10 CFR 20 levels.

However, this characteristic of the site clearly increases potential exposures in case of accident a.s well.

55 One kind of accident analyzed is operation of the reactor with the plug for a beam port or irradiation port accidentally removed e.g., if a sample was inserted and the plug was inadvertently not replaced)(. An incident in which an exposure took place while the reactor was shut down and an individual was for about a minute exposed to a beam from an open beam port resulted in a 4 Rem exposure. Dose from an open beam port  !

with the reactor shut down is reported as 50 Rem / hour. Obviously doses from an open port while the reactor was operating could be much, much hi6her, ,

and include substantial neutrons as well. '

56. Doses from open ports could thus obviously produce substantial doses, both to people in the room and people outside or above. One, or even two, floors of six inch concrete would not reduce doses sufficiently to prevent people from obtaining doses considerably in excess of 10 CFR 20 limits, particularly if the inadvertent failure to replace a a plug were not discovered for several hours or longer. (Likewise, were an SL-1, SPERT, or BORAX type power escursion to occur involving core destruction, core shielding could be substantially displaced and substantial doses from exposures to fuel fragments might res' ult.)

Miscellaneous Exposure Potentials

57. It is a subject for another hearing to determine whether the various spills, leaks, contamination incidents and mis-estimates of gaseous releases over the years at the UCIA reactor facility have resulted in exposures in excess of 10 CFR 20 levels. However, it is clear that they represent accident sequences which could produce exposures substantially above those levels. For example, l the incident in which a shipment of spent fuel was found to be contaminated with Cobalt-60, and the history of leaking Cotalt-60 sources at the site, could have been much more serious. The contamination could have been much higher, including fission products from the fuel, or a leaking plutonium source.

For example, a fuel handling accident might result in substantial direct radiation exposures. Minutes of the Radiation Use Committee for December 22, 1977, indicate that a person close to the fuel cask would "reghire just 4 seconds of exposure for a reportable incident should the shielding of the cask suddenly be removed and a few minutes to a lethal dose." If correct, substantial doses to others nearby could also result from fuel handling incidents.

For example, eneapsulation failure of the radium-borylium reactor start-up source appears to have resulted in radon concentrations at levels in the range of. naximum permitted concentrations when diluted by the ventilation air system.' Clearly, more serious failure of such a .

source could result in exposures in excess of limits. The same can be said flor failures of irradiation samples (" rabbits") upon return from irradiation in the core, fire involving stored samples in the process of " cooling down,"

primary coolant leaks, cladding damage to fuel through corrosion or other means. accidental increase in Argon-41 productione criticality accidents, etc.

ese Exhibit C-IV- 9

Conclusion

58. Because of the site characteristics and other factors, a series of accident categories have the potential for substantial public exposures.

H e Hawley fuel-handling accident may result in doses of approximately 10,000 rem to the thyroid at the facility boundary and doses in excess of 10 CFR 20 and ANSI /ANS site criteria out 600 meters. A more reasonable estimate for release during a major accident, the 25% radiciodine release suggested by the ANSI /ANS site evaluation standard and appropriate for several classes of accident at the UCIA Argonaut, results in doses in ,

excess of 1 million rem to the thyroid near the facility boundary and '

doses in excess of the standards out as far as 75 kilometers. These results can be scaled up or down proportionately to fit presumed releases.

59. Numerous characteristics of the site have substantially unfavorable fattres, increasing risks. associated .with accidents. The meteorology is quite unfavorable, the extensive construction nearby may tend to reduce .

dispersion out-of-doors, and placement of the reactor inside a large public building complex creates exposure pathways for both airborne and direct exposure that could be very substantial. The lack of containment structure and exclusion zone very much elevate potential exposures the extremely high f6pulation density, due to being placed at the center of a large campus in the midst of one of the most populous cities in the world, creates potential for a very high population dose as well.

60 S e unfavorable site characteristics combine to compensate for the small size of the fission product inventory, relatives to that of a big power reactor. Iack of containment structure and other engineered features to reduce release compensates for a several order of magnitude difference in inventory; lack of exclusion zone provides a several order of magnitude additional compensation. '

61. Doses far in excess of appropriate standards are found for accidents, such as the fuel handling accident, involving far less than 1% release of the assumed radioiodine inventory. Even releases substantially smaller would produce doses in excess of those levels.

l 62 A major accident (e.g. one ~ involving a release af la the range of 25%

of the radiciodines) would be arguably the worst reactor accident to date by far, power reactor or otherwise, in terms of population exposure. The Three Mile Island accident is said to have released less than 20 curies of I-131, i not much more than assumed for the Hawley fuel handling accident at UCIA, although maximum doses from the UCIA accident would be far higher than the doses from i

TMI because of UCLA's lack of exclusion zone. (Concentrations drop by several l orders of magnitude in a few hundred meters). The other reactor accidents of note (e.g., Windscale, SL-1) were rurally based, with substantial exclusion

( and low population zones to keep both the maximum dose and the population dose

! far below that estimated for an accident involving substantial core damage at UCIA.

l 63. A range of accidents, from release of a small fraction of one percent I

of the core radiciodine inventory to substantially larger fraction of the j inventory, all result in public exposures in excess of acceptable levels.

l

= ---- --

, References

1. Regulatory Guide 1.145, " Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants", U.S.

Nuclear Regulatory Commission, Au6ust 1979

2. NUREC/CR-2079, " Analysis of Credible Accidents for Argonaut Reactors",

S.C. Hawley, R.L. Kathren, M. A.' Robkin, April 1981

3. ANSI /ANS-15 7-1977 (N379), "American National Standard Research Reactor Site Evaluation", American Nuclear Society, 1977 4 Safety Analysis Report, University of Florida Training Reactor, by Nils J. Diaz, William G. Vernetson, University of Florida, 1981 5 Halitsky, J., " Gas Diffusion Near Buildin6s", ASHRAE Trans. 69, #1855, pp 464-485, 1963 ,

6. Hosker, R.P., Jr., " Methods for Estimating Wake Flow and Effluent Dispersion Near Simple Block-like Buildings", NLTEC/CR-2521 ERL-ARL-108, 1982

7. Li, W.W., Moroney, R.N. , Peterka, J.A. , " Wind Tunnel Study of Gas Dispersion Near a Cubical Model Suildin6", NUREG/CR-2395, 1982

8. .UCIA Training Reactor Hazards Analysis, by R.D. Faclain, UCLA Report No. 60-18, March 1, 1960

9. Affidavit of R.L. Kathren in :NRC Staff Supplemental Response to Intervener's Interrogatories", Docket No. 50-142, April 19, 1982

10. Safety Evaluation Report, NRC Staff, Docket No. 50-142, June 1981

11. Ctway, Battat, Lohrding, Turner, and Cubitt on The Risk from an Urlan-sited Reactor, cited in Leonard A. Sagan (ed.), Hunan' and Ecologic Effects .of Nuclear Power Plants, Charles C. Thomas,1974, p.146.

1

..21-Accident Consequences Exhibit List Exhibit Number Description C-IV-1 ANSI /ANS-157-1977, American National 5tandard Research Reactor Site Evaluation C-IV-2 AffidavitofRonaldL.Kathren,4/8/82 (excerpts)

C-IV-3 Reg. Guide 1.4, pa6e 1.4-5, indicates

%/Q=0.01at200 meters C-IV-4 Univ. of Florida Safety Analysis Report, page 2-60 estinates 'X/q = 0.01 at 0.1 miles C-IV-5 3/6/60lettertoAECchairmanF.cConefromACRS, excerpted in Ckrent, Nuclear Reactor Safety C-IV-6 photographs taken outside reactor building, and in corridors outside NEL C-IV-7 excerpts from Willrich & Taylor, Nuclear _'Iheft C-IV-8 letter, 3/10/65, racIain to AEC on open beam port incident C-IV-9 Minutes of the Radiation Use Committee, 12/12/75 C-IV-10 photographe taken within the Nuclear Energy Iab See alae Exhibit C-I-5, >Mation use Committee Minutes (12/22/77),

attached to power excursion panel testimony, on fuel handling

/

Exhibit C-IV-1 page 1 of 9 ANSl/ANS-15.7-1977 (N379)  ;

}

American National Standard Research Reactor Site Evaluation

~

) .

Secretariat American Nuclear Society Prepared by the i American Nuclear Society Standards Committee Working Group ANS-15.7 Published by the American Nuclear Society 555 North Kensington Avenue La Grange Park, Illinois 60525 USA h Approved August 30, 1977 7 by the American National Standards Institute, Inc..

700348

page 2 of 9 Contents ection S Page

1. In trod uction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . 1

2. Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

3. Site Evaluation Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3.1 . Popula tion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3.2 Geology / Seismology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.3 Hyd rology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.4 . Meterol ogy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.5 Other Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

4. Critaria for Downwind Concentration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 4.1 Downwind Diftusion from Instantaneous Releases . . . . . . . . . . . . . . . . . . . . . . . 4 4.2 Downwind Daffhsion from Continuous Release . . . . . . . . . . . . . . . . . . . . . . . . . . 5

5. Critaria for Radionuclide Release from the Reactor Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

6. Biologie.tl Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 6.1 In ha b tion Ra tes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' . . . . . . . . . . . . . . . 6 6.2 Iodice .onversion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 6.3 Cloud L Wensions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

7. Refereness . . . . . . . . . . . . . . . . . . . . . . . . . . ................................... 7 A ppen dix A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S 6 Appendix B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 4

e

k pa6e 3 of 9 i

, Research Reactor Site Evaluation

1. Scope capable fault. A capable fault is a fault which

. has exhibited one or more of the following i

This standard is to be used in evaluating characteristics:

research reactor sites and their'amociated boun- (A) Movement at or near the ground surface daries. at least once in the past 35,000 years or more than once in the past 500,000 years. In the ab.

2. Definitione sena of data permitting absolute dating, faults i with sudiciently recent movement to leave per-  !

For the purpose of this standard,.the following ceptible evidence of surface rupture, surface worde and phrases are defined: -

warping, or offset of geometric features are con-sidered capable faults, boundaries and zones. The following (B) Instrumentally well. determined macro-definitions for boundaries and zones are seismicity for a fault located in the continental peculiar to research reactor siting and relate to: United States west of the Rocky Mountain front, a) the type of authority the reactor chief ad- , or in Alaska, Hawaii, or Puerto Rico.

mimstrator has over a specific area, and, (C) A relationship to a capable fault ac-b) the potential time required to evacuate a cording to characteristics (A) or (B) such that given area to achieve minimum exposure to ac- movement on one could be reasonably expected

, cident-caused radioactivity. to be accompanied by movement on the other.

(1) operations boundary. The operations (Title 10-CFR - Part 100, " Reactor Site boundary means the reactor building (or the Criteria," Appendix A " Seismic and Geologic nearest physical personnel barrier in casse Siting Criteria For Nuclear Power Plants.") [1]8 when the reactor building is not a prmBapl

!h physical personnel barrier) where the reactor chief admmistrator has direct authority over all design basis accident. A design basis accident (DBA) is a postulated accident used to evaluate activities. The area within this boundary shall the site and the engineered safety features. The have prearranged evacuation procedures known DBA describes consequences more serious than to permannat frequenting the area. those arising from any probable amident for the (2) rural zone. A rural zone is a sparsely reactor under evaluation and usually assumes populated but not directly controlled area or some degree of radionuclide rolesw; that neighborhood where evacuation of all personnel release is used to evaluate population does com-can be achieved in less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> using mitments.

available resources.

(3) site boundary. The site boundary is dose commitment. Dome commitment is that that boundary, not - ily having restrictive total radiation dose equivalent, internal or ex.

. harriers, surrounding the operations boundary tornal in origin, to the whole body or specified wherma the reactor =d==ini=*rator may directly part of the body, that will be received during the initiate emergency activities. The area within 50-year period following the release of radioac-the site boundary may be frequented by people tive material to the specific environment. Dose unacquainted with the reactor operations. quantities that apply to the "whole body" shall (4) urban boundary. The urban boundary also apply to the head and trunk, active blood-means the nearest boundary of a danaaly formmg organs, gonads and lens of the eyes.

populated area or neighborhood containing Does quantities that apply to "other organs" population of such number or in such a location shall apply to those organs not specified above.

that a complete rapid evacuation is diHicult or cannot be accomplished within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> unmg %mbers in breches refer to correspondins munbers in see.

available resources. tion 7. References O

1

pass 4 of 9 Amencan National Standard ANSI /ANS-15.7-1977 (N379) research reactor. A research reactor is a Figure 1 I

device designed to support a self-sustaining Typical Boundaries <

neutron chain reaction for research, or develop-mental purposes, and which may have provisions for the production of nonfissile radioisotopes. ,

en ,- ---

sha!!, should..and ,may. The word "shall" is _ ,, ,,,,, . e used to denote a requirement, the word "should" lE is used to denote a recommendation, and the O word "may" is used to denote permission,  !  ! c - .m == !

neither a requirement nor a recommendation. ", _.-- 7 l gg,

EEi

3. Site Evaluation Factors ja

-  : CJ This section discusses the factors that shall be  :!O' considered in evaluating a research reactor site """. Z --

and associated boundaries. Routine radioactive emissions from the facility may influence the site location; information related to rout'ne 4

emissions exists in draft form.8 3.1 Population. The protection of the health i and safety of the general public, and the on-site Fi

, g,,g undaries personnel is paramount in site and boundaries evaluation and in the design of engineered. I safety features. Generally, research reactor utilization requirse operators, experimentera, g and support personnel to be in the vicinity of the '

,,, a y -

reactor. It is recognised that personnel in the a== - ---- == em-=

reactor vicinity are at greatest risk, com- \  !

i

==n-wate with their duties and objectives. """" Q O {,]

l Site evaluation is discussed in terms of dose commitment to persons within the operational boundary, site boundary, rural zone, and at the urban boundary. The populations should b9 hh _

chosen from projections over the design life time of the facility. Refer to Figures 1 and 2 for a pf description of how these boundaries could l_' l__ ,

typically appear. Depending on the site, some of '

the boundaries may be coincident. Criteria listed in Sections 4,5, and 6 are an acceptable

• method for dose calculations; actual data are to be preferred where available. ,

3.1.1 Dose Commitment, Persons Within Operations Boundary. In the event of a DBA, 8 Damen objeco, m for and Monisering syseems controlung planmag shall assume all persons within the Remoarch Reactor Emuenen, "ANS 15.12-1973. Corrupon. operations boundary are evacuated in a suf.

Ses5Un d

• ny, N.Ynive ty P ficient time such that the dose commitment does Pa 16s02. not exceed 25 rems to the "whole body" or 75 4

2

pago 5'of 9 American National Stand:rd ANSI /ANS.15.71977 (N379) rems to any "other organ". [2] Realistic time or believed to be subject to seismic activity of in. j h dependent radionuclide release rates may be used in evaluating this dose commitment when tensity V or greater, should provide a seismic alarm to the reactor operator. [3] Reactor it can be shown that instantaneous release la safety related structures and systems shall be impossible. Credit may be taken for realistic seismically designed such that any seismic event i evacuation measures. -

cannot cause an accident which will lead to dose commitments in excess of those specified in 3.1.

Note: The term sufficient time shall relate to (3) Liquefaction. The reactor site should be escape routes, facility emergency exits, etc., and in an area known to haw low soil liquefaction is generally fractions of an hour. potential The potential for liquefaction of the 3.1.2 Dose Commitments, Persons Within surfaces of the proposed site should be  ;

the Site Boundary. In the event of a DBA the evaluated using the design basis vibratory i i

dose commitment for people within the site ground motion.

boundary shall not exceed 5 rems to the "whole body" or 15 rems to any "other organ" 3.3 Hydrology. The effects of accidental calculated for a specified exposure period releases of radioactivity. into nearby streams, following the accident. [2] A 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exposure lakes, or watertables shall be evaluated within i i

period shall be used if actual data are ,

the guideline specified in 3.1. (Information unavailable. related to routine releases of radioactivity exists 3.1.3 Dose Commitmente, Persons In the in draft form.8) Seismically induosd floods for Rural Zone. The dose commitment associated sites along streams, rivers, and lakes shall be with the DBA for persons situated within a evaluated. Effects of a probable maximum rural zone shall not exceed .5 rems to the "whole flood, seiche, surge, or seismically induced flood body" or 1.5 rems to any "other organ" over a 2 such as might be caused by dam failure shall be hour exposure period i==arilately following the considered. Hazards of tsunami, river blockage, accident. -

diversion in the riwr system, or distant or j 3.L4 Does Commitments, Persons A'i or Beyond the Urban Boundary. The dose com.

locally generated " sea waves" shall be reviewed to establish the suitability of a site.

mitment ===aanted with the DBA for persons at or beyond the urban boundary shall not exceed 3.4 Meteorology. The atmospheric charac.

.5 rem to the "whole body" or 1.5 rems to any teristics at a site are an important consideration "other organs." The event duration shall be 24 in evaluating the dispersion of radioactivity.

hours lacking other information. The total The potential effects of atmospheric extremes whole body man. rem dose commitment from the (for example, tornados and exceptional icing accident should be compared for the sites under conditions) on the safety.related structure shall consideration. be evaluated within the guidelines specified in 3.1.

3.3 Geology / Seismology. The geology and s sesamic characterstics of the site and the region 3.5 Other Factore surroundmg the site shall be considered in light 3.5.1 Multiple On-Site Facilities. In the of the following restrictiuns: ewnt that two or more nuclear reactors are (1) Fault Proximity. No proposed facility operated on. site, the possibility of simultaneous -

shall be located closer than 400 meters from the accidental releases from mmmon events shall be surface location of a known capable fault. In considered. The releases from such accidents seismically active areas the earthquake shall not cause dose commitments in excess of generating capacity of the fault as well as its those in 3.1. Simultaneous releases for in.

ground displacement capability may be reason dependently caused accidents need not be con.

far additional separation. sidered.

(3) Seissaie Design. The design of the 3.5.2' Industrial, Military, and Tran-I '

proposed facility shall conform to accepted stan. sportation Facilities. A site shall not be selec.

j dards for arena having similar earthquake ted if, in the event of an accident at a nearby i histories. Facilities in areas known to have had, facility, it is not possible to safely shut down the 3

l L____ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ ____ __.__ _ . _ _ _ . . _ ._ _ _. .__

?

page ($ of 9 Amartean National Standard ANSI /ANS.15.71977 (N379) reactor. The evaluation shall include the listed in this section provide an acceptable ,

possible effects of moving trains or whicles in method for determining downwind con-cases where railways or highways are nearby. centrations of radionuclides; actual data are to 3.5.3 Air Traffic. Factors such as frequency, be preferred when available. For close in distan-and type of aircraft movement, flight patterns, ces (typically less than 200m) these criteria may local meteorology, and topography shall be con- not apply and special methods may be required sidered for on a case.by. case basis.

(1) sites located within 8 kilometers of an existing or projected commercial or military air- 4.1 Downwind Diffusion from Instan-port or tanoone Releases. The following general (2) sites located between 8 and 16 equations are recommended for calculating kilometers fhun an existmg or projected com- downwmd radionuclide concentration and ex-mercial or military airport with more than ap- posure from instantaneous pointmurim releases proximately 200 da (where d is the distancs in of radionuclides. Values of the nae ===ary kilometers from the airport to the reactor site) parameters shall be consistent with Pasquill commeretal or military aiaraft movementa per condition F [4], with wind speed of 1 m/s or in year. some cases another Pasquill condition where Special consideration shall be~ giwn when condition F may not be sufficiently conservative siting the facility within the trajectory of a run- for elevated releases.8 way of any airport. The analysis should demon. 4.L1 Concentration. The expression for con-i strate that there is a low probability of any contration from a puff release is:

potential aircraft including seneral aviation air- , g X =e craft affecting the facility in such a way as to j, , , 7,g , ,g ,; ,,+ f,,,,+ g cause the release of radioactivity in excess of the guidelines specified in 3.1. -

3.5.4 Environmental Factore. In general, ~  % " *****"I'* O*"' "3 research reactors dd not require the preparation N * " "

• h = h beisitt d Messe, m g of an Environmental Impact Statement. Ap-pendix A of this standard, however, does list 3 " "*** wind sM m/s 8 * ****

• some of the environmental aspects that may be a:I. F yr. r:I = M standard deviation, in .

desirable to consider in the, preparation of the meters, of plume m x (downwind), y (crosswind),

3,f, gg

• s (vertical) directions with

• I " 'Y I 8

'"*'*II Y

4. Criteria for Downwind Concentration 4.1.3 Exposure. The total integrated exposure Several general criteria arist for estimating, for the cloud may be determined by the radioactivity dispersal and subsequent done f*II*"'"8 P'"I'"

rates to persons downwind of a radioactivity release from either the failure of core fuel or a p- O erp -j 7 j + 7, radioactive experunent. Reactor characteristics,  !! r *yt 'd (2a,27 2ah safety features and other factors will have a ~

direct bearing on how the radioactivity is disper- ~

"I"

sed from the fhel cladding, or experunent con-tainer, to the reactor building. Dispersal from Y = e*P0888, g '} #

the reactor building must then take into account m an elevated or ground level release. Radioactive decay and nuclide platmout may be tahan into account for nuclides within the reactor NWar In general, radioactive decay, ocupied with the -

formation of daughter products, and fallout may >See Figwas A-5. A-4. A 7 of Reference (4) be allowed durms the atmospheric diffusion ass. Table 4.23. pese 17s et R terone. [4] rar massemed process exterior to the reactor building. Criteria valune at these seandard deviacion.

k 4

i pass 7 of 9 L.

American National Standard ANSI /ANS.15.71977 (N379)

Emuent temperature and wrtical movement Effluent temperature and vertical mowment

) may contribute to form an effectzve release may contribute to form an effective stack height hetsht which is the sum of the actual stack which is the sum of the actual stack height h height (h) and a correction (Ah). Information and a correction Ah. Information for deter-for determining the correction to the stack mimny this correction may be found in Ap.

height may be found in Appendia B. Otherwise pendix B. Otherwise the actual value of the  ;

the actual value of the stack height may be used stack may be used as the effectzve release height.

as the effective release height.

When the effective stack beight is less that. 2.5 When the effectiw stack height is less than 2.5 times the building height and the release is times the building height and the release.is associated with that building, the release height associated with that building, the release height may be set equal to zero and the building wake may be equated to, sero and the efect of efect accounted for by substituting Milding wake accounted for by substituting

• ry and In for ey and ei respect wly, rygand Ed for eyr and ed respectively where where t rgy =(aII8 + C N r)18 (,2 + CNr)18 Ig = (eg + C N r)18 C = .5, arbitmy constant r{

g (,s + CNr)14 C = .5, arbitrary constant A = buildung cross section A = building cross section normal normal to wind, m' ga ,5,g, ,1 4.12 Coneontration for Exposure Times of 4.2 Downwind Diffusion From Continuous 2 24 Hoare. The following general equations Ralease. The following general equations are are recr=nmanded for calculating downwind recommended for calculating downwind concen-concentration for periods greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> tration from continuous point-source relemas_of but less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

) radionuclides. Consistent corrections may be made to the equations to account for Sector averaging over a 22.5' sector for this radionuclide decay during the transit time to longer duration exposure is taken into account the dose point-but values of necessary parameters shall be con.

4.2.1 Concentration, Expoenre Times Lees sistent with Pasquill condition F and a wind Than 2 Hours. Values of' the n - ey speed of 1 m/s. Other Pasquill atmospheric con-parameters shall *be consistent with Pasquil condition F, with wind speed of 1 m/s. Other ditions should be used in cases where the F con.

Pasqudl conditions should be used in caess dition is not sufficiently conservative for elevated releases.

where the F condition is not mihiantly con-servative for elevated releases. The general ex- X = 2.a32 Q ers (-- M'M CIAsa pression for plume matarline concentration II e, x from a continuous release is:

where x, Q ,,, _

h2 x = distana from release point to done point, u r ey e, ,2d,,

A = efectzve height of elevated release, m where = o for ground releases.

X = concentration, C1/m3 Q = eauros strength, Ci/s Nam % mahods om demnmang de efanive height of ii = mean wind speed, m/s mismas and "ww ==he eseca as dison d la 4.2.1 may Fr * = standard deviation of ph me be und whom appimables Ba=Wm wake efece shall not be a the y, s, directions, m. These values can included for'espamme penods at smeur than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, be found on Fig. A.2 and A.3, T.LD. 4.2.2 Concentration, Exposure Times of 24 24190.[4] ~

Hours or More. In cases where diffusion h =" effective height of elevated release, estimates are sought for periods exceeding 24

) meters = 0 for ground release. hours, the equations shown in 4.2.2 should be i

5

\

' - page 8 of 9 American National Standard ANSI /ANS.15.71977 (N379) used but with the following less conservative at- leakage to the reactor building in direct propor- ,

mospheric parameters: tion to percent of failure of core, radioactive ex-Time Atmospheric Condition perunent, or fuel elemert.

1-4 Days (a) 40% Pasquill Type D, wind (3) Radioactive Decay. The effect of speed 3 m/s radioactive decay during holdup in the reactor l (b) 60% Pasquill Type F, wind building or other buildings may be taken into  ;

speed 2 m/s amount-greater (4) Engineered Safety Features. The than (a) 33.3% Pasquill Type C, wind reduction in the amount of radioactive material 4 Dag speed 3 m/s available for leakage to the environment by (b) 33.3% Pasquill Type D, wind engineend safety featum may be taken into ac-speed 2 m/s count, but the amount of reduction in con-(c) 33.3% Pasquill Type F, wind centration of radioactive materials is evaluated speed 2 m/s on an individual case basis. The reactor .

. bmMing leaks at the leak rate incorporated, or to be incorp ora ted, in the tecnnical specifications for the duration of the accident.

8. Biological Factore

5. Criteria for Radionuclide Release 8,1 Inhalation Rates. For' internal doses, from the Reactor Building dependent on inhalation rates, the following The assumptions related to release of shall be used.5 radionuclides from the reactor core, a radioac.- (1) Imes than 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s- Breathing rate will be tive experunent, or a fuel element will depend 3.33 x IP cubic meters per second (breath rate on the environment in which they fail. A failure durms working day only).

(2) Between 2 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Breathing rate g

i in a water environment for example would not lead to the same assumptiwis as a failure in air. will be 2.58 x 10d cubic meters per second The design basis acx:ident must address the (averaged breath rate for work day and resting).

failure environment either implicitly or ex. (3) Greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Breathing rate plicitly. If the failure is subject to radionuclide will be 2.64 x 10d cubic metere per second transport directly to the air and actual data do (averaged daily breath rate).

i not exist, the fcilowing ===imptions shall be I

used. 8.2 Iodine Conversion. The iodine dose (1) Radioactive Iodinee. Twenty.five per. ' conversion factors are given in ICRP cent of the equilibrium radioactive iodine inven- Publication 2, Report of Committee II "Per-tory developed from maximum full power mi==ihle Dose for Internal Radiation",1959.[6]

cperation cf the core, a radioactive experiment, or a fuel element is immediately available for 8.3 Cloud Dimensions. External whole body leakage to the reactor building in direct propor- doses may be calculated using " infinite cloud" tion to perant of failure. assumptions (the dimensions of the cloud are Ninety.one percent of this 25 percent is in the ""nu to be large compared to the distance form of elemental iodine, 5 percent of this 25 (mean free path) that the gamma rays and beta perant is in the form of particulate iodine, and particles travel). Other more refined analytical 4 percent of this 25 percent is in the form of uniques may be used and are required for organic iodines.[5] elevated releases close in.

(2) Radioactive Noble Gases. One hundred perant of the equilibrium radioactive noble gas 'honalum m dmioped from tfm Rosiert oMm Task Greg on Refemnes Man. International Commitsee on inventory developed from maximum or full Radiation Protection. Publication No. 23. 1975, Pergamon power operation is immediately available for Pream, Oxford. New York. Tomata, Sydney. Bamnachweg.

6 -

' paga 9 of 9 American N:tional Standard ANSI /ANS.15.71977 (N379)

7. Referencee [4] Table A.1 Meteorology and Atomic Energy.

) [1] Title 10, Code of Federal Regulations, Part 1968, T.I.D. 24190, National Technical In-formation Service, United States Depart.

100, " Reactor Site Criteria Appendix A - ment of Commerce, Springfield. Virginia.

" Seismic and Geologic Siting Criteria for [5] " Review of Organic Iodide Formation Un-Nuclear Power Plants," Government Prin- der Accident Conditions in Water-Cooled ting Omce, Washington, D.C. Reactors, October 1972-WASH 1233 (UC-

[2] National Council on Radiation Protection 80), Superintendent of Documenta, United Measurementa Report No. 39, " Basic Scates Government Printing Office, Radiation Protection Criteria," January, Washington, D.C.

1971, NCRP Publications, Washington, [6] ICRP Publication 2, Report of Committee D.C.

II " Permissible Dose for Internal

[3] Abridged Modified Mercalli Intensity Radiation," 1959. Pergamon Press, New Scale, After Wood and N=mann (1981). York.

Abstracted from USAEC Report: ORNL-TM-2900, "An Interpretive Review of 9-=4 Design Methods," May 1970.

National Technical Information Service, United States Department of C--- cs,

• Sprasfield, Virgmia.

t

) .

I l

)

7

Exhibit C-IV-2 paga 1 of 3 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0pei!SSION ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of -

i Docket No. 50-142 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA (Proposed Renewal of Facility License)

I' (UCLA Research Reactor)

~ AFFIDAVIT OF RONALD L. KATHREM I. . Ronald L. Kathren, do hereby depose and state:

1) I am a staff scientist employed by Battelle, Pacific Northwest Laboratory in the Occupational and Environmental Protection Department. A statement of E professional qualifications is attached to this affidavit.

2) I hava read " Interrogatories jTo S. C. Hawley, R. L. Kathren and M. A. Robkin As To ' Analysis of Credible Accidents for Argonaut Reactors' NUREG/CR-2079 PNL-3691". The responses that follow explain or interpret the research or results from NUREG/CR-2079, of which I was a principal author and which is based on research at the Pacific Northwest Laboratory operated by Battelle Memorial Institute. My responses are ntebered to correspond to selected interrogatories.

3. Examination of the references listed on pages 53-55 of the report will showthespecificworksused;;byreferringtothedatesofthese works, it can be readily be ascertained which of these have been i published since the late 1950's. Numerous others were, of course, also consulted. In addition,-the lack of reported serious or otherwise significant operational accidents at Argonaut reactors,

i pago 2 of 3 statement of the section entitled " Core-Crushing Accid::nt" was 1

included to. enable the consequences of such scenarios to be readily '

i determined, if desired. Also note that the whole body dose equivalent l I

should be 0.066 rem, rather than 2 rem, as noted in the errata to the report.

91. The x/Q value of 10-2 was selected as being the maximum credible value; the downwind distance at which this value might occur is site and time specific. The report assurned that this value to occur at the location of a downwind observer irrespective of the distance of that observer from the point of release.

SECTION II B(1). A current resume and statement of professional qualifications for R. L. Kathren are attacned to this affidavit.

B(2).

Affiliate Assistant Professor of Radiological Sciences, University of Washington, Joint Center for Graduate Study, Richland,1978 to date; Coordinator in Radiological Sciences, Joint Center for Graduate Study, Richland,1980 to date. Sve also given occasional lectures / seminars at the University of Washington, Seattle, in Radiological Sciences and Environmental &alth classes and have taught continuing education classes through Joint Center for Graduate Study, Richland.

See 3(2) above.

B(3).

B(4). My professional acquaintances and associations are many, and I am i

unaware of the specific background experience of each nor am I cognizant of the current or past staff of the five Argonaut facilities. Needless to say, I am acquainted with some members of the staff at the University of Washington Argonaut reactor. If specific I names of interest are provided, I will endeavor to accurately identify the nature of rny association with each.

i l

a

~ .

l

,. . pago 3 of 3

3) I hereby certify that the preceding information based on research

~

conducted in connection with NUREG/CR-2029 is true and correct to the best of my knowledge and belief.

f -

_b K -

Ronald L. Kathren Subscribed and sworn before me on this Y day of April 1982.

YY.Wldlu/

mtAry % lic i ' My commission >expims: /[itO /( /974~

i I

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Exhibit C-IV-4~ paga 1 of 1 Tacle 2-15 DESIGN 3 ASIS ACCIDENT OIF:USION COEF:ICIENTS WIB NRC STANDARD METEOR 01.0GY 3 .

DISTANCE DIFFUSION COEFFICIENTS (sec/m )

(miles) 0-8 hours 8-24 hours 1-4 days 4-30 days 0.1 1.0 E-02 3.0 E-03 1.3 E-03 3.5 E-04 0.2 4.5 E-03 1.0 E-03 5.5 E-04 8.5 E-05 0.3 2.2 E-03 6.4 E-04 2.7 E-04 4.4 E-05 0.4 1.4 E-03 4.0 E-04 1.0 E-04 2.5 E-05 0.5 3.0 E-04 2.5 E-04 7.0 E-05 1.5 E-05 from University of Florida's SAR 2-60 ,,

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l Nuclear Reactor Safety On the History of the Regulatory Process t

i David Okrent j _ _

7 5

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The Unisosity of Wisconsin Press P S

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NI"cLEA2 RE ACTC S FETY Rcarror Sirmg Before 1%f 33 y 4 .

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fected by errorsin safety analpes and judgment of ahe re. actor assembly. It stands as permtent subsiding motion in the atmosphere :here. Air eittmed by this descent, a visually obsious and intuitisely attractise bulwark against the possible conse-contacts the coasts! witer surface chich is cold as a result of upwelling. Hy this i mechanism an ins ersion is formed.a nd t he sir la)er ettending up lo a few thousand quences of errors in reactor design, malfunction and misoperation which are admittedly present in any human undertaking. feet abose the surface becomes a trap for air pollution.  !

[. I

• Whereas persistent poor dispersion Istagnation) conditions of meteorology.

la should be noted that the maximum credible accident approach was not { lasting ses cral days, may be espected on the as erage once per year an> w here cast of unisersally accepted. For example, at the 1964 tlnited NationcAtoms for j the Rockies. the frequency of such episodes in the Southern Cahfornia coastal strip is of the order of sescral per month. For example,during a two-3 car period, from Pe:ce" Conference in Geneva, F. R. Farmer of the ilnited Kingdom gave a .,

July 1956 theough June 195N, the I os Angeles weather was of ahe" smog warning" paper (Farmer 1964) in uhich he pointedly attacked the concept of he -' t> pe 164 days.

ma ximum credible accident, especially for use in a ny com parison of ditfer- In selecting a site for a high power reactor, consideration should be gisen to an ent reactor types. In particular, he emphasized the arbitrariness uhich is .

adequate excluu a radius and the population density, not only in the imraedicte inevitably ins ols ed in the selection of a n M CA. Fa rmer went on to emphas-  ! sicinit)_. fne to ten miles. but also f r greater distances. Obsiousis the lower the s

ire the importance in the future of a comprehensise safety assessment and y population density the better. T he meteorology of the Southern CaIifornia coastal not merely a study of a consequences of a few selected major faults. i strip is so unfavorable for dissipating polluta nts that t his arca should be as oided ifit At the nineteenth meeting September 10-12.1959,the AC RSdiscussed } is coupled with a high population density. In theory a reactor can he so designed, the Pathfinder reactor and the Carolinas-Virginia Tube Reactor IC\ T RI { constructed, and operated that it will offset ihe unfasorable meteoroloFy and high and put in w riting a position it had taken on several pt erious cases. namely- j population density. Because of the present hmited experience with the operation of that it lacked sufficient information with regard to certain design features j power reactors a nd the larFe power les cl ofihe proposed reactors the prosision of an adequate degree of safety in practice may require an extreme of consersatne to arrive at a conclusion concerning construction of these plants. When one y design and containment.

considers the very limited information (by today's standards) which was ,

presented for those reactors on which the ACRS decided it could act, the -l

.L Not surprisingly, the record of discussion within the ACRS itselfindi-information on these reactors must have been sery sketch).

3 cates divided opinion as to how satisfactory the souther.n California coastal

^f area was for reactors of appreciable power. Some members beliesed that The First Review of Caliform,a Sites { very good containment, together with vaste retention such that routine I releases would occur only under ideal weather conditions, would eliminate On March 5,1960.the ACRS held a special meeting toconsider a reque3: '

jg restrictions duc to unfas orable meteorology. Iloweser. this did not appear by A. R. I.nedecke. general manager of thc AEC,for adsice concerning the to be the consensus of the committee, which felt then that meteorology was possibilitv of siting some relatisely large I.WRs(1,000 M Walin California.

~

l a principal ensironmental consideration for a reactor accident in southern Excerpts follow from the ACRSletter of March 6.1960,to AEC Chairman California. The ACRS of that day appeared to be fairly unconcerned about McCone: the difficulties of building a reactor only one mile from a fault.

4 With respect to scismic considerations, we understand it is present utility industry practice in California to locate generating stations at least one mile from known

{

y surface faults and to design and construct these stations using h> cal codes supple-5 ACRS Rejection of Two Sites 8g mented by sper il analyses and increased scismic design factors for those critical l Soon after,at the twenty-fourth meeting. March 10-12,1960,the ACRS to plant components necessary o maintain ihe station on the line. In addition,in the revieued and rejected the proposed 40 MWt reactor at Point 1.oma (San g c se of a nuclear reactor facility, special analyses and increascJ seismic design Diego) California. It appears f rom the ACRS minutes that Dr. Beck of the ,9 frctors tre needed for those reactor plant systems uhose failure could result in a regulatory staff did not feel that the Point Loma site needed to be rejected, release of radioactive material. With these precautions the Committee belies es the although he conceded that it was r.ot a s ery good site. Beck appeared io feel reIctor facility would be adequately protected agairwt seismic disturbance. ,

Referring to the frequency of insersion conditions, the situation of the Southern ,a that the unfavorable meteorology and the unfavorable hydrology (which CLlifornia coastal strip (south of San Francisco)is essentially unique in the U nited  ; I related to the limited rate of ocean flow to remove routine radioactivity St:tes. The semipermanent Pacific high pressure area induces a slow,large-scafe, releases) could be dealt with by appropriate containment. Ilowescr th'e

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Ballinger Publishing Company

• Cambridge, Mass. W' A Subsidiary of J.B. Lippincott Company '

t 24 Nuclear Thtf t: Risks and Safeguants O Nuclear SVemons ]5 levels can he stated in terms of the Klint, which is related to the Ibsentgen, a Icw days is almut a doren milligrams (tlumsandths of a giam). All these unit of ten used for measuring x-ray dosages. A radiation exposure of alumt live i esiinutes, particulady flusse related to sluntening id lih foim lung iancen me lumdred Riiht of eitlier gamma rays os neutions absoihed over a tiessmfs enlue j imceslain, pantly because the sessmses of dificient individiuls to the same doses Imdy (a so-called "wtude body" dose) would kill lulf the people so exposed

• of plutonium are hkely to vary consideraldy, l'on pngeses of this discussion, within a few weeks or less. A radiation Jose of almut 1,(KM) Riiht wouhl kill gwticulaily for comguaisons with olhes toxic substances, we assume slut lifty alnmst all the people expised. The piompt radiation is ecleased so sapidly that micsograms of plutonium-239 sepsesent a " lethal" dose, i e., the anumnt slut these would not he time foi geogde in the vicinity of the explosion to take cover wouhl be vesy likely to cause eventual death if it weie inteinally absoibed.

In shelless or behind buildings.

In terms of the total weight of nutesial that sepesents a lellui dose, Delayeti radiation fium line fallout of a nucicar explosion coulti plutonium -239 is at least 20,0(X) limes nune toxic shan cobra venom os delives leilial doses lo people wlui senuin in the open whe:e radioactive dehnis intassium cyanide, and 1,00() times nuue toxic liian lieroin ni imideen nesve lus scilled long enough for them to ecceive a total dose of roughly 500 lllikt. gases. It is probably less toxic, in these same teams, ilun lhe loxins of some The ranges of distances indicated in Talde 2-1 for radioactive fallout aie based especially virulent biological organisms, such as anthrax genus.

on the assumptions that the wind velocity in the area is alumt live miles per The anmunis of piuttmium that cimid mse a threat so society aie i

lumr, and that exgused geople remain within the area for one lume, for yichts accordingly very small. One hundred giams (lluce and one half ounces) of this less than one kiloton, increasing to twelve imms for a yield of one megaton.

nutesial could be a deadly risk to everyone wo: Ling in a lange of fice building or lhese distances are the most uncertain of any shown in the table, since theY factory, if it were effectively dispersed. In open air, the effects wouhl be nune depend strongly on the hical weather condilions, the amount and characteristics dduled by wind and weather, but Ihey would still he serious and long-lasting.

of the smface mateiial aliat would he picked up in an explosion's fischall and The quantities of pinionium that might prmluce severe lunnds in later deposited on the ground, the extent to which people would be able to take Luge areas ase sumnurie.ed in Ilie very crude estinutes presented in Table 2-2.

cover or leave the area quickly after an explosion, and many other factors. To estimate the areas within which people might he eximsed to lethal doses The distances indicated in Table 2-1 for severe and moderate blast inside a buihling, we assume that dispessed plutonium is painuiily pin-danuge and cratering are considesably note predictable than the distances for tonium-239 in the form of an aerosol of finely divided particles distributed severe danuge by radiation. A peak overpressure of ten pounds per square inch uniformly in air throughout the buihlinF, We also assmne that eximsure of would he hkely to cause very severe danuge to almost all residential and oflice people to the contaminuled air is for one hour, flut ten percent of the inluled buildings, and underate danuge to heavily reinforced concrete buildings.Tinee particles ase setained in lheir lungs,and that, as stated cadier, the fell al setained imunds per squase inch wouhl cause sevese damage to wmid frame sesklential dose of plutonium is lifty micrograms. These comlitions might he achieved by buildings. carefully inermhicing the plutonium aenisol into the intake of a huihhng's air To sumnuiite, the hunun casiulties and properly danuge that conhl conditioning system. This might he quite dif ficult to do in nuny cases.

he caused by nuclear explosions vary widely for different types of explosions detonated in diffesent places. Nevestheless, it is clear that under a vasiety of Tatde 2-2. Lethal and Significant Contamination Areas for Helease circumstances, even a nuclear explosion one humhed times smallei tlun the one _. _ of Air Suspensions of Plutonium inside Buildings a that destroyed Ilimshima could lave a terrible impact on society. Sig,,ipeans ren,,ta,,,,,,ari,,,,

inhalation I.cthal Dose Requiring Some hacuati,m h A,nount of of Suspendal Alaterial a,ul (1ea,n,su RADIOLOG1 CAL WEAPONS Ifut,,niuria Relo,s,J

. . . . . _ _ . _ . . . _ . ._ __ -. __ _pre

_a i,s sqinarc s,,cta s/

_ prea ire squara tierscrif

_ D t gram -500 - 50,n00 __ 3 Plutonium Dispersal Devices 100 gums -50.000 -5.00n.mm We have alseady stated that plutonium, in the form ot, extsemely w small particles suspended in air, is exceedingly toxic. The total weight of An asca of 500 separe meleis(almut 5.00llsquase feellcunesimuds plutonium-239 which, if inhaled, would be vesy likely to cause dealli by hmg to lhe asea of one ihms of many typical ollice buildings. An area ut 50,1NNI cancer is not well known, but is probably between ten ami 100 micrograms square meters (abimt 500,000 squ;ne feellis compnable to the entiie floor aiea (millionths of a gram). liven lower intenul doses, pedops below one micsogiam, of a lasge skyscraper. liven a few grams of dispeised plutonium could lmse a night cause significant shoitening of a peison's life. The total metained dose of sciinus danger to the occupants of a rather large of fice huihling or enchned plutonium slut would be likely to cause death from libiosis of the lung within a industrial facihty.

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26 Nuclear Theft: Risks and Safeguards Nuclear Wenons 27 o I

The areas in which plutonium contamination wotdd he significant i People who absoih leihal imi not nussive doses of plulonium wonhl enough to acquire evacuation and subsequent decontamination are roughly suit sense any of its ellects for weeks,in peilups years. Tlie pesence og gine;y estinused to be alxmt 100 times the areas subjected to a lethal dose. Almut a 'ivided plutoniuni in an area could be detected only with sensihve sadi.ition

"'""il'"ing equipment. Such equipment is now indy used to nuinities die dozen grams of plutonium dispeised fluouglume the largest enclosed buildmgin F#^C"Ce 'if plutonium or other dangerously sadioactive notesi.ils in nuclean the woild might iaake the entire building unusable for the many weeks slut I"$'dUdhi"is. lixcept in such inslallations, thescfoie, people would not know would be sequired to complete costly decontamination operations. ,

they weie exp, sed until they were told, eithen by those sespmsible tin she The dispersal in large open areas of plutonium with lethal con.

centiations of radioactivity is hkely to be much moie difficult to carry oug fueat, or by soincime in aullunity who luppened to detect II.e plutonium with Inste nments.

cifeelively than dispersal indimes. The height of the affected rone wouhl be diflicult to hohl down to a few feet, liven a very genlle, two-mile-per hour We use not aware of any successini non-militasy allempts to use eniical, bactersological or radiological poisons to contaminate large aseas hiecie wouhl dispeise the suspemled nutesial several kilomeless downwind in an hether any such means will be used in Ilie future hn ceiminal or leninish lumr. 't his would nuke it extremely difficidt to use less than about one kilogiam P"' poses is, we believe, an even nune speculative question llun whether nuclean of plutonium to produce scrcre radiation haiaids. With a few dozens of grams of CXPl "sives well be so used. Many types of p>tentiall Y leilial po sons aic no mine plutonium, however, it would he sciatively easy to contaminale several squaic kilometers sulficiently to icquire the evacuation of people in the area and dif ficidt to acquhe flun chemical high explosives. lloweves, high exphisives ase necessitate a very dif ficult and expensive decontamination operation.

heing used with grealer frequency and in incicasing anumuts by lenosists and After the plutonium-hearing particles settled in an area,they wouhl extortsomsts, while we liave fimud no evidence that they lave eves used P"sonous agents. The practically instantaneous, quite obvious destruction llus renuin a potential luzard until they were leached below the smface of the giound or weic canied of f by wind or surface water drainage. As long as the ss luoduced by an explosion appuenlly bettes snits the purpnes og teoosists and extortsomsts than poisons llut aci nuire slowly'and subtly, hui slut aie at particles senuined on the smface, something might happen to draw them hack into the air. Contamination levels of about a microgram of plutonium per square least as deadly. linlike other piisons, however, pinionium can he used cither as a meter wonid he likely to he deemed unacceptable for public health.Tims,in an P"is"""' as explosive material. Accordingly, a llueat using a plutunium dismi mhan area with little rainfall, a few grams of plulonium optinully dispeised oug device could conceivably be siilhiwed by a llucal mvolving plutonimu useilin a smclear explosive, of doors might sesiously contaminate a few square kilometers, but only over a very much snuller area would it pose a letici alueat.

So far in our discussion,.we have considered only plutonimn-239, other Types of Radiological Weapons

. As past of our research lin this study, we considened,in some detail the isotope of plutonimn alial is p oduced in the largest quantities in nuclear the ellects that nught he produced by dispersing sadioactive nutenials othei Ihan -

scactms. Plutonium-238, which is also nude in significant quantities in smne ieacto s, is consiilerably nuue toxic than plutonium-239. Its Iulf-life for plutonium. or by pmpisely pdsing vmious p W' mluu mg %,

'",destniction without achieving a real nucleas explosion. We conclude that emitting alpha pasticles is or.ly about eighty-seven years,instead of about 25,1NM) D'

"'88hef 8ype of weapon would he as effective as a plutonium dispeisal device on years; one giam of plutonium-238 therefore emits alpha particles at approxi- a low.y,i eld fission bomb.

nutely 3(M) times the rate that plutonium-239 does. As a result,the lethal dose Spent nuclear reactor fuel and the lission pmducts alunated hom of phitonium-238 is ahimt 1/300 of what it is for plutonium-239. We mention reactor fuels at a chemical reprocessing plant are, imlentially, exlremely this because plutonium-238 has been used in radioisotope-powered nuclear "hatteeies," and is being seriously considered for use in power supplies for heart u/anlous af dispersed in a pipulated asca. ling they would also be veiy h dangerous to fundle in sulheient quantities to pise a Ilucat to a lange asca punps in people suffering from centain types of heart disoiders. As much as sinly grams of plutonium-238, the equivalent in toxicity of alnmst twenty ["ccause they emit highly penetrating ganmu rays,ihm n ph% im Mg p utect shieves or weapm makens,in shos t, emtoninan wonid be casies to use Aibgmms of plutonium-239, nuy he in each such heart pump battery. 'this is 4 i estnictive pmposes than radioactive fission podness.

enough nuscrial to produce serious contamination of hundreds of square miles, Il a nucleas reactor cose weie pdsed to destmclion,it would selease if dispeised in the form of snull particles.

a comparatively suull amount of ene:gy equivalent 10, at most, a few hundo d A varicly of ways to dispense plutonium with timed devices aie conceivahic. These would allow the threatener to leave the area hefuse the l]" nils of high explosive f om a device weighing sevesal lons. It wonid als te me announts of radiation and radiiuctive nutesials that would be veiy snull nutesial is dispersed. Any plutonium contained inside such a device wimid not conipaied lo a low.yichl maclear exphision unless the scaclor lud been operated be a hazard until it was released. _~

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=24 i%LlluRNtt March 10,1965 Director, Division of Licensing and Regulation U. S. AtomicD.Enena washington, C. y Commission ..g, 20545 ." " 'ubW. ('('} '.

Dear Str:

pg csEG LM On the evening of March 5,1%5, while work was in progress around on open apparently received o dose -

of, ongammo en ployee rodiation The beam was tightly collimated and struck the ofmo section 4 Rem.

below the sternum.about 2 inches obove the pubic bone and extend His film bodge was located on his belt above p. his left hiup periment wm being loaded into , ando beam port.The a comr>licated ex- expo been meowr d and was knownThe the opercrien that result 3d in th3 overexposur.

to be dose 50mte R/hrin the boom had Five employees were ervraged i e.

nature of the operation, the ::cH member who wa fSecouse of the complicated physicist allowed himself to be dmwn into progress.

pationactual in t porticis unctioning o Thus, for o pericd of several minutes all supervision offected employee intercepted .

During the this intervalbeam the with hisI right his of the dosimeters. emergent beom. When this was s while noticed worki just to the ed to rood was therefore token off the job and his film . bodThey were foun The employee possible, which was on the Monday moming following the ige was dev ncident.

the calendor quarter.This mon will not be permitted to work in radiation as for the remainder of a qualified supervisor who ngiseinunder not the the work.

engoged direction of in partic we will exercise every effort tos prevent .

ncident, and that its repetitionP

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. D. Mo T. E. Hicks, Directorain', Chief Supervisor oly ec: Engineering Nu'elear Reactor y j 4.,[Qff.

Monoger, Jun Francisco Operations Office, AEC 3 ' 9, y g;

/bl C. Erecd:, Radiological Sofety Officer, UCLA J. ,

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I l page 1 of 1 Exhibit C-IV-9 4 University of California Los Angeles, California Nuclear Energy Laboratory RADIATION USE COMMITTEE Minutes of the Meet:.ng of December 12, 1975

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The meeting was called to order by Dr. Kastenberg. Other committec members present were Dr. Apostolakis, Mr. Ashbaugh, Mr. Hornor, and Dr.

Okrent. A quorum was present. Mr. Ostrander was also present.

Mr. Ashbaugh outlined the evidence indicative of an encapsulation failure of the radium-beryllium reactor start-up sourec. He said that unusual alpha emitting radioactiv'ity had been found in the reactor process pit and that gamma ray spectroscopy had identified radium decay products lead-214 and bismuth-214 among the constituents. He estimated that the steady state radon-222 production could theoretically provide a concentration of 3.97 x 10-9 pc/ml when diluted by the present ventilation air system rate. However he noted that by limiting core ventilation to periods of no more than a few hours attending reactor operations, then under nony'en-tilation conditions, decay of radon during escapc might reduce concentration below the maximum permissibic concentration of 3 x 10-9 uc/ml. Mr. Ashbaugh sought committee approval for continuing modest operational levels through s

.Q December 19 in order to honor current committments and to collect further data. The reactor would then be shut down for removal and examination of the radium-beryllium source in early January.

Dr.Okrentnotedthattheslteadystater'cleaseofradonwouldprovide '

an equilibrium mixture of the successive decay products. Heaskedwhetherkhc ,

Federal Code of Regulations placed limitations upon all of the constituents.

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Mr. Hornor replied that in his interpretation, the daughter products were a natural consequence of the radon release and that this was implicitly recognized in setting the radon release limit at 3 x 10-9 pc/ml. '

Several members participated in a discussion of whether reactor oper-ations influenecd the radon relcare rate. The difficulties of sampic ac-quisition during operations were briefly mentioned. It was concluded that although thermal expulsion might occur, reactor operations would not alter the radon creation rate, but that the relcase rate might be influenced by the core ventilation tactics, i t

Dr. Okrent suggested that intercrystalline diffusion of radon within the source should be reviewed to evaluate the potential delay-decay effect upon actual releases of radon. '

Mr. Hornor said that State ' License regulations should also be considered in addressing the question of permission to continue operations for even a limited period of time.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINC BOARD In the Matter of Docket No. 50-142 THE RECENTS OF THE UNIVERSITY

& CALIFORNIA (Proposed Renewal of Facility License)

(UCIA Research Reactor) l DECIARATION OF SERVICE I hereby declare that copies of the attached PREFILED TESTIMONY j POR THE T NHER ENT SAFETY HEARINGS l in the above-captioned proceeding have been served on the following by deposit in the United as indicated, ce thisStates date: mail,14,first June class, postage prepaid, addressed 1983 .

John H. Frye, III, Chairman Christine Helwick Atomic Safety & Licensing Board Glenn R. Woods U.S. Nuclear Regulatory Commission .

office of General Counsel 390 University Hall Dr. Emmoth A. Imebke . 2200 University Avenue Admindstrative Judge Berkeley, CA 94720 . _ -

Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Mr. John Bay Washington, D.C. 20555 3755 Divisadero #203 San Francisco, CA 94123 Dr. Glenn O. Bright Administrative Judge Atomic Safety and Licensing Board *Ms. W Naliboff Deputy City Attorney U.S. Nuclear Regulatory Commission City Hall Washington, D.C. 20555 1685 Main street Chief. Docketing and Service Section **

Office of the Secretary Dorothy Thompson U.S. Nuclear Regulatory Commission Nuclear Iaw Center ,

h ahi"6 ton, D.C. 20555 6300 Vilshire Blvd., #1200 Ios Angeles, CA 90043

• Counsel for NRC Staff -

U.S. Nuclear Regulatory Commission WeeMn-ton, D.C. 20555 attention Ms. Colleen Woodhead

• William H. Cormier Ms. Carole Kagan, Esq.

Office of Administative Vice Qiancellor Atomic Safety and Licensing Board Fanel University of California U.S. Nuclear Regulatory Commission 405 H"s"d Avenue Washington, D.C. 20555 Los Angeles, California 90024 ,

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• by express mail , nNI -

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Daniel Hirsch President CCMMITTEE TO BRIDGE THE G D

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