ML20064K257

Affidavit of Le Foster.Results of Radiation Monitoring Program Established by UCLA Unreliable.Even If Data Was Reliable,Radiation Doses to Public Unacceptable from Safety Standpoint.Prof Qualifications Encl

ML20064K257
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Site:	05000142
Issue date:	01/07/1983
From:	Foster L COMMITTEE TO BRIDGE THE GAP
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UNITED STATES OF AMERICA 6 NUCLEAR REGUIATORY COMMISSION a 9-- d44 BEFORE 'lHE ATCMIC SAFETY AND LICESING BOARD C D

\ a A 1 In the Matter of (

Docket No. 50-142 '

s THE REGE!frS & THE UNIVERSI'N OF CALIFt)RNIA (Proposed Renewal of Facility License)

(UCLA Research Reactor)

DECIARATICN CF LOUIS E_. FCSTER I, Louis E. Foster, do declare as follows:

1. From 1975 through 1979 I was employed by the Nuclear Environmental Services Division of Science Applications, Inc. My duties were pri!rarily in radiation safety and environmental protection in and around nuclear facilities.

These duties included implementation of radiation monitoring systens at nurrerous nuclear power plants throughout the country. A statement of professional qualifications is attached.

2 In cooperation with colleagues at the Southern California Federation of Scientists, I have reviewed existing radiation monitoring data from the UCLA research reactor.

~) . Based on that review, I have concluded that the results of the radiation monitoring program established by UCIA are not reliable as to their accuracy.

Furthermore, even if one assumed the data were reliable, the results indicate radiation doses to the public that are unacceptable from a safety standpcint.

In other words, the' data acquired and the estimates rade by UCLA to date are suspect because of inadequate mor.itoring and calibration practices and faulty nenitoring program design and dispersion model design. But even were the data correct. the doses indicated thereby are unacceptable from a public health standpoint, and clearly violate the requirements to keep radiation doses As Low As Reasonably Achievable (ALARA). Significant reductions 8301180344 830112 PDR ADOCK 05000142 G PDR

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in radiation exposure are rea's onably achievable at this facility through I any of a number of means, and the radiation monitoring prc6 ram and calibration [

programs need very significant improvement before adequate protecticn of i the public could be considered to te reasonably provided.

4 Although questions had been raised by the Atomic Energy Commission atout the adequacy of UCLA's Argon-41 monitoring system, arri the ability to keep the Argon-41 effluents within permissible limits, even before the reactor received its initial license in 1960 and at various times I thereaf ter, it was not until the reactor had been operating for fif teen years that the Cor.ission learned that calibration and instrumentation errors had led to a gross underestimation of the Argon-41 effluent concentration.

Inspectors had determined (1) that UCIA had lost its maintenance log, which included the calibration procedures and methodology of its derivation, and (2) that UCIA had failed to calibrate the radiation monitors at the required I

intervals. Both of these were serious violations with potential for l impacting upon public safety. To compound the problem. UCLA notified the NRC that it had initially detected a factor of 10 error in the calibration of its Argon-41 monitor, but stated that they were " convinced these calculations are correct." (inspection report 75-01, p. 7). However, further recalibration and re-instrumentation led to the finding that the error was actually of several hundred-fold. (see letter of Charles E. Ashtaugh III of UCLA to David Jaffee of NRC, dated April 23, 1975, correcting previously reported annual effluent release , by a factor of between 200 and 400. ) The estimates of actual Argon-41 concentration at the point it enters the environment were revised to approxitately 2 x 10-5 pc/ml, as opposed to the previously reported concentration of 6.8 x 10~b pc/ml. ( Ashbaugh letter, ibid. )

The level is currently estimated to te around 1.65 x 10~0 (St.R p. 11-5).

5 The Faximum Fermitted Concentration of Argon-41 is 4 x 10" pc/ml l (10 CFR 20, Appendix B. Tatle II). 'Ihus , the calibration and instrumentation errors put the emitted concentration far in excess of the F.FC (over 400 tines FIC, if one uses the 1.65 x 10 -5 concentration, higher even than that if one uses the Ashtaugh figure).Y The URC, correctly, found UCLA to be in violation of 1

both its Technical Specifications and the requirements of 10 CFR 20.

(See memo of enforcement conference. April 2?.1975, in docket).

M In addition to the calibration and maintenanca leg problems, the University j wac cited for the stack being too short, the accelerator nozzle removed, and failure to dilute the effluent to 14000 CF):. Cnly the last iten has been corrected.

_ - . - - .- . - - . - - _ _ - . _ - - = . _ _ _ _ -

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6. It was determined that annual averaging was permissible, so a reduction factor of .188 was approved to reflect the licensed utilization limit 4

(p. 3, Safety Evaluation, NRC Office of Nuclear Regulation, for Amendment 10 to the license). Thus, concentrations of Argon-41 at the point of entry into the environment (the only place where those concentrations have actually l been measured), even when annual averaging is factored in, would remain 1.65 x 10 -5 x ,1gg . 3,1 x 10-6 Thus, even when averaged over a year the concentration remains approximately 78 times the_Jaximum Permitted Concentration of Argon-41, as defined in 10 CFR 20 Appendix B.

7. The University asserts it may ignore the concentration at the point where the effluent enters the environment and add a further reduction factor for presumed dispersion of the pl.ume before it passes the wall of the Eath Sciences Building, a few feet fron the reactor stack. 10 CFR 20.106 (d) expressly indicates that the concentration is to be determined, for purposes of complying with the Appendix B MFC limits, "at the point where the material leaves the c onduit." Only where the conduit is located in a restricted area, as defined in 10 CFR 20 3(a)(14), can dispersion factors te includeds the reactor roof area where the stack is located is not a restricted area

) as so defined, in that essentially nothing prevents public access to the area.

As noted in "The UCLA Reactor: Is it safe?", there are seven unlocked doors and two elevators that open onto the Boelter Hall / Math Sd ences roof complex, and the roof area contains planetarium, meteorolcgy labs, observatories, a seminar room, and even a public restroom. It is not a locked or fenced-off j roof top but rather a public, readily acceseible location. The concentration must be considered at the point it leaves the stack and enters the environment.

8. But, assuming for the sake of argument that one consider dispersion to the area the University argues is the bouLdary of the restricted area, the nnarby Math Science Building wall, the concentration at that point remains many times the Maximum Fermitted Concentration. UCLA calculated dispersion

according to the standard NRC dispersion model for such releases, determined the dilution factor to be .115, which the NRC approved in granting Amendment 10.

There are some non-conservative elements in this calculation, particularly tecause the dispersion model begins at distances greater than 100 meters and UCLA's extrapolation to the much shorter distances in this case may tend to overstate the amount of dispersion that actually occurs. However, taking UCLA's calculated dispersion factor, based upon the NRC model and approved by the NRC 3taff, the concentration en the Eath Sciences roof would te

~7 3.1 x 10 uc/ml x .115 = 3.6 x 10 uc/ml. This is nine times the Eaximum Fermitted Cencentration of 10 CFR 20

9. A student associated with the UCLA reactor attempted a student project to demonstrate the conservative nature of the dispersion model used. (It should be noted, of course, that a dispersion model for safety analysis is supposed to be conservative. ) Dr. Lyon has, in his declaration, provides a summary critique of the Rubin student project, with which I concur. The study can, perhaps, provide some level of support for the appropriateness of the original dispersion calculation used in obtaining Amendment 10, but it most assuredly cannot be used to substitute for it or for true ' measurements of the Argon-41 in a controlled, scientific study.

10. UCLA was required to undertake a TLD study to cenfirm the conservatism of the Amendment 10 calculations. Unfortunately, the TLD data indicate doses still most uracceptable from an environmental protection standpoint and very nuch above ALARA. The study is flawed (as Dr. Lyon notes, the use of a " control" hundreds of miles away when the nearby TLD on Fauley Tavillen read consistently lower is hard to fathom). However, taking the rmdings, which were consistently substantially above even the 3unnyvale "inckground" quarter after quarter at virtually all of the locations surrounding the exhaust stack, doses of about 130 mrem / year gamma are indicated at the licensed level of opezation (approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per 45 hour5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> work week).

l We beta dose, as we shall see below, would add substantially to that.

But, even taking the University's reading and 1 6noring beta radiation, doses equivalent to about 4} additional chest X-rays per year are indicatedi put another way, doses 26 times the limiting conditions for the big power reactors I used to do radiation monitoring for. This is far in excess of

] ALARA, and significant reductions are readily achievable.

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11. Film badges at the stack read 425 mrem per year teta radiation (Application, T. II/2-la), which would indicate considerably higher teta doses at the authorized operating level of 438 full power hours per year.

The Annual Peport for 1979, p.15, reports a correlation between the hi6h teta reasurements on the film hadges and direct neasurements of 2-4 millirem /hr the direct measurements would thus indicate teta doses of from E76 to 1752 crem por year at the authorized operating level (2 x 438 = 876 4 x 438 = 1752).

Cbviously the teta dose will be substantial at otner locations as well.

An indication of how substantial will te given below.

12. The NRC 3taff, in addition to (a) employing a dispersion factor to red uce the effluent concentration when no such dispersion consideration is permitted due to the unrestricted nature of the area where the Argon-41 is released, and (b) using a dispersion factor two orders of ma6nitude less conservative than the official UFC regulatory guide mandates, further attempts to add a reduction factor for plume geometry. ho such reduction factor is permitted in 10 CFR 20 Appendix E, which they cite as their basis.

Furthermore, the source of their actual numerical value used for the reduction was not intended for the purposes to which the Staff are putting it.

But, given the fact that no reduction factor for plume geometry is authorized in the regulations, and given the fact that the specific reduction factor utilized by the 3taff is of questionable and undemonstrated validity in this situation, for the point of argument let us consider the result that would ensue from its use.

13 The NPC Staff, in the Attachment to the April 11, 1980, Ee morandum from Robert Reid to Samuel Bryan regarding CEG's charges on the Argon-41 na tter, estimates Famma doses of 24 mrem /yr inside the Iath 3ciences Euilding.

i One should note that this is 17 times higher than the dose estimated by i

the 3taff in the SER (p.11-6) for the roof area. It would mean that individuals within the Fnth Sciences Building, consisting of many hundreds of people, would have been getting the equivalent each of an additional redical chest X-ray annually, year af ter year, uhich is totally unacceptable, given the lack of medical benefit from such exposure, the risks involved, and the unnecessary nature of the exposure to tegin with. The calculation ignores a number of factors which tend to indicate far higher doses. For example, it ascumes that the only radiation received is from the Argon-41 in the room in which one is located, ignoring the contribution from the Argon on floors above and floors below and fron the Argon surrounding the building,

i

) some of which has clear line-of-site through office and classroom windows.

Argon-41 is a very strong gamra emitter, with a gamra intensity (1293 key) greater than that of Cobalt 60(1173) according to th: Handbook of Chemistry and Physics. NRC Staff Regulatory Cuide 1.109 (p. 69) indicates an attenuation factor to account for shielding provided by residential structures of 507 for the general public, less than that attentuation for the maxirally exposed individual. The Staff's assumption of 100% attentuation of the peretrating ganra is inappropriate, and thus their estimate based on the dose received from just the Argon-41 in the sane room, or even floor, is extremely low.

14 However, taking the gamma estimate of 24 mrem per yer inside Fath Sciences as put forth by the Staff lased on a correction factor of .03 for the plume size inside, what would be the teta dose?

As UCIA in its answer #8 (September 5,1980) to NRC Staff questions indicated, at MTC the gamra-teta ratio in a semi-spherical infinite cloud of Argon-41 is 3:1, for a teta dose at MFC of 127 reem/yr. As UCIA observes, "The -dose rate is largely due to the local concentration" and is therefore a simple function of the fraction, or multiple of MFC of Argon-41 within a few meters of the individual (because of the few meter range of beta in air). The Staff in its 24 mrem calculation assumed a stack concentration of 1.6 x 10 -5 uc/ce, a dilution factor of .115, and an operating factor of .05, producing a concentration inside Fath Sciences pulled in by the

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ventillation system of 9.2 x 10 , or 2.3 times the Faximum Fermitted Concentration, WITHIN the Vath 3ciences Building. The Staff was able to estimate a low radiation dose from such a concentration by only considering the contribution from the room or floor on which the individual was located, thus using a correction factor of .03, and by ignoring beta. However, the beta dose for such a concentration is, as UCLA indicated, unaffected by the plume size tecause the beta dose is of local origing thus the beta dose received by hundreds of people within that building would be, assuming the Staff estimate of 24 mrom gamra is correct, an additional 2 3 x 127 or 292 mrer/yr at the authorized level of operations (about 8 full power hours weekly). This would be unacceptable. So, even were the NRC Staff assumptions correct (and numerous non-conservative assumptions have been identified), doses that are unacceptable would be the result. (I note also that using the Staff calculation for within the building, gamra doses on the roof would be 5 times as high, or 120 mrem gamra, because Staff uses a plume size correction factor of .03 for inside the building and .15 for on top tecause l of the assumption of a larger plume outside. It is interesting to note that

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the actual gamma measurements by the TLDs are in very tight agreement with that figure; thus doses on the roof, by TLD extrapolation and from the NRC calculation, would be approximately 120 gamma and 292 teta, for a total of 412 mrem annually. This is all based on a series of very non-conservative assumptions by UCLA and the NRC Staff which are very questionable, so actual doses could be much higher, in the Rem range. As indicated earlier, concentrations on the roof, given the dispersion factor assumed by UCLA and NBC Staff in Arendment 10, are several times FIC.)

15 I would note also that UCLA's monitoring system is so poor that accurate readings just have not been made. The film badge system, for example, has minimum detection limits so high (20 mR for gamma and teta cach and 40 mE for neutron) that very significant doses would be reported as sero (particularly for the badges changed monthly; dvses of nearly a rem annually could be reported as zero. )

16. A few comments on UCLA dismissing the results of its own TLD program.

The TLD study was supposed to demonstrate that doses unmeasurable above bickground were being produced by the Argon-41 emissions and thus justify permitting the facility to release concentrations far in excess of the FTC.

Unfortunately, quarter after quarter and location after location, the recorded doses were significantly above background. UCLA first attempted to explain away the high readings by claiming other radiation scurces on campus (Nuclear Medicine, the animal incinerator at the Med School, etc. )

were responsible rather than the reactor. It has since settled on the assertion that the TLDs were picking up radiation from the concrete rather than the Argon-41 plume.

17. To attempt to " prove" this justification for rejecting its own measurements, UCLA has performed a rather childish exercise. It placed several of the roof-top TLDs on lead bricks, and placed others in cracks in concrete in a parkin6 structure. The :esults were what anyone who has even a rudimentary acquaintance with radiation monitoring would predict--the doses recorded on the TLDs placed i on lead went down, whereas the doses recorded on the TLDs in physical contact with concrete on several tides went up. UCLA says, CED, it is the concrete, not the Argon-41 plume, that is responsible for the elevated TLD readings on the Fath Science roof.

1

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18. What is wrong with this " experiment" need hardly be detailed.

Eackground radiation, of course, has two primary components--terrestial and cosmic. The cosmic component, obviously, affects a TLD from above, while the terrestial component, composed of radiation from soil, building materials, etc. , affects the TLD from below. Putting a lead brick under any TLD. no natter where. will cause the recorded dose to go downt because

the lead brick blocks out normal terrestial radiation.

19. If UCLA were to assert that the 40 mrem per year rcccrded above tackground by the TLDs (at considerably less than full licensed operating level) were coming from " hot" concrete (i.e. , that the concrete was 40 mrem more radioactive than normal back 6 round as seen by the TLD), then placing a lead brick under the TLDs must necessarily cause the elimination of the 40-50 mrem / year nornal terrestial conponent of background plus the 40 or so nrem/ year above background recorded by the TLDs and asserted by UCIA to be coming from the

" hotter-than-normal" concrete. In other words, for UCLA to be right, the TLD reading would have to go down about 80 mrem / year when placed on a lead brick, which would block out both normal terrestial radiation and the effect of the concrete.

20. Ecuever, UCLA's data show that the TLD readings only went down about 25-35 n. rem / year when placed on lead bricks, not the 80 or so necessary to prove them right. In other ucrds, the concrete, if anything, is less radioactive than normal background and cannot be the source of the elevated ILD readings.

I note also that the recent NRC Staff measurement en the Math Science roof reported in the June 9,1922, despite its questionable usefulness in determining Argon-41 doses (discussed below), does appear to demonstrate that the concrete on the roof is not a source of greater-than-background i

radiation, because the measurement made of background on the roof corresponds to the background used in the TLD study.

21. An additional word is probably not necessary about the TLD-in-the-crack-in-the-wall. It is well known that naturally-occuring radiciosotopes are foumi in concrete and that by placing a detector so that it is essentially in physical contact on all sides will elevate the recorded das e tecause of the geometry and physical proximity. To do so in a parking structure says absolutely nothing about the Argon-41 dose on the Ecelter/Nath Sciences roof.

_9_

22. The single measurement by the NRC Staff reported in the June 9,1982, inspection report is of little value. First of all, the measurements conducted at the thth Sciences air inlet are, by the inspectors'own admission, useless;for anything except a neasurement of background, because the wind was in the other direction then. The other measurement was conducted at an unidentified location. Without knowing where the measurement was taken, the geometry and shielding relative to the plume and so forth, the reading is useless. Furthermore, however, a single reading at a single location on a single day is of far less statistical significance than even one TLD, which integrates over several months, let alone a dozen or so pairs of TLDs with consistent results quarter after quarter.

23 A few other comments about that inspection report. That report makes clear that the problems identified in the mid 1970s--failure to' adequately calibrate, no calibration procedures, lack of familiarity with one's own Technical Specifications, underestimation of actual radiation releases and so on--continue to this day and appear to be actually considerably aggravated. The picture one gets of the radiation protection program at the UCLA reactor from this inspection report is one of a very lackadaisical approach to radiation protection. It is incomprehensible to me how a health physicist could get away for a year with calibrating devices without any calibration procedure, how not a single calibration label could match with the records, how supervisorial personnel would not catch the calibraticn errors, how a facility could operate without acceptance criteria, etc.

Terhaps the most telling finding of all is the lack of any reported exposure on the part of the health physicist, when his predecessor consistently j had such exposures and his duties are such that exposures would be inescapable if he was doing the monitoring required. The radiation protection program, the monitoring, calibration, ad=inistrative controls, otedience to regulations and license conditions, are all dangerously deficient, posing a substantial threa t to public health and safety.

24 I understand that the NRC Staff has asserted that radiation doses in the reactor room are about 1 mrem / hour. My review of the radiation data indicates that is incorrect by two orders of magnitude

, da+a indicates that that assertion is incorrect by tuo orders of magnitude.

The Application (p. III/5-5) indicates doses of 200 crem/hr. in areas of the 1

l reactor room. The annual radiation surveys that I have reviewed confirm this.

Furthermore, readings taken outside the reactor room (for example, on the 3rd floor above the reactor) indicate doses many times that asserted by the NRC 3taff as the maximum within the reactor roen. This is of concern particularly

, for the snack bar/ cafeteria a few feet from where these measurements were taken; I have seen heuever.no record of an attempt by UCLA to monitor in that populated area. There is also a substantial concern for the people in the offices and classrooms on the 5th floor above the reactor. The hourly doses recorded on the 3rd floor are the equivalent of many Rem per year, even if one assumes that the radiation is present only when the reactor is operating, which of course would not be the case. Even with attenuation through the floor, people on the 3rd and 5th floors could be getting very substantial doses, considerably in excess of regulatory limits.

25 Furthermore, as Fr. Pulido indicates in his declaration, there are a number of penetrations in the reactor room ceiling for airducts and the like; the doses streaming through those penetrations could be substantially hi 6her yet.

And when the experimental vertical holes in the reactor are opened, shielding rolled away, to insert or remove experimental samples, the dose could be extra-ordinary. The radiation exposure incident reported in the April 1965 inspection report involved an exposure of a worker to a 50 R/hr team from an opened port while the reactor was shutdown and an experiment being inserted or removed. Assuming 50 R/hr from such teams through the vertical ports uhen samples are loaded or unloaded, very substantial doses could te received by the people on the floors above.

26 In conclusions the monitoring at UCLA has been and appears to remain very inadequate. The calibration errors and other failures of the radiation protection system appear to put at risk substantial nunters of the public.

The concentration of Argon-41 in unrestricted areas, given the data available from the Applicant and the Staff, far exceeds the Fhxinum Fermitted Concentrations of 10 CFR 20 Appendix 3. Doses from the Argen-41 to members of the public far exceeds acceptatle levels and clearly is not as low as reasonably achievable. Camma and neutron " shine" fron the reactor likeuise appear to constitute a very si6 nificant public health threat, particularly to those en floors above. The attitude evidenced in the radiation protection record, and the lack of adequate managerial controls and supervision, are seriously deficient. The public health and safety has not teen, and remains, not well protected by the radiation monitoring and control program at the UCLA reactor.

I declare under penalty of perjury that the foregoing is true and correct to the test of my knowled6e and belief.

Aoi 9 Louis E. Foster Executed at Los Angeles, California, this day of January, 1983

i Statement of Professional qualifications LCUIS FCSTER My name is Louis Foster. From 1975 to December 1979 I was employed by the Nuclear Environmental 3ervices Division of Science Applications, Inc.,

involved primarily in radiation safety and environmental protection in and around nuclear facilities.

My duties at 3AI included implementation of radiation tenitoring systems to determine levels of gamma and beta emitting nuclides in effluent streams and in environmental samples.

I was assigned through SAI to implement radiation tonitoring systems at the nuclear power plants at Calvert Cliffs, Cyster Creek, Salem, Feach Bottom, Ihree Mile Island, Ginna, Indian Foint, Vermont Yankee, Main Yankee, Cuad Cities, Dresden, Zion, and others.

I have extensive experience in field and lab radiation measurements

] and quality analysis / quality assurance testing.

)i When I lef t 3AI I was the Technical Supervisor for the SAI field J research team involved with radiation safety monitoring as well as experimental research on radiniodine differentiation and concentration as part of the

Three Mile Island Unit 2 cleanup.

I received my Associate of Arts degree in Environmental Science and Technology in 1977 from Montgomery College in Faryland, and thereaf ter completed numerous courses at the University of Maryland relating to my

! radiation protection work at 3AI. Since 1980 I have been associated with 1 Citizens' Campaigns, Inc. , an organization concerned with energy ,

environmental and related issues.

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tt, a.M.'244f e April 11 3 -!p3

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%, .' '.'. . / m CE OF THE SECRET:,RY 9 0.C .

Uocket No. 50-142 l O /a Qar y

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-11 jay 3 71983 y z

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Samuel E. Bryan, Assistant Directgr, 01 on of Reactor MEMORANDUM FOR:

Operations Inspection, OIE Q w .,

FROM:

Robert W. Reid, Chief, Operatinf eacf rs Branch #4, Division of Operating Reactors, NRR

SUBJECT:

NRR INPUT FOR RESPONSE TO PETITION FROM THE COMMITTEE T BRIDGE THE GAP (CBG) CONCERNING THE UCLA RESEARCH RE n

Enclosed is a discussion of CBG charges contained in its October 3,1979, The specific CBG charges dis-petition concerning the UCLA research reactor.

cussed are those which allege deficiencies in our review procedures used to support Amendment 10 to the UCLA operating license.

It is expected that further NRR input will be necessary to assure that all issues raised by the CSG have been properly covered. Please contact Mr. Hal Bernard (X27435) for assistance.

s ,+ d L>. %

Robert W. Reid, Chief Operating Reactors Branch #4 Division e operatins.aeactors

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Enclosure:

Discussion of CBG Charges cc w/ enclosure:

DEisenhut WGammi11 0 Garner HBernard SBlock RBachmann, OELD JBuchanan, I&E GKlinger, I&E GKnighton i

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- v A  ; Attachment Calculations have been made for estimating the dose that could be received by '

a " maximum individual" occupying a room in the math-science building. We will define a " maximum indi dual" as one who occupies this room for the entire year during which time the .eactor is at power (i.e., 8.4 hrs / week), and is subjected to the same 41Ar concentration as is on the roof of the math-science building (e.g. We assume the same concentration in the room as is at the intake to the ventilation system supplying air to the room).

From Regulatory Guide 1.109 " Calculation of Annual Doses to Man from Routine Raleases of Reactor Effluents for the Purpose of Evaluating Compliance with ~

10 CFR Part 50 Appendix I", table B-1 provides the total body gamma dose factor for exposure to a continuous semi-infinite cloud of 41 Ar as 8.84 x 10-3 mrem /yr.

Using this dose factor, the paramenters of the UCLA reactor effluent, pei/md and a geometry correction factor, we get the following:

41 Ar dose factor, 8.8 x 10'3 mrem /yr 0 0 pci ,10mJcc = 8.8 x 1,0 ""'*#Y" 9

pei/md x 10uc1 uci/cc (g UCLA para"teters:

41 Ar emission concentration = 1.6 x 10-5 uci/cc Dilution factor at Math-Science ventilation intake = 0.115 Reactsr utilization factor = 8.4 hrs / week x 52 weeks /yr 8760 nrs/yr = 0.05 I

Since the Ar dose factor is based on a semi-infinite hemisphere, a correction factor must be used for a finite rocm volume. From the report "The Atmospheric Diffusion of Gases Discharged from the Chimney of the Harwell Pile (BEPG)",

N.G. Stewart, et. al . , AERE HP/R 1452, a correction factor for a room of 9 meter radius is about 0.03.

Collecting terms we get:

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y = 8.8 x 10 j{eI " x 1.6 x 10-5 uc e

x 0.115,x 0.05 x 0.03 = 0.0024 x 104 = 24 mrem /yr0 This value is in reasonable agreement with the approximate 40 mrem /yr dose measured by an independent contractor on the roof.

the roof dosemeters would be "seeing" a larger It would plumebeofexoected 41A r. to be smaller since l

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