ML18079A766
| ML18079A766 | |
| Person / Time | |
|---|---|
| Site: | Salem, Zion  |
| Issue date: | 02/27/1979 |
| From: | Webb R LOWER ALLOWAYS CREEK, NJ |
| To: | |
| Shared Package | |
| ML18079A767 | List: |
| References | |
| NUDOCS 7908080136 | |
| Download: ML18079A766 (129) | |
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.REGULATORY DOCK.Er FILE COPY CCN7E~TIONS REGARDING THE ACCIDENT_ :iAZr\RDS OF SPE~T FyEL STORAGE AT THE SALEN NUCLEAR POWER PLANT SALEM, NEW JERSEY I
I
,,;.,*
':\BY:
.(RICHARD E. WE~B, Ph.D. - I
'Fchruc1ry 27! 1q79
FJIA \ , CONTENTS
- 1. I~TRODUCTORY CONTENTIO~: THE LOSS-OF-WATER ACCIDENT
- 2. ?HYS!CAL CONSEQUENCE OF A LOSS-OF-WATER ACCIDENT
- 3. POTE~TIAL HARMFUL CONSEQUENCES OF THE RADIOACTIVITY RELEASE FROM A LOSS-OF-WATER ACCIDENT
- 4. POSS!BLE LOSS-OF-WATER ACCIDENTS: SPECIFIC
, POSSI-3: LITI ES
- 5. CO~CEIVABLE POSSiBILITJES FOR LOSS-OF-WATER ACCIDE~TS
.,...
- 6. CRI~ICALITY ACCIDENTS
- 7. R~ACTOR ACCIDENTS CAUSING A SPE~T FUEL POOL LOSS-CF-
- ..;ATER I~CIDENT 8* P~R~A~ENT SPE~T FUEL REPOSITORY AT SALEM C(. Tmpr-ac"t/ Cc,(r'-t-r "f Tu. eote't/cC,1 I 1
.,4~y S/ 5 c?Hd E7~y/~-?il Ye-/
!(). ~
-. CONCLUSION
/ --- t.., /
- 1. I~TRCDUCTCRY CO~TENTIO~: 7HE LOSS-OF-WA:~R AC:IDENT The utility operating the Salem ~~:]car P~~er S~a-tion 2t Sale~, ~ew Jerscy--Public Se~vicc Electric and Gas Co~pany--(?SE&G)--is requesti~g a licc~se f~Qm the United States Nuclear Regl:latory Ccrn~ission to store indefi-nitely up to lliO highly radioactive, sr,:e:nt nuclear fuel red assemblies in each of two spent ~ucl storage pools located at the reactor site. The Station consists of one operating nuclear power reactor and one under construction.
Each spent fuel pool is housed in a separate fuel handling ~uilding which is located next co its rcsocctive reactor con:ai~ment building. Originally, it was intended o~lv ~o hav-2 in stcrage about 64 spent fuel asscr.-:olies, at any one ti~e in each pool, as the plan Nas to ship s~enc f~el coo:.ing-off ?Cried th,1t: allo\..:s t_hc r2dioactivity ar.d associ-ated heat in -~he spent fuel to dc:ay substantially. No~, ho~ever, ?SElG proposes to increase :he storngQ capacity
,..,c .., ... eac~ storage pool, by replacing the original design of the storage racks with a rack des:gn :,:hid, allov.:s t::e spent fuel assemblies to be packed in the pool at a high density (comra.ction). The proposed i:1cre.:1sc in scoragt; c~paci:y would incre~sc the amounc o~ long-lived radio-activi:y cc be stored i~ the pool eighteen-fold. Apcr:val =~ i~crease :he stora~e capaci:y ~s req~esced bv PSE&G
I "*
}' F.1 l F because there piese11tly exists no nuclear ~astc (~s=csa~
system for diseasing oE the spent fuel. ---- *-***---- ------ With respect to the hazards of the rroposed f~el storage increase, it is contended th~:: (a) The proposed design chnnges to the S -,.::,r-
. , J _ .. . , _ f ..:~l s:crage pools ~ould greatly increase the nuclear ac:i~e~:
hazar~s of the Salem Station ~~th respect :o the heait~ and safety of the public. (b) The proposed desig~ changes would create ~~ny seve=-Q accident possibi.lities *.,hich would :iave t:1e pc-ter.- tial for extremely disastro~s consequences. Such ac:idsn:s would involve t~e loss-of-pool-~~tcri hereafter dc~=~i~a~ed the loss-of-water accident. (cl Bet~ the ?SE&G's Snfety Analysis Report anc t~e ~uclcnr Regul~tqry Commission's Snfcty Evnluntion Rcp~~c fa~ t~e ?reposed design ch~ngcs full to analyze the :ass-of-water accident. Cd) The potential cons~quences of loss-of-wcte~ accidents are so serio~s that the utility !PSE&Gl a~d che ~uclear Regulatory Commission's st3ff nust analyze cr.e~, and the Atc~ic Sa:ety and Licensing Board (ASlL3 and t~e Comrniss~on itself must invcstigntc nnd c:ns:~~~
- he~ for both their likelihood and pctenti~i har~f~: ~=~3e-s:. o:; , ; : hat i_.:,'
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fo-rn an opinion as to ,,*hcther the proposed spent fueL stora.;e *,.;ould be "ini..1ical to the health c1nd safc:cv of ,; the public" (referring to Section 103 of the Atomic Energy Act) and to responsibly inform the public of the full risks co health and safety.
. -- ----------
(c) The likel~hood of a loss-of-water accident cccurri~g is not remote or extremely low; but rather, the ?robability of occurrence is indeter~inable. More specifically, it cannot be proven mathematically or statis-tically that the probaJ1.lJJ:.Y.,_Q_f__~µch an accid_ent occurring
~ J.1 {' I /j e -~f t !:!__e plo,d . a ,.. __ e ve]j;> .
in the time period o~, .:i deca<l12 ci:,,l-' .- ** is 1ess than 100~~ o~ sig~ificantly less than 100%. There exists an indetermin-able but extremely large number of possibilities for fOten-tially 01* cc-nceiv.1bly causing .:, 1 oss-of-:.,,;itcr accident i.n 8. storage pool. Furthermore, ;71,my incidents assocL.:J.ted with nuclear power reactors of ncar-nccidents, equipment
~al:unction accidents, and human erTor have occurred.
These facts indicate that the probability of a loss-of--
~ater ac=ident is high, not low~ Because of these facts, plus the fact that the probability of a loss-of-water accident is indeterminable and the fact of the extre~e potential for har~ful consequences of such nn uccider.t,m2kc t~e proposed storage facility uns2fe .
. / (:) The ~~clear Regulatory Commission's current prac:ice o~ evaluati~g the risks of the worst or seve~e
~ ,_
)
- 1ucle2r accide~t pJss:.bilitics by ccnsidcrLng only the likel:.hccd of such accidents, and not ev,1iu:iting and c:msid-e~ing :he potencial harm~ul consequences, is not co~s~~cent
~ith t~e ~ell-established method of assessing accident risks, i..:hich is to consider both the likelihood and t:ie conseauences of accidents.
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- .. . FJ (a; The radioactivi.ty in spc~t fuel '*genera'.:es hea: r ........ ;
*"./l~ .. '-'**
-~
~~st be diss:.pated in ordc~ to prevent t~e spe:1t fuel asserr.blies from overheating. r~r this reaso~
and fo~ radiation shielding purposes, :he spent fuel asse~- blies arc stored under water. *The pool ~ater serves to re~cve the heat of the radioactivity. The pool water in turn is ccoled bv ~ater circul~ting coolin~ svste~s to J - - ~ cre\*ent the pool .:ro:;1 dverhctJ.ting nnci boi.li:ig dry. In a loss-o~-~ate~ accident the spent fuel nssemblies ~Li~ heat ~p :o a high te~?eratu~e,- beca~se natural air ccnvec-
- .on a ~a' c .:1e r.na .!. ~adiaticn hear diss:~~cion rrocesses
- .re
. -:....-
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.""-**~,...
.... .._;._ .. _. e:-::. s:
di
- ha: t~e potent~al may exist fer the ur~niu~ oxide:~
~ ,I A
- he spent fuel to heat U? beyond its rrel
, ...... t...!..1 ,-,..rr. .... e.---**-e
-:ng 1-t;.;,,:-., .. C:::.'-'-~
of abc~t 2800°c, even if all cf the spcr.t fuel we:-e st'.J!:"ed for tc:i years. s ~ (c) C<2lculation11 exist~ which tend to set a :.:at:-:e-
~2tical lower bound of the spent fuel hecJ.tup potenti~l; ar.d these calculations indicate that as a minimum the zirconiu:n (ziKcaloy) fuel rod cladding material will heat up to 900°c and catch on fire for spent fuel that has decayed (aged) ~or three years. These calcul~tio~s ~ere ?erfor~ed by Sandia Laboratory and are presented in a report titled "Spent Fuel Heatup Following Loss of ';.;ate!:" )uring Stcrage" (SAND77-1371, Sept. i978, draft), b:: A.
S. 3enjn:nin, et al.; hereafter called t!"":.c Sondia R~ort.
- he Sandia Report does not c~lcul.~tc the r~cl te~pe:-at~re
- -ise beyond the point when the tcmpcruturc is culculated
~o reach the zirconiun fire ignition tc~pernture, and subseq~e7!t z:.rconu.:m * * ~ - 1__..l. ~ryg_
c 1 a~g. * (1s--
. -*--) 1 c' 0
. 1.
( d} A zir-:onil:rn fire would gcncr;itc suhs:anti.:i.l
* -4 * .. . ,
cC-11...1.ona.L heat with the potential for melting a~ay the claddi~g cf the f~el ~od and also melting the uraniu~ oxide ~ucl o~ rais~ng the fuel to its mclr!ng te~oerac~re
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(2) .!.. z:.rcc:1it.:rn fire ,,..,hi.ch star::s in rel2.ci*:e:..*:
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** o_*,.;
-:,.J-*~- --~- Isa***
c;:-...,,...,- F*,.c,1
\ .:, three year s:or2.ge or less): ~cu:d inc:..ude 16% cf the total planned stnr~gc er less.
che ~hcle load of spent fuel in the ?Col. ( -. _, Severe zirconiuu1 explosions ~1.-c: -:oncei.v11:-~~,
- I
* * * " 1
*. .. ,/'* ,*,... . ., t..U 1*f :,
't due t.:, zirconium-water t"ec1ct1ons ,;! ,.;;;'J.,,' *
- _,,
' 2i r r c.*,"J}~' - air rt:) :"'t:°C;* ~.
(g) Hydrogen explosions are conceivable due to
- he h::,:c:.r:)gen released in a zircon:u:-.:-watcr rc.:iction anc / ti; reacti~g ~ith air.
(h) Since zirconium fuel clad mel.ting is possitle,
- t is conceivable that :he air fiow passages inside t~e spent iuel rod assemblies could become plugged due to f he
-2 , 'r cc~-.- r"v:;1 c(/o 7-lt:f@ r-? .7' t-f /,* :1 Pree(vt "t o ;,, d av ..e 'i- o
~clte~ zirconium running down cownrd cooler portions of A
~he s;ent fuel and freezing there. ?lugged air flow pas-sages ~ould greatly worsen the spent fuel heatup. Also, ex?:osivc zirconium-water reactions and hydrogen explos-
- I I
ions =culd conceivably damage adjc1ccnt spent fuel so as
- o co~strict air flows Llnd thus worsen the spent f~cl in these as~dmhlies as ~ell.
( l.. ' I Strontiurn-90, Cesium-137 and Plutonium are
- he d~~i~anc radioac:ive substances ~n spent fuel fron 1
- a ;:n; 1-,. *
. . .:.:.c
- nea ... tn risk s t ~rnd po in t . It is canceiv~ble--~ea~~n~
- hat ~= has not been ruled ouc scientificLllly--thac a nc~:- 1.;0'\ rclc"1sc of 5;trontiurn-90 .:inc: Ccs ium-137 rc:1.ci..;::;-
c:c:~vi::v fr~m chc spent fuel into the c1tmosphere wot!ld
~cc~r ~~ a spent fuel heatup excursicn in a loss-oi-~a=~=
acc~~e~C. For such a ncar-100% relcnse ca occur, the s:2~c
- * . ; ) .. - Q. ,":a _,.: -n,.... ~ . .
~cc-ess2:-i:y re3cn' ~c1:~:1g
- "- - - ** - - ~ l .v ._
r . r-.eed onl.y attain a *Le*:e l or- en 1 y .J!)O'..~t ' °
*1 9 C') 0 C ,ir,u. ::i.JJ..:-1:,q:.n
* *
- ha: 1..- ... .:>....,n.:i.ratu.,..p
.. * , - ~- r-or a c~"'v or so C *'-',; *
- Ti..*,"-
- St"",ont1*t1m-c,n,,. ,-.-r.. :esiu:n-137 cal..!ld c:1en diffuse out of solid uo 2 f:.H:l ~:
sue~ tempe~atures. ThLs assumes that the fuel roes have Les: their zirconium cladding ~pon ~eltdown of the zir:on-ii..!~ bu: that the reds ~ould maintain their rod shape be-
,._.,
-c:.'-"Se ~"-
--~,,, U*O z fuel rellcts ins!de the fuel rods *,:o:..:~d
~ave sintered together during reactor operation to :o=~
a long uo 2 red capable of maintai~ing its shnpe. If the
~o 2 recs should c~umblc, ~ir croling would he further i:::p~ded .:ind lead to higher CO.,... tcr:1peraturcs and conse-
~ue:1tly a greater cher:-:ial potential for strorttium and ces:u~ diffusion out of the uo 2 fuel.
( .)
- - - . *-*-----
Calcul~tions exist ,,.,hich indicz1te that t::1c
.~-~--~-~--*-- Fl L; J.
.:!i-:- i".lsidc spent fl!el stcrt.1gc builcJi.r.g ~~*ouLd he<1t ui::: a.:-.d pressurize d~e to the heat cf the spent fuel. (che building
~ould become like an oven). The air pressurization ~ould bu-:-st cpen ~he building and th~s allc~ the radioactive va~cr and s~cke to escape int6 che at~osphere. If the cu~lding vents were opened, the radioactive vapor ar.d s~oke could conceivably escape through these vents. Zir:on-
- . '.J~ ~nd hvdrogcn cx~lcsions could concciv~blv rupture J
- J
,~ ('
(k) Ko ex~e-:-i:r:ental dat:a ~ theorctica'i. a:12.lyses
FJ.L of plutonium in the spent fuel into chc nt~osphere ~~ a loss-of-~ater accident. Stea~ 2xplosions, hydr:g~n e~pl~- sions, and zirconiu~ explosions ~re conccivahle ~ec~ar.:s~s Nhich could pulverize large quantities of spent ~ue: bear-ing plutoniu~ and blo~ it into the outside environrnccc. ~here the plutoniu~ ~ould then spread through the environ-
- ien::::.
(1) Calculations exist which indicate that the
*-. --------------
Salem spent fuel storage building could not be ~edified
~c eli~inate the ~oss!bility of a zirconiu~ fire occur:-ing ~n ~ loss-of-~ater accident. The Sandi~ R~port suggests the possibility of ~edifying the building to prov~~e ror an ope~ chimney effect: a large hole ~n the cei:ing a~i -
I I a large hole at the £:oor level of the building sid wall 1 ~ I to allow rcrfcct :-oc:71 .:1i.:- vcntil.-1cion during a lcss-cf-
~ater accident to ex?el the hcnt~d air exiting from the spent fuel assecblies. The holes or openings ~ouid be ~or~al:y closed by la:-gc doers. which wculd be opened in a loss-of-w~ter c~crgency to create the chimney effect.
Such a cl1imncy effect by CX?cLling heated uir, would t~nd
~-o 1- -;_,.;
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t th_.,
,a; S"""Cn~
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- o San~ia's analysis, hut wnGld not eli=inatc the psss:-
\.,;~;- 0:: . . -
-----Y .. fi~c. Since such u ci:i.mney t e.1::~:-e
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a :::1:.:.::-.ev co:..:ld
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/I ct all; for the building openings ~ould provide unl~~i:ed air (oxygen) to promote the spret1.di.ng of tne fire. a:id wcul~ provide ready access of radioactive vapors a~d s~cke co the outside atmosphere. Nor ~ould the activation of
- he chimney (automatic or manual opening oE its doc~s:
be ~eliable in the case of a severe reactor accide~~ ~~ich ca~ses a spent fuel loss-of-wacer. A severe reactor ac:i-den: can potentially cause such~ high level of radiation in and around the site that the whole site operating c~ew could flee in panic, leaving the spent fuel pool and relat-ed safety and cooling syste~s un~ctended. Under such a panic situation, it ~ould not be ~xpected th~t the chi~ney doors, if incorporated into the building, wbuld be opened. (ml A reduction in the number of spent fuel asse~- .C-2
~lies stored in the pool could not eli~inate the possi-bility of a zirconiu~ fire occur~:ng in a loss-of-wate~
accident, nor preclude the possibility of a loss-of-wa:er accident. (n) Emergency efforts to cool the spent fuel fcllc~- ing a loss cf pool water could conceivably worsen the accident or otherwise h~vc no miti;ati~g effect. Spr2y:~g the overheated spent fuel wit~ w2ter (~hich would have
.
co ~ue cone remote 1 y, due to the heavy radintion e~a~a=~~g fro~ the spent fuel) would cause zirconium-water re~c:::~
=culC
..
the :.gni.:ion er sp~2ac1~g at
- 2
. .
z:~~=~:~~ q
' .L fie
..
- ..:-e, ~r cause explosi.or,s. :-1orco\r*er, tt1e heatup o:: che s~e~t :uel could conceivably c~Gse tne boral neutr~n aJso~b-
- .~g :::a:erial to i:1eltdot...*n, lt?nvLng n region of spcnc f-:.,;el
~Lt~cut enough neutron absorption to prevent a cricica:ity sho~ld the pool be reflooded. Furthermore, the heat of
- he spent fuel in a loss-of-~2:er accident (and ?OSsib:e
~xplcs~ons) could conceivably dnrnnge the spent fuel to sue~ a degree that the pool ~ould continuously leak heavi~
ly, should the pool be reflooded, which would result in a heavy seepage of radioactivity into the ground an~ nearby
-..:c. ~ers.
---*-** -- ----- -- -*--*--* *--- . -- *-*------*- ----
(oi In order co evalua:e the pocential for rad:c- ,=-j. act!vitv release in a scent
~ . fuel pool less-of-water acci- ~e~:, 2 cher~al analysis must he pcrfor~cd, of course.
c-f ~.r"'.-?-*l~ ...*._ *..-: ;* . . **: *. ).~
- he cn:y ;:;~chcmatica.l U1cor~~ :"*:,Leh exists in a for:i'l for f i;,-2 s,'ef ~ s tf,1$ c7 '..I 't.'*c r:; -: J, ~~~;*/)
,
~eacy "..lse* is the SFUE:.. co:npute~ code of the Sandia L'abora-
..
- c=y, ~h:ch is described in the above-~entioned Sandia
~e~cr:. The Sandia Report analyzes the loss-of-water acci-
~e~: !er a spent fuel storage pool ~hich is close to tte Salem ~esign. However, the Snndi~ Report is not suffici2nt
- o--: e*:aluat:.ng the S?ent fueJ. hcatup potcntinl for Salc:n
.. ~r a~y other spenc fuel storQgc rool); nnd, further~cre, S?~SL co2puter code is not s~fficicnLly developed veri~ied to provide
=~=~ ~~=h reascn~b!e accuracy.
I.' 1- ') The Sandia Report does not invcstigace the spent ~uel tc~pcrature excursion beycn~
- he ig~i:ion of the zi~conium or zirconium
- ielting.
(2) The San~ia Report does not analyze the
,:~ s Q
~igh-density storage racK design for t h e ~ building vcntil~tion, the case for all pressurized water reactor (PWR) storage pools, i~clud_in§~alem. ( 3)
----------
Sandia's mathcmnticol theory (SFUEL) contains serious theoretical deficiencies which, based on independent scoping calculc-tions, may be causing the code to be drascica:ly underprcdicting spent f~el he~tup te~pe=a-tu~cs. Forc~ost arc the nssump:ions in the SFUEL theory that the te~pc~atures of the fuel rods in a given spent fuel rod assembly and at~ given elcv~tian nre che same (unifo=~ te~perature distribution horizontally), and that the tc~peraturc,.distribution inside a fuel roe at any given elevation-is also uni-(4) Sandia's mathc~acical theory is nee ,, ace-r.-..) .
~ua:ely des~ribed in the Sandia Repo~~~ a~~
req~ires a syste~a:ic checki~g to verifv =~e
.. ,.
-j * 'I
~ -! 1, -- ,. "( .::, L / '.?.'. ,_,'
¥_ ( '* ... .. .. /
code : f. e -f-::. : 1) and c 2 1 cu 1 at ion Q l 1. y . (5) A reliable mathematical theory or s;:e:-.t
~
fuel heatup may nol be practicnl, due.to c~m~u-ter U.nitations. (6) Sandia's SFUET. cheory has not b-:en ex::eri-mentally verified, contrary tn the clai~ ~ade in the Sandia Report that adequate experimen-tal data exists to validate the SFUEL t~eo~v., . Th~re expcri~ent relied on in the Sandia Re?ort consisted of two heated plates held at a lcw, constant and uniform temperature cooled by natural air convection; where~s the sit~ation in a spent fuel heatup accident is one cf a highly vnriable temperature distritut~~~ and extreme air cernperaturcs in a rod b~~d:s configuaration. ~orcover, th~r~al ra~iatic~ heat transfer aided by thermal heat con~uct~on, appear to be a crucial heat transfer processes in a spent fuel heatup, which were totally absent in the two-heated-plate experiment cited in the Sandia Report. To adequately account for ~hcrmal r~ciiation intcrchang~ among, and heat dissipation fro~, spe~t ~~e: rods in a s:orage pool un~er a loss-of-~a:e~ accident, :'..t would be necessary to ccndu::
- . .
an exper1~ent ~hich includes a large sc~:e load!n~ a: si~ulatcd spent fuel (eleccrieally heated) c~ actual spent fuel. 8ecause the electrical resistance of electrical heater
- ilaLlents :s dependent on temperature, a~
adeq~ate si~ulation of spent fuel heat~~ ~ay net be possible wLth electrically heated ~ads; in ~hi=h :ase 1c ~ay ~ot be possible to ex?eri-
~en:ally ~erify a mathematical theory of spent fuel heatup, because Lt would not be pract~cal er sa~e tJ conduct such tests wLth spen: n~clear fue:. r:.ds.
-----------
, -; ) I n snort,
' '
tne .eport must b e c~1*t*~- p *
~an d'ia R c:
(ol It ~cu!d ~ot be pr~ctic~l or snfe to ex;er~~en-
~
tally inves:igate :he radioactivi~y release potenti~l of a loss-of-water accident; particularly in the event of a zirconium fire, zirconium melting, explosion, or ot~er severe precess ~hich cnuscs signifi~nnt chnnges_
- n che fuel's physical condition, bec~usc the fuel tem?era-
- u=e excursion and the interrelated radioQctivity release
~ou:d boch depend on the physical condition of the f~el a~c c~ t~e size o: the spent fuel ~ass undergoing a :ass-c~-~a:er ac~ident. ~oreaver, the behavio~ O! the spen:
of spe'."'.: ..... -
.I...--= -
. . in ,..;ater and the physical history oE the srcnc f-..:cl *.,.-;'1en it ~as i~ the reactor, such as ~hcthcr the fuel ~ad ~~~er-gone overheating in the reactor in an accident. (q) It is not rossible to accurately predict t~e course of a loss-of-water accident once the zirconiu~ clacding becomes ignited, Instead, only mnthemati=a: upper bound esti~ates of the radioactivity release potenti~l could be developed, which presently do not* exist. f near-- 100% release of radioactive strontium and cesium is plausi-
.;1 ;, ('
,. .,
( C)c.,*_IC{ ble...
-----------*- - - -----. ---* ---*---- --------
..
(r) The Salem Safety Analysis for the proposed F1..? spent fuel storage supplies in3dequate infor~aticn en
~hich to perform heatup calculations; for example, the - I pool a~d building ci~ensions arc not given.
".
,J
- POTE~TIAL HAR~FUL CONSEQUE~CES OF THE RADIOACT!~ITY RELEASE FRO~ A LOSS-OF-~ATER ACCIDENT (a) Each spent fuel storage pool at Salem ~auld contain at capacity forty-five million curies of Strontiu~--
90 tadioactivity and about the same a~ount of curies ~f Cesiur:1-137. For comparison the l!nited States Atomic E:iergy Commission's reporc Theoretical Possibilities ~nc Ccnse-cuer.ces ,Pf ~1aj.£E, Accidents In Lar,ge 1 ::uclear Powe?:' Pla:-::s (WASH-7l0, ~arch, 1957) calcul3t~s thac the release o: C.15 ~illicn c:ur!es cf Strontium-90 (150,000 cur~es) c:~l~
-
..... :=**c:.=
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- ,,-~..-.,1~,,-- ...L
-::,*--"-~---a restrictions ~ver a L1nd area ;::..-,.
- -"--- = ..
;-_,...
to 150,000 square miles, which is the size of New Jersey,
~cw York, Connecticut: Massachusetts, Rhode Island. Ver-
~c~:, New Ha~pshire, ~aine, and half of Pennsylvania, combined. A loss-of-water accident in one Salem spent f~el storage pool could conceivably release nenrly all of the Eorty-fivc million curies of Strontium-90, er :hree hund=ed times the WASH-740 assumed release quantity of
-
S~rontium-90.
- z ~0 -:--~~~-:-:--:---:---------~-----:-~~--:----~=--------
~.,A._,'Xssuming that land which is cont~minated more than fifty F1 times the WASH-740 contamination limit for Strontium-90 would be ruined agriculturally, *..;hich is a prudent assump-tion and one which is consistent with the view taken in the WASH-740 Report (the WASH-740 Report asserts that Strontium-90 land contaminntion at ten times the Report's contamination limit would require prohibiting dairying
. : i::
~/
for a very l*.:ing time))~ can be calculnted that a spent fuel pool loss-of-water accident which releases forty-five million curies of Strontiurn-90 (which canriot now be shown to* be i.mpossible) could result in ruining agricultl.rally a land area of the size of about one-third of the land East of the ~ississippi River, or certainly the entire eastern seaborad of the United States and Canada, fo~ a r.~~c~ed years o~ ~ere.
. { b) The release o[ Ccsi'..Jrr.-137 rc1dio,1ctivity f:-om t~e sta~age pocl into the at~os~hc~c could ~csuit in ~Lgh
. I levels of gamma radiation (intense xrav-like ,.. ., radiat!on)
X e~anating from the ground over ~n area equal to 150,000 squa=e ~iles. The ga~~a radiaticn ex?osure to persons stancing on the ground could potentially occur ~ta r2:e
~hi=h exceeds by a factor of thir:y-eight or more the health li~it recommended by the U~ited States Environ~ental Protection Agency of 25 millircms per ycnr for total radia-tion exposure from e~ission cf radioactivity due to nuclear
- Jcwer.
-----------
'~c} ~fo reliable estii:r.a~:::s exist of the potential P-J.*,
....
**
can~e~ and genetic harm that could result from a near full release of Stroncium-90 and Ces~um-137 (and other vol2ci:e radioactive materi.2ls. in a spent fuel loss-of-water accident. Such estimates ~~c necessary and sh~uld be developed, in order ~hat the spent fuel accident hazards can be f~lly evaluated. (di The conta~ination ~evels indicated in (a)
~nd (b; above apply to the bou~dary of the fnllout land area zcnes that arc quantified in these sections. In the c;,ncr' c/;e;,-? r- -::= :* .'*t- -~.12;*~
inter!cr of the zones~ the co~t2~ination levels would be :::u;::: *...;orse. (e'. One s?ent f*..;el pool at S2lem would ccntair: r-1-o
'- *.- - e-::;1.:ivalent cf ch::.rty-ni~e t~ns o: ?lutonium-239
.
-*
P:-1 ~ ra~ioacti~ity. If dispersed unifor~ly, this a.:;o~~t plutcniu~ would have :he potcn~ial for cnusing 2=a::1ccn~e~c
~= abo~t Eive ~illion square miles of land, whic~ is 1.5
- i~es :he total U~ited States land are~, including Alaska.
~c ana:ysis exists which proves that an area cf :~e size
~f ~ew Jersey, say, wcLlld not require per~2nent aoa~ao~~enc d~e to a ?lutoniu~ release in the event of a loss-of-~acer accide::1t in one soent fuel storage pool. ___ _
' J...: .)
\ It is possible that a reac~or accident at FJ.. R
- he Sa:em Station cou:d induce ioss-of-~ntcr accidents i~ joc~ S?ent fuel storage peels, ~hie~ ~ocld then doutle
- ne above esti~ates o~ potential har~f~l ccnseq~ences.
(g) Even if t~e spe~t :uel pcol held a mini~~~ a: s~e~t fucl--six:y-~iv~ fuel assemblies, or one-:hir~
'.) ;- a C C'l r C , ~l S w .'.1 S t hC C 1- i g i' t1 :1 I i ll t C' l1 l - - t i H' f10 t C n: i u: C ("'. :1 S C -
que~ces of a loss-cf-~atcr accidc~t ~ould still be extre~e: fer e~a~ple, a land a~ea of the size of Ohio, or five
- irnes :he size of ~ew Je~sey, could be ruiGed agricul:~~ally
- or a hundred years or more, due to Strontiurn-90 re!eas~
-'* . P8SSI3LE LOSS-OF-WATER ACC!DE~TS: SPECIF:C ?OS-SI3IL:TI:::S A :~ss-o:-w2te~ accicent 1s pcss:.blc,
- l. : the pool wa:er cooling syste~ should b~eak ~:~~.
~co . .
~~!ch ~o~ld take about four dnys to two ~eeks, based on the figu.:-e for the ";:iaxi:::um evaporation rnte" ( S1S *g<!llons pc~ m~~u:e) given in the Nuclc~r Regulatory Commission's Sa:ety Evaluation Report (p. 2-5). The most likely cause of a breakdown in the pool water cooling system is a severe. reactor accident (sec contention No. 7 below). A severe reactor ac=!dent could result in such heavy radiation levels at the reactor site that the storage pools would a. be abi\ndoned. In that event the cooling system would have to be assumed to breakdo~n; and there would be no adequate assuran=e :ha: makeup ~ater could be supplied to the peal. accident must be assumed to be hioh1v 0 -., likely to o=cur (see contention No. 7). There are other possibilities for ctQdsing a loss-of-- pocl-~atcr accident ~hrough*a b~cakdown in the pool water cool~ng system ~hich must be given serious consideration. One such possibility is for the reactor plant to have to be ?er:nanently closed down due to J. rc:1ctor accident, leavir.g cnly a very smJ.11 crew to per~ctually watch over the storage pool and mJ.intnin perpetual cooling. In thi~ situacion, a cooling breakdown could occur through negli-gence a~d ~ct be corrected. Sabocage and acts of war are c:her p~ssibilit:es.
----------------*-- - *----*-- -
- 5. CO~CEIVA3LE ?0SS!3!LITIES FOR LOSS-OF-WATE~ t:CI:E~TS
_ne~e are a nu~ber of conceivajl2 possibilities
o~ accidents and sabotage which could result Ln a loss-of-y
*' .... w~ t e r a c c i d e :1 t a n d ;.; h i ch_, th c r c f o r c , :"i1 u st h c c v c1 l '..! c'.1 t e d for their likelihood and their potencLal for causi~g a less-of-pool-water. T~ey are:
(a) Spent Fuel Shipping Cask Drop. It appears to be possible for the henvy shipping cask to fall f~o~ its crane into the storage rool. s~ch an incid~nt should be evaluated fer the potential for ruptur~ ing the pool and causing rapid dr~inage of the pool. A
~ranc fnil-urc h<!s <1lrcc1rly occurrccl over ;1 spent fuc~ stor-('Sh;,o . ~,* ....._J...~: r';');
'j age poclA and an incident of improper handling of a spent
,.. I - ; :
- 1 'j
.:uel pcoi cask has already occurred l e,*g hoc, , on r *
(b) Criticality. Indications are that it is possible for a local cri:icality
- o occur in the storage pool (see contention ~o. 6 below).
Such a criticalitv has -vet to be evaluated for the course
.;
it could cake; so no upper bound exists of its ther.nal and mechanical conscq~enccs. It may be possible that the f~ssion hea: gecerated by such a criticality could cause a rapid boil-off of the pool water, despite the pool ~ater coa:.ing svstem. ( C) Sabotage and Tcrroris~. 80Ssibilities for sabotage and acts of terroris~ a~e very real. The ~se of ex?losives could destroy the coo:~ng svste~, a~d t~e removal cf a ~e~ Si)en: _fuel ass e:-i bl*:
of the pool water would produce such high levels of radia-tion in the pool building that accion to supply ~akc~? water ~ould be severely impeded. Also, explosives cc~=eiv-ably could be used co rupture the pool and thcre'.Jy cat:se rapid drainage. (d) Others. Cnde~ this heading, carthqu~kes breaking open the pool and large airplane crashes should be considered.
- 6. CRITICALITY ACCIDENTS A critic~lity accident in the srcnt fuel pool ~s a very real possibility. Possible cuuses are as follo~s:
(a) Missing boral plates in a local reg~on of a sto~age rack, or boral plates with a deficient a~ount of Boron-10; and (b) Underpr_cdiccion of c:hc effective net;t:-cr. ..:~llip-ticat~on factor (Keff). Public Service Electric and Gas Co~pany's Safety Analysis Report and the Nuclea:- Regulatory Cow~ission's Safety Evaluation ~eport do not provide ade-cuate information to assess the hazard of a criticali:y accident. For example, there is no indication that there ~ould not occur any positive reactivity feedbac~ effe:t
.
-
during the fission oower
. rise in a cric:icalitv
.
. s 1 t: ...:a c:. on .
I: is a valid concern that a criticality ~ight :ead t: a :-~~id boi~-off of the pool water. The radiati~n fro~ such a high-pc~er criticality co~ld conceivably cj~:r~c:
e=for:s to control the acciden:. I~ order to assess c~e criticality hazard, _therefore, i..t :.s nc:cessary that a b-e w c:-:* c~ '-' r.! r?S full analysis of ~ all p~s.; .. "j_._lf:,, -r cl criticalit*, J "
- '= dc._:...,~e.:. n1af f o.(*p -
Th~ benchmark critical cxperi~cnts used bv Public Service Electric and Gas Company to verify its mathe~atical
- heory for calculating (Keff) 3re not adc~untc to verify the accuracy of the predicted (Keff) factor. These experi~
ments should only be considered as a means to develop the t~ecry for design purposes. In the final analysis, the loading of fuel assemblies into the rQcks will be
- he pr~o~ cf the validity of the arecictions of <K -fl.
* . et 7herefore, it would be necessary to perfo~m an experiment
- n which new fuel is placed in the storage racks under controlled insertio~ ~nd n~utrcn ~onitor!ng for criti-cal:ty. This should be a practical confirmatory experi~ent.
it is well-established that such an experiment is neces-sary. Also, consideration should be given to the quest~on of ~he:her local boiling inn nu~bcr of spent fuel asse~- blies could cause an increase Ln ( Ke;.ct-); thci t is, 1,;he hc-:- t_ the fuel in the storage racks ~ould be over-moderated. In ch!s ~egnrd the above described experi~cnt shoul~ inves-tiga~~ the effect of voids and ~~=c~ :c~pcrature. ( f(O re)
;;_ I
r,C)' l' :.s c::,r.c;?.:..*,a=le, too, ~:-.at spent fuel-particu.:ar:.~*,
~i~vi~~
..,._v ... ___ .-- c~,,,~ -....,~_..,. -~~* ... __ ,_, (~* c:..~ ./vv~~~oo~)
- thus of ~clte~ !uel wi~~in a ~rozen shell or ,.... c:- t"'_...
C ..... .. _ .. v- ~~a~i~~ dicxi=e a..-~c steel ar.d :irconiu~. it !s cc:1cei~able that the ~lu~oniu~ in the ~olten ~ra~iu= c~oxi~e cculd separate a~d stratify in such a pool-- or a~ :.:~s~ ~~d c=a~~e as a result a ~uclear fuel ~ass capable of generat:r...g
- ""'"""**---- , ""
sa.::e
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------------~~----
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-
i
- R=ACTCR ACC!DE~TS CACSI~G;~~~~s~P~E~~~-~~r~-~-=~~L~~*~*L~~~----~---~---*~- 1
~ .:..,*:L r,.:: _1:
r**--- N:-.~!:.:<. *-*"'-*-'-*'~'
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(a) --------- Seve~e ~c~c:or _.,. acciccncs die Che :1:0 S: fue:
- ~0 .:.se O!:- .: ,_.~-s~-o--~-w~.~cr - ~~
- i~cident in~ spent
. -
pool. A severe reactor accident could rcst11t in s~ch heavy radioactive contamination in the ~1rccJ o[ t.:hc spc~t fuel s:orage pool and ~uilding chat the entire operating crew would be forced to flee for their lives. Such high raciaticn levels ~ould persist for ~cnths and thus would prevent e~ergency crews from returning to the spent fuel po61 ~uilding to maintain the pool cooling svstem. In such an ac~ident, it is likely thnt the cooling system would breakdown, due to a lack of m~intcnenace, which would lead to a rapid boil-off of the pool water. In addition, the spent fuel storage pool for Unit No. 2 would suffer t:ie same consec;ue~ces. iinc:ecd, the Unit No. 2 reactor would likely be abandoned as well, setting.in motion a
. .,
trai:1 of events leading to a core meltdown and poss:.c .. e explosion in that reactor as well). (b) there exists a grent number--cssentially an i:-ifinite number of severe reactor accident pos*sibilities that could result in a loss-of-water incident in the spent fuel storage pool. (c)
--------- ---------. -*---------
Severe reactor accident possibilities have ;:::- ,1
, ~
never been investigated and nncJlyzcd by the ~uclear Regula-to~y Co~mission and its Atc~ic Safety and Licensing Board for the potent~al consequences or the likelihood cf s~=h
accidents, except co a limited Jcgree in the ~uclear ~egula-to:-y Com;.1ission's Reactor Snfctv Study (~,1siTiussen R.e~::r:), ~hich is not an adequate hazards' onc'.llysis to assess ~he re a c to r a c c id en t r i s ks ( s e e con t en t i on ~o . ( f ) ( 6 1 be 1 C.v' )
- It is contended that it has not been ruled out by sci~n-conccnsus th.:1 t the potential harmful consequences of a servere reactor accident c.:1using radioc'.lctivc contar:1i-
- 1a::i:m ~ould be:
(1) 120,000 square miles of land requiring evacuaticn or living restrictions. (2) A lethal range o( seventy-five iiles of a released radiation causing acute radiati~n disease. (3) 500,000 squ;1rc ;.1f.lcs of L:rnd req~ir-ir:g agricul~ural restrictions ~uc to the release and fallout over the land of Strontium-90 alone; and (4) If the living nnd agricultural restri~- tions ~re relaxed subst~ntinlly, about lOC,OOC to 500,000 additional cancer deaths could result. From .the figures, it cnn be apprec.:.at::c thut there exists the potentinl for c2usi~; abandonment of the spent fuel storage r,ocls
<,=,*/.:'r"'e in the event of a .::'--**~r~e reactor ac::..de:::.
The pr~ros~d i~crc~sc i~ the storage c: s;~~t -.,.-
~ ~~el ~n eJc~ s::or~ge peel fro~ ~bo~t 65 sncnc fu~~ ~ss~~-
r blies to 1170 spent fuel assemblies: n~ounts to a~ eigh-teen- fold increase in :he quanti:y of spent fueL a~~ hen=e Scrontium-90 and Cesiurn-137 radioactivitv ~o be stored. Since the core of one reactor would cont~in about 3.7 r:.illion curies of StrontiL:::i-9() whic:i, i.f rel~c1sed in a rc~ctor accident, would have the potential for causing agricultural restrictions over 500,000 square mi~es, and since one storage pool woul~ by the proposed storage in-crease, contain forty-five million curies of Stror.tium-90, or :~elve times more Strontium-90 than in the core of the =eactor, which could conceivably be released intd the at~osohere in a loss-of-water incident,* it is i~perative
- hat the ~ost likely causes of a loss-of-water incident storage pool, namely. severe reactor accident possi-bi~icie~be investiiaccd. Severe reactor acciden: possi-bilicies cannot be considered independent of spent fuel storabe loss-of-water accidents. Fro~ a radiologica: health s:an~p~int, and in view of the fact tha: Stronti~m-90, Cesium-137 and Plutonium are among t~e most biologically haz~rdous radioactive substances, if not the ~os: ~aza~dous,
. so the proposed storage increase would gre~tly incrcas2 t~c
.,,
~cte~tial consequences of reaccor accidQnts that t~e :ssue of :he likelihood of severe reactor accidents ~~st je corr.pletel~ investigated.
storage increase is like proposing the ~anstruct~on o: cwe~ty-four large power rcacto~s fro~ n r~diolog~~a: ~az-ards s:andpoint, particularly with rcsp~ct to St~~n:iu~-90, Cesium-137, and Plutonium release potentials).
--------------------
( e) The Nuclear Regulntory Commissi0n has ar.nc~nced F on January 18, 1979 that it supports the "use of p--ba:~:..i P*r- ~ r o L' / I , * /
- s '
- c
"'
; '...
, 1 !""",
.:::.es risk assessr:1e;1t in regulator1 decision r:iaki::g," i:1
~ .
other ~ords, the making and considering es:i~ates or c~e numerical probability of severe re2ctor uccidents. Ho~ever, ic is contended thilt the proh;1hility of~ scve:-e re.1ctor acci~ent occurring within the next twcncy years or so 0 (" C r"C ~ }1 :- which :-esul:s in a loss-of-water i~c~de~t in a s:orage r --\/ pocl./cannot he proven to be sig~ificantly .less :r:an 100%~ p 't.:L, ,*,.:; _l.'_st1 C and that, the-:-cforc, br=-shal::+-t-+L h-Bh ri.sk asscss:nc:1t :i'!ct:iods J. shculd net be used to assess the risks of the proposed scorage increase.
*-*-----------
It is contended that in order to safely judge the 0 '(°'* f"I ~ Z t:1Y'd S cvcr.:111 sa:et\li' o[ the SJ.lcm reactors and associa:ed st~rage
- l pools, the applicants (utility) and their nuclear olant desig~crs and supplier and/or the Nuclear Regulatory C=~m1s-sion ~ust analyze and evaluate nll kno~n nccident poss~bili-ties (s~ch as ~ultiplc control rod ejcc:ion accider.ts,
*
- .::~ ~ ...1
~
c*.;... 1t= __ ._,l""*na~n . . . . ....
. ~-..,c"-,
.... --;on* .,.~u!-'
... ~tu,..~e:::.- o,.,; "--c :-i ,...... r::i~1 -:..OC* c*-.;
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- -:-:ec:--.anisr.: :icus::.ngs, loss-of-ecol.ant acc:..ce:ncs '..;:.::-.c-_;:
c::-~ !
... ~ .._. * *.,.
".iI
* * ~ c: n high
r . a~d pcwer excursions wich excess boron concentration in the coolant) for boch t~eir likelihood cf occurre~ce and their potential consequences, anc publish the encire an~ly-sis and evaluatior. (th~t is, without reduction or si~~lifi-cation), .:is well as a reduced, si:1q1l.i.f:cd summ.:1:-y. F~:-:hcr.- rr:ore, the Nuclea1* Re 0oulJ.torv., i..:o:r.:::i.ssion should accect . and hear testi~ony from all parties on the adequacy o~ such an analysis and evaluation, and should a~cept 0 ,:>T"'O,... ~ 1 o-**--c:.J. testimony as to the likelihood nnd conse~ucnccs of all i possi~le serious reactor accidents "';-:.._ should not be li~ited to the scope of che applicant's present safety analyses or the analysis nnd evalua:icn called for above, but receive independent analysis as - '
,.,.-ell), and should fullv consider and fullv weigh all ~f J J the testimony and analyse~ nnd cv~luations as above de-scribed in for~ing its opinion on the application. The called for analysis and evaluation of all possible ac:i-dent--their likelihood and ccnsequcnces--should also in-clude:
( 1) A l Ls t i.. n g 0 r ;: l 1 t :-, C () r C l i C a 1 u rl C C r t a i n C i C s
*...;ith :-cg:irJ to the p0ssibilitv for \.:Orse :cnse-qu,:;nces th.1n µ:-ccJicl:cd <1mi the combined e:fe:t
~f c:-le 1.:nccrtainties.
(2) An iCcntific~~iQn oE all pnrts cf:~~
~r:.2lyscs 1.,;hich h<<ve not been c:-:pcri:ner::=.:~y
verified. (3) A detailed ~ault :ree graph for each accident possibility and a graph of the ctain of events and equip~enc failures and h~~a~ errors for each 2ccidcnt possibility; and (4) A comrilntion cf nll experiences of reac-tor equip~ent f~ilurcs ~~d human crrJr related to each accident ch~in of events. It is further contended that a severe reactor a:ci-
-:, ,.:* ( , *,*"...-. : ' :-
i / . de~t ~~ich ~ould likely c~usc ~ 10 S S - 0 f - W .:1 t C r i P. ; i d : .....t. I* in a spent fuel storage peel is likciv :o occur--that is, such an accident can reascn2bly ~e expected--based on the fact that there is seemingly ~n infinite number of s~c~ accident possibilitic~. ~nd b~scd on the large potenti.::l for human* error .:2nd c~;rclcs:;;.1css .-ind other h*.Jrr,an fail~ngs, and on the experience record of cquip~ent ~al-f~r.c=ions, past reactor accidents, a~d near-acciden: i~ci-dents. ( f) The following additicnal contentions regarding F_ rea::c~ accidents are offered: (1) The* theoretic.::11. ::>rcdictions of ~he cc-~rse of the reactor dcstgn ~asis ~c:idents have
~ot been adequa:ely v~~ified cxperi~en:a::y.
The accidents of ~cs: ~~~ce~n a~e t~e ::ss-cf-coc:~nt accicie~:s. :~2 c:n:~ol ~cd e~ec:::~
accident, cool.Jnt pur.:p seizure, contr::)l . _~
---
w1.*chd ra*,.;c1 l acc1*d en t , anc t-...... e .:in t*1c-i-'a:..-::c
,.l ,*- *-~ 1 .__c.,.:::_-
- - - ... - ;
ents ~ithout SCRAM (:hat is, wichout e~erg~ncy fast shutdown of the [issicning). For exa~~~es of particulars, see The Accident Haza:-cs Cf Nuclear Power P l.1 ~~ hy R i chn rd E. i~e bb { l:1i-vers i ty cf Massnchusctts, 1976), Chapter L. and 9. The applicant's re~ctor safety analysis reports do not give 3dequate scientific reasons why full-sc.Jle re.Jeter tests 2rc nee necessary, nor d o t:: c r c p u t* t s c v c n .:1 d cr c s s th e q u c s t :. *: n
- of the necessity of full-scale_or even large--
but-less-than-full-scale tests. (2) The thcorcticc1l c1nc1lyscs of the: desi 6:1 p-'2," basis accidents hc1vc a number of theoretic2.: and mathematical shortcomings. See exa~ples in chapter four of The Accident Hazards of Nuclear Power ~lants. { J) The s.:ifcty analysis rcpo~ts submi:tcc.: f" by the applicant do not justify the selec:i~n of the reactor design basis accidencs re~a:ive co possible accidencs which are more severe.
(4) The reactor design basis accidents ~re analyzed in the applicant's s~fety cnalysis report with the added assumption in some cases of a single additional failure of some compon-ent in the safety systems intended to control the accident. However, the Llpplicant's and the Nuclear Regulntory Commission's a~alyses do not give adequate analysis and ccnsiderction of past reactor accidents and near-accident incidents, some or wost of which occurred by and with multiple malfunctions and huma~ error. This is further renson why the full analysis and evaluation of all ~ccidenc possi-bilities--their likelihood and potential conse-qucnccs--should be rrepcJrcd ,ind considered. The ~ucicar Regulatory Commission's "single failure criterion" to judge accidents worse than the design basis accident as "incredible" is -;.;holly inaclcqu.1tc to c1ssurc snfety, and should not be a busis to deny the full investi-gation of all t1ccidcnt possihi.lities as c&lled for above.
----------*-*---- -*---* . ----- ----------
( 5) The magnitude o[ the potential consec~en- P-J.. ces disc~ssed above ~2quires that the ~~ci2ar Regulatory Commission should rc~uire t~~ c~alv-
-c
-/
t-.,.. sis and evaluation of the likelihood and ;8ten-tial consequences of all accident possibi:~- ties, as described by the above contentions, and should fully consider and fully weigh the said likelihood and consequences of all accide~t possibilities, and should fully c~n-sider and fully weigh the said likelihood and consequences in the light of the experience of past reactor malfunction (see Accident Hazards generally, and chapters 5 and 6, includ-ing the section on Probability of Accidents, pp. 96-98 and appendix 2, nnd the testi~ony by J. Bridenbaugh, ct al., before the Joint Com~ittec on Atomic Energy of the U. S. Con-gress, ~cb~uary 18, 1976, which suggest that the li~elihood o( such scve~e accidents is net remote and may be unacceptable). A so~nd, rational JU* d grnent o~C reactor satety - 1s
,
~ot possible without the full annlysis and evalua-tion called for in the above contentions.
(6) T~e Nuclear Regulatory Co~mission re:ies Fi on the ~efore-mentioncc ~asmussen Report c~d a review o: that Rcpor~ ~nown as the R:s~ Assess~e~~ Review Crcu~ ~ecort (Lewis Re~c~:J
~~ .
tc juCge that the r- i- -~ l_...,
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.:
.._
C -,...
~
- e -~ *._ -- :_.*
., f ~ and safety due to the <<c::id~nt possi:Jil~c.:.-:::s which 3re more severe th~n the design.b2sis accidents is acceptably low and t~at the ~ere severe accidents need not be further cQnsi=e=ed. It is contended that the Ras~ussen Report and the Lewis Report have f~ndamcntal shcr:- cornings which preclude their being used to establish the level of risk of the said severe accident possibility. See Accident Hazards, chapter six and nrrcndix one, and the revic*..Js cf the Rosmusscn lkport by the United States Environmental Protection Agency, dated A~g~sc, 1975 and June, 1976 (r.P:\-520/3-75-012 2.:d EPA-520/3-76-009), for disc~ssions o~ same cf the shortccmings. For cx2mplc, the ~cs: severe class of rc~ct~r accide~ts, na~e:v nuclear runaway, are not analyzed for t~eir likelihood and conseque-:ices in either_ ::he (~ RasiTiussen report or the Lewis Rcpcrc:':* -~- Other shortco~ings of the ~asmussen Repcrt are: The report does not present the a~alys~s of rhc probability of the severe nccid2~ts
-x
/ \
*. ;hich the reportCccnside'!:"ec:, such as ::-ar.s:.-
encs-withouc-scram; rather the repart ~e:-e_~ g.:. *.:es the results cf :he analysis pe:-::- :-~e c.
~ I
by the Rasmussen study group, by the use cf si!i:pli[icd, 11 rc<lucc<l" L.1ult trees, for c.;x.!rnple. In one extremely important instance, at least, there is no fault tree given nt all, specifical-ly, for the accident involving the failure of the recirculation pump trip safety ~ction
- during an "anticipated transient wic~ouc scram" (though this is a boiling water reactor ac~i-dent, there likely are instances for the pres-surized water reactor in the report as we:l, for I recall no fault tree for coolant pump siezure and control rod ejectio~ accidents).
The pub li c i s b c i n g a s kc d , th c r c fore , co a cc e pt _ the results of the Rasmussen Report and the Lewis Report on faith. This prevents n:hers from being able to adequately scrutinize the probability evaluation of the Rns~ussen Report for its accuracy, c0rnp~eteness, anc*validity of assumptions (explicit a~d implicit), w~ich are nostly subjective. Moreover, the* simplified analysis presented in the Rnsmusscn Report contains svrr.bols
- wh~ch .:ire not definec: adequate- .
ly for purposes of ex3~ining the s2fety systems
.
for :heir ootcnti.1.l for, .:rnd the l:.kelihcod of, ~al:unction.
. Overall, it is contended that the appli-cant's and the Nuclear Regulatory Ccmmission's safety analysis reports are not an adequate basis for assessing the safety of the proposed Salem pressureizcd water reactor and its storage pools, and that the Rasmussen Report and the Le,;.;is Report are not an adequc1tc supple:.:en:
to answer the concerns of these contentions. (7) The reliability of the SCRAM system to f'"1 control accidents has not bee~ adequately
- demonst-:-atcd. (SCRAM mcnns the rnpid insertion of the reactor control rods, which shuts do~n the atomic reaction). No backup SCRAM sy~tem exists. The applicnnt has not c1dequa:ely demon-strated th.1t a b.1ckur scram system is unneces-sary, inas~uch as the pressure surge of a~tici-pated transients without scram mav be too high.
(8) The integrity of the reactor contain~ent system under a design basis acci~ent (loss-of-coolant) has not been adequately confir~ed experi~entally. Full-scale tests nppear tc be neccssa_~..;........v_.___ *-*----------- - - - - - - - - - - - -
core cooli.ng system (ECCS) h;1s not been sh.:wn to be ~he -ost *11*kely for~ or~ a
'-' ,..
- i;,
1
.1.. oss-o_F-c~~1-~~-~
-...; ~'"-
accident. Specifically, the applicant has not demonstrated th~t a loss-of-coolant a=ci-dent will not more likely occur as a result of a strong pressure surge transient. Str~r.ger coolant pressures would produce stronger fcrces on the various components of the contair.ment systems. As for the ECCS, a stronger coolant pressure may be the result of a transient that produces a hotter core ~t the time of the coolant system rupture. The ECCS is net designed to control the higher pressure anc hotter core (higher temperatures) of such y / a loss of coolant ~ccidcnt.~ (10) It is contended thac there should be additional consideration of an earthquake producing a loss-of-coolant accident, inas~~ch as a ~rototype reactor plant will not be proof tested by siraul~tcd earthquakes (due to obvic~s __ ________ impracticality). ...;... (11) Ic is contended that the sponta~eo~s P-1 reactor vessel rupture type of accider.: a~d a vessel , ruocurc
. due to .cressure surges~- -
ancici?ated tr~nsicnts without scra~ h3v~
'*. not been adequt1tely demonstrated to be ::if
-
negligible probability (to ~arrant their ~2-glect in the reactor containment design). There is the question of no leak-before-break warning. (12) The applicant's safety analysis has net given adequate consideration for the possi-bility, perhaps the likely possibility, that a severe reactor accident will occur as a result of unforseen causes or effects, as that seems to be the experience of accicents or near-accidents in nuclear rower plants. (13) The applicant's safety analyses ha~e given inadequate cnnsiJer*1tion to the poss~- bility of c,;:nmon-rnocle type f.:1ilurcs in tr..:: coolant piping and the emergency core cooli~g system piping, especially the possibility for sequential failure of the latt~r due tc the forces generated by the former. (14) the .:1pplic:1nt h.1s given inadcriuatc c-::,r.si.c-rZ c1*.:1tion lo the possibility of sa!Jotage, -Co:- exawplc, consider.:1tion should be given~~ the lack of provision for separate roo~s 2~d blast sh~2lding in between, to separate:~~~~~ safety systc~s, instru~cnt~tion, and c2~~25
..
**
from p~imary equipment in rooms normally~~- attended, to minimize the likelihood of a saboteur's bomb knocking out primary and back-up safety equipment at once. Also, a mulci~le control rod ejectioD accident could easily be caused by a saboteur's bomb. (15) ALlplification of the preceding conten:io~ along with supporting arguments and infor~aticn are given in the following documents, whict have never been dLsrutcd by the ~uclear Regula-tory Commission:
- a. The Accident H2zards Of Nuclear Power Plants, R. E. Webb.
- b. Memorandum in support of the conten-tion of the Con1ition for Safe Energy in the construction permit hearings fer the proposed Erie pressurized water reac-tor (Docket No. STN-50-580 and 581),
dated September 26, 1977, which treats issues ccrnccrni ng the emergency core cooling system; specific possibilit.ies of "anticip<1tcd tr.:msients without s2:-::.:-:-: c1nd their likelihood; che need for t'.J __ seal~ tes:ing cf analyses cf certa~~ accidents; kinds and causes of ::-.
. . .
..!it1.;:_2 1
'. control rod ejection accidents; ?C~er excursions with excessive boron c~~ce~tra-tion in the coolant; loss-of-coolant accidents without scram; and co~mcn ~cde f3ilures in coolant piping and e~e~ge~cy core coolant piping in loss-of-coola~c accidents.
-------*-****-***--***--****-- .. ---- -- *-----
C, Remarks by R. E. Webb before the Nuclear Regul~tory Com~ission's Atomic Snfcty <1ncl I.icc'1'sing Eonrcl on the sa:d Eric proceeding, July 28, 1977, Transcrip: pages 81-176, defending his contention.
- d. Petition to Congress "C:111:.ng f,~r a Fu11 Rcvic*..; ,1ncl Invcstig.:1ti.on o: t::e Hazards of Nuclc~r Power Plants an~ ~adic-active Waste* Disposal," by R. E. Webb, May 20, 1978, including' an appendix titled "Remarks on the Cruc L:i l Fae tor cf the Surface Contaminntion Limits for Plutcniu~
and Strontium-90."
- 8. PERMANENT SPE?-H FUEL REPOSITORY AT SAi.EM C' "} .1 r O< .J-(nl It is contended lhnt it is likely thac ch~
spent fuel f~om the Sale~ reactors will be storec aer~E-nently ~n the on-site storage pools--that the Sa:e~ ~e=:~c~ site ~itl become a permanent rcposltory for the ~~;~-:~~el
-~..,
....
. t.
radioactive, spent fuel gcner~tcd at the plane. (b) There presently exists no geologic nuclea~ waste repository for disposing of the spent nuclear fuel; and no such repository is likely to be developed and demon-strated to be safe, or permitted to he built and opera:ed. (c) Off-site spent fuel storage pools which store only aged spent fuel assemblies (older than six ~onths or a year) have catastrophic loss-of-water accident possi-bilities as well as the reactor site storage pools. Such off-site pools have yet to he evaluated fully fer their spent fuel heatup and radioactivity release potential in loss-of-water accident. FLlrthermore, the theoretical deficiencies in Sandia's mathematical theory (SF~ELl fer spent fuel heatup in a loss-of-w~ter accident, which are discussed in conten~ion no. 2.(o) ~bove, mav., verv., well mean that the heatup predictions presented in the Sandia Report for off-site pools may be grossly in error in the unsafe direction. Therefore, off-site st~rage pools c~nnot be considered a safe alternative for storing Salem_ spent fuel; nor does it appear to be an economically viable alternative. (d) Even if the spent fuel were not allo~ed to acc~mulate in the Salem pools, there will be at least sixtv-five new spent £uel assemblies stored in each ~eel a: a~y one time, which ~enns that there ~ould be ajc~: 3K
- ,
2.5 million curies of Strontium-90 in each storage pool (and a like amount of Cesium-137). Infor~ation recen:ly dev~loped about the loss-of-water accident hazards of spent fuel storage pools reveals that ic is ~onceiva~le that the Strontium-90 and Ccsium-137 could be released from the fuel into the outside atmosphere in *,n..:.c~ an S-.:.;.c 0 accident (even for open, low density storage reeks). Thus, a loss-of-water accident in c:1 single soent fuel pool could
,-6 result in ruining agriculturcj over a land area equal to three times the size of Ne~ Jersey, n~ong other disas-trous consequences. The combi~cd rclcnsc of radioac:ivit~
from a reactor accident and two spent fuel stoTage pools (as a consequence of a reactor acciden:) would be about three ti~es worse.
-
(e) The only way to avoid the risks of spent fuel
-t !.,..; ;*~:fr r ~;
storageMis to cease generating the radioactivity ~y closing down the station and terminating the ccnstructio? of Unit II--that is, to revoke the reactor licenses.
Verification. theoretical 2.naly2es and -=X?eri:-.e:1"'.:s t!"'.a-: *,.,-:t.:2.c ::::e necessa::-:.,* in order to fully evaluate the ~azards o: s~ent fuel storage (and reac~or accidents). ~o*.*1ever, it is co::te!'1ded that no~ practical (r.urnanly possible) to prepare the needed analyses nor to conduct the needed experime~ts; and, therefo::-e, the full r.azards could never be sc~en"'.:if~cally established, except by assuming the worst conceivable consequences--that is, a near full release of radioactivity :r~m the storage pool. CONCLUSION
------
Spent fuel storage nt Sale~ (ard ~ny ocher reactcrs)
.
is unsafe because loss-of-water accidents are possible and because the potential harmful cons~qt.:.'r.~c-s are extre:ue. Closing down the reactor*°is the only responsible course cf action. This would eliminate the risk o[ reactor acci-d c n t s , :,.; h i ch i ts e 1 f is ext r ,2 me 1 y grave .
' . An Analysis of the Acciden~ ~azarrls o! :-:oring ~ighly Radioactive, SD en t ?!le l Rods in Spent ?uel 3-:orage ?oo ls a"': :;uc l2ar ?ower :? lan-: s 3.r~~ 3.t Ot~;.e:- Cff-Site, Storage ?c.cili~ies: **:i.:~ Special Reference
- ion ~uclear Power Pla~t near Chicago, Illinois
(?ressurized ~ater Reactor) by Richard:. ~ebb, Ph.D.
I. Introduction Nuclear power plants produce extremely large amounts of radioactive substances as a by-product of oneration ~ substances which emit harmful nuclear radiation and which ~ust be absolutely ccnfined to containers and prevented fro~ escaping into the oio-sphere ( the human environment), in order. to avoid ex;,osir.g huma"'.s and other life to high levels of radiatior: and the high risk of cancer and other diseases that would result. These substances are co~sidered as nuclear waste that must be safely disposed of, except possibly the by-product plutonium, which is a nuclear fuel material that can be further used, but which is also a highly toxic radioactive substance. 3ven if plutonium were used to fuel nuclear power plants, however, a substari.tial residue of it would still remain in the waste material, thereby adding to the waste's toxicity. It was originally intended to dispose of high level racioactive waste by pla.cir:g it deep underground, :or isolation from the biospr~ere in special .:acili ties call*ed '6 eologic reDosi- ~ories". However, there presently exist no such facilities for
.
pe~~anently and safely disposing of nuclear waste; nor is there any assurance that such facilities will exist in the next twenty
.
years, er ever will exist, due to technica~ ,roblems or" ass ur 1.r:.g isolation of the waste for the hundreds anc tens of thousands of years that will be required for the material to decay to safe levels of radiation. As a consequence, high-level radioactive waste and plutonium is dangerously accumulating in storage pits at nuclear power plants and other places in the !arm of spent - fuel rods (to be described shortly). These "spen~ fuel storage pits", though each is enclosed in a buil~ing, are creating an
ex~re~ely serious hazard to the public health and safety, be-cause they can suffer accidents in which most of the radioactive substances, chiefly, Strontium-90, Cesium-137, and Plutcniu~could conceivably be severely heated, vaporized, and released (vented) into the atmosphere as smoke, through explosion or other ~eans, to cause geographically widespread radioactive fallout contamina-tion, death, cancer disease, and genetic mutations in future generations. Specifically, an accident i.""l.volving one spent fuel storage pit could potentially result in ruining agriculture over a land area of the size of one half of the land east of the Miasissippi River (500,000 square miles) for over a hundred years, due to the release and fallout of Strontium-90 radioactivity~ a calcium-like substance that would enter the !ood chain through pl2.."'.t uptake and settle in human bone tissue -:o cause bone cancer. The fallout of Cesium-137 would also severely contaminate agricul-tural land; and in addition it would create severe X-Ray-like radiation levels above contaminated ground, covering about 250,000 square mites for over a hundred years. Finally, the buildup of plutonium., which besides be*ing radioactive is also an atomic bomb material, creates the possibility of nuclear explo-sions occurring in a storage pit during an accident, which would disperse plutonium into the environment. ?lutonium dust js an extremely toxic rad ioacti*,e substance which causes lung and bone cancer and which lasts for thousands of years before decaying to harmless levels. A release of a fraction of the plutonium from a spent fuel storage pit would have the pote~tial for causi~g
?age J ner~anent abandonment of a land area th~ size of 150,000 square
- niles, which equals Illinois, Indiana, Ohio, and half of Pen.:1syl var.ia, cor.1":Jined. Clearly, it is extremely important that the accident hazards of spent fuel storage pits be thoroughly evaluated. There will be hundreds of such storage pits scatterec throughout the country. Already, there are about seventy-five.
It should be noted that a "nuclear disaster" is reported to have occurred in the Soviet Union in which about one hundred million of curies of Sr-90 and Cs-137 had been released and had fallen out over a land area covering a lake basin. This figure was estimated on the basis of contamination data published in scientific journals of the Soviet Union as analyzed by a Russian scientist. ?he figure 3..s ,:ompara':Jle to the Sr-90 and Cs-137 content of a spe!"',t fuel
- i I
stora 6 e pool, and makes it all the more important to evaluate t!".e accident hazards. 7-he source of the radioactive waste ~azard is the nuclear reactor, which is the heart of a nuclear po*Her plar.t. ':'r.e reactor is a steel vessel containing a mass of nuclear fuel, called the reactor core, which undergoes an atomic reaction to prcduce heat (nuclea~ energy) for generating steam and even:ually electricity. T~is atomic reaction also produces the radioactivity as a by-proG* UC.,'
'T" which builds up within the fuel material (uranium dioxide).
The fuel is in the form of rods, which are sealed zirconium-alloy me"':2.l tubes containing solid uraniu:n dioxide :pellets and which are acout a hal:' inch in diameter a."1d twelve feet long. 'I'he zi~con~um tube.is called the fuel rod cladding, wh~ch acts to pro~ect t~e ura~ium oxide from erosion by the reactor coola~t flow
..
Page L;. a~d also ~o prevent the radioactivity from seepi~g out of the
- 'uel rod. For handling convenience the fuel rods are ,._...,aunc..
together in separate bundles, called fuel assemblies, each containing about 250 rods. Typically, a reactor core consists o.f a closely packed array of about 200 fuel rod assemblies to7.alling 50,000 fuel rods.* ~he fuel rods are ~ot destroyed by the atomic reaction, but instead !'!'l.aintain tteir mechanical for~ throughout their service in the reactor. (The zirconium clac:ding is designed to remain intact.) T:hen the fuel rods. become exhausted~depleted beyond efficient use~they are re~oved from the reactor and stored to await disposal. There-af~er, the fuel rods are n;.:i:1.::ir'l -T"lon ... ~--
. . , __. __ .~"""' ::.:::.::..:..'..J -~*,o1 ..... ",..1 ~
-V*~:-:, *,*",.,i'c},
,, . ., .-:.
'=:-:-':re:.1.ely r2.d ioac ti ve, due to the r..axi:num bui2.:::1 U'9 cf :he ~ad is-ac~ive by-products within the ura~ium dioxi~e. 'i'ypically, about 65 spent fuel assemblies (over 16,000 span~ fuel rods) are
- ,
!"e::1.aved annually fror.1. a reactor :er :-e.fueling.
'The spent !~uel rods are stored u:-i.cer water 1n steel-line*::,
water-filled, concrete basins, called spent fuel storaee pits or pools, located next to the reactor. (~ereafter, we shall refer to them as storage pools.) Underwater storage is ncessary for cooling purposes, because the radioactivity within the spent fuel rods generates heat, which must be dissipated in order to prevent the roes from o*rer!'leating and releasing its radioactive materials 1 vaporization. m'- ( .L f'..e nuc _ear rac* 1a
. .._ *
,.,ion emi,., ' .._.._ .
,.,ea the rad ic-
- mhoc:
................. ~~~~,.,...:::,s
_5 .......... - ::>""'~ly
--y:;J..- *o
..., .. ...,~:::,s-u.,...;z.:,,rJ
....u ... ...,. .;:,, - .- - ..1. ..,'IC:."'--
,~*.:,y- .,...:,,,:::c*o-s"
.. - - - .., _ ,
.L-;;,o.,..._
"boili:-,g wate::- reactors"~ t:ie otr.er t:,rpe of nuclear po*.ver reactor in use - the fuel rod/ assembly data a:-e some*Nha t different, but t~e principles are the same.
?age 5 activity js energy, whic:1 ends up as heat generated withi:i the spent fuel materia~since the spent ~uel absorbs ~ost of its own rad iatio:1 when it is bundled 0 -..i.. --ckerl 1;.:::.
- u +o~e*~~er
~ 5 \J.;.:. -
- T1'1e \-tater in a spent fuel storage pool also acts to ab3orb the :1uc~ear radiation v1hich escapes the spent fuel and, thus, to shield tr.e plar.t workers from the intense radiation.) The water in the pool effectively cools the spent fuel rods by efficiently absorbing the heat; but the water, tao, ~ust be cooled by a circulation outside cooling system, which disc:i..arges the heat to the/enviro~-:1ent, or else the water would heat up and boil away. However, the radio-activity decays with the passage of time--- that is, the levels of. radiation and heat generation decreases wi tr. ti::ie- suer. that after a period of six months in the storage pool the spent f~el can be removed in lead-shielded, water-cooled shipping casks and transported to a waste disposal facility without excessive radiation levels and heat generation rates that would otherwise
- 1ake portable shielding and cooling systems i:np.ractical. Furt:':er-more, shipping casks containing new spent ~uel (no decay) would certainly be unsafe for transport, since a:1 accident er.route which causes a loss-of-cooling would more likely lead to excessive spent fuel heatup and, presumably, a heavy radioactivity release and, hence, a ~ajar public disaster.
~ence, nuclear power plants are equipped with spent fuel stc.rage pools, to provide interim stora6 e of spent fuel assemblies
- .vhile they "cool down" to heat generation and radiation levels that a~e low enoug~ to per~it relatively safe shi;ment away from the reactor site :or disposal, (T~e heat generated by t~e radio-
'
. ?age 6 activity in spent fuel will r.erea.fter be callee decay ~ ' w:,,.ich is its common name; to associate it with the decay of the radio-ac ti vi ty, ) The spent fuel storage pools, therefore, were designed
- in the assumption that spent fuel assemblies would be removed fr~m the pool after the six month cooling-off period and, consequently, would not accumulate in the pool,* ~ith an annual or 1/J of a reacto:
refueling discharge of about 65 spent fuel assemblie~ then, the co: spent fuel storage pools at nuclear power plants were expected to contain at most one third of a core load of spent fuel (two thirds for a pool which services two reactors). In addition, the pools were also designed to store a whole core, if it should be necessary to remove it from the reactor in an emergency, making a total storage rack capacity of l l/3 core loadings of fuel assemblies
- I
'
( l 2/J cores for two-reactor pools).
~owever, because of the lack of waste disposal facilities, the industry with government approval is replacing the storage racks in the pools with new racks designed to per~it close packing of the spent fuel assemblies and, therefore, storage of much more spent fuel in each storage pool. Also, it is planned to store the spent fuel on a long term basis (decades), It may even turn out that the densely packed storage pools will be *the per:nanent repositories for the radioactive waste. Specifically, plans call fo~ packing sixteen to eightee~ times more spent fuel into tte storage pools than was origin2.lly intended to be stored - up to Zion nuclear station pool, :o~
e:rn~-:1.ple, compared to lJO asse:.'.blies as originally intended. Tr.is will amount to over half a ~illion spent ~uel rods in one pool.
- n ter~s of radioactivity the Zion pool will contain at its new storage ~acks capacity 75 million curies of Strontiu::1-90
',
Page 7 radioactivity. (A curie is a unit of radioactivity.) ?or reference, the Federal Radiation Council has reco~.mer.ded that O.l micro-curie of Strontium-90 be used as a health li~it for Strontium-90 ingestion, or one tenth of one millionth of a curie. For a mare concrete comparison, the Atomic :::nergy Commission report *Theoretical Possibilities and Consequences of r,1ajor Accidents in Large* Nuclear Power Plants C:!ASE-740: March, 1957) calculates, using a considerably greater health limit for Strontium-90_, that a vaporous release of 1.50, 000 curies of Strontium-90 from a reactor accident could potentially result in agricultural restrictions on 150,000 square miles of land, which equals Illinois, Indiana, Ohio, and half of Pennsylvania.
-
Strontiwn-90 than this
---
The Zion spent fuel storage pool will contain 500 ti~es ~ore
--
':'l.-\.SE-740 release value. Moreover, there presently exists two spent fuel storage pools which are not reactor site pools for storing new spent fuel but rather they are sepa::-ate, independent storage facilities designed to receive aged spent fuel (six months radioactive decay or longer). The Federal Government anticipates six such independe~t storage facilities by the year 2000 to store the overflow of spent fuel frcm several hundred reactor-sited sper.t storage pools. It is planned to store even greater a:naunts of spent fuel in t:-,ese independent storage pools, For example, the General :::lectric
- 80. 's independ e::t' storage pool at :,I orris, Illinois, is to s"'core tor,_"11.es of 3~ent fuel, containing 120 million curies of
- tro:--.tiu.m-90, w}'.ic:1 is .Seo ti:-:i.es the 'JAS:-i-74-0 release value.
T~e magnitudes of the buildup of Cesium-1J7 and ?lutonium will be extremely large as well, as ha3 b2cn ;uantified at the outset. These ~agnitudes, includin 6 the figure of 75 million curies of Strontium-90 to be stored ; ...
-**
~
the Zion reactors' pool, are derived in Append ix 1. It should be noted that both Strontium-90 and Cesium-137 decay slowly and plutonium extremely slowly, which explains their long-term contamination effects.* We now turn to the matter of the accident hazards of storage pools-accidents by which the radioactivi -ty could escape into the :::::-'.vircnment. As before mentioned, the spent fuel rods ~ust be s .....1..orec. i:-t . water :or cooling purposes- to remove the decay heat and -thereby prevent the rods from overheating. Any accident resulting in a loss of water in a spent fuel storage pool would, therefore, to S?ent fuel heatun with potentially disastrous conse-quences, as will be shown in this analysis. T~e loss-o~-water accident is the basic accident hazard of spent :'uel storage Dools and is, therefore, the focus of our analysis. The rate of radioactive decay is measured by the amount of ti~e i+. takes for the radioactivi-:y-level of radia1:ion- to de-crease to one half of an earlier level. This decay time l.S called the "half life."
~o illustrate, if the level were J2 curies ~o start with, then in a succession of half-li~e ti~e neriods, t~e level would i...ecrease as ::o
,-l ~ 11
~ows: '1'J _,,,._, ..1..1 c" , *Q.... , ...,.,
!,- ~
.::::,
,
.... ,
0* , 5 , v * .::::~5 , e1..c. I"\ ... Stro~tium-90 and Cesium-137 ~ave half-lives o~ 29 and JO years, respectively, and plutonium has half-lives ra!'lg.i:'..g :'ram a few
~h,..ue:ar",d .., ... v - .. -+-o ?4 t..,.01"iv0 ye::i---s 1.., - -- I a*o.,.,er,di...,g
__....,, ** -** u~n -ho ~ *. ._. 0
<::"'°Cl. -~.;C
~;;:'*- .., "iso~O'"'"""
- w .:;J-Qf plutonium.
- I::1 a loss-of-water accicent there woul:j exist only t,*,o means of decay heat dissipation: cool ir.g by :'.a tural convec tio::1 air flow thrpugh the spent fuel rod assemblies and thermal o:' ~',.,.~
*.1 .. 1-spent fuel assemblies. Eowever, as ~ill be show~ i~ this analysis, these heat dissipation mechanis~s are not sufficient to prevent severe spent fuel heat up. ?urther~ore, the heat-up potential is aggravated by closely packing spent fuel assemblies in the storage pools, which is now happening due to the spent fuel buildup problem. Close packing impedes natural convection air flows and thermal radiation heat dissipation. It will be shown in this analysis report that the spent fuel heat-up potential i~ a loss-of-water accident is such that the zirconiu~ fuel rod clad~ing would catch on fire, starting first in new spent fuel assemblies and spreading to e~gu:f the entire load of spe~t fuel
~n the pool, and thereby greatly adding to the heat generation in ~he spent fuel. (The zirconi~m could ignite at 900°:.) ~olten zircor.ium metal could then for:-:1 an:: run dowr. and f:-eeze in the _ inlet passages of tile spent fuel assemblies to plug a-i.... .... UD these passages and thereby starve the fuel assemblies of any ---~ 3..; ,... ccoli::-1.g, wn.1c . . r, ....
.. would further worsen '...,ne spent fuel heatup.
U~der such conditions, it can be calculated that the .vaporiza-tion and release of nearly all of the Strontiun-90 and Cesium-1J7 radicactivi~y from the spent fuel rods is conceivable. The S?ent fuel building would heat up like an oven, and the i~ternal a~ .... pressure :ue to air heating could turst ope~ the o~ilding or its ve~t valves to allow the escape of the radioactivity. Or,
?a~e 10 z irconiu:n and hydrogen ex-plo s io:--ts are possible, due to t'.'1e presence of residual water w~ich could chemically react via-ler,tly wi "th zirconiur:1 to prod1.1ce explosio~,s a:1d also r.:,'drogen, which, too, could detonate. Such explosions could conceivably burst the storage pool building as well, besides compacting the fuel rods and thus causing them to heat up even further, due to ~jded restrictions to the flow ~fair for cooling.
It is concei*,able, too, that spent fuel-particularly, the ura:--,ium dioxide-could melt (at 5000°?) and thus for:n a liquid pool of molten fuel within a frozen shell or crust of ur~niur.1. dioxide and steel and zirconium. Under this condition, it is conceivable that the plutoniu~ in the :ncltan uraniu~ dioxide could separate and stratify i:1 such a pool-- or at least
- 2. ::1ass of fuel r.1.a terial could form whic:--. is rich i:1 plutonium-create as a result a nuclear fuel mass capable of generating the s2..me kind of in an a to::1ic comb- a runaway reaction 'Nhich could produce a st:-or.g nuclear ex-plos.ior-. that would increase the d is-pers2.l of t:-'.~ radioactiYi t~*,
into the environment, especially t~2 plutonium. Plutonium mi~:. t not ~scape heated solid fuel r8~S as readily as Strantium-9C
*-:esi1..:.t1-1J7; and so pulverisation or vaporizatio~ O.i...,:, '.
-:ne ~-,,
-
I 0,,
\.A,\_. -
amc *J.nt O -f'~+..;..i.., (.,..11*+o"'i"m)
,_._.. ..... ~ .... ,l,,.i,_;...i... could be released into the at~osphere. -*
( -......., ~.::-;
' . ~uclear ex~losion possi~ility is
...... si~ilar to the mechanism
! """ .;.:. *~.::::.
"**- -~0'!.:-'-~ ~*\., ~Tni'
"" Or.., n mol y
** 2.! .. ~- ' -~ co~centraticn of plutonium in a
~uclear waste burial trench.) Such are the courses a loss-of-
- a.ge 11 water accident could conceivably take. The possibilities must b 0 thoroughly investigated.
Finally, it appears that sue~ loss-of-water accidents are possible in independent storage pools, which would store only aged spent fuel. Al though the decay heat i;";. agec spent fuel is CTuch less that ~ew spent fuel, there still exist3 the poter:.tial for sev~re hea tup, zirconium fire, and so forth, as will be sho*,m. The question arises: what i~cidents could cause a loss of water in the storage pool,and how likely are such incidents? are several possibilities which need to be investirated; r:.amely, d ro;,, earthq ual-:e, sabotage, cooling sys te::: '::rea}:d own, a "criticality" accident, and a reactor acci::ien-t. It is possible the heavy spent fuel shipping cask could fall its cra:--.e in~c the storage pool and break the floor of the s~orage pool, causing rapid drainage of the pool. ~arthquakes and saoiteur's bo~b are additional possibilities for breaking open the storage pool walls ar.d causing rapid d:-air,age. Anotter ~03si~ility is a breakdown in the peel water ccoli~g system, which would result i~ the pool water heating u~ and boiling* dry due to the decay heat of t~e spent fuel: but this would be a relatively slow process, requiring three weeks or so. Still ==.nether pcssi~ili ty is an occu.rrer.ce of a :'1uclear "criticality;* whic:: is t!".e name o: t:-.e ~ain atomic reaction which nuclear fuel u~dergces i~ a nuclear reactor when produci~g hiih power. C!'"i ticali +::*.:/ ca.-. occ*ur i:-'~ _ spe~t fuel storage ~coli~ fuel is re~.oved f ro:.1 reactor without full usage !or some emergency reasc~ and is stored in ?artially used fuel is ~ore potent t~a~ sne~t --f """._ - . 1 '! Q ~
..
?age 12 sf'e ~ t the question arises whether it is pos~ible for a mass of fuel rods I'
to-_ und e::::-go cri- -;-; r-1 i +-y as -+-hey are ~uch depleted o! :'uel ( -'-'n.oua;..,
"""--4::l,--.., ' I.., ..,, b*"'
they still contain about one half of the origi~al amo:.i.nt of nuc_ear 1 f'
~ue_, ) . A criticality is to be prevented in a spent fuel storage ~oal by the -olacement of special "neutro!", absorbing" material sheets placed between the spent fuel assemblies.
Accide;1t Hazards -9.f Nuclear Power Plants for a description of
-
(See Th.P the criticality phenomenon and nuclear runaway accident possibili-t i~~
--..:J invo1vi~c
-- -- _1 ... 1::.i cr1.'t1*ca1;-")
* .i.1.1.:J* However, it is possible that a few of the sheets could be missing and a criticality accident occur as a result. Co~ceivably, such a criticality accident :ould generate enc~gh heat to overwhelm the cooling system a~d boil the pool dry.
The criticality accident has ~een stated to have such a possible co~sequence, but no analysis of it evidently exists. T:1e U. S. ;luclear Regulatory Commission U~RC) and the nuclear ind ustr:r t..::--,d oubtec: ly eel ieve that the likelihood or :pro ba'c ili ty of such incidents occurring can be made acceptably low. ?or in-stance, special pads can be installed on the pool floor to cushion the fall of a cask; but whether such pads are in :act going to be f~ol installed remains to be deter:nined. The ~a~ can ~e desi ""!:.ed to
". 0 withstand a given size earthquake (it seems that a nuclear plant is never designed for the worst possible earthquake, however, but only the worst size that is considered likely). Sc:.botage can be made difficult by plant security measures. ). r.d, three wee~s may see~ like a long enough time to repair a failed cooling system to ave:?:'t a boil-of.: of the ::-col water: and, besides, water can always be added in a ~akeshift way to replenish water which boils off and thereby gain ~ore +~
'J~--~-
-"""O for repairs. 3u-t,
,,
'='aao.
- o- -l J nevertheless, such accidents are possible: for a pool and its equipment could possible be wrongly co~structed or installed, or the safety measures could contain design flaws which lie undiscovered due to no inadequate experimental verification ar confir~ation of the desi~.
It should be noted that once the zirconium cladding of the fuel rods reaches high temperatures, any attempt to cool ... v!le spent fuel by injecting water back into the pool could, instead of quenching the spent fuel, merely hasten its heatup, because - I I wa~er reacts chemically with heated zirconium to produce heat I
!
conceiva'aly, I 2nd possible e:....'1)losions. ~!oreover,/the intense he2.t in the sTient
-
fuel could cause some or all of the criticality-o~evention
-
sheets between the spent fuel assemblies to ~eltdown, leaving the *fuel to generate a powerful criticality~that is, a hig~
""Jower nuclear reaction-which could prevent reflooding, and eve~ result in explosions.
It is not possible to demonstrate the reliability of acci-dent ~reventive measures or to foresee all possibilities for rapid drainage (Could the foundation of the pool be eroded?): but rather one can only ~ake a judgment on whet~er the pool design, tr.e pool foundation, and the safety ~easures are ade-quate, which will be a subjective judgment. ~owe'rer, in oMer to adequately assess the overall risk to the public, one must analyze the loss-of-water accident to deter~ine t~e ~otential consequences, for surely the ~agnitude of the potential ccnse-
;uences ~as a crucial bearing on whether the risk is accepta~le,
' 3:..:.t regar::iless, t:-.ere is one :possible catlse of a loss-of-water in the storage ~col which is highly likely, ~hat ~eing a severe
?age re2.ctor accident. A reactor explosion accide::;.t would release such heavy amounts of radioacti*ri ty tr.a-l: the radiation le?els ir. tb.e vici!"!.i ty of tl'i. e reactor and its storage pool ~Nould be so great that the reactor plant person~el would surely flee, leaving the storage pool cooling system unattended. ~xcessive radia~ion levels could, potentially, persist for months; so tha~ once the the cooling system broke down,/pool could boil dry before emergency crews could reach the pool and re-establish cooling (assuming such crews could be raised). For o~e class of nuclear power
- -aactors-specifically "boili:,.g *::ai.:2r" reactors -the s;:orage pool is locateJ a~c~a tho r~actor, so ~hat a reactor explosion I':'.e 0th,?:::- class of reactors -;".lresst..:.rized w2.te!' reactors, such
~uildin;s connected to the reactor building. There are a sreat nany- virtually in:-i.umerable-r2actor a.ccident possi1::1.i ties that could er.d in explosion *.vi thout
- .*1::.rning and ca.use severe releases of radic2.ctivity that *:1ould force evacuation of the reactor site, including the spent fuel s~ora.ge pool or pools. For analysis of the reactor accident
- 1otentials, see *his i,,_........ au**nor'~ ~re~ti~o L, J. - - ....,. Cl. -~- ~h~ ......
-=-:..:.;:_ ~cia'en*
*1 i....; - .. L. Hazards of
~uclear ?ower ?lants, University of Massachusetts Press, 1976, and his related works which are enumerated in reference no. l the end of t~is present report.
- ruclear power reactors are high nrec::~u.,...~;* ....... - ...... ~.. --
sys~ems *:Ii th potentials for severe "ru:--.a*::a?s" in the po*:1er level of t~e reactor ccre or syste~ ruptures - _. -4 . ~I,(""' ~1
en the verge of rapid, uncontrollable core heatups and ax,lcsio~. It takes a very great amount o~ hi~hly J~tailed, careful attention and ins~ec tion throughout the en tire cc urse of ::.a::.:.t:g a reactor and ether reactor plant systems, operating t~e p:'.32':t, ~n8 main-taining it, in order to prevent explosion acci~ents, leaving very little or no roo~ fer tlli~an carelessness. Ir~ tl1e o-p :.niori of this author, the vast range of reactor accident possibilities and their ~ossible causes, aJ"l.d t:*.e instances of equipment failures, near-accident incidents, and reactor accidents that have already occurred indicate that severe reactor explosion accidents are likely to occur, or we must assume so.
- Reactor accidents, therefore, are the like~y events to cause the spent fuel storqge pool to lose ].*+', s erun~.
~ It is noted that this report was written a week before the Tr.ree ~-Ule Isl::.nd reactor accident in ?ennsylva.nia.
':he potential disastrous consequences of 2. ::>eacto::- accident alcne--e:{cluding a spent fuel pool erupt:ion--are extremely severe Q
?er example: (1) agricultural restricticns for several years over an area ec;_ual to h~lf of the land east of the Mississi;Jpi ?,iver could be recriired, and agricul~ure cculd be ri..l.i.ned ove-::i an area t~e size of Ohio for over a hundred years, due to strontiu.~-90 release and fallout alone; (2) severe living res:rictions oyer 120,000 sq_uare ~iles ~nd evacuation of several thousands of square miles for a year and possibly longer (assuming no plutonium release); and (3) death and disease due to unavoidable radiation exposures affecting a millicn people: for example, a possible million cancer deathso (See this author's treatise Accident Hazards and his essay ~o the Congress of the United States,~ Petition Calling fer a 3'ull Review* and Investigation of the Hazards of Nuclear Power Plants and Radio-aci:ive Haste Disposal, May 20, 1978) From these figures, and especially the land area figure for evacuation)which is a straight fo:cward ext:-apola tion of WASH-740 figures to apply to today I s larger reactors, we can appreciate why the reactor/storage pool personnel would abandon the reactor site in the event of a severe reactor accident. Furthermore, there is an advanced reactor under vigorous Q*eve1~omen~
-U . . . . . V 1,'"""0Wn C:::.-
;....*
-~ ~he"""'""
I~~~~
.....:::.::...:
neu~~on
... l...,.:,. -
~~e
........
0 ~e~
-- -
~ 0...... ac~o~
- ,J - , which.has accident potentials of nuclear explosi*ons, which could release, say
~we tons of plutoniu.~ 3 as well as ~he ether radioactivities, with f'(21'ma.., e>1t" the poten~ial consequence of abandonment of 150,000 square :rJ.iles due
"
to 0he lung cancer hazard of plutonium dust fallouto (See Accident ~azards and Petition to Congress). Such reactors could be considered
- o be mere prone to accident and would be more devastating to the
- eactor site. We r:..ay expect ~hat fast neu-cron breeder ::-ieactors would
,, 17 be built on the site of water-cooled -reactors and the:!.:-- spent fuel storage poolsj so that a b~eeder reactor accident tco could effect a spent fuel pool loss of water accidento Therefore, reactor accident hazards must be thoroughly evaluated in order to assess the risks of spent fuel storage pool accidents a Unfortunately, the Federal Govern-ment has not evaluated the severe reactor accident possibilities, and has refused to investigate them for either their likelihood or their potential consequences in its licensing hearings; so that the public has not been inf'ormed by their Government of the full serious-ness of the reactor acci~ent hazards, except by this author's analysis and related works and those of other critics (see Petition to Con-The purpose of this report, however, is no~ to analyze the reactor accident hazards$ but rather to analyze the spent fuel pool less-of-water possibility for its potential ccnsequenceso (However, the pctential radiation levels around a reactor site due to a postu-lated reactor accident will be evaluated to justify the assumption that plant personnel would have to evacuate the site and thus leave the spent fuel pool unattendedG) ~he spent fuel storage pool loss-of-water accident must be evaluated for its potential harmful con-sequ~nces because a storage pool will contain ~P to 20 times more Sr-9C and Cs-137 than the reactor and 16 times more plutcnium.--and thus a storage pool loss-of-water event, should it be caused by a reactor accident, would have the potential for greatly com.pounding
-che har~ful consequences of a reactcr acciden-c.* * *.1..'hus, this presen-c repor,., is a supp.Lemen-c -co my -creatise Tt.e Acciden~
- ns.zard.s cf Nuclear Power Plan1:s. It is noted that 1:he trea-cise a.ces no-c consider ~ne s:orage poo.L accident due to an oversight. At ~he time 1:he ~rea:ise was prepared, spent fuel accu.~ulation in ':he storage peels was no-: anticipatedo Fu:'ther:nore, it was assurr.ed that the s~ore.ge cf only cne third of a ccre of spen-c fuel in a non-compac-;: arrangemenG would not oresent a serious heat up hazard in the event of a loss-of-
':rater in ':he storage pool; but this assumption was unfounded and i~ccrrec:, as we shall see later.
.. Also 3 since a loss-of-water accident is a possibility having a nu...uber cf possible causes; even without the prior occurrence of a reactor accident, it needs to be evaluated for its consequences, in order to wisely assess the overall risk.so Unfortunately, the Goverri..ment and the nuclear industry have issued no adequate analysis of the loss-of-water accident in spent fuel storage poolso Only three reports have been issued concerning the subject~ The Uo Sa Nuclear Regulatory Commission 1 s Draft Generic Envircnmental Imnact Statement~ Handling and Storage of Spent Light r:!a ter Power Reactor Fuel (NUP.EG-0404, March 1978); (2) The NRC's ?.eactor Safety Study, known as the Rasmussen
?.eport1 which contai!"..s a crude analysis of the loss-of-water accident in s~ent fuel storage pools, and which is the only published 2.nalysisa (3) An analytical report by Sandia Laboratories cf Albuquerque, New Jvlexico, titled "Spent Fuel Heat-up Following Less of Water During Storage", by A,. So Benjamin, et alo (Draft, Sept 1978, SA.i.'\l'D 1371).
As *t1e shall see, only the Sandia report provides a useful analysis of the loss-of-water accident; although it is far from adequateo
~he Sandia report only partially analyzes the loss-of-water accident tc detel"r!line whether spent fuel will seriously overhea~ but the report does not analyze for the radioactivi~y release consequenceso ?urther.nore 1 -:.he analys i.s has several serious shortcomings w.b...ich ~a~e the numerical results presented in the repor~ unreliable, 2.cccr<iing :o '::his author's reviewo 'This present report presents a
' C
..:.. /
critique or the Sandia Report, which is a basis for the present analysisg This critique is outlined below; but first let us dispose of the.NRC's environmental impact report and the P~smussen Report 0 The NRC's environmental impact report totally ignores the loss-of-water accident possibility in reactor-sited spent fuel storage pools (despite the fact the National Environmental Policy Act requires a "detailed statement 11 of the "risks to health and safety 11 ) 0 The report only mentions that calculations were made of a loss-of-water accident occurring in special storage pool facili~ies located away f:-om reactors in which only aged spent fuel 't:as assumed to be stored. (Recall that the decay heat rate is less in aged spent fu.elo ) The NRG report asserts that the calcula -cions shm*i t:ha:; loss-o:'-water vrnuld not result in a serious heat up of one year old
- i spent fuel; but the report cites no details of the cal:ulation - I nor any reference where the calculations can be fcund and eXaI.;.ined for their valid.i ty g Moreover, a report of the S and.i.2. Laboratory in Albuquerque contradicts the NRC's statemento In place of rigorc,.1s scientific analysis, the NRC report offers only vague, :'.iUalitatiYe, and unsubstantiated assertions, such as: That the waste in spent 11 fuel :!:'epresents little potential hazard to the health and safety of the public 11 (J?o S-3); That the 11 underwater storage or aged spent fuels ~s an operation involving an extremely low risk of a catas-
twer-e is trochi*: release of radioactivity 11 Po 4-13); And that..... no mechanisLt 11 a~1aila:le for the release of radioactiYe materials [i'rcm aged
')
spent .fuels 1J in significant quantities from the facility, either a~ a reactor site pool or away-from-reactor peel (Po 4-13). Su=-ely, such assertior~ .are not acceptable substitutes for ~igorous, scien-tific .=.nalysis. It is important to note that the ::-rnc I s report
2 C) introduces its section en accidents with the statement: 11 A range of potential accidents and natural phenomena events have been analyzedo" Clearly, this statement does not assure that all possible spent fuel storage accident situations have been analyzedo (\ 'T'1.-.
-l~-
i s problem cf the Federal Government failing to issue full hazards analysis applies to nuclear reactors as wello See this author's Accident Hazards and ?etitiona) The NRC I s report of its Reactor Safety Study--kno.'ln as the ?..as mus sen Report--addresses the possibility of a loss of ~*rater accident in spent fuel storage pools at reactor sites, and estimates that the potential resultant radioactivity release would be small relative to a reactor accidento However, the report was not based on any scientific analysis but rather on a number of u.~founded assumptions (guesses).> the effect cf wl:1ich was to force the es ti::r.:.a ted radioactivity release potential to be smalla Firstly, the report considers only light storage of spent fuel--130 spent fuel red assemblies: 65 new spent fuel assemblies and 65 aged. spent f-uel assemblies--and not a heavy buildup of spent fuel in the storage pool as is now planned, such as the figure of 2112 spent fuel assem-blies planned fer the Zion reactors poola Secondly, the report assumes that a serious release cf radioactivity from. the spent fuel reds would occur only if the uraniu.r.i dioxide of the spent fuel would heat up to its melting temperature (28CG 0 c) and rr..elt, and that only the new spent fuel--65 assemblies--would melt and, hence, release ra.d.icactiYityo Thirdly, the report assumes that cnly 1C% of the strontium-9C ra.dioacti,;ity in 65 new spent fuel assemblies would escape the spent fuel upon a meltdown by vaporizationo
,, 21 Fourthly, the report assumes that S*9% of the strontium-90 that dces escape the spent fuel would subsequently be absorbed in the filters of the air ventilaticn system of the spent fuel storage building; and th'e rest (1%.) finally escapes into the atmcsphereo The result of these assumptions is that the Rasmussen Report estimates that about 2000 curies of Sr-90 would be ~eleased to the atmosphere in a loss-of-water accident (This value is not stated in the Rasmussen Report but :nust be derived from the data given in that reporta See appendix l)o This 2000 curies release value should be compared to the total of about 4a6 million curies of stronti-w11-90 that would be present in the 130 spent fuel assemblies assumed in storage (a release fraction of about 005%), and compared to the potential release of 75 million curies of Sr-90 from a spent f*.1el storage peel (Zion) that is now possible because of the planned buildup of spent fuelo Recall that the WASH-740 report assumed a release of 150,0CO ctU"ies cf strontium-90 from a reactor; so the Rasmussen R~port!s estimate of 2000 curies is a relatively small releaseQ Let us now review the assumptions of the Rasmussen Report o 1'he ,1s:;umptions that a serious radioactivity release will occur only upon fuel melting and that only the new spent fuel would reach melting temperature a.re not based on any analysis but instead are simply arbitrary a.ss'Ulllptionse Fer one thing,the report neglects the possibility of a zironiu..i"Il fire, which has been predicted to start when the spent fuel rods reach 900°c temperatureo If new spent fuel ca._-ri heat up to the melting temperature ( 23Co 0 c), as the
- ?\asmussen 2eport assumes, the possii:ility certainly *#culd e.:dst for
22 the zirononillill fuel rod cladding to ignite (at 900°c) and the fire to spread throughout the whole storage cf spent fuel rods--not just confined to the new spent fuel region of the storageo 1 ans i..,,e D__ ( r.,'h now for close-pacld.ng of spent fuel rod assemblies in ~ne s-cor2.ge
~1
- pool would promote the spreading of a zironiUJ.u fire a) F-:...rthe!'!uore.,
the heat generation potential of a zironium fire would be enough to cause spent fuel to melt without the decay heato It will be shown in the present analysis that a near full release of Sr-90 from the entire load of spent fuel (new and aged) in a storage pool is conceivable and certainly has not been ruled out as a possibilityo It will be shown also that the spent fuel need not reach melting te~perature for a large fractional rele2se of Sr-90 (and Cs-137) to occur, out tha. t a 1900°c level rr..a.y suffice o The asslllilptic!l of 99% absorption of the radioactivity released from the spent fuel by the ventilation filters is also a mere assumption. It is conceivable that the ventilation system will break down in the event of a loss cf water accidento The high radiation levels from the exposed unshielded spent fuel and the high air temperatures within the build.i~g (the spent fuel building would heat up like an oven, to be shewn) would pres"...:.Ir1~bly prevent maintanence of the ventilation systemo Also, if a reactor accident occurred, the severe site contamination would force evacuation of the spent fuel storage facility, as before noted., leaving the ventilation system unattendedo Furthermore, there is the possibility of air pressure rises in the pool building due to heating and ccnfinement of the air that cou2.d ru:pture tt.e building (if the building were sealed shut), or zi.rccniu...;1 ar..d hy:::.::-cgen explosions could rupture the cuild.i.ng, either of *,:hich could ca'\ls e the r2..dioacti 7e v2:;)ors and smoke to vent directly tc
.. 2J the atmosphere, by-passing the .:'ilters o The Rasmussen ?.eport ad.i.T.its the possibility of the failure of the *1entilaticn system, but con-siders tri..is an 1.U1likely event.. However, such ari esti.:rzte of the likelihood is merely a guess, since the less-of-water accident was not scientifically analyzed for the course it *could take (Zirconium explosions, for example). For the Rasmussen Report states that its esti~ates of the radioactivity release resulting from a loss-of-water accident were not based on any scientific analysis but 11 instead only on rough estimates 11 , (in other words, guesses): Said 11 the report: Detailed analyses of radioactive :-elease, retention and removal under the specific conditions of the accidents considered celow have not been performedo 11 : ,\pp. I, p. 95) o Clearly, there-fore, the Rasmussen Report's evaluation of the spent fuel ~col accident hazards is useless.
'I'he Sandia Report
~he Sandia Report mentioned previously is an atteffipt to evaluate the loss-of-water accident scientifically by means of mathematical m.ere analysis, to avoid(\ speculation .. Inasmuch as ~c other analysis exists, the Sandia Report appears to be the basis for the N?,C I s evaluation cf the spent fuel storage pool hazards with respect to the loss-of-water accidentg Although the report itself has yet to oe published, a preview of it has been published in the American
~Tuclear Society's ~r2.nsacticns (Nov. 1972) which asserts that the s :;,ent fuel would not seriously cverhea t in :1:r_os t peel dra.i.nage accidents 11 , p:-ov-:i.ded that certain design moc.ificaticns are. :nade,
24 which the article i~~inuates are practical, and, therefore, that the spent fuel storage accident hazards ar~ ~ct tee seriouso However, this insinuation is not supported by the yet-to-published draft report, as will be sho*..rn herein. Moreover, the Sa.."'1.d.:!.a 1 s analysis is grossly inadequate and may be greatly under-predicting the spent fuel heatup potentialo c.alculating the spent fuel heatup (temperature excursion) in a loss-of-water accident ,is a formidable mathematical problemo A mathematical theory of spent fuel heatup must account for the natural flow of heated air through two thousand spent fuel assemblies, containing a total of a half' a million fuel rods (the air passes between the fuel rods) o The decay heat is highly non-unii'orr.1 throughout the load of spent fuel in a poolo The fuel rod temper-atures affect the air flow andJvice versa, the air flow affectsthe temperatureso Also, a theory must accou.."'1.t for the ~henomenon of ther:r.al radiation, which is the form of heat emission from a body other than convection currents of heated fluids (such as air) or heat conduction through a mediu.."11 in contact w*ith a bodyo Thermal radiation passes through space (air or vacuum) in the same rr..a.nner as light, and is the source of heat transmission which a person feel.s standing next to an open fireo Heated spent fuel rods will give o~f ther.nal radiation and adjacent fuel rods)and pool walls will absorb this energyo Therefore, besides the process of air flows) the!"!Ilal radiation is a process by which heat will diff'.1se through a sperlt fuel lead and eventually escape the pool, 2.."1.d therefore :nust be accounted for in any theoryo
~he -1..mbient temperature inside the spent fuel building ';,J'ill
....,
c: :J
.-
greatly affect the spent fuel temperature heatup; so the rate of ventilation--purg:!.ng the heated air with cold air from outside the 1:uilding--is a very i:nportant factora Other factors ',vhich ,,.rill greatly affect the spent fuel heatup are the details of the stor~ge rack design, the decay heat generation in each spent fuel assembly, t>4 t~~ of which depends on the length of time since a spent fuel had been
"
producing power in the reactor and its po*wer historJ in the reactor (this decay time is sometimes called the decay period); and the total amou..~t of spent fuel in the poolo Storage rack designs vary according to the distance or spacing between spent fuel assemblieso Large spacings for non-compact storage tends to promote air flow cccl::.r:g, whereas close spacing ( 11 high density" racks) tends to iri.hi'bit air flew by constricting air passages between fuel assemblieso (Present plans use high density racks, in order to maximize the amou..~t of spent fuel that can be stored in a pooL) The Sandia a.';.alysis was performed using a theory that was constructed to accm..rr~t for these various factors and precesses o The results are presented in its report, which analyzes a variety of storage rack des:!.. 6:::-is, pool designs, decay periods, and building ~,entilaticn rates, and ot~er condition.so The Sandia analysis predicts that the spent fuel heatup in a loss-of-pool-water accident can be severe enough to cause the zirccnium fuel rod cladding to catch en fire--a self-sustaining
- 'ire, especially for mediu.rn-density and high.-density storage rack desie:;r:s. -:hat is, the San.dia's heatup theory pred.ict3 that spent f1.:el rods, particularly the newer spent fuel a.'rld not so ::nu.ch the aged f*.:el, would heat up to a temperature of 9co 0 c, at wr..i.ch point
26 the theoI"J predicts that the zircor..ium will begin to burn (react with air) to generate more heatg The report states that the fire would cause the zirconium cladding to melt ( the rr,el ting temperature 1 ~ -, v~s7°c) -&.. I S HoweYer, the Sandia 1 s analysis was not extended beyond zirconi1..un ig:-ution and melting to determine the full heatup potential of the spent fuel (including the potential for the fire to spread to the aged fuel) and the potential for radioactivity release 0 In other words, the Sandia report does not analyze the loss-cf-water accidents through ita entire course to deterrnine the potential harmful consequencesg Instead, the report uses the zirconium ignition temperature as a temperature limit/safety criterion and merely evaluates d~t-ferent storage conditions to determine what set of circumstances would prevent the spent fuel assemblies from heating up to this temperature--circ'U!IlStances which might then be designed into the storage facility (design modifications) to minimize the chance of a fire occurring.and an uncontrolled spent fuel accidentg Eased on its analysis, the Sandia report cescribes several possip~e design modifications which theoretically could prevent the zirconium ignitiJn temperature from being reached in a loss-of-water accident, except for a relatively brief period of time after a batch o~ spe!1t fuel has been removed from the reactor a~d stored in the pool, during which the decay heat rate in that batch 't'lould. still be highg 1 ':'his period is called the "critical decay time '. ~owever, for the high density storage rack design, w!:1.+/-:ch is the design bei.."lg planned. by the utilities and which is ":::eir..g judged acceptable by the ~JRC, the critical decay ti~e, asstll1'1ing the desig~ ~ocifications were
27 adopted, would still be great: 30 days, as predicted by the Sandia heatup theO!"Ja Since refuelings occur annually, this means that a uncont:'ollable, catastro9hic spent fuel heatup accident would still be possible for 22% of the time ( 2,0/365 = a22). In v:Lew of the potential consequences, the risk would surely not be acceptable 0 r<loreover, none of the described design modifications are
-e apparently being implA,..uented, and none may be even practical.
Without the modifications, the Sandia theory would predict zirconium ignition in a critical decay time of 700 days, which would span the entire reactor operating/re.fueling cycle (1 year) and beycndo The most crucial of the possible modifications seems totally im-practicalo It would consist in modifying the spent fuel storage building to provide for a large door and a chimney which would be opened upon a loss-of-water accident to allow the heated air to escape the building, and cold air to be drawn into the building to ~epl~r...:!.sh the discharged air, to achieve perfect ventilation. ~his would e:cpose highly radioactive spent fuel directly to the outside environment, and would provide air to fan a zirconium fire, if a fire snould start, and also provide a direct escape path into the atmosphere for radioactivity which may be released frora the fuel.
- ~hus, .3Uch a open door/chimney feature could not oe judged a safety Y~orecver, there could be no assurance that the door a..."'1.d chi:nney wculd be opened in the e 1ent cf a severe reactor accider:.-:,
1 when t:1.e plant perscnnel would be fleein 6 G '!he Sandia report alsc f2ils to analyze the spent fuel heatup for the ca~es cf ~est .:.nte~est, r..amely high-density stcr==.ge with existing 'building 7entilation 8c.paci ties o ~*it.en cmilding 7entilation is ;,erfect--no recycling of heated air th"l"lough the spent f'.lel--it*may be that aged spent fuel
2~ (the bullc of the spent fuel in a full storage pool) could not heat up to zirconiu.11 ignition temperature due to its own decay heat and that the only way for it to seriously heat up is for a zirconiU1n fire to start and spread from newer spent fuelo But if heated air is re-cycled through the fuel, due to imperfect ventilation, then it may be that the whole load of spent fuel could overheat rapidly and much more intenselyo The heatup potential of spent fuel is hardly explored at all in the Sandia report for the case of imperfect ventilation; and those cases that are analyzed (medium density racks that promote air cooling) indicate that the heatup in high density spent fuel would indeed be intense, even if only well aged (well decayed heat generation rates;. spent fuel were storedo r-!oreover, the Sandia analysis assumes a relatively small storage load of spent fuel: about 338 fuel rod assemblies as com-pared to 2112 in the Zion poolo It will be shown that heat trans-rrdssion from fuel rod to fuel rod (mainly thermal radiation) has a ~ajor effect on the spent fuel heatup; so that the size mass of s-;;ent fuel in a pool will affect the heatup: a larger !!".ass T,*:ould mean a higher peak temperatureo L~ short, the Sandia analysis needs to be extended to cover all storage conditions and circumstances of interesto The next major shortcoming of the Sandia analysis concerns the r::athem.s.tical theory that was usedo ':he theory is not adequately describedi nor is the theory and its various assu.~ptions demonst~ated to be val.ido The theory contains a major 2.ssU1J1.ption that may force -::he spe:-it fuel heatup :~emperatures to be grossly ur..der-predic-cedo
?C
-/
Specifically, the theory asstunes that the f"'J.el rods *,rithin a given s~ent fuel assembly undergo identical temperature rises; that is, at any 5i~;en height i,,;r a c:::-,oy,+- f*:~l asse:::bJ:,r the temperatures of e..11 of the fuel rods in a fuel assembly are assumed to be the same, and the temperature is assumed to be uniform across each fuel rod, again at a given height up the rodo It will be shown that air flow alone through the spent fuel assemblies is far from being a suffi-cient decay heat removal--heat dissipation--mechanism for any spent: fuel storage conditions, including those cases for which the Sandia theO!""'J predicts temperature rises that do not reach the zirconium ignition temperatureo In order for the Sandia theory to predict limited, less-than-900°c heatup temper2.tures, therefore, it m.ust have pred~cted a strong diffusion of heat from hotter spent fuel assemblies to cooler, adjacent assemblies by the thermal radiation heat transfer mechanismo However, the assumption of uniform tem-perature across a spent fuel assembly contradicts the physical pro-cess cf lateral heat d.iffusiono In order to create a lateral flow of heat, there must be a finite temperature difference between adjacent fuel rods and across each fuel rodo Such temperature differences for driving the lateral heat flow are due to the re-sis-:a.nce to heat flow that will existo Ey assuming a constant temperature across a fuel assembly, and only a temperature difference between assemblies, the Sandia theory artificially minimizes the resistance for lateral heat dissipation and, thereby, over-predicts sc:ch heat dissipationo Acccrd:!.ng to a cour..:iing calculation which (..!)i-i'H,'1-t accounts for such temnerature
-
differences /I *,.....:. th: fuel assemblies, "'.:l:e constant temperature assumption i..'11. the Sandia theory could be causing such gross under-predictions of the spent fuel heatup
JO te~J.peratures as to make the numerical results in the Sandia report useless a T:his theoretical problem will be treated in this report 9 It will be shown that it may not be possible to Lrivestigate the size of the error by rigorous calculations, because the mathematical be problem mayA~ccmQ intractableo The Sandia analysis does include some ass,~~ptions which may introduce some conservatism in the pre-d.ictions--tendencies to over-predict the heatup temperatures--but these may not be substantial, and may also be more than off-set by the above-mentioned source of erroro In addition, the Sandia theory suffers from a lack of essential experim.ental verificationa The Sandia Report does compare the theory with some experimental results, but the experimenta bare little resemclance to the spent fuel heatup accident conditionso IT1he experiments consisted of two parallel heated plates at a constant, uniform temperature of 57°c between which flowed air by natural convection; whereas the spent fuel accident will Lrivolve air tem-
~eratures which rise greatly as the air flows up thro~gh a fuel assembly--up to 900°c temperatures--and, consequently, large changes in the physical properties of the air (density, and viscosity) and in the air v-eloci ty, which affects frictiono Moreover, spent fuel heatup accidents will involve intense thermal radiation heat trans-
- ission, *t1hereas the experiment relied on by Sandia involved essentially no thermal radiation heat transfer" It is well estab-lished that theory--especially concerning the flow of fluids involving
~eat transfer--requires rigorous experimental verification using e.:,:act e:c~eri:nental mcch.-ups of the systems to which the theory w*ill be a?Pliec.o This lack of experimental ve::'ification is doubly
---
Jl irr.*portant because the Sandia theo~j predict.s little I!l.3.rgin bet*ween the predicted maximum temperature and the gcc 0 c temperature limit for those spent fuel storage conditions 'ilhich the report concludes ~rnuld not result in a severe heatup in the event of 2. loss-of-water accidento FL~ally, the Sandia report analyzes the spent fuel heatup potentials of loss-of-water accidents in independent, "away-from-reactor, spent fuel storage pools, which would contain only aged spent fuelo The report concludes that the spent fuel heatup might be 11:ru.ted in these pools, provided that the spent fuel is aged for at least two to four years, depending on storage rack designo
- I Hcwever, tJ:i...is conclusion is of 11 ttle practical importance, since pr2..ctically all o.f the stor2..ge pools are and ;.rill continue to be reactor-connected pools, which will ccnt.:un new spent fuel as well as aged s~ent fuel 9 and, therefore, will have severe heatup poten-tials. Further.:i.ore, the Sandia report does not explore the full accident possibilities of independent storage poolso Specifically, the report considers an accident in which there was no ventilation of the building at allo A zirccniu.~ fire was predicted to occurj but the building room would become depleted of oxygen ( consu.'Iled by the fire) and the. fire extinguished itself before the zirconiu.r:::
would ~elt., The report fails to treat a partially ventilated situation, which would support a fire., ~!oreover, the S2ndia report does not consider the consequences of t~;ing to ::>e-flood the pool after the s"9ent :'uel .:-eaches and rernai:is at a high tem?erat'i.U'e. ,Jpening the 'b"".lild:.ng to 6 ai..T1 entry could trigger a fire flare-up by allcwing cxygen to e~ter, or the injection of water could initiate a violent
J2 z.irccnium-water reaction and explosion, which could conceivably rupture the building and trigger a massive fire and radioactivity release. Moreover, there is the pcs s i'bili ty that S IDdia 's 2-11.alys is grossly under-predicts the spent fuel heatup temperatures, as before discussedo
'The preceding critique of the S a."1.dia report applies to the report's analysis of spent fuel storage for "pressurized water reactors 11 (PWRs) o The spent fuel storage pools for this class of reactors are located in an auxiliary building attached to the reactor buildingo For the class of reactors known as "boiling water reactors" (E*JRs), the spent fuel storage pool is located inside the reactor building, and aimost directly above the reactor. The preceding critique applies to Sandia's analysis of BWR. spent fuel heatup as wellj however, the following additional cor:JIJ.enta are necessary:
The Sandia report indicates that EWR. storage has a much less spent fuel heatup potential than PWR storage in a loss-of-water accident, and that with simple modi~ications (no chi.:nney feature), the BWR spent fuel could be virtually prevented from seriously overheatingo However, the Sandia report neglects to analyze the "high-density 11 s toJ'age rack design which is apparently being adopted in f;\).),?/3. High density racks would mean greater air flow restriction and, consequently, greater heatup potentialso Also, there is no evidence that the storage modifications suggested in the Sandia report are being iinpli.uentedj namely, removal of the chari..nel ducts that nor!n.2.lly house a/ :CWR fuel asserr:bly, and side holes in the spent fuel holders (discussed later in section ). Furthermore, the 3W?.
spent storage situation presents peculiar loss-of-water accident pos3ibilities that require separate analysis: Eeing inside the re.s.ctor building, a reactor explosion accident could I"J.pture the storage pool and cause rapid pool drainage o 'i:he heated steam air r.1.ixtu.re from the reactor e.:i:plosion ( reactor coolant flashed to steam) would tend to promote spent fuel heatup as the steam-air clxture circulates through the spent fuel. The steam would tend to react with the zirconium fuel rod cladding., if it is still pre-sent in the reactor building L~ quantity when the spent fuel heats up to reaction temperatureso Also, it is conceivable that a portion of a molten reactor core expelled from the reactor by a reactor explosion and other debris of the explosion could fall into the spent f'J.el storage pool,.. The fallen debris could restrict the I I
-1 free .:'low of air from the tops of some of the spent fuel assem'clies a.'!d result in greater heatup temperatures ai'ter the pool drains than would otherwise cccurg In addition there is a question as to the physical condition cf the pool after a severe reactor explosion,.
Cc'J.ld the pcol not cnly be ruptured but be so damaged as to cause the spent fuel to fall into a pile with a configuration that could not be adequately cooled by natural air .convection? It is emphasized that in the BWR case a reactor explosion accident would (prestunably) I"~pture the reactor building and allow a di~ect path of escape of r2.dicactivity into the atmosphere as well as supply air to sustain a zirconium fireo Therefore, the storage pool accidents in ~uclear pc.;er ?lants r:r.ust be :i.istL"'lguished .between ?il?. and EW~ ::>eactor plants a..~d each analyzed separatelyQ
In short, the Sandia report needs to be critically reviewedj for it does not establish the full, true potential of spent fuel
,.
heatup during a loss-of-water accidento On the other hand, the report does indicate that zirconi"..1!:l fires are possible and thus shows the need for a full analysis of the accident hazards of spent fuel storage pools--of the course of an accident following the initiation of a zirconium fire--to determine the radioactivity release potentiale Purpose and Plan of Present Report
?he purpose of the remainder of the present report i : :
(1) to critically review the Sandia Report in more detail; (2) to prove the above assertions concerning theoretical short-comings of the Sandia analysisj and thus to show that the nU1r.erical heatup predictions in the Sandia report are not reliable and that a corrected mathematically theory may not be practical; (3) to exami..11e the experimental basis gi*;en in the Sandia I report for Sandia's mathematical theory of spent fuel heatup I a~4 to show that it is wholly inadequate and that, therefore, Sandia's theory is experimentally unconfirmed; (4) to demonstrate the possibility for nuclear explosions occurring in a spent fuel pool accident due to plutoniurr. c:::::ncentration during a possible 1:1el";down of spent fuelj and (. - \
':) i.. to s~cw that it is not practical. to s ci.entii'ically es tat li.sh t::e radioactivity release potential o~ loss-of-water accidents L'1. spent fuel storage pools; ether tt.a...'1 to ass*..:me a near-100%
- <
release of strontium-90 and cesiu.~-137 and possibly other radioactive substances, because full-scale experiments cf loss-of-water in a large-scale storage pool filled to capacity with actual spent fuel would be needed--which is otviously impractical. Also, there is no escape from the risk of spent fuel storage pool accidents no matter how nuclear power is managed .. Even if spent fuel were ::::1emos:red from the pool after a six ~onth cooling period, the quantity of.storage at reactor pools would still be great in terrn.s of radioactivity., includin6 strontium-90 and.cesium-137--almost as much strontium-90 and cesium-137 as in the reactor core, or ~ore so fo::::1 pools which sers:rice two reactorso Since the 1ecay heat leyel of new spent fuel is much greater than aged spent fuel, the time required for storage pool water to boil a*.-ray in a loss-of-cooling mal-function is not significantly affected if aged spent fuel is net al2.cwed to accum11late in the poola If spent fuel were shipped to a chemical reprocessing pool for separation of usable fuel a...'l1.d the radioacti7e waste, there *t1ot:ld be created the accident hazards of the spent fuel storage pools that wculd exist at the reprccessing plant for receiving six-month old spent fuel transported from reactorso Such pools would be full of roelatively new spent fuel, unlike reactor pools, which would contain mostly aged fuel when full to capacity; and so reprocessing plant receiving pools would have ~uch ~ore severe spent fuel hea.tup potentials. Therefore, it is necessary to evaluate the hazards of spent fuel storage pools and thB validity of the mathematical theory of analysis which Sandia is d.evelo-;i:r:g, :-.. c rnatter *,-vhat plan of nuclear waste d.is-;:,osalo
- <
~he remainder cf this report consists of the following chapters:
(1) A detailed description of spent fuel assemblies and their storage ;ioo ls : (2) An intrc*ductory mathematical analysis of spent fuel heatup assuming natural air convection only, to demonstrate the severe affect im~erfect building ventilation has on the heatup of spent fuel, and to show the necessity of accounting for lateral heat transfer to between fuel assemblies, in order to then be able to show the shortconiing of the Sandia theory in this regardj (3) A more detailed critical review of the Sandia Reportj (L~) A chapter discussing the full course which a spent fuel loss-of-water accident could take after a zirconium fi~e startsj (5) A chapter demonstrating mathematically the land contami.~ation pctential of a release of radioactivity; (6) A chapter on information needs; (7) A chapter on non-reactor sited pools; and (3) A concluding chaptero
.. Append Lx 1 Cerivation of Strontium-90, C:esium-1J7, and ?lu~oniu~
- uanti:lites to be 3tored in the Zion ?ool
,;1uan+i f'y -Pased
'CIC, .., ___ -- O""'
___ *: ?5 u"'on
- ,_ -.J *.,~.*,'"'\/r:rr bu~u.....,
** -*~- _ _ .. i....,
Sr-90 Li 6.LJ.*x 10 curies/netric ten of uranium
*':s-1J7 l.!.
A.J x 10 ci/M':'TJ Plutonium - 7. 7 Kg/MTl! Source: :-."*R-:;-G
"*n...; ......, - OlJ.0
. - , p. G *-*,
11 1 , a:1d G-16. ~here are xk& 0.45 ~T of uranium per fuel asse~bly and 2112 spent fuel assemblies to be stored in the Zion ?ool. :'hus, the Zio!1. pool will contain PQ.J x 10 6 curies of strontium-90: LJ. 1J 000 / 2112 X ,45 X 6.4 X lC X .., '
,~O.; x: 10-:: Ci, 2.5, oc6 er about 75 million curies of Sr-90, as there ~ill be a slight decay (29 year half life) after 15 years buildup of spent fuel, 7he factor )3,000/25,000 la~ accounts ~or ~he higher fuel 4
'\Jurnup which is expected. of 6.~ X :_o applies to 25,000 :.f:Q/,1TU whereas JJ, 000 i-,7. /J/r1LTU burnup is 1 expected, (rir'J/D/MTU means megawatt-,::ays per metric ton f~ of uranium).
,.
?or Cs-137, 2112 x ,45 x: ?.J x 10~ x J:3DGO lO!J.. X
,.., .
..., ]. .
25000
~hat is, the Zion pool will contai~ 101.J. million curies of *:esiu!'!l-1J7.
The plutonium quantity would be: JJCOO 2112 X 7 7 ..,.. a-/~*.~'i"H X 25000
.. 0 ~
a,'
- 7I X
- l,..,J
'v n~ *.r:::-
;)..t::I'
-
* * --I.I J
0~ 0
/ .'!' r:1etric tons of plutoniur.1.
... Append ix 2
~asmussen ~eport' s Ir.rplici t St:-ontium-90 ~1! Release ?ig 1re 1 for a Spent ?uel Storage Pool Accide~t: 2800 curies.
,,
':he Rasmussen Renart est:mates
- t.La*. ro ... ,~* o. Q x in.Jo ci..:ries of "al~aline earths" radioactivity escapes one third of a core load of spent fuel which a has aged for 6c days, and that 1~ of this radioactivity escapes the building (Ras. ~pt.,
anp. I, p. 10}-104), Alkaline earths consists of Barium-140, strontium-89, and strontium-90, with r.alf lives of 12.3 days, 50,5 days, and 29 years, respectively. ~he NRC's environmental impact statement for spent :uel (~~R~G-J40u) tabulates .;..* "ne qua~tities of these substances ~er ~etric ton of s~e~t fuel. At t~me of dischar~e from the reactor (p. G-11): 6 3a-l~O---- 1,72 X 10 ._, J. . L 1 c.* (' ' / * *.-,TT Sr-~? 9,47 ~ 105 4
~
\..J. 4 X 1r.
V
,.,..;l. 1--,,.,r*
~*l.L.\J*
The mass of fuel per ass~mbly is ,LJ.j !*';':'U (~rr?.:::G-OL:.04, p. G-5); end one core contains l?J ~uel ass~mblies: hence 1/J of a core equals 65 assemblies. From these data one can calculate the release fractio;1 of alkaline earths and the:1 th'? :r:an release quantity o~ stro:1.t5.um-90. **,'e ca!i. compute the release fraction (Fr) i~plicitly assumed in the Ras~ussen's esti~ate from the followinG equation for ra~ioactive decqy: i_ .. :1..' ~ 7.
- [
,~r ",..,,J
" 11r 1.. -
X 1?.S X I
- 7).;t/C} '_;_,,;.;_~ e ---- ,~.~ f- 7*¥7 a Y/0 J
- _L,,~-60
--=---
_. °"*~
. --;:;-~-;:-~
1 ... ~r.nn .:,.1
~.!,',r/0:::
o7 1/'~
;~ol*Ji"""' f'or -:;, C::.
- I"'\ 0,.. .,..o,,a-'h1 'l l- ,"c! ~~ere!ore, the asu~ed
.- - - '" ., * ") - - - ~ I r..,. #4., ) '"" - ~ * *-,.. ',,,.) I j I 3+/- assu~ed strontium-90 release ~rom the storage pool building (ass~smed a (assumed +'ho i........... ~as
.1. *
~ 0 ~~.,..+)
*1.-:-1-- ,.., i*~"-'
- 6. t.J r;o ~ { t'/t,rr,.; X. ./.IS Nj{s51 Ji S os.s'y-< rJ, / .Y ~.o/ - /%' l ~ c;'
/
c, r Qb~ f J..o oa Cc..,, rr'~s r.)
..,.
THE FINEST IN DRAFTING SURVEYING & PRINTMAKING DIETZGEN GENERAL CONVERSION TABLES Multiply by to obtain Multiply by to obtain acres ............... . 43.560 square reet cubic inches .... 0.03463 pints (liq.) acres .. 4047 square meters cubic inches .. 0.01732 quarts (liq.) acres.......... .. . .. . l.562xl0*> square miles cubic yards. 7.646xl0J cubic centimeters acres. 5645.38 square 11aras cubic yards. 27 cubic feet acres. 4840 square yards cubic yards. 46,656 cubic inches amperes. . ... . 1/10 abamperes cubic yards. 0.7646 cubic meters amperes. . . . . . .. . 3xlO* statamperes cubic yards. 202.0 gallons atmospheres.... . .... . 76.0 ems. of mercury cubic yards 764.6 liters atmospheres. . . . . . ... . 29.92 inches of mercury cubic yards. 1616 pints (liq.) atmospheres..... . .. . 33.90 feet of water cubic yards. 807.9 quarts (liq.) atmospheres .......... . 10,333 kgs. per sq. meter cubic yards per minute. 0.45 cubic feet per sec. atmospheres ........... . 14.70 pounds per sq. inch cubic yards per minute. 3.367 gallons per second atmospheres ........... . 1.058 tons per sq. root cubic yards per minute. 12.74 liters per second British thermal units ... . 0.2520 kilogram-calories degrees (angle) .. . 60 minutes British thermal units ... . 777.5 foot-pounds degrees (angle) ... . 0.01745 radians British thermal units .. . 3.927x10** horse-power-hours degrees (angle) .. 3600 seconds British thermal units . .. *. 1054 joules dynes. l.020xl0*> grams British thermal units ... . 107.5 kilogram-meters dynes. 7.233xl0*J poundais British thermal units ... . 2.928xl0** kilowatt-hours dynes. 2.248xl0** pounds B.t.u. per min .. 12.96 foot-pounds per sec. ergs 9.486xl0*" British thermal units B.t.u. per min .. 0.02356 horse-power ergs 1 dyne-centimeters B.t.u. per min .. 0.01757 kilowatts ergs 7.376xl0** foot-pounds B.t.u. per min ... 17.57 watts ergs l.020xl0** gram-centimeters 9.t.u. per sq. ft. per min. 0.1220 watts per sq. inch ergs 10*1 joules bushels.. . . 1.244 cubic feet ergs 2.390xl0* 11 kilogram-calories bushels.. . . . . ... 2150 cubic inches ergs. l.020xl0** kilogram-meters bushe~.. .. 0.03524 cubic meters feet 30.48 centimeters ( bushels ................ . bushels ............. . 4 64 pecks pints (dry) feet .. feet... . . 12 0.3048 inches meters bushels .............. . 32 quarts (dry) feet .. .36 varas centimeters.. . ... . 0.3937 inches feet .. 1/3 yards centimeters...... . .. 0.01 meters feet of water 0.02950 atmospheres centimeters. . . . . . . ... . 393.7 mils feet of water 0.8826 incnes of mercury centimeters. . . ....... . 10 millimeters feet of water. 304.8 kgs. per sq. meter centimeter-grams .. 980.7 centimeter-dynes feet of water 62.43 pounds per sq. ft. centimeter-grams. . . lQ*J meter-kilograms feet of water 0.4335 pounds per sq. inch centimeter-grams .. 7.233xl0*J pound-feet foot-pounds. l.2S6x10** British thermal units centimeters of mercury. 0.01316 atmospheres foot-pounds. l.356xl0' ergs centimeters of mercury. 0.4461 feet of water foot-pounds ... 5:050xl0*' horse-power-hours centimeters of mercury. 136.0 kgs. per sq. meter foot-pounds .. 1.356 joules centimeters of mercury. 27.85 pounds per sq. foot foot-pounds .. . 3.24lxl0** kilogram-c3iories centimeters of mercury. 0.1934 pounds per sq. inch foot-pounds .. . 0.1383 kilorgram-meters centimeters per second. 1.969 feet per minute foot-pounds. .. 3. 766x 10*' kilowatt-hours centimeters per second. 0.03281 reet per second foot-pounds per min .. l.286xl0*> 8.t. units per minute centimeters per second. 0.036 kilometers per hour foot-pounds per min ... 0.01667 foot-pounds per sec. centimeters per second. 0.6 meters per minute foot-oounds per min. 3.030xl0** horse-power centimeters per second. 0.02237 miles per hour foot-pounds per min .. 3.24lxl0** l<g.-calories per min. centimeters *per second. 3.728xl0** miles per minute foot-pounds per mm. 2.260xlO** kilowatts cubic centimeters .. . 3.531xl0*J cubic feet foot-pounds per sec. 7.717xl0** B.t. units per minute cubic centimeters ...... . 6.10?.xlO.z cubic inches foot-pounds per sec ... l.818xl0*> horse-oower cubic centimeters ... . 10** cubic meters foot-pounds per sec.. l.94Sxl0** kg-calories per m,n. cubic centimeters .. . l.308xl0** cubic yards foot-pounds per sec .. l.356xl0** kilowatts cubic centimeters ...... . 2.642xl0** gallons gallons. 8.345 pounds of water cubic centimeters .. . 10** liters gallons 3785 cubic centimeters cubic centimeters ...... . 2.ll3xl0*> pints (liq.) gallons 0.1337 cubic feet cubic centimeters ...... . l.057xl0** quarts (liq.) gallons 231 . CUCIC inches cubic feet....... .. 62.43 pounds of water gallons 3.785xl0*> cubic meters cubic feet..... . ... 2.S32xl0* cubic ems. gallons. 4.95 lxlO** cubic yards cubic feet .. 1728 cubic inches gallons 3.765 liters cubic feet .. ..... . 0.02832 cubic meters gallons 8 pints (liq,) cubic feet .. 0.03704 cubic yards gallons 4 quarts (liq,) cubic feet... .. 7.481 gallons gallons oer minute ... 2.228xl0** cubic ft. per second cubic feet.. ... . ... 28.32 liters gallons per minute. 0.06308 liters per second cucic feet... . .. 59.84 pints (liq.) grains (troy) l grains (av.) cubic feet..... . .. 29.92 qua'rts (liq.) grains (troy) 0.06480 grams cubic feet per minute .. 4.72.0 : cubic ems. per sec. grains (troy). 0.04167 pennywe1rgnts (troy) cubic feet per minute ... 0.1247 gallons per sec. grams. 980.7 dynes cubic feet per minute .. 0.4720 liters per second grams. 15.43 grams (troy) cubic feet per minute. 62.4 lbs. of water per min. grams. 10*> ~1lograms cubic inches... . ... . 16.39 cubic centimeters grams ..... . 10> milligrams cubic inches. . ...... . 5.787xl0** cubic feet grams. 0.03527 ounces cubic inches. . . . .. l.639xl0** cubic meters grams. 0.03215 ounces (troy) cubic inches. . .. .. 2.l43xl0** cubic yards grams ..... . 0.07093 ooundals cubic inches .. 4.329xl0** gallons grams 2.205xl0** pounds cubic inches. . . l.639xl0** liters horse-power ..... 42.44 B.t. units per min.
THE FINEST IN CRAFTING SURVEYING & PRINTMAKING DIETZGEN GENERAL CONVERSION TABLES Multiply by to obtain Multiply by to obtain. horse-PO'!Yer 33,000 foot-pounds per min. miles per hour 1.6093 kilometers per hour horse-power 550 foot-pounds per sec. miles per hour 0.8684 knots horse-power 1.014 horse;power (metric) mtles per hour 26.82 meters per minute horse-power. 10.70 kg.-calories per min. miles per hour per sec. 44.70 cr'ns.persec.cersec. horse-power 0.7457 kilowatts miles per hour ~r sec. 1.467 ft. per sec. per sec. horse-power 745.7 watts miles per hour per sec. 1.6093 kms. per hr. per sec. horse-power (boiler). 33.520 B.t.u. per hour miles per hour per sec. 0.4470 M. per sec. cer sec. horse-power (boiler) 9.804 kilowatts months 30.42 days horse-.power-hours .. 2547 British thermal units months 730 hours horse-power-hours. l.98xl0* foot-pounds months 43.800 minutes horse-power-hours .. 2.684xl0* joules months 2.628x 10* seconds horse-power-hours. 641.7 kilogram-calories ounces 8 drams horse-power-hours .. 2.737xl0* kilogram-meters ounces 437.5 grains horse-power-hours ..... 0.7457 kilowatt-hours ounces 28.35 grams inches._ 2.540 centimeters ounces .0625. pounds inches. lOS mils ounces c_er square inch. 0.0625 pounds per sq. inch inches. .03 varas pints (dry) 33.60 cubic inches inches of mercury. 0.03342 atmospheres pints (liq.) 28.87 cubic inches inches of mercury. 1.133 feet of water pounds 444.823 dynes inches of mercury 345.3 kgs. per sq. meter pounds 7000 grains inches of mercury 70.73 pounds per so. ft. pounds 453.6 grams inches of mercury 0.4912 pounds per so. in. pounds 16 ounces inches of water. 0.002458 atmospheres pounds 32.17 poundals inches of water 0.07355 inches of mercury pounds of water 0.01602 c_ub1c feet inches at water 25.40 kgs. per sq. meter pounds of water 27.68 cubic ,ncnes inches of water 0.5781 ounces per so. in. pounds of water 0.1198 gallons ~ inches of water 5.204 pounds per sq. ft. pounds of water per m,n. 2.669x 10-* cubic feet per sec. ,o***** ;;r. inches at water. kilograms. 0.03613 980,665 pounds per sq. in. dynes pounds per cubic foot pounds per cubic foot 0.01602 16.02 f;~~;e~~,u~~::;,;:~ ;*:. - ) kilograms. 10s grams pounds cer cubic foot 5.787xl0** pounds cer cubic in. ~' - ' kilograms. 70.93 poundals pounds per cubu: foot 5.456>d0-* pounds per mil foot * ~ kilograms. 2.2046 pounds pounds per square foot 0.01602 feet of water kilograms .. l.102xl0-S tons (short) pounds per square foot 4.882 kgs. per so. meter kilogram-ca1or1es. 3.968 British thermal units pounds per square foot 6.944xl0-* counds per SQ. inch k1logram-calor1es. 3086 foot-pounds pounds per souare ,nch 0.06804 atmospheres k1iogram-calories. l.558xl0** horse-power-hours pounds per square ,nch 2.307 feet of water kilogram-calories. 4183 joules pounds cer square inch 2.036 inches of mercury kilogram-calories .. 426.6 kilogram-meters pounds per square ,ncn 703.l kgs. per so. meter kilogram-calories. l. l62xl0*S kilowatt-hours pounds per souare inch 144 pounds per sq. foot kg.-calories per min .. 51.43 foot-pounds per sec. quarts. 32 * !iu1d ounces kg.-calories per min .... 0.09351 horse-power quarts (dry)_ 67.20 cubic inches kg.-calories per min *.. 0.06972 kilowatts quarts (liquid) 57.75 cubic inches kilometers 10* centimeters rods. 16.5 *feet kilometers. 3281 feet square centimeters l.973xl0* circular mils kilometers .. lOS meters square centimeters l.076xl0-* square feet kilometers 0.6214 miles square centimeters 0.1550 square ,ncnes kilometers. 1093.6 yards square centimeters 10-* square meters kilowatts 56.92 B.t. units per min. square centimeters 100 square millimeters kilowatts 4.425xl0* foot,pounds p-,r min. square feet 2.296x!O-* acres kilowatts. 737.6 foot-pounds pe,' sec. square feet 929.0 - souare centimeters kilowatts 1.341 horse-power square feet 144 souare inches kilowatts. 14.34 kg.-calor1es per min. souare feet 0.09290 square meters kilowatts. lOS watts square feet 3.587xl0-* square miles kilowatt-hours. 3415 British thermal units' square feet .1296 square varas kilowatt-hours. 2.655xl0* foot-pounds square feet 1/9 square yards kilowatt-hours .. 1.341 horse-power-hours square inches l.273xl0* circular mils kilowatt-hours. 3.6xl0* joules souare ,nches 6.452 square centimeters kilowatt-hoors. 860.5 kilogram-calorie5 square inches 6.944xl0** square feet kilowatt-hours ... 3.671xl0* kilogram-meters square inches 10* square mils log**.\" .... 2.303 log4 .Y or In .V square inches 645.2 square millimeters log~ .Y or Zn .Y. 0.4343 log,o.V square miles. 640 acres meters .. 100 centimeters square miles. 27.88xl0* square feet meters. 3.2808 feet souare IT'iles .. 2.590 square kilometE'rs meters .. 39.37 incnes square mucs. 3.613.040.45 souare varas meters .. 10** kilometers square miles .. 3.098xl0* souare yards meters .. 10s millimeters square yards 2.066xl0** acres meters .. l.0936 yards so uare yards. 9 square feet miles .. . l.609xl0* centimeters square yards 0.8361 square meters , 1-.-...~.--'~~ miles ..... . 5280 feet square yards 3.228xl0*' square miles _"" ~~ miles. l.6093 kilometers souare yards. l.1664 square varas ~* *.; miles. 1760 yards temc. (degs. C.) -17.8 1.8 temc. (degs. Fahr.)* * -1 'C miles. miles per hour 1900.8 4.4.70 varas centimeters per sec. temp. (degs. F.) -32 tons (long) 5/9 2240 ~~~~d~degs. Cent.) '~..r~.!; miles per hour 88 feet per minute tons (short). 2000 pounds ~ miles per hour l.467 feet per second yards. . ... .9144 meter'S
.
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THE FINEST IN DRAFTING SURVEYING & PRINTMAKING DIETZGEN GENERAL CONVERSION TABLES Multiply by to obtain Multiply by to obtain acres .................. . 43,560 square feet cubic inches .......... . 0.03463 pints (liq.) acres .... . 4047 square meters cubic inches .. 0.01732 quarts (liq.) acres. l.562xlO** square mites cubic yards. 7.646xl0* cubic centimeters acres ... *.. 5645.38 square varas cubic yards. 27 cubic feet acres. . . . . . . ...... . 4840 square yards cubic yards. 46,656 cubic inches amperes. . ....... . 1/10 abamperes cubic yards. 0.7646 cubic meters amperes ............. . 3x10* statamperes cubic yards 202.0 gallons atmospheres....... . .. . 76.0 ems. of mercury cubic yards. 764.6 liters atmospheres ..... . 29.92 inches of mercury cubic yards. 1616 pints (liq.) atmospheres .......... . 33.90 feet of water cubic yards. . . .. 807.9 quarts (liq.) atmosoheres.. . . .. 10.333 kgs. per sq. meter cubic yards per minute. 0.45 cubic feet per sec. atmosoheres....... . .. 14.70 pounds per sq. inch cubic yards per minute. 3.367 gallons per second atmospheres..... . ... . 1.058 tons per sq. foot cubic yards per minute. 12.74 liters per second British thermal units ... . 0.2520 kilogram-calories degrees (angle) .. . 60 minutes British thermal units ... . 777.5 foot-pounds degrees (angle) .. . 0.01745 radians British thermal. units .. . 3.927xl0-* horse-power-hours degrees (angle) ... . 3600 seconds British thermal units .. :. 1054 joules dynes. . .. . l.020xlO** grams British thermal units .... . .107.5 kilogram-meters dynes. .. 7.233x10** poundals British thermal units .. . 2.92Sxl0** kilowatt-hours dynes. 2.248xl0-* pounds B.t.u: per min... . . 12.96 foot-pounds per sec. ergs. 9.486xl0*" British thermal units B.t.u. per min .. 0.02356 horse-power ergs l dyne-centimeters B.t.u. ;:,er min .. 0.01757 kilowatts ergs 7.376xl0-* foot-pounds 8.t.u. per min ... 17.57 watts ergs l.020xl0** gram-centimeters B.t.u. per sq. ft. per min. 0.1220 watts per sq. inch ergs 10*' joules bushels. . .. . 1.244 cubic feet ergs 2.390xl0* 11 kilogram-calories bushels.. . ... . 2150 cubic inches ergs. l.020xl0** kilogram-meters bushels.. . ........ . 0.03524 cubic meters feet 30.48 centimeters / bushels ............ . 4 pecks feet 12 inches bushels .... . 64 pints (dry) feet 0.3048 meters '* bushels.* ............ . 32 quarts (dry} feet .. .36 varas centimeters .. . 0.3937 inches feet. 1/3 yards centimeters,. . . . . . 0.01 meters feet of water 0.02950 atmospheres centimeters ..... . 393.7 mils feet of water 0.8826 inches of mercury centimeters. . .... . 10 millimeters feet of water 304.8 kgs. per sq. meter centimeter-grams .. . 980.7 centimeter-dynes feet of water 62.43 pounds per sq. ft. centimeter-grams .... . 10** meter-kilograms feet of water 0.4335 pounds per sq. inch centimeter-grams. . . . . 7.233xlO** pound-feet foot-pounds. l.286xl0** British thermal units centimeters of mercury. 0.01316 atmospheres foot-pounds .... l.356xl0' ergs centimeters of mercury. 0.4461 feet of water foot-pounds. 5:0SOxlO** horse-power-hours centimeters of mercury. 136.0 kgs. per sq. meter foot-pounds.... . . l.356 joules centimeters of mercury. 27.85 pounds per sq. loot foot-pounds .... 3.24lxl0** kilogram-calories centimeters of mercury. 0.1934 pounds per sq. inch toot-pounds .. 0.1383 l<ilogram-meters centimeters per second. 1.969 feet per minute foot-pounds. 3.766xl0*' kilowatt-hours centimeters per second. 0.03281 feet per second foot-pounds per min. l.286xlO** B.t. units per minute centimeters per second. 0.036 kilometers per nour foot-pounds per min .. 0.01667 foot-pounds per sec. centimeters per second. 0.6 meters per minute foot-pounds per min .. 3.030xl0** horse-power centimeters per second. 0.02237 miles per hour foot-pounds per min .. 3.24lxl0** kg.-catories per min: centimeters per second. 3.72Bxl0** miles per minute foot-pounds per min. 2.260xlO** kilowatts cubic centimeters .. . 3.53lxl0** cubic feet foot-pounds per sec .. . 7.7l7xl0** B.t. units per minute cubic centimeters ... . 6.102x10-l cubic inches foot-pounds per sec ... . l.818xl0** horse-power cubic centimeters ...... . 10** cubic meters loot-pounds per sec *. l.945x 10** kg-calories per min. cuo1c centimeters ... . l.308xl0** cubic yards foot-pounds per sec ... l.356xl0-* k1iowatts cubic centimeters ... . 2.642xl0** gallons gallons. .8.345 pounds of water cubic centimeters ... . 10** liters gallons. 3785 cubic centimeters cubic centimeters ... . 2.l 13xlO-* pin'ts (liq.) gallons ..... 0.1337 cubic feet cubic centimeters ..... . l.057xl0** quarts (liq.) gallons. 231 cubic inches cubic feet ..... . 62.43 pounds of water gallons. 3.785xl0** cubic meters cubic feet .. 2.832xl0* cubic ems. gallons .. 4.95 lxlO** cubic yards cubic feet... . . . . . . 1728 cubic inches gallons .... 3.785 liters cubic feet ............ . 0.02832 cubic meters gallons 8 pants (liq.) cubic feet .. 0.03704 cubic yards gallons 4 quarts (liq.) cubic feet ..... . 7.481 gallons gallons per minute .. 2.228xlC** cubic ft. per second cubic feet .. 28.32 liters gallons per minute. 0.06308 liters per second cubic feet ...... . 59.84 pints (liq.) grains (troy). l grains (av.) cubic feet. 29.92 quarts (liq.) grains (troy). 0.06480 grams cubic feet per minute .. 472.0 cubic ems. per sec. grains (troy). 0.04167 pennyweights (troy) cubic feet per minute ... 0.1247 gallons oer sec. grams ... 980.7 dynes cubic feet per minute .. 0.4720 liters per second grams. . .. 15.43 grains (troy) cubic feet per minute .. . 62.4 lbs. of water per min. grams.. . . 10** kilograms cubic inches.... . .... . 16.39 cubic centimeters grams. .. 10* milligrams cubic inches. . . . ... . 5.787xl0** cubic feet grams. 0.03527 ounces cubic inches. .. l.639xl0** cubic meters grams. 0.03215 ounces (troy) cubic inches .. 2.l43xl0** cubic yards grams ...... . 0.07093 poundals cubic inches .. 4.329xl0** gallons grams.
- 2.205xl0** pounds cubic inches ... l.639xl0** liters horse-power. . .. 42.44 B.t. units oer man.
THE FINEST lN DRAFTING SURVEYING & PRINTMAKING DIETZGEN GENERAL CONVERSION TA 8 LES Multiply by to obtain Multiply by to obtain horse-power . . . . .... 33,000 foot-pounds per min. miles per hour l.6093 1<1lom*eters per hour horse-power. 550 foot-pounds per sec. miles per hour 0.8684 knots horse-power l.014 horse-power (metric) miles per hour 26.82 meters per minute horse-power 10.70 kg.-calor1es per min. miles per hour per sec. 44.70 crns.oersec.persec. horse-power 0.7457 kilowatts miles per hour per sec. 1.467 ft. per sec. per sec. horse-power 745.7 watts miles per hour per sec. l.6093 kms. per hr. per sec. horse-power (boiler). 33.520 B.t.u. per hour miles per hour per sec. 0.4470 M. per sec. per sec. horse-power (boiler) 9.804 kilowatts months 30.42 days horse-power-hours. 2547 British thermal units months 730 hours horse-power-hours .. l.98xl0* foot-pounds months 43.800 minutes horse-power-nours .. 2.684xl0* joules months 2.628xl0* seconds horse-power-hours. 641.7 kilogram-calories ounces 8 drams horse-power-hours 2.737x 10s kilogram-meters ounces 437.5 grains horse-power-hours ..... . 0.7457 kilowatt-hours ounces 28.35* grams inches .. 2.540 centimeters ounces .0625 pounds inches... . ....... 10* mils ounces per square inc!"! 0.0625 pounds per sq. inch inches .. .03 varas pints (dry) 33.60 cubic inches inches of mercury .. 0.03342 atmospneres pints (liq.) 28.87 cubic inches inches of mercury l.133 feet of water pounds 444.823 dynes inches of mercury 345.3 kgs. per sq. meter pounds 7000 grains inches of mercur1 70.73 pounds per sq. ft. pounds 453.6 grams inches of*mercury 0.4912 pounds per sq. 1n. pounds 16 ounces inches of water 0.002458 atmosc,heres pounds 32.17 coundals incnes of water 0.07355 inches of merc:uy pounds of water I 0.01502 cubic feet incnes of 'Nater 25.40 kgs. per sq. meter pounos of water 27.68 CUCIC inches inches of water 0.5781 ounces per SCI. in. pounds of water 0.1198 gallons inches of water 5.204 pounds per sq. ft. pounds of water c:;er min. 2.669x 10** cubic feet per sec. inches of water. 0.03613 pounds per sq. in. pounds per cubic foot 0.01602 grams oer cubic cm. kilograms. 980.665 dynes pounds per cubic foot 16.02 kgs. per cuc1c meter kilograms. 10, grams ;iounos per cubic foot 5.787xl0** pounds per cubic in. kilograms. 70.93 poundals pounos per cubic foot 5.456x 10** pounds oer mil foot kilograms. 2.2046 pounds pounds per SC1uare foot 0.01602 feet of water kilograms. l.l02xl0* 1 tons (snort) pounds per square foot 4.882 kgs. cer SCI. meter kilogram-calories. 3.968 British tl"lermal units pounds per SC1uare foot. 6.944xl0*' oounds per SQ. ,ncl"I kilogram-calories. 3086 foot-pounds pounds per SC1uare inch 0.06804 atmospheres kilogram-calories. l.558xl0* 1 horse-power-hours pounds cer souare ,nch 2.307 feet of water kilogram-calories .. 4183 joules pounds cer SC1uare oncn 2.036 ,ncnes of mercury kilogram-calories .... 426.6 kilogram-meters pounds per square ,nch 703.l kgs. per sq. meter kilogram-calories. l.l62xl0** kilowatt-hours pounds per square inch 144 pounds oer sq. foot kg.-calor1es per min .. . 51.43 foot-pounds per sec. quarts 32. fluid ounces kg.-calories per min ... . 0.09351 horse-power quarts (dry) 67.20 cubic 1ncnes kg.-calor1es per min ... . 0.06972 kllowatts ouarts (liquid) 57.75 cubic inches kilometers. lOs centimeters rods. 16.5 feet kilometers 3281 feet square centimeters l.973xl0 1 circular mils kilometers 10* meters square centimeters l.076x 10*' SCIUare feet kilometers 0.6214 miles square centimeters 0.1550 square inches iulometers. 1093.6 yards square centimeters 10** SCluare meters kilowatts 56.92 B.t. units per min. SCIUare centimeters. 100 square millimeters kilowatts 4.425xl0* foot-pounds per min. square feet 2.296xl0*' acres kilowatts. 737.6 foot-pounds per sec. SCIUare feet 929.0 square c*entimeters kilowatts l.341 horse-cower SCI uare feet 144 SCIUare ,nches kilowatts. 14.34 kg. -ca Ion es per min .. SC1Uare feet 0.09290 square meters kilowatts. 10, watts square feet 3.587xl0** square miles kilowatt-hours ..... 3415 British thermal units SCIUare feet .1296 square varas kilowatt-hours .. 2.655xl0* foot-pounds square feet 1/9 square yards kilowatt-hours.. . . l.341, horse-power-hours sC1uare inches l.273x!O* circular mils kifowatt-l"lours .. . 3.6xlO* joules square ,nches 6.452 square centimeters kilowatt-hours .. . 860.5 kilogram-calories square , ncnes 6.944xl:J*' square feet kilowatt-l"lours ..... . 3.671xl0S kilogram-meters square inches 10* square m,ls log 1*.V .... 2.303 loge .V or !n .V square ,nches 645.2 square millimeters log* .\" or In S ... .. 0.4343 log, **v square miles. 640 acres meters .. 100 centimeters square miles. .27.98xl0* square feet meters .. 3.2808 feet SC1uare miles. 2.590 square kilometers meters .. 39.37 inches sC1uare mucs 3.613,040.45 square varas meters. 10*' kilometers SCIUare miles 3.098xl0* square yards meters .. 10, millimeters square yards 2.066xl0** acres meters. l.0936 yards square yaros. 9 SCI uare feet miles .. . l.609xl0* centimeters souare yards. 0.8361 square meters miles .... . 5280 !eet SC1uare yards 3.228xl0* 1 square moles miles .. l.6093 kilometers SCIUare yards l.1664 SC1uare varas miles .. . 1760 yards temci. (Oegs. C.) -17.8 1.8 temc. (degs. F-:1hr.) miles .... . 1900.8 varas temp. (degs. F.) -32 5/9 temo. (degs. Cent.) miles per hour 44.70 centimeters per sec. tons (long) 2240 oounds miles per hour 88 feet per minute tons (short). 2000 pounds miles per hour l.467 feet per second yards .... .9144 meters
.. ., CONTE:HIONS REGARDING THE ACCIDENT H,V,\RDS OF SPENT FUEL STORAGE AT THE SALEM NUCLEAR POWER PLANT SALEM, NEW JERSEY
,;,,1
*. \BY:
\R~CHARD f. WE~B. ~h.D.
'Fchrt1[lry 27, 1q79
.. ., FJIII
\ .
CONTENTS
- 1. INTRODUCTORY CONTENTION: THE LOSS-OF-WATER ACCIDENT
- 2. PHYSICAL CONSEQUENCE OF A LOSS-OF-WATER ACCIDENT
- 3. POTENTIAL HARMFUL CONSEQUENCES OF THE RADIOACTIVITY RELEASE FROM A LOSS-OF-WATER ACCIDENT
- 4. POSSIBLE LOSS-OF-WATER ACCIDENTS: SPECIFIC POSSI-BILITIES
- 5. CONCEIVABLE POSSIBILITIES FOR LOSS-OF-WATER ACCIDENTS
- 6. CRITICALITY ACCIDENTS
- 7. REACTOR ACCIDENTS CAUSING A SPENT FUEL POOI. LOSS-CF-WATER INCIDENT
- 8. PERMANENT SPENT FUEL REPOSITORY AT SALEM Cj'. T141pt-ac'tr'co(r't-r of T~ eo't'e'f/ccd ,J~ly S/ 5 1
t:.?Hd E-;x~y/11;..;.J, 1,;,/
!(). '-9-: CONCLUSION
,, '
,. 1. INTRODUCTORY CONTENTION: THE LOSS-OF-WATER ACCIDENT The utility operating the Salem ~ucJcar ?uwer Sta-tion <1t Salem, New Jerscy--Public Service F.lcctric and Gas Company--(PSE&G)--is requesting a license from the United States Nuclear Regl'.latory Commission co store indefi-nitely up to 1170 highly radioactive, s;,c11t nuclear fuel rod assemblies in each of two spent fuel storage pools located at the reactor site. The Station consists of one operating nuclear power reactor and one under construction. Each spent fuel pool is housed in a separate fuel handling building which is located nexc co its respective reactor containment building. Originally, it was Lntended onlv,- to have in storage about 64 spent fuel assc~biies at any one time in each pool, as the plan was to ship spent fuel
.:11.v.:1y from the site ror disr,osctl ;1ft.::cr c.1 bdc[, 150 dav ,'
cooling-off period th,1l allows Lhe radioac.:tivity and associ-ated heat in the spent fuel to decay substantially. Now, however, PSE&G proposes to increase the storag~ capacity of each storage pool, by replacing the original design o f the s tor age racks wi th a rack des i g n w h i. c :1 a 11 ow s the spent fuel assemblies to be oackcd in the pool at a high density (comractionl. The proposed incrci1sc in scorJ.gl! c2pacity would increusc the amounc of long-lived radio-activity co be stored in the pool eighteen-fold . .!.r,proval to increase the storage capacity is requested by PSE&G I
FJ. l F because there presently e:<ists no nuclr.:!ar :. ;asle disposal s y s t em for d i s po s i n g o f the s pen t f u e .b..:_ __.. ___ _ With respect to the hazards of the rroposed spent fuel storage increase, it is contended that: (a) The proposed design changes to the spent fuel storage pools would greatly increase the nuclear accident hazards of the Salem Station with respect to the health and safety of the public. (b) The proposed design changes would create ma~y severe accident possibilities which *..;ould have the poten-tial for extremely disastrous consequences. Such accidents would involve the loss-of-pool-water, hereaf:er dcncmin3t2d the loss-of-water accident. (c) Both the PSE&G's Snfety Analysls Report and the Nuclear Regulatory Commission's Snfcty Evnluation Report for the proposed design chungcs fuil to analyze the loss-of-water accident. (d) The potential consequences of loss-of-water accidents are so serious that the utility (PSE&G) and the Nuclear Regulatory Commission's st3ff must analyz~ them, and the Atomic Safety and Licensing Goard (AS&LB) and the Commission itself must invcstigntc and consider them for both their likelihood and potent[~] harmful conse-quences, in order to enable the Nucl~nr Regulatory Commis-sion? that is, the Commission, itself, to -responsibl 1
r .J,dd form an opinion as to whether the proposcc! spent fuel storage *..;ould be "inimical to the hcc1lt;i c1r:cl sc1fecy of the public" (referring to Secti.on 103 of the Atomic Energy Act) and to responsibly inform the public of the full risks co hec1lth and safetv.
. -----------
(c) The likelihood of a loss-of-water accident occurring is not remote or extremely low; but rather, the probability of occurrence is indeterminable. More specifically, it cannot be proven mathematically or statis-tically that the probabili.J_y_g_f._?.µch an accident occurring {ft,,{' /1j e ~f ti!__.? p/o,d -~ r ___eve]j) in the time period ofla /( decade dilf'.. *. is Tess than 100~~ or significantly less than 100%. There exists dn indeter~in-able but extremely large number of possibilities for poten-t i a 11 y O 1" C ,* n C e i V 3 b Ly C cl US i ng ,1 1O S S - o f - 1
.,; ,1 t C r c1 C C i dCnt in a storage pool. Furthermore, m~ny incidents associated with nuclear power reactors of near-accidents, equipment mal~unction accidents, and human error have occurred.
These facts indicate that the probability of a Loss-of-- water accident is high, not low~ Because of these facts, ,t plus the fact that the probability of a loss-of-water accident is indeterminable Qnd tne fact of the extre~e potential for ha!"mfu1. consequences o[ such an o.ccicient,makc the proposed stor3ge facility unsnfe. (F) The Nuclear Regulatory Commission's current practice of evaluating the risks of the worst or sevece
nuclear accident possibilities by ccnsi.dcring only the likelihood of such accidents, .:1nd not cv:ilunti.ng and ccnsid-ering the potential harmful consequences, i.s not consistent with the well-established method of assessing accident risks, which is to consider both the likelihood and the consequences of accidents.
---- ***--*-*--*--****-** ------------
( ('P)
--0 Be'"ause cf ,_ \.,. 0 C ~ I, - e.ct..ce ... c pot<...;ltti.c.1:. LO&.. ir *.J.L .11f at r .J. I(*
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- 2. PHYS I Ci\ L CONSEQUENCES OF A l.OSS-OF-WATEK A.CC I DE~:T (al The radioactivity in spent fuel generates heat which must be dissipated in order to prevent the spent fuel assemblies from overheating. Fnr this reason and for radiation shielding purposes, the spent fuel assem-blies arc stored under water. The pool wdter serves to remove the heat of the radioactivity. The pool water in turn is cooled by water cir~ulnting cooling systems to prevent the peal f ram overhca ting and bo i.L i ng dry. In a loss-of-water accident the spent fuel assembti*es will heat up to a high temperature, because natural air convec-tion and thermal radiation heat dissiration processes are insufficient to cool the spent fuel. The [ulL potent~al for spent fuc: heatup has yet to ~e rredicccd by a thermal/
hvdraulics analysis. (bl Cpper bound calcuiatio~s exist ~hich indicate
/
I ,..J,,. r'- ' , . '< d;" that the potential may exist for the uranium oxide in A the spent fuel to heat up beyond its melcing temperature of about 2800°c, even if all of the spent fuel ,,.;ere stored for ten years. ( c) 5 .1-Calculation exist::jl which tend to set a mathe-
"
matical lower bound of the spent fuel heatup potential; and these calculations indicate that as a minimum the zirconium (zi£caloy) fuel rod cladding mnterial will heat up to 900°C and catch on fire for spent fuel that has decayed (aged) for three years. These calculations were performed by Sandia Laboratory and are presented in a report titled "Spent Fuel Heatup Following Loss of Water-During Storage" (SAND77-1371, Sept. 1978, draft), by A. S. Benjamin, et al.; hereafter called the Sandia Report. The Sandia Report does not cc1lcuL1tc the Cucl temrerature rise beyond the point when the tcmpcruturc Ls culculated to reach the zirconium fire ignition tcmpernture, and subsequent zirconium cla..d_rri.~1.ttng_(_~_~57°C). ( d) A zirconium fi.re i.vou1c.! gcncr;1tc substantL1l additional heat with the potential for melting 3way the cladding of the fuel rod and also ~elting the uranium
.oxide fuel or raising the fuel to its mclring temperature of 2850°c (abovtl.
(e) A zirconium fire which starts in relatively new spent fuel (say, three year storage or ,less), :;.;hich would include 16% of the total pl~nncJ storage or less, COu l d CO n CC i V.:1 b 1 y s pr C,'.1 d CO O1. d s p Cn t Cu (' i ; l r1( j t: h us Cn g u 1 f
'.
the whole load of spent fuel in the pool. (f) Severe zirconium explosions :1n.: (:onceivable,
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'( due to zirconium-water reactions 01 ,..::,;*:J'~*;*:*, ! - ~
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(g) Hydrogen explosions are conceivable due to -. ~ I the hydrogen released in a zirconium-water reaction and ;t~ reacting with air. (h) Since zirconium fuel clad melting is possible, it is conceivable that the air flow passages inside the spent fuel rod assemblies could become plugged due to th t:'
~[r,o-vu'v:,,, cti'~-;,;/tf@ r~'-7':-t,*1:*:1 Prccfuct o 1,,1d (/u-e i o molten zirconium running down coward cooler portions of A
the spent fuel and freezing there. Plugged air flow pas-sages would greatly worsen the spent fuel heatup. Also, explosive zirconium-water reactions and hydrogen explos-ions could conceivably damage adjacent spent fuel so as to constrict air flows and thus worsen the spent fuel heatup in these assemblies as well. ( i) Strontium-90, Cesium-137 and P1utonium are P:-1/....t. i the dominant radioactive substances in spent fuel from a public health risk standpoint. It is conceiv.:ibl.e--meaning that it has not been ruled out scientificnlly--thac a ncc1r 100':~ rclensc of Strontiurn-()0 :inci Ccsil!m-137 radio-activitv from the spent fuel into the ntmosphere ,,;ould occur in a spent fuel heatup excursion in a loss-of-water accident. For such a near-100% release co occur, the scene
~uel need not necessarily reach ~cltLng temperature, but
.. need only attain a level of only ~1hoL:t 1900°C and :n.:1intc1in that temperature for a day or so. The Strontium-90 2.nd Cesium-137 could chen diffuse out of solid uo 2 fuel ac such temperatures. This assumes that the fuel rods have lost their zirconium cladding upon meltdown of the zircon-ium but that the rods would maintain their rod shRpe be-cause the uo 2 fuel pellets inside che fuel rods would have sintered together during reactor operation to form a long uo 2 rod capable of maintaining its shape. If the uo 2 rods should crumb1 c, ,1i r cooling ,..,;ou1 d he further impeded and lead to higher uo 2 tcmpcro.tur.cs and conse-quently a greater thermal potential for scroni..ium and cesium diffusion out of the uo 2 fuel.
- - - . *--*-----*-
(j) Cc1lculations exist which indicate that the r J. L'f-
.:.iir inside spent fuel storage builJing \voul<.1 hcc1t up and pressurize due to the heat of the spent fuel (the building would become like an oven). The air pressurization would burst open the building and thus allow the radioactive vapor and s~oke to escape into the atmosphere. If the building vents were opened, the radioactive vapor and s~oke could conceivably escape through these vents. Zircon-ium and hydrogen explosions could concciv~bly rupture the building as well, to allow the escape of radiaacttv~ty.
l' l"' (k) No experimental data~ theoretical analyses
-1 exist en which to establish the potential for release
F1L.
- I of p:..utonium in the spent fuel i.nto the ac:nosphere in a loss-of-water accident. Steam explosions, hydrogen explo-sions, and zirconium explosions are concciv3hle mechanisms which could pulverize large quancities of spenc fuel bear-ing plutonium and blow it into the outsid~ ~nvironment, where the plutonium would then spread through the envLron-ment.
--- -- -*----.
( 1) Calculations exist which indicate that the Salem spent fuel storage building could not be modified to eliminate the possibility of a zirconium Eire occurring in a loss-of-water accident. The Sandia R~port suggests the possibility of modifying the building to provide for an open chimney effect: a large hole in the ceiling and a large hole at the floor level of the building side wall, to allow perfect room '"1 Lr vcnti 1 ;1ti.on during a loss-of-water accident to expel the hcnt~d air exiting from the spent fuel assemblies. The holes or openings would be normally closed by large doors, ,,.;hich would he oper.ed in a loss-of-water emergency to create the chimney effect. Such a chimney effect by expelling heaccd ni.r, would tend to limit the spent fuel heatup tc~perat~rcs, 3cccrding to Sandia's analysis, hut would not eliminntc the possi-bilitv of i.l zirconium fire. Since such .:.1 chimney feature would not eliminate the possibility of~ zirconium fire, a chimnev could conceivablv ~ot have any mitigating ef~ect
FJ. ;n( at all; for the building openings would rrovide unli~ited air (oxygen) to promote the spre~ding of the fire and would provide ready access of radioactive vapors and smoke to the outside atmosphere. Nor would the nc~ivation of the chimney (automatic or mdnunl opening of its doors) be reliable in the case of a severe rec:ictor accident which causes a spent fuel loss-of-water. A severe reactor acci-dent can potentially cause such a high level of radiation in and around the site that the whole site operating crew could flee in panic, leaving the spent fuel pool and relat-ed safety and cooling systems unattended. Under such a panic situation, it would not be expected that the chimney doors, if incorporated into the building, would be opened. (ml A reduction in the number of spent fuel assem- ,:'°2/i blies stored in the pool could not eliminate the possi-bility of a zirconium fire occurring in a loss-of-water accident, nor preclude the possibility of a loss-of-water accident. (n) Emergency efforts to cool the spent fuel follow-ing a loss of pool water could conceivably worsen the accident or otherwise have no mitigating effect. Spraying the overheated spent fuel with water (~hich would have to be done remotely, due to the he~vy rnJintlon emanatLng from the spent fuel) would cause zirconium-water reaction that could promote the ignition or spreading of a z~rconi~~
fire, or cause explosions. ~1oreover, the heiltup of the spent fuel could conceivablv cause the hor~L neutron absorb-ing material to meltdown, lec1vi.ng c1 region cf spent fuel without enough neutron absorption to prevent a criticality should the pool be reflooded. Furthermore, the heat of the spent fuel in a loss-of-~3ter accident iand ?OSsible explosions) could conceivably dc1mnge the spent fuel to such a degree that the pool would continuously leak heavi-ly, should the pool be reflooded, which would result in a heavy seepage of radioactivity into the ground and nearby waters.
---* ... --- --* **- -* -*-**-* **-**-*-*-'"--*----- .. *-*.
(oi In order to evaluate the potenti2l for radio- ~J.C. activity release in a spent fuel pool loss-of-water acci-dent, a thermal analysis must he performed, of course. c-j .: .r-~ ** ~ {:.* .. ,' ; .... **~ *,-J_.-:>
- "-. The only* m.1thematic.1l Lhcorv*A \,'hich exists in a for:n for
.r*o~ s,-,lPs tf,/s ~..,v t:-: r:.: : /.*_-~~.,-,,')
,
r~ady use.. is the SFUE~ computer code of the Sandia Labora-tory, whLch is described in the above-mentioned Sandia Report. The Sandia Report analyzes the loss-of-water acci-dent for a spent fuel storage pool which is close to the Salem design. However, the Sandiil Report is not sufficient for evaluat::.ng the spent fuel. he:atup potcntinl for Salc:n (nor any other spent fuel stor~ge pool); and, further~ore, the SFUEL computer code is not sufficienLly developed and verified to provide reliable heatup temperature predic-tion ~::.th reasonable accuracv. To elaborate:
FJ,.QJ_ (1) The Sandia Report does not investigate the spent fuel temperature excursion beyond the ignition of the zirconium or zirconium melting. (2) The Sandia Report does not analyze the cqS Q high-density storage rack design for t h e ~ of imperfect building ventilation, which is the case for all pressurized water reactor (PWR) storage pools, including Salem.
---------
(3) Sandia's mathcmntical theory (SFUEL) contains serious theoretical deficiencies which, based on independent scoping calcula-tions, may be causing the code to be drastically underpredicting spenc fuel he~tup tempera-tures. Foremost arc the nssumptinns in the SFUEL theory that the temperatures of the fuel rods in a given spent fuel rod assembly and at a given elcvntion are the same (uniform temperature distribution horizcnt~lly), and that the temperature distribution inside a fuel rod at any given elevation is also uni-form. (4) Sandia's mathematical theory is not ,,, 2de-
;
'/'- quately described in the Sandia Repor~nd requires a systematic checking to verify the I I
----
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code the¥1: 11 ar.d ceclculation.:1l1.y. (5) A reliable mathc:mcJ.tical theory of spent fuel heatup may nol be practical, due to compu-ter limitations. (6) Sandia's SFUET. cheory has not been experi-mentally verified, contrary tn the claim made in the Sandia Report ~hat adequate experimen-tal data exists to validate the SFUEL theory. There experiment relied on in the Sandia Report consisted of two heated plates held at a low, constant and uniform temperature cooled by natural air convection; where~s the situation in a spent fuel heatup accident is one of a highly v~riable temperature distribution and extreme air temperatures in a rod bundle configuaration. Moreover, th~rmal radiation heat transfer aided by thermal heat conduction, appear to be a crucial heat transfer processes in a spent fuel heatup, which were totally absent in the two-he.:1ted-place experiment cited in the Sandia Report. To adequately account [or thermal rndiation intc~chango among, and heat dissipation from, spent fuel rods in a storage pool under a loss-of-w2t2r accident, ic would be ~ecessary to conduct 1c:J..
an experiment which includes a large scale loading of simulated spent fuel (electrically heated) or actual spent fuel. Because the electrical resistance of electrical heater filaments is dependent on temperature, an adequate simulaticS-n of spent fuel hcatup may not be possible with electrically heated rods; in which case it may not be possible to experi-mentally verify a muthematical theory of spent fuel heatup, because it would not be practical or safe to conduct such tests with spent nuclear fuel rods.
-----------
(7) I n sort, h . t,h e S an d 1a Report must b e crLt1-
*
- P:L callv., ev.11uatcd .
(pl It would not be pr.1ctLcal or s.1fe to experimen-tally investigate the radioactivity release potential of a loss-of-water accident; particularly in the event of a zirconium fire, zirconium melting, explosion, or other severe process which cnuscs signifi~nnc changes in the fuel's physical condition, because the fuel tempera-ture excursion and the interrelated radioactivity release would both depend on the physical condition of the f~el and on the size of the spent fuel mass undergoing a loss-of-water accident. ~oreover, the behavior or the spent fuel ~ay be a function of the prior aging of spe~c fue1
in water and the physical history of the srent fuel ~hen it was in the reactor, such as wh~thcr the fuel had under-gone overheating in the reactor in an accident. {q) It is not possible to accurately predict the course of a loss-of-water accident once the zirconium cladding becomes ignited. Instead, only m~thematical upper bound estimates of the radioactivity release potential could be developed, which presently do not exist. _A near-- 100% release of radioactive strontium and cesium is olausi-
'
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. / . X Ci:- i:J/ P
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------------ .... - **--*-. ----* *--*--*- ---------
( r) The Salem Safety Analysis for the proposed spent fuel storage supplies inadequate information on which to perform heatup calculations; for example, the
?OOl and building dimensions arc not given.
- 3. POTENTIAL HARMFUL CONSEQUENCES OF THE RADIOACTIVITY RELEASE FRO~ A LOSS-OF-WATER ACCIDENT (al Each spent fuel storage pool at Salem would contain at capacity forty-five mil.lion curies of Strontium--
90 radioactivity and about the sa~e amount of curies of Cesium-137. For comparison the l'.nited States Atomic Energy Commission's report Theoretical Possihilities and Ccnse-1
.
.;- .;.. c u enc e s P- f ~1 a j or Ac c i d e n t s I n La r g e ;-Ju c 1 ea r Powe r P1 an t s (WASH-7~0, March, 19571 calculat~s that the release of 0.15 million curies of Strontium-90 (150,000 curies) could cause agricultural restrictions ~ver a land area equal 1 The size of che power reaccor assumed in the WASH-740 R *:, n O r.':~ . .i..s.
-t.:.::-- : . nO t 11 1
_arg~ 11 comrarea' ;..O_r>~ rescn*t s1.ze . . p1.:mts. S0ec1c1.ca1lv WASH-140 assume~ a ) 60 megawatt tner~al (M Wt.) rea2 or whereas each Salem reactor has a rated pwer outputo about 3300 M Wt. JI
to 150,000 square miles, which is the size of ~ew Jersey, New York, Connecticut! Massachusetts, Rhode Island, Ver-mont, New Hampshire, Maine, and half of Pennsylvania, combined. A loss-of-w3ter accident in one Salem spent fuel storage pool could conceivably release nearly all I y_ of the forty-five million curies of Strontium-90, or ~hree hundred times the WASH-740 assumed release quantity of Strontium-90.
,,------'\
---:iol~* -~~~-:--~---:---:------:--~~--
.
~ s u m i n g that land which is CJntnminated more than fifty times the WASH-740 contamination limit for Strontium-90 would be ruined agriculturally, which is a prudent assump-tion and one which is consistenc with the vi~w caken in the WASH-740 Report (the WASH-740 Report asserts that i
Strontium-90 land contamination at ten times the Report's _ I contamination limit would rc~uire prohibiting dairying " I
'
....J...i
'*
i :1: for a very long time)) +1:_ can be calculated that a spent fuel pool loss-of-water accident which releases forty-five million curies of Strontium-90 (which cannot now be shown to* be imp o s s i b 1 e ) co u 1 d re s u l t i n ru i n in g a gr i c u 1 tu r a 11 y a land area of the size of about one-third of the land East of the Mississippi River, or certainly the entire eastern seaborad of the United States and Canada, for a hundred years or more.
. ,-,-
/ ."J
(b) The release o[ Ccsium-137 rc1c!ioc1ctivity f:-om the storage pocl into the atmosphere could result in high . I levels of gamma radiation (intense xray-like radiation) .X ,.. emanating from the grGund over .:1n area equal to 150,000 square miles. The gamma radiation exposure to persons standing on the ground could potentially occur at a rate which exceeds by a factor of thirty-eight or more the health limit recommended by the United States Environmental Protection Agency of 25 millirems per year for total radia-tion exposure from emission of radioactivity due to nuclear power_.---------------**--- ( c) No reliable estimates exist of tht:: potential rJ.(;, cancer and genetic harm that could result from a near full release of Strontium-90 and Cesium-137 (and other volatile radioactive materials) inn spent fuel loss-of-water accident. Such estimates nrc necess.:1ry and sh'.Juld be developed, in order that the spent fuel accident hazards can be fully evaluated. (d) The contamination levels indicated in (a) and (bl above apply to the boundar~ of the fallout land area zones that are quantified in those sections. In the c;, n er' c / :; <; ~ r ~ :: i .' * -~ -~ 12 : * '7:' interior of the zonesA the contamination levels would be much worse. (el One spent fuel pool at Salem would contain the equivalent of thirty-nine tons of Plutonium-239 alpha-
/C:,
radioactivity. If dispersed uniformly, this amount of plutonium would have the potencial for causing obandonment of about five million square miles of land, which is 1.5 times the total United States land area, including Alaska. ~o analysis exists which proves that an area of the size of New Jersey, say, would not re~uire permanent abandonment due to a plutonium release in the event of a l.oss-of-water accident in one spent fuel stora_&_~_po?..-1:_.:_ ___ _ ( f) It is possible that a reactor accident at FJ. Re the Salem Station could induce loss-of-water accidents in both spent fuel storage pools, which would then double the above estimates of potential harmful ccnseq~ences. (g) Even if the spent fuel pool held a minimum of spent fuel--sixty-fivc fuel nsscmblics, or one-third o [ a core, :is w,1s the od g i 11:1 I i nl C'nt--thc' rotcnt in l conse-quences of a loss-of-water accident would still be extreme: for example, a land area of the size of Ohio, or five times the size of New Jersey, could be ruined agriculturally for a hundred years or more, due to Strontium-90 release .::lone.
- 4. POSSIBLE LOSS-OF-WATER ACCIDE~TS: SPECIFIC POS-SIBILITIES A loss-of-water accident is possible, which can happen if the pool water cooling system should break down.
A boil-off of the pool water is possible in such an event, I ,.,
which would take about four days to two weeks, based on the figure for the "rn.1ximum cvoporation rc1te 11 (56 gnllons per minute) given in the Nuclc~r Regulatory Co~mission's Safety Evaluation Report (p. 2-5). The most likely cause of a breakdown in the pool water cooling system is a severe reactor accident (see contention No. 7 below). A severe reactor accident could result in such heavy radiation levels at the reactor site that the storage pools would a. be ab~ndoned. In that event the cooling system would have to be assumed to breakdown; and tt1cre would be no adequate assurance that makeup water could be supplied to the pool. Such a reactor accident must be assumed t2 be highly likely to occur (see contention No. 7). There are other possibilities for ctQdsing a loss-of-- pool-water accident through a breakdown in the pool water cooling system which must be giver. serious consideration. One such possibility is for the reactor plant to have to be permanently closed down due to J. rc:ictor accident, leaving only a very small crew to perpetually watch over the storage pool and maintain perpetual coating. In this situation, a cooling breakdown could occur through negli-gence and not be corrected. Sabotage and .:.1cts of war are other possibilities.
---------------
- 5. CONCEIVABLE POSSIBILITIES FOR LOSS-OF-WATER ACCIDE~TS There are a number of conceivabl2 possibi~ities I 9
of accidents and sabotage which could result in a loss-cf-
'I
_/ '- w~ter accident and which~thercforc, must he cvRluated for their likelihood and their potential for causing a 1 o s s - o E- po o 1 -w a t c r . 'l.' he y a re : (al Spent Fuel Shipping Cask Drop. It appears to be possible for the heavy shipping cask to fall from its crane into the storage pool. Such an incident should be evaluated for the potential for ruptur-ing the pool and causing rapid drainage of the pool. A crane fc1i.lurc hns :ilrcc1rly occurred over ;1 spent fuel stor- '-._ I (<;; '.,,ipPi"jP= rt)_; age poolA and an incident of improper handling of a spent l
'-./
.' fuel pool cask has already occurred{ f?,,'q ir'ocf ,-Co/>1iJ ..
(bl Criticality. Indications are that it is possible for a local criticality to occur in the storage pool (sec contention No. 6 below). Such a criticality has yet to be evaluated for the course it could take; so no upper bound exists of its thermal and mechanical consequences. It may be possible that the fission heat generated by such c1 criticality could cause a rapid boil-off of the pool w~ter, despite the pool water cooling svstem. (cl Sabotage, and Terrorism. The possibilities for sabotage and acts of terrorts~ are very real. The use of explosives could destroy the cooling system, and the removal of a new spent fuel assembly out I 0
of the pool water would produce such high levels of radia-tion in the pool building that action to supply makeup water ~ould be severely impeded. Also, explosives conceiv-ably could be used to rupture the pool and thereby cause rapid drainage. (d) Others. Under this heading, earthquakes breaking open the pool and large airplane crashes should be considered.
- 6. CRITICALITY ACCIDENTS A critic~lity accident in the spent fuel pool is a very real possibility. Possible causes are as follows:
(al Missing boral plates in a local ~eg~on of a storage rack, or boral plates with a deficient amount of Boron-10; and (b) Undcrprediction of the effective neutron mullip-tication factor (K_ff). e __ Public Service Electric and Gas Company's Safety Analysis Report and the Nuclear Regulatory Commission's Safety Evaluation Report do not provide ade-quate information to assess the hazard of a criticality accident. For example, there is no indication that there would not occur any positive ~eactivity feedback effect during the fission power rise in a criticality situation. It is n valid concern that a criticality might lead to a rapid boil-off of the pool water. The radiation from such a high-power criticality could conceivably obs~ruct
efforts to control the accident. In order to assess the criticality haz3rd, _therefore, it is necessary that a 1 0 .P
-
;:>!.:.?:'ff
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full analvsis
, J of ~ al/ j)t:S.; .. J".,*. e~
~ n criticalit~, .
bg de,elo~cd. )1U7'/ f ol*p - Th~ benchmark critical experiments used by Public Service Electric and Gas Company to verify its mathematical theory for calculating (Keff) J.re not ade~uc1te to verify the accuracy of the predicted (Keff) factor. Those experi-ments should only be considered as a means to develop the theory for design purposes. In the final analysis, the loading of fuel assemblies into the rJ.cks will be the proof of the validity of the predictions of IK e ...Ff). Therefore, it would be necessary to perform an experiment in which new fuel is placed in the storage racks under controlled insertion J.ncl neutron monitoring for criti-cality. This should be a practical confirmatory experiment. It is well-established that such an experiment is neces-sary. Also, consideration should be given to the question of whether local boiling inn number of spent fuel assem-blics could cause an increase i. n ( Ke_ft- ) ; t hc1 t is, i,..;hether the fuel in the storage racks would be over-moderated. In this regard che above described experi~cnt should inves-tigatc the effect of voids a~d ~2tcr temperature. {/'(()re)
~I
(c) It is concei*13:":Jle, too, that spent fuel--particularly, tr.e ura:1iun dioxije- could melt (at soco 0 ?) and t!"-.us form a liquid pool of molten fuel within a frozen shell or c~~s~ of u::-aniu:n dioxide and steel ar.d zirconium. 0nde~ this condition, it is conceivable that the plutonium in the molten uranium dioxide could separate and stratify in such a pool- or at least a r.iass of fuel :naterial could for~ 'Nhich is rich i.;1 plutonium-and create as a result a nuclear fuel ~ass capable of generating the same kind of ato~ic reaction which ~akes place i~ an atomic bomb- a runaway reaction wl"'.ich co*1l~ procuce a st::-or.g nuclear e ""' 1 o~~a,, .... \.i_ ...
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~ot escape heated soli1 fuel rads 33 readily a~ Strontiu~-90 a:-:J Cesiu:n-1J71 a!"ld so 'P'J.lveri::.ation or vaDorization of the fuel m~y be requi~ed, as i.:1 a nu:lear explosion, befo~e a large a~ou~t of it (olutonium) could b~ rel~ased into the at~os~here. wn i ch :-,as ':),;? en s~ec ula terl to !l.a~:-2 ca.used t:1e "nuclear .j i.32.ste r" i*1 the Soviet U:--.ion, na.rnel:;, 2. conc~ntration o: plu-1:onium in a
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- 7. REACTOR ACCIDENTS CAUSI:JG /,ASPE~T FuEL PCOl LOSS-Or-
..JATER <INCIDENT/
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r-1* (a) -------- Severe reactor nccidcnts are the most likely sc:ora-:r::,e cause of a loss-of-water incident in~ spen_r ;:-~ue- "'1
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pool. A severe reactor accident could rcsL1lt in such heavy radioactive contamination in the ~1rco. o[ the spent fuel storage pool and building that the entire operating crew would be forced to flee for their lives. Such high radiation levels would persist for months a~d thus would prevent emergency crews from returning to the spent fuel pool building to maintain the pool cooling system. In such an accident, it is likely thnt the cooling system would breakdown, due to a lack of maintcnenace, which would lead to a rapid boil-off of the pool water. In addition, the spent fuel storage pool for Unit No. 2 would suffer the same consequences. (Indeed, the Unit No. 2 reactor would likely be abandoned as well, setting in ~otion a train of events leading to a core meltdown and possible explosion in that reactor as well). (bl there exists a great number--essentially an infinite number of severe reactor accident pos~ibilities that could result in a loss-of-water incident in the spent fuel storage pool.
---------
(cl Severe reactor accident possibilities have never been investigated and 11nnlyzcd by the Nuclear Rcgula- _tory Commission and its Atomic Safety and Licensing Board for the potential consequences or the likelihood of such
I ,r accidents, except to a limited Jcgree in the Nuclear Regula-tory Commission's Reactor Sc1fctv Stu~ (R,1siilussen Report), which is not an adequate hnzurds' analysis to assess the reactor accident risks ( see contention ~o. ( f) ( 6) below). It is contended that it has not been ruled out by scien-tific concensus that the potential harmful consequences of a servere reactor accident c3using radioactive contami-nation could be: (1) 120,000 square miles of land requiring evacuation or living restrictions. (2) A lethul range o[ seventy-five miles of a released radiation causing acute radiation disease. (J) 500,000 sqtwrc mLlcs o[ L:md requiring agricultural restrictions due to the release and fallout over the land of Strontium-90 alone; and (4) If the living nnd agricultural restric-tions ar6 relaxed substuntinlly, about 100,000 to 500,000 additional cancer deaths could result. From the f igurcs, it cc1n be appreciated that there exists the potcntinl foe causing abandonment of the spent fuel storage pools ';( in the event of a
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accident. (d) The proposed incrc3se in the scorage of spent F"2 fuel in each storage pool from ~bout 65 sncnc fuel assem-
' J blies to 1170 spent fuel asscmbllcs, ~mounts to an elgh-teen- fold increase in the quantlty of spent fuel and hence Strontium-90 and Cesium-137 radioactivitv to be stored. Since the core of one reactor would contain about 3.7 million curies of Strontlum-9n whi.ch, i.f released in a reactor acciucnt, would have the pol:cntial for causing agricultural restrictions over 500,000 square miles, and since one storage pool would~ by the proposed storage in-crease, contain forty-five million curies of Strontium-90, or twelve times mere Strontium-90 than in the core of the reactor, which could conceivably be released into the atmosphere in a loss-of-water incident, it is imperative that the most likely causes of a loss-of-water incident in a storage pool, namely, severe reactor accident possi-bi~itie5;, be investig~tcd. Severe reactor accident possi-bilities cannot be considered independent of spent fuel storage loss-of-water accidents. From a radiological health standpoint, and in view of the fact that Strontium-90, Cesium-137 and Plutonium are among the most biologically hazardous radioactive substances, if not the most hazardous, so the proposed storage increase would greatly incrciase the
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potential consequences of reactor accidencs that the issue of the likelihood of severe reactor accidents must be thoroughly and completely investigated. (The proposed
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storage increase is like proposing the construction of twenty-four large power reactors from n rQdiological haz-ards standpoint, particularly with respect to Strontium-90, Cesium-137, and Plutonium release _....._ _________________ potentials). (e) The Nuclear Regul~tory Commissi0n has announced F'2 on January 18, 1979 that it supports the "use of p~2babL:..i p*r- ~ r -7 {, ///st-/ C
~ s risk assessment in regulatory decision mc1king, 11 in
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other words, the making and considering esti~ates of the numerical probability of severe reactor Llccidents. However, it is contended that the prob;1bility of .:-t severe reactor accident occurring within the next twenty years or so 0 (' C /d-? }1 f-
-'f. which results in a loss-of-water incideAt in a storage r
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should not be used to assess the risks of the proposed storage increase. It is contended that in order to safely judge the FJ. J, or* f'I '1 ZJl Y'd ! overJ.11 safety/! of the Salem rcnctors and ussociated storage pools, the applicants (utility) and their nuclear plant designers and supplier and/or the Nuclear Regulatory Commis-sion must c1nalyze nnd evaluate .:ill knmm accident possibili-ties (such as multiple control rod ejection accidents, including chain reQction ruptur~s of control rod drive mechanism housings, loss-of-coolant acc~dcnts withouc SCRAM, ejection of a high ronctivitv worth control rod.
and power excursions with excess boron concentration in the coolant) for both their likelihood cf occurrence and their potential consequences, and publish the entire anJ.ly-sls and evaluation (that is, without reduction or simplifi-cation), J.S well as a rcducccl, sirnrl.if;cc\ summJ.ry. Further-more, the Nuclear Rcgul.Jtory Corr.:.,i.ssion should accept and hear testimony from all parties on the adequacy of such an analysis and evaluation, and should t1ccept general testimony as to the likelihood and conse~ucnces of all
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possible serious reactor accidents ( that i.s, the '"",Hi'.:L..,crany should not be limited to the scope of the applicant's present safety analyses or the ~nalysis nnd eval~a~ion called for above, but receive independent analysis as well), and should fully consider and fully weigh all of the testimony and analyses ~nd evaluations as above de-scribed in forming its opinion on the application. The called for analysis and evaluation of all possible acci-dent--their likelihood and consequences--should also in-clude: (1) A li.stLng oi- :111 thcorcl:ical Ltnccrtuintics with rcg~1n.l to the ;,nssibi. lity Cor (,.;orsc conse-quences th,1n prec..liclccl <1nu t.:hc combined effect of the uncertainti<2s. (2) An identification oE all pn~ts of the analyses which have not been c:<pcrimentaily
I. verified. (3) A detailed fault tree graph for each accident possibility and a graph of the chain of events and equipment failures and human errors for each dccidcnt possibility; and (4) A compilation of ~11 experiences of reac-tor equipment failures and human error related to each accident ch.Jin of events. It is further contended that a severe reactor acci-
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- in a spent fuel storage pool is lLkcly to occur--that is, such an accident can reasonably be expected--based on the fact that there is seemingly an infinite number of such .Jccident possibilitic~. ,rnc! bnscd on the large potentL:i.l for human error o.nc.l ecit*clcssncss and other human failings, and on the experience record of cquipillent ~al-functions, past reactor accidents, and near-accident inci-dents.
(fl The following additional contentions regarding FJi reactor accidents are offered: (1) The* theoretical predictions of the course of the renctor design b0sis ~ccidents have not been adequately verified experimentally. The accidents of most concern are the loss-of-coolant accidents, ~he control ,od ejection
accident, cooL:mt pump seizure, control rod withdrawal accident, and the anticipated cransi-ents without SCRAM (~hat is, without emergency fast shutdown of the fissioning). For examples of particulars, see The Accident Hazards Of Nu c 1 ear Po~ P l.1 ~~ h y R i ch ;i r cl E . 1~ ebb ( lJ n i - versity of Massachusetts, 1976), Chapter 4 and 9. The applicanl's reactor safety analysis reports do not give Qdequate scientific reasons why full-scale reactor tests arc not necessary, nor do the rcpoct:s even address the question of the necessity of full-scale or even large-- but-less-than-full-scale tests. (2) The thcoretic;il nnnlyscs of the design basis accidents hc1vc a number of theoretical and mathematical shortcomings. See examples in chapter four of The Accident Hazards of Nuclear Power Plants. ( 3) The sofcty analysis reports submitted f" 1 by the applicant do not justify the selection of the reactor design basis accidents relative to possible accidents which arc mo~e severe.
l" (4) The reactor design basis 3ccidents are analyzed in the applicant's s~fety analysis report with the added assumption in some cases of a sL~gle additional failure of some compon-ent in the safety systems intended to control the accident. However, the applicant's and the Nuclear Rcgulntory Commission's a~alyses do not give adequate analysis and consideration of past reactor accidents and near-accident incidents, some or most of which occurred by and with multiple malfunctions and human error. This is further rcas*on why the full analysis and evaluation of all accident oossi-bilities--their likelihood and potential conse-quences--should be prepared und considered. The :Juclcar Regulacory Commission's "single failure criterion" co judge accidents worse than the design basis accident as "incredible" is wholly inaclequ.1te to nssurc sc1fety, and should not be a busis to deny the full investi-gation of a11 c1ccic!cnt possihi.lities as called for above. ( 5) The mc1gni tude of the potent i.a l consequen- P-J_; ces discussed above requires that the Nuclear Regulatory Commission should rc~uire the analv-
sis and evaluation of the li.keli.hood and poten-tial consequences of all accident possibili-ties, as described by the above contentions, and should fully consider and fully weigh the said likelihood and consequences of all accident possibilities, and should fully con-sider and fully weigh the said likelihood and consequences in the light of the experience of past reactor malfunction (see Accident Hazards generally, and chapters 5 and 6, includ-ing the section on Probability of Accidents, pp. 96-98 and appendix 2, and the testimony by D. Bridenbaugh, ct al., before the Joint Committee on Atomic Energy of the U. S. Con-gress, February 18, 1976, which suggest that the likelihood o[ such severe accidents is not remote and may be unacceptable). A sound, rational judgment of reactor safety is not possible without the full annlysis and evalua-tion called for in the above contentions. (6) The Nuclear Regulatory Commission relies F1.: on the before-mentioned Rasmussen Report and a review of that Report known as the Risk Assessment Review Grouo Report (Lewis Report) to judge that the risk to the public health
and safety due to the nccident possibilitLes which .:1re more sovc1*c th.in the design basis accidents is acceptably low Qnd that the more severe accidents need not be further considered. It is contended that the Rasmussen Report and the Lewis Reporc hQve fundamental short-comings which preclude their being used to establish the level of risk of the said severe accident possibility. See Accident Hazards, chapter six and c1rrcndix one, c1ncl the reviews of the Rasmussen l:{cport by the United States Environmental Protection Agency, dated August, 1975 and June, 1976 (EPA-520/3-75-012 and EPA-520/3-76-009), for discussions of some of the shortcomings. For example, the most severe class of react0r accidents, namely nuclear runaway, are not analyzed for their likelihood and consequences in either the (".;t* . ~ - Rasmussen report or the Lewis Report~- '-' Other shortcomings of the Rasmussen Report are: The report does not present the analysis of the rrobability of the severe accidents i / \ which the report~onsidered, such as transi-ents-without-scram; rather the report merely gives the results cf the analysis perfcr~ed JI
.,, by the Rasmussen study group, by the use of simpli[icd, "reduced" [J.ult t:rces, for c.;xample. In one extremely important instance, at least, there is no fault tree given Qt all, specifical-ly, for the accident involving the failure of the recirculation pump trip safety action during an "anticipated transient without scram" (though this is a boiling water reactor acci-dent, there likely are instances for the pres-surized water reactor in Lhc report as well, for I recall no fault tree for coolant pump siezure and control rod ejection accidents). The public is being asked, therefore, to accept the results of the Rasmussen Report and the Lewis Report on faith. This prevents ochers from being able to adequately scrutinize the probability evaluation of the Ras~ussen Report for its accuracy, comp~etcness, and validity of assumptions (explicit and implicit), which are mostly subjective. ~!oreovcr, the simplified analysis presented in the Rasmussen Report contains ,syrr:bols ,,;hLch .:1.re r,ot defined 2dcquate-. ly for purposes of examining the safety systems for their potcnti~l tor, - nnul the likelihood of, malfunction.
Overall, it is contenued that the appli-cant1s and the Nuclear Regulatory CommissLon's safety analysis reports are not an adequate basis for assessing the safety of the proposed Salem pressureized water reactor and its storage pools, and that the Rasmussen Report and the Lewis Report are not an adequate supplement to answer the concerns of these contentions. (7) The reliability of the SCRAM system to control accidents has not been adequately demonstrated. (SCRAM mcnns the rnpid insertion of the reactor control rods, which shuts down the atomic reaction). No backup SCRAM system exists. The applicnnt has not adequately demon-strated th..1t a backur scram system i.s unneces-sary, inas~uch as the pressure surge of antici-pated transients without scram may be too high. (8) The integrity of the reactor containment svstem under a design basis accident (loss-of-coolantl has not been adequately confirmed experimentally. Full-scale tests nppear to be necessarv.
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(9) The appplica~L's design basis accident F -1 i..- for the containm~nt system and the emergency
.. core coolLng systc:!m (ECCS) h:1s not been shown to be the most likely form of a Loss~of-coolant accident. Specifically, the applicant has not demonstrated th~t a loss-of-coolant acci-dent will not more likely occur as a result of a strong pressure surge transient. Stronger coolant pressures would produce stronger forces on the various components of the containment systems. As for the ECCS, a stronger coolant pressure may be the result of a transient that produces a hotter core nt the time of the coolant system rupture. The ECCS is not designed to control the higher pressure and hotter core (higher temperatures) of such a loss of coolnnt accident.. * (10) It is contended that there should be additional consideration of an earthquake producing a loss-of-coolant accident, inasmuch as a prototype reactor plant will not be proof tested by simulntcd earthquakes (due to obvious impn1cticalityl.
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(11) It is contended that the spontaneous reactor vessel rupture type of accident and a vessel rupture due to pressure surges of ancicipated trnnsicnts without scram have i- l ~/ ~ j)fJ)s,,i /,,J Cl 5 h ev, dew 0111st rt1't-ec{ ThY-ee h'//e Is law/ b I -tt,12 1 eci>vt't" r~C? C fc r 0 ,cr'tt-P~t-
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not been c1dequ<1tely demonstrated to be of negligible probability (to warrant their ne-glect in the reactor containment design). There is the question of no leak-before-break warning. (12) The applicQnt's safety analysis has not given adequate consideration for the possi-bility, perhaps the likely possibility, that a severe reactor accident will occur as a result of unforseen causes or effects, as that seems to be the experience of accidents or near-accidents in nuclear rower plants. (13) The applicant's safety analyses have given inadequate c0nsiJcr*1t:iun t.:o the possi-bility of c-,mmon-mocle type L1ilures in the coolant piping and the emergency core cooling system piping, especially the possibility for sequential failure of the latter due to the forces generated by the former. ____ _ F2, ( 1 4 ) th C Q r r 1 i C on t h ,1 S g i VC n i nod C CJ U a t C ccnsid-cr:.1tion Lo the pussLhLlity o[ saGotagc, for example, consider3tion should be given to the lack of provision for separate rooms and blast shielding in between, to separate b2ckup safety systems, instrurnent~tion. nnd cables
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from primary equipment in rooms normally un-attended, to minimize the likelihood of a saboteur's bomb knocking out primary and back-up safety equipment at once. Also, a multiple control rod ejectioD accident could easily be caused by a saboteur's bomb. (15) Amplification of the preceding contention along with supporting arguments and information are given in the following documents, which have never been disputed by the ~uclear Regula-tory Commission:
- a. The Accident Hdzards Of Nuclear
- b. Memorandum in support of the conten-tion of the Con] ition for Safe Energy in the construction permit hearings for the proposed Erie pressurized water reac-tor (Docket No. STN-50-580 and 581),
dated Se~tembcr 26, 1977, which treats issues concerning the emergency core cooling system; specific possibilities of "anticiratcd tr.1.nsients without scram 11 and their likelihood; the need for - .' tU.!. l. scale tescing of analyses of certain accidents; kinds and causes of multiple
... -- control rod ejection accidents; power excursions with excessive boron concentra-tion in the coolant; loss-of-coolant accidents without scram; and common mode f3ilures in coolant piping and emergency core coolant piping in loss-of-coolant accidents. 4 ---*-***-*--**---- * * * -... - - - - * - - * - * - * - - *
- c. Remarks by R. E. Webb before the Nucle3r Regul~tory Commission's Atomic Snlcty nncl l.Lcc'nsing Bot1rcl on the said Eric proceedi.ng, July ZS, 1977, Transcript pages 81-176, defending his contention.
- d. Petition to Congress "Calling for a Full Rcvic1..; nncl Invcstig.:i.tion of the Hazards of Nucle~r Power Plants and Radio-active Wasce Disposal," by R. E. Webb, May 20, 1978, including an appendix titled "Remarks on the Cruc L:i 1 Fae tor of the Surface Contamin.:i.tion Limits for Plutonium and Strontium-90."
- 8. PERMANENT S?L'H FUEL RF.POS I TORY AT SAi.E>I ,1 'F F.:xJ J- .
(nl It is contended thnt it is likely that the spent fuel from the Sal.em reactors will be stored per~a-nently in the on-site storage pools--that the Salem reactor sit~ will hecomc a permanent repository for the high-level ai.
1 - r radioactive, spent fuel gcner~tcd at the plant. (b) There presently exists no geologic nuclear waste repository for disposing of the spent nuclear fuel; and no such repository is likely to be developed and demon-strated to be safe, or permitted to be built and operated. (cl Off-site spent fuel storage pools which .store only aged spent fuel assemblies (older than six months or a year) have catastrophic loss-of-water accident possi-bilities as well as the reactor site storage pools. Such off-site pools have yet to be evaluated fully for their spent fuel heatup and radioactivity release potential in loss-of-water accident. Furthermore, the theoretical deficiencies in Sandia's mathematical theory (SFUEL) for spent fuel heatup in a loss-of-w~ter accident, which are discussed in contention no. 2.fol above, may very well mean that the heatup predictions presented in the Sandia Report for off-site pools may be grossly in error in the unsafe direction. Therefore, off-site storage pools cnnnot be considered a safe alternative for storing Salem spent fuel; nor does it appear to be an economically viable alternative. ld) Even if the spent [ucl were not allowed to accumulate in the Salem pools, there will be at least sixtv-five new spent fuel assemblies stored in each pool at ~ny one time, which means that there would be about 3a
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2.5 million curies of Strontium-90 in each storage pool (and a like amount of Cesium-137). Infor~ation recently developed about the loss-of-wacer accident hazards of spent fuel storage pools reveals that it is conceivable that the Strontium-90 and Ccsium-137 could be released
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from the fuel into the outside atmosphere in *,;hi.eh an accident (even for open, low density storage racks). Thus, a loss-of-water accident ind single spent fuel pool could
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result in ruining agriculture~ over a land area equal to three times the size of New Jersey, ~mong other disas-trous consequences. The combined rclc~sc of radioactivity from a reactor accident and two spent fuel storage pools (as a consequence of a reactor accident) would be about three times worse. (el The only way to avoid the risks of spent fuel
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storageMis to cease generating che radioactivity ~y closing down the station and terminating the construction of Unit II--that is, to revoke the reactor licenses. ( More)
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- 9. !rnnracticality of Theoretical ~nalysis and ~x~erimental Verification.
T~e ~receding contentions describe a broad scope of theoretical 2.nalyses a:i.d eX"peri!:'!e!'lts that *.vould ":Je necessary i:1 order to fully evaluate the hazards of spent fuel storage (and reactor accidents). :-:owever, it is contended that it is no~ practical (humanly possible) to prepare the needed analyses nor to conduct the needed experiments; and, therefore, the full hazards could never be scientifically established, except by assuming the worst conceivable consequences--that is, a near full release of radioactivity from the storage pool. CONCLUSION Spent fuel storage nt Snlcm (and any other reactors) is unsc1fe because loss-of-water accidents are possible cind because the potentia 1 ha1*mful const:ql.!Cr.l ~s are extreme. Closing down the reacto-1"is the only responsible course of action. This would eliminate the risk o[ reactor acci-dents, 1,:hich its elf is extremely gr.ave.}}