ML20064K339

Affidavit of J Beyea.Release of 600 Ci I-131 Would Cause Doses W/Regulatory Significance Out to Distances of Many Kilometers & Even Further Depending on Weather Conditions. Certificate of Svc Encl

ML20064K339
Person / Time
Site:	05000142
Issue date:	01/06/1983
From:	Beyea J AUDUBON SOCIETY, COMMITTEE TO BRIDGE THE GAP
To:
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l UNITED STATES OF AMERECA l NUCLEAR REGULATORY COMMISSION g_. g BEFORE THE ATOMIC SAFETY AND LICENSING BQA '

E

{. W& s In the Matter of ) 1

) Docket No. 50- 1 ^ /jp/qq -

THE REGENTS OF THE UNIVERSITY ) y M A JI !'

(Proposed Rene a o v ,,%

0F CALIFORNIA )

) Facility Licen e . h4 4 s

(UCLA Research Reactor ) $, ,

J i DECLARATION OF DR. JAN BEYEA I, Jan Beyea, do declare as follows:

1. I received my Doctorate in Nuclear Physics from Columbia University.

From 1970 to 1976 I worked as an Assistant Professor of physics at Holy Cross College in Worcester, Massachusetts; from 1976 to 1980 I worked as a member of the research staff of the Center for Energy and Environmental Studies at Princeton University, since 1980 I have been working as Senior Energy Scientist for the National Audubon Society.

I have prepared papers on consequences of hypothetical accidents at specific nuclear facilities for a number of government bodies: for the Pres-ident's Council on Environmental Quality (TMI reactor), for the Swedish Energy Commission (Barsebeck reactor), for the state of Lower Saxony in West Germany (Gorleben waste disposal site); and for the N.Y. State Attorney General (Indian

, Point reacter.)

l I participated in the international exercise on consequence modelling rox (Benchmark Study) coordinated by the Organization for Economic Cooperation De-US velopment (0.E.C.D. ) . (In this study, scientists and engineers from fourteen go

, cio l (DQ countries around the world calculated radiation doses following hypothetical b

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" benchmark" releases using their own consequence models.)

N I served as a consultant from the environment comunity to the N.R.C. in om gge connection with their development of " Safety Goals for Nuclear Power Plants."

I have preparad risk studies covering sulfur emissions from coal-burning energy facilities.

A complete resume is attached.

2. At the request of the Committee to Bridge the Gap, I have considered the magnitude of thyroid doses that might be received at various distances fol-lowing the puff release at the reactor of 600 curies of Iodine 131 (and a pro-portionate quantity of other radioiodines). As is well known in the radiologi-cal health community, radiciodine causes unusually large doses to be delivered to the thyroid gland. This result occurs because the thyroid gland scavenges radio-iodine from the blood, thereby concentrating and storing the radioactiv-ity in one organ.

3. I have examined the calculations of Steven Aftergood concerning pro-jections of thyroid doses using NRC Regulatory Guide 1.145 (Atmospheric Dis-persion Models for Potential Accident Consequence Assessments at Nuclear Power Plants). He appears to have correctly followed the prescription given in the guide and properly projected downwind radioactivity concentrations for a puff release of. 600 curies under weather conditions corresponding to atmospheric stability class, F, and wind speed of one meter per second.*

In addition, Mr. Aftergood has followed a reasonable procedure for converting downwind concentrations to thyroid exposure by relying on Table 4 of " Analysis of Credible Accidents for Argonaut Reactors."** In this way he has estimated thyroid doses of 107, 37, 11.5 and 5 rem doses at distances of 1, 3, 10, and 23 kilometers, respectively.

However, it should be noted that the Regulatory Guide Method neglects plume depletion, radioactive decay, and changes in stability class. Accounting for these factors could significantly reduce the doses calculated by Aftergood beyond 20 kilometers.

• Should the release occur over a period longer than one hour, calculated doses should be reduced (scaled inversely as the one-third power of the release duration).

• • Hawley, Kathren, and Robbin, NUREG/CR-2079.

4. I have not carefully investigated the probability of the weather conditions used in Aftergood's calculations, but I presume such conditions would occur with a probability less than 10 percent. It is also of interest to examine doses for weather conditions that might have a high probability of occurring at the time of an accident: Using, as an example, the average wind speed of 2.5 meters per second and D atmospheric Stability Class, pro-jected thyroid doses would drop off more quickly with distance than calculated in Aftergood's example. However, according to calculations I made some time ago for a general site, even under these conditions a 1.5 rem thyrcid dose would be projected at 8 kilometers for the release magnitude under discussion.

I presume an 8 km or greater cutoff distance would be characteristic of meteorological conditions that would occur with, say, a 50 percent probability.

5. As Reg. Guide 1.145 does not include calculation methods for dispersion between 1 and 100 meters from the source, Mr. Aftergood utilized other methods for estim& ting concentrations and doses within 100 meters of the reactor room wall. I have not checked those calculations, but it is obvious ,

that potential doses at this distance will be enormous because all of the radioactivity will be concentrated in the localized plume volume close to the leak point. In any case, since the thyroid gland is essentially completely destroyed by the time the dose reaches 10,000 rem, it is really not very important to know precisely how high the thyroid dose might rise above 10,000 rem. It is doses to other organs that become of major importance this close to the reactor. Although Aftergood has not considered doses other than to the thyroid, it should be noted that such doses could also be quite high.*

• Even though the whole body dose might lie a factor of 200 or so below the estimated thyroid dose, the magnitude of the whole body dose could be of concern within a few hundred meters of the site for some weather conditions.

l . .

6. In conclusion: A 600 curie release of Iodine 131 (and the accompanying iodine 133 and 135) would cause doses with regulatory significance out to l

l distances measured in many kilometers and under certain weather conditions out much farther.

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

1 1

W -'

Jan Beyea, Ph.D.

Dated at New York City, New York, this 6th day of January,1983.

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j Resume for Jan Bayea 4 March 1982 4

EnUCATION:

Ph D., Columbia University, 1968 (Nuclear Physics)

B. A., Amherst College, 1962 EMPLOYMENT HISTORY:

1980 to date, Senior Energy Scientist, National Audubon Society, 950 Third Avenue, New York, New York 10022.

1976 to 1980, Research Staff, Center for Energy and Environmental Studies, Princeton University.

1970 to 1976, Assistant Professor of Physics, Holy Cross College.

1968 to 1970, Research Associate, Columbia University Physics Department.

i CONSULTING WORK:

Consul tant on nuclear energy to the New Jersey Department of Envi ronmental Protect i on; the Of fices of the Attorney General in New York State and the

! Commonwealth of Massachusetts; the state of lower Saxony in West Germany; the Swedish Energy Commission; and various citizens' groups in the United States.

PUBLICATIONS CONCERNING ENERGY CONSERVATION AND ENERGY POLICY:

I " Comments on Energy Forecasting," material submitted for the record at the Hearings before the Subcommittee on Investigations and Oversights of the Committee on Science and Technology, U. S. House of Representatives; Committee j Print, June 1, 2, 1981 / No. 14 /.

"The Audubon Energy Plan Technical Report," Peterson, Beyea, Paulson and Cutler, National Audubon Society, April 1981.

I i

l " Locating and Eliminating Obscure but Major Energy Losses in Residential

( Housing," Harrje, Dutt and Beyea, ASHRAE Transactions, 85, Part il (1979).

Winner of ASHRAE outstanuin~g paper award.

l

! " Attic Heat Loss and Conservation Policy," Dutt, Beyea, Sinden. ASME Technology and Society Division paper 78-TS-5, Houston, Texas, 1978.

" Comments on the proposed FTC trade regulation rule on labeling and adver-tising of thermal insulation," Jan Beyea and Gautam Dutt, testimony before the Federal Trade Commission, January 1978.

" Critical Signi ficance of Attics and Basements in the Energy Balance of Twin Rivers Townhouses," Beyea, Dutt Woteki , Energy and Buildings , Volume i (1977) , Page 261. Also Chapter 3 of Saving Energy in the Home, Ballinger, 1978.

l.

"The Two-Resistance Model for Attic Heat Flow: Implications for Conservation Policy," Woteki, Dutt, Beyea, Energy--the International Journal, 3,657,(1978).

f

" Energy Conservation in an Old 3-Story Apartment Complex," Beyea, Harrje, i Sinden, Energy Use Management, Fazzolare and Smith, Pergamon 1977, Volume I, Page 373 j " Load Shifting Techniques Using Home Appliances," Jan Beyea, Robert Weatherwax, Energy Use Management, Fazzolare and Smith, Pergamon 1978, Volume til/IV, j Page 121.

PUBLICATIONS CONCERNING ENERGY RISKS (PREDOMINANTLY HUCLEAR POWER):

Articles:

"Containing a Nuclear Reactor Melt-Down" (with Frank von Hippel), Bulletin of the Atomic Scientists, to be published.

"Second Thoughts (about Nuclear Safety)," to appear in Nuclear Power: Both Sides, W. W. Norton and Co. (Publication date: October 1982.)

" Indoor Ai r Pollution," Commentary in the Bulletin of the Atomic Scientists, 37, Page 63, February 1981.

" Emergency Planning for Reactor Accidents," Bulletin of the Atomic Scientists, 36,, Page 40, December 1980. (An earlier version of this article appeared in German as Chapter 3 in im Ernstf all hil flos?, E. R. Koch, Fri tz Vahrenhol t, edi tors , Kiepenheuer & Wi tsch, Cologne, 1980.)

" Dispute at Indian Point," Bulletin of the Atomic Scientists, 36, Page 63, May 1980.

Published Debates:

The Crisis of Nuclear Energy, Subject No. 367 on William Buckley's Fi ring Line, P.B.S. Television. Transcript printed by Southern Educational Communications Association, 928 Woodrow Street, P. O. Box 5966, Columbia, South Carolina, 1979 Nuclear Reactors: How Safe Are They?, panel discussion sponsored by the Academy Forum of The National Academy of Sciences, 2101 Constitution Avenue, Washington, D. C. 20418, May 5, 1980.

Reports:

"Some Long-Term Consequences of Hypothetical Major Releases of Radioactivity to the Atmosphere f rom Three Mile Island," Report to the President's Council on Envi ronmental Qual i ty , December 1980.

" Decontamination of Krypton 85 from Three Mile Island Nuclear Plant," (with Kendall, et.al.), Report of the Union of Concerned Scientists to the Governor of Pennsylvania, May 15, 1980.

l "Some Comments on Consequences of Hypothetical Reactor Accidents at the l Philippines N2 clear Power Plant" (wi th Gordon Thompson), National Audubon Society, l

Environmental Policy Department Report No. 3, April 1980.

" Nuclear Reactor Accidents : The Value of fmproved Containment," (wi th Frank von Hippel), Center for Energy and Environmental Studies Report PU/ CEES 94, Princeton University, January 1980.

"The Ef fects of Releases to the Atmosphere of Radioactivity from Hypothetical Large-Scale Accidents at the Proposed Gorleben Waste Treatment Facility," report to the Government of lower Saxony, Federal Republic of Germany, as part of the "Gorleben International Review " February 1979

" Reactor Safety Research at the Large Consequence End of the Ritk Spectrun."

l presented to the Experts' Meeting on Reactor Safety Research in the Fede ral

( Republic of Germany, Bonn, September 1, 1978.

Published Debates (Cont'd.):

A Study of Some of the Consequences of Hypothetical Reactor Accidents at Barseback, report to the Swedish Energy Commission, Stockholm, DS 1 1978:5.

January 1978.

Tes t i mony :

"In the Matter of Application of Orange and Rockland Counties, Inc. for Conversion to Coal of Lovett Units 4 and 5," testimcoy and cross-examination on the health impacts of eliminating scrubbers as a requirement for conver3 ion to coal; Department of Environmental Resources, State of New York, November 5,1931.

" Future Prospects for Commercial Nuclear Power in the Un' ted States," before the Subcommittee on Oversight and Investigations, Committee on Interior and Insular Affai rs, U. S. House of Representatives, October 23, 1981.

" Stockpiling of Potassium lodide for the General Public as a Condition fc-Restart of TMI Unit No.1," direct testinony on behalf of the Anti-Nuclear Group Representing York, April 1981.

" Advice and Pecommendations Concerning Changes in Reactor Design and Safety Analysis which should be Requi--> !r. Light of the Accident at Three Mlle Island,"

statement to the Nuclear Regui. .y Commission concerning the proposed rulemaking hearing on degraded cores, December 29, 1980.

" Alternatives to the Indian Point Nuclear Reactors," Statement before the Environmental Protection Committee of the New York City Council, December 14, 1979 Also before the Committee, '!The Impact on New York City of Reactor Accidents at D. Indian Point," June 11, 1979 Also " Consequences of a Catastrophic Re =ctor Accident,"

statement to the New York City Boa.'d of Health, August 12, 1976 (with Trank von Hippel).

" Emergency Planning for a Catastrophic Reactor Accident," Testimony before the Cali fornia Energy Resources and Development Commission, Emergency Response and Evacuation Plans Hearings, November 4, 1978, Page 171.

"Short-Term Effects of Catastrophic Accidents on Communities Surrounding the Sundesert Nuclear Installation," testimony before the California Energy Resources and Development Commission, December 3,1976.

" Consequences of Catastrophic Accidants at Jamesport." Testimony before the New York State Board on Electric Generation Si ting and the Envi ronment in the Matter of Long Island Lighting Company (Jamesport Nuclear Power Station, Units I and 2), May 1977 Miscellaneous:

" Comments on WASH-1400," Statement to the Subcommittee on Energy and the Environment, Oversight Hearings on Reactor Safety, June 11, 1976, Serial No. 94-61, Page 210.

" Upper Limit Calculations of Deaths from Nuclear Reactors," Bull. Am. Phys.

Soc. 21, 111 (1976).

Contention II RESMNSE TO STAFF'S ASSERTED F.ATERIAL FACTS ,

1. "A calibratian error made in 1975 b) UCLA rea d en corrected arx1 has not been repeated." persog%s*

(

DISPLTED h, y h (Foster,13-26 Cooperman, 23-5:Fonosson, 221-23 'd 'g-y #

2." Written procedures for calibration of instruments A$, h _ __ facility have been developed ani reviewed by the Radiation Use Committee."

DISPITIED (Letter, Wegst to Wenslawski, June 24, 1982--doesn't support the stated fact Inspection Report 82-01: Cooperman, 23-5: Foster, 223 F.onosson,222)

3. " Appropriate actions have been taken by UCLA to correct all items of non-compliance."

DISPUTED (Note again the citations refer to only a portion of the license period.

CBG citations as for fact 4 of Contention III 'are applicable here as this is a restatement of that Staff fact. )

4 " Calibration errors at the UCLA reactor facility have not been significant to public health and safety."

DISFUTED (F.onosson,121 Foster, I 3-26 Cooperman, I3-5: Lyon14-20) 5 "The calibration of instruments and maintenance of equipment at the UCLA reactor facility has been inspected by NRC for many years."

NOT DISPUTED

6. "No risk to public health and safety has arisen from inadequate equipment maintenance at the IX:la reactor facility."

DISFUTED (Coopermn 14 Plotkin as to XII, I20,22 Flotkin as to XVI, 15-7,9,11-16)

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IX-2 RESPONSE 'IO UCIA'S ASSERTED FATERIAL FACT

32. " None of the calibration errors or equipment malfunctions which have occurred at the U1 A reactor facility are of safety significance."

DISPUTED .

(citations for Staff facts 4 and 5 above, plus honosson 14-19: Plotkin as to III, E iv, 3-5,10,11,18,24-29) f

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