ML20206N024
| ML20206N024 | |
| Person / Time | |
|---|---|
| Site: | Berkeley Research Reactor |
| Issue date: | 11/21/1988 |
| From: | Gelb M, King C BERKELEY, CA, CALIFORNIA, UNIV. OF, BERKELEY, CA |
| To: | |
| Shared Package | |
| ML20206N021 | List: |
| References | |
| 88-574-07-OLA, 88-574-7-OLA, OLA, NUDOCS 8812020141 | |
| Download: ML20206N024 (151) | |
Text
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1 UNITED STATES OF AMERICA NUCLEAR RFr.ULATORY COMMISSION 2 78 El 25 Pl2:43 3 ATOMIC SAFETY AND LICENSING BOARD i 4 Before Administrative Judges l
Helen F. Hoyt, Chair 5 Glenn O. Bright James H. Carpenter 6
)
7 In the Matter of ) Docket No. 50-224-OLA
)
8 UNIVERSITY OF CALIFORNIA, ) ASLBP No. 88-574-07-OLA BERKELEY )
g )
10 SETTLEMENT AGREEMENT 11 I2 This Settlement Agreement is made and entered into this 13 21st day of November, 1988, by and between the City of 14 Berkeley ("Intervenor") and the University of California, 15 Berkeley ("Licensee").
IO 1. On January 8, 1988, an application to amend License I7 No. R-101 for a research reactor located in Etcheverry Hall on 10 the campus of the University of California at Berkeley (the 10 "Research Reactor"), was filed by Licensee to allow for the 20 decommissioning and removal of the Research Reactor, and the 21 subsequent termination of License No. R-101. This application 22 was docketed as Docket No. 50-224-OLA by the Nuclear 23 Regulatory Commission ("NRC") . See S3 Fed. Reg. 7823 (Mar.
24 10, 1988).
5
- 2. On April 12, 1988, Intervenor filed a "Petition to 0 Intervene in License Amendment Proceeding, Request for 8812020141 0011 1 24 PDR ADOCK O 0 DH 5648k a
t 1 Hearings and Further Relief" and, pursuant to the Order of the 2 Atomic Safety and Licensing Board ("ASLB" or the "Board"), was t 3 allowed to intervene on May 25, 1988. Said Order provided
- 4 that Intervenor was to file a supplement to its Petition to 5 Intervene within thirty (30) days setting forth a list of 4
6 contentions which Intervenor wished to have litigated in this l t
7 matter. !
8 3. Licensee and Intervenor both believed it was in 9 their best interests and the interest of the public to pursue i
10 settlement -f this matter. As a result, the parties
]
11 stipulated to a 90-day stay of proceedingr which was ordered 12 by the Board on June 22, 1988. A second stipulation for an i
13 additional thirty (30) day stay of proceedings was ordered by l 14 the Board on September 27, 1988. A third stipulation to i 15 extend the stay of proceedings for an additional twenty-one 16 (21) days was submitted to the ASLB on October 17, 1988.
17 '4. During the terms of the stays of proceedings in this 19 matter, Licensee and Intervenor, including certain 19 raoresentative commissions of Intervenor and members of the b public ("Interested Persons"), have participated in several 21 meetings and discussions to address the concerns raised by 22 Intervenors and Interested Persons regarding the proposed 23 defueling and decommissioning of the Research Reactor. This 24 further public and institutional input resulted in the 25 resolution of the concerns of both Intervenor and Interested 26 Persons, as set forth in that certain Public Information 2
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1 Document, dated October 5, 1988, attached hereto as Appendix 2 A and incorporated herein by this reference, and the manual 3 entitled "Emergency Preparations for Removing the Berkeley 4 Research Reactor", dated September 7, 1988, attached hereto as 5 Appendix B and incorporated herein by this reference.
6 5. The Public Information Document (Appendix A) was 7 prepared specifically to address various issues raised 8 regarding the proposed decommissioning and removal of the O Research Reactor pursuant to several transmittals and 10 discussions between Licensea and Intervenors and Interested Il Persons, particularly the Peace and Justice Commission of the 12 City of Berkeley. The majority of issues addressed, discussed 13 and resolved pursuant to said transmittals and discussions I4 pertain to the matters and concerns raised through Licensee's 15 review process and Irtervenor's comments on the application to IO amend License No. R-101 regarding the proposed decommissioning II of the Research Reactor.
18 6. The document entitled "Emergency Preparations for 19 Removing the Berkeley Res sarch Reactor" ( Appendix B) was O created to provide specilic information to the City of 21 Berkeley Fire and Police officials regarding emergency 22 preparations for the Research Reactor removal project, with 23 procedures and activities requiring ceordination with said 24 city officials apecifically identified, and particularly 25 delineating r.etivit.'en and emergency procedures involving 26 Licensee and Interver or.
3 5648k
1 7. Licensee and Intervenor agree that this Settlement 2 Agreement is premised upon the binding obligations of the 3 parties as set forth in Appendice. A and B. The parties 4 further agree that the Joint Motion for Dismissal of 5 Proceedings, dated November 21, 1988 and filed herewith, is 6 subject to the condition that the commitments set forth in 7 Appendices A and B are not breached by either party to this 8 agreement'or any of their delegates or assigns. In the event l
9 that aray provision of said dceuments is breached by either 10 party, the other party hereto may move to enforce such II provision as set forth herein.
12 8. The commitments set forth in this Settlement 13 Agreement arise from the specific facts and circumstances I4 involved in this proceeding and are not intended to serve as 10 precedent in any other proceeding.
IO 9. The partier have agreed to execute in good faith the I7 commitments contained in this Settlement Agreement.
IO 10. As a result of the agreements reached by and between I9 the parties and reflected in this Settlement Agreement, the O parties agree that this hearing procedure should be dismissed II and the request for amendment of License No. R-101 be returned to NRC Staff for further processing as an uncontested matter.
23 Intervenor and Licensee agree to prosecute diligently the terms of the Settlement Agreement and the Joint Motion for 5 Dismissal of Hearing Procedure before the Board, and to pro' ride such additional informaticn, file any additional 4
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l 1
1 pleadings, make such appearances, and provide such support as 2 the Board deems necessary to effectuate the dismissal of these !
3 proceedings.
d 11. This Settlement Agreement, including Appendices A 5 and B, constitutes the entire agreement between the parties a
i 6 and supercedes all other prior agreements, representations, ;
j 7 statements, promises, and understandings, whether oral or '
8 written, express or implied. This Settlement Agreement is l ll
! 9 binding upon and inures to the benefit of each of Licensee and 10 Intervenor.
II 12. Any communications or notic a made or given by l
12 either party hereto in connection with this Settlement 13 Agreement shall be in writing (by certified mail, return I4 receipt requested, or hand delivery) to the following:
15 If to Licenseer l
I9 Milton Gordon, Esquire 37 office of the General Counsel University of California
) 590 UnWersW Hall
$g 94720
! Berkeley, CA t
19 with a copy to:
O David R. Pigott, Esquire i
Jane B. Kroesche, Esquire 21 Orrick, Herrington & Sutcliffe j 600 Montgomery Street 22 San Francisco, CA 94111 l
3 If to Intervenor 24 Manuela Alburquerque, City Attorney 1
25 Marj rie Gelb, Deputy City Attorney i
Jonathan Rothman, Assistant Attorney 2180 Milvia Street, Fifth Floor l 26 i Berkeley, CA 94704 i
J 5
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1 NOW, THEREFORE, it is agreed among the parties that:
2 A. Intervenor's "Petition to Intervene in License 3 Amendment Proceeding, Request for Hearingu and Further Relief" 4 is withdrawn in its entirety based upcn the agreements set 5 forth herein.
6 B. The parties shall request in their Joint Motion for 7 Dismissal of Proceedings, dated November 21, 1988 and filed 0 herewith, that the ASLB accept this Settlement Agreement and 9 dismiss this hearing proceiure, subject to the following 10 conditions and agreements among the parties:
II 1. The request for amendment of License No. R-101 I ahall be returned to NRC Staff for further processing as 13 an uncontested matter. Licensee's activities shall be I4 concluded under said Application upon final approval by 15 the NRC and termination of License No. R-101.
I6 2. Licensee shall serve Intervenor with any II proposed change 1/ in the programs as described in its IO Plan to Decoraission the Research Reactor at the time 19 such proposed change is submitted to the NRC.
20 3. Licensee shall provide Intervenor with notice
' of changes to the emergency procedures contained in the i
22 manual entitled "Emergency Preparations for Removing the 23 1
l 24 "Change" as referred to in this paragraph means any 1/
m dification, deletion or substitution of 'eny of the programs 25 described in Licensee's Plan to Decoraission the Research Reactor.
26 6
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1 Berkeley Research Reac. tor", dated September 7, 1988 2 (Appendix B to this Settlement Agreement) no less than 3 ten (10) business days prior to implementing such 4 changes. Intervenor shall respond to Licensee within 5 five (5) business days prior to the date such changes are 6 to be implemented with any comments to or dispute 7 concerning the proposed changes. The parties shall 0 resolve any such disputed change in accordance with 0 paragraph C.2 and C.3, below, prior to the implementation 10 of any such disputed change.
II C. In tre event that any dispute between Licensee and I2 Intervenor arises relating to any matter pertaining to this 13 Settlement Agreement or the Order of the Board dismissing this I4 hearing procedure, Licensee or Intervenor, as the case may be, 15 shall seek to resolve such dispute as follows:
16 1. The aggrievcd party shall promptly notify the I7 other party hereto no later than ten (10) business days IO after idsntification of a dispute as to the existance of IS any such dispute.
20 2. Licensee and Intervenor shall exercise their I boat efforts to resolve the dispute between themselves.
22 3. In the event the parties are unable to resolve 23 the dispute between themselves, the aggrieved party may file a petition with the Commission pursuant to the 5 procedures set forth in Section 2.206 of the NRC 26 Guidelines (Title 10 C.F.R.). Compliance with the 7
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. 1
. (
)
t 1 requirements of Section 2.206 anall be the sole means of i 2 obtaining Commission review and a resolution by the l 3 Commission of said dispute. Any determination of the 4 Commission regarding said dispute shell be binding on the [
t t
' 5 parties, i
The provisions in this Settlement Agreement 6 4.
7 shall be the exclusive remedies of the Licensee and J
(
8 Intervenor for seeking resolution of any disputes related f
9 to any matter under the jurisdiction of the NRC 10 pertaining to the proposed decommissioning of the i f
11 Research Reactor and the termination of License No. ;
12 R-101. The provisions in this Settlement Agreement do j
13 not prohibit Intervenor from contesting further I4 amendments or changes to Licensee's Plan to Decommission
[
J
! 15 the Research Reactor in accordance with NRC procedures.
a :
10 L. This Settlement Agreement shall become effective i
II whan it is accepted by the ASLB and this hearing procedure is 18 dismissed. Upon such effective date, the parties mutually ;
II sgree to release and dis:harge the other party hereto, and 20 each of their delegates, reprenentatives, contractors, 21 successors and assigns, from any and all claims, demands and 22 causes of action that they now or in the future may have i 23 arising out of or in any way connected to this hearing 24 procedure, except as expressly provided otherwise herein. l J
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t 8
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_ _ . . . . _ _ . , . . _ _ _ _ , _ _ _ _ . . . _ _ _ _ _ , _ _ _ _ _ _ . . ~ _ _ _ . _
1 The undersigned warrant and represent that they have fuli 2 and complete right, power, authority and capacity to execute 3 this Settlement Agreement on behalf of the parties hereto.
4 UNIVERSITY OF CALIFORNIA, BERKELEY, 5 MANUELA ALBUQUERQUE, Licensee City Attorney 6 MARJORIE GELB, Deputy City Attorney 7 JONATHAN ROTHMAN, 3y
-- [M/e k n 4 < s , P Provost C. Judson King 3 Assistant Attorney 8
~ p i November 21, 1988 9 )
10 Kttorpeys 'for Intervenor CITY.0F BERKELEY 3
Dated: November 21, 1988 12 13 14 15 16 17 18 19 to 21 22 23 24 25 26 9
56484
s PUBLIC INTORMATION DOCUMENT i
- 1 ETCHEVERRY HALL REACTOR DECOMMISSIONING AND REMOVAL UNIVERSITY OF CALIFORNIA AT BERKELEY i
5 OCTOBER 1988 j
i
)
l Prepared by:
f 1
- Bendix Environmental Research, Inc.
' 1390 Market St., Suite 418 San Francisco, CA 94102 j
1 and l
Camput Planning Office
- University of California Berkeley, CA 94720 l for:
Office of the Chancellor University of California
- Berkeley, CA 94720 1
i i
i i
}
Appendix A f
TABLE OF CONTENTS 1
Introduction.........................................................
l 1
' 2 Alternatives.........................................................
P ro j e ct De s c r i p t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 S a f e ty I s s u e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 7 69 Project. Specific Procedures.........................................
82 i Footnotes...........................................................
G 1 o s s a ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 9 i-
.i.
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4 J
LIST OF FIGURES l 1. Campus Map Showing Project Site in Relation to Bay Area............. 5
- 2. Pl a n Vi ew of Etcheve rry Hall , Fi rst Level . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ;
i
- 3. Secti on through Etchever ry Hall . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 !
1 4. Plan View: Etcheverry Hall, Patio, and Surrounding Buildings....... 9
- 5. Campus Map Showing Soil and Sediment $arpling Locations............11 l q 6. Di ag ram of BMI-1 S h i ppi ng Cask. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 l
- 7. Route for Fuel Shipment from U.C. Campus to Major Highway.......... 20 i
o 8. Tent ative Route for Shipment of Fuel to Idaho. . . . .. . . . . . . . . . . . . . . . . 21 ,
J t i 9. B ounda ry of De c ommi s s i oni n g Are a. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 :
i f I
LIST OF TABLES l
- 1. Categories of Uranium Enrichment and their Required Security Levels.18 i i
- 2. Calculated Radiation Doses from Routine Transport of Radioactive ;
Material (in person-rem)............................................ 31 ,
- 3. Cal cul at ed Occu pat ional Radi ation Dos es. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 l t
Estimated Occupational Lost-Time Injurie and Fatalities............ 35 ;
4.
l i j 5. Summary of Postulated Accidents and Radiation Doses to the Maximum- -
Exposed Individual.................................................. 36 4
- 6. Exposure Limits for Exclusive-Use Transport of Radioactive
- Materials...........................................................52
! t
! 7. Calculated Radiation Doses from Atmospheric Releases During !
R outine Dec anmi s sioni ng and Fuel Rod Removal . . . . . . . . . . . . . . . . . . . . . . . . 56 ,
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I l i r 4
i -si- i t
.i ETCHEVERRY HALL REACTOR DEC0ttHISS10NING AND REMOVAL UNIVERSITY OF CALIFORNIA AT BERKELEY Introduction This document has been prepared in order to discuss questions which have been raised regarding the proposed decommissioning and removal of the Etcheverry Hall Reactor (hereafter, Reactor). The questions addressed in this information document have their origins in several transmittals and meetings with City of Betkeley staff, Peace and Justice Commission members i
and the public. The bulk of the questions have been raised through the q
review process conducted by the University of California (UC) and through l
the City's comments on the proposed license termination request to the i Nuclear Regulatory Commission (NRC) by UC.
i This public information document should be considered with the other re-ports, manuals and documents prcduced for this project: Project Planning i
Guide Decommissioning Plan, Quality Assurance Manual, Environmental Report, i "Ent.rgancy Preparations fcr Removing the Berkeley Research Reactor," NRC j regulations, etc. These and other publications relevant to this project are available at the Berkeley Public Library and at Doe Library on the UC Campus.
l l-I
\ - - - _ _ - - _.- -_ _ - . - _-_ -
ALTERNATIVES Alternatives to immediate Reactor removal were considered but rejected.
Delayed decommissioning and permanent entombment of the Reactor after de-fueling were rejected because UC plans to use the Reactor Room (Room 1140) for other teaching and research purposes and because the levch of radioac-tivity do not require a long decay period before dismarcling can be accom-plished safely. The no-project alternative was reje:ted because of the costs of continued Reactor operation when little use is being made of it.
Alternative routes were considered for shipment of radioactive materials.
The most direct routt through the Bay Area has been selected, in compliance with federal regulations in 49 CFRt 177 and 397. An alternate route through a less populated area was considered but rejected because of lack of compli-ance with NRC and Department nf Transportation (007) regulations, compar-atively poorer maneuverability and visibility, a higher probability of ac-cidents on less accessible roads with steep embankments, and passage through watershed lands.
' Permanent on-site entombnent of the fuel rods was rejected because of:
(1) concerns about keeping irradiated fuel in an urban areal; (2) the '
requirement of perranent security measures and monitoring proceduresl; (3) the legal position of Department of Cnergy (00E), the owner of the fuel, that refusal to return the fuel would constitute the criminal offence of theft or diversion of nuclear materialsl and the improbability that DOE
' would release the fuel to UC; (4) UC's desire to use Room 1140 for teaching and research purposes; and (5) cost.
t iechnical terms defined in the glossary are marked with a dagger (t) at first use.
PROJECT DESCRIPTION This section describes the history of Reactor operations, the location of the site, the two phases of the project occurring on the UC campus (fuel removal and decommissioning of the Reactor), and the proposed transportation routes for shipment of radioactive _ materials (fuel rods, Reactor parts, concrete rubble and other debris).
The proposed project has two phases: (1) removal and shipping of fuel rods from the one megawatt (MW) TRIGA Mark 111 nuclear research Reactor; and The first (2) decommissioning (dismantling and removal) of the Reactor.
phase is expected to take about three months; the second phase, including inspections, would take about eight months. The Reactor, operated by the Department of Nuclear Engineering on the UC campus from 1966 to 1987, was shut down on 23 Decemoer 1987 in preparation for proposed decommissioning.
Background
The Reactor was used primarily for research and educational purposes by faculty and students of UC Berkeley, other UC campuses, and other local universities and collegu as well as by personnel from Lawrence Berkeley and Lawrence Livermore Laboratories. The irradiation services of the Reactor were also used by industry contractors such as Chevron Research Company, Motorola, Inc., Hughes Aircraf t Inc., and Lockheed2 for commercial purposes or, in the case of defense contractors, for unclassified U.S. Government projects.3 The total cumulative energy production of the Reactor at the time it was shut down was 293 MW-days t . Energy production averaged about 24 MW-days per 3
a .. . ;
PROJECT DESCRIPTION 4
year from 1967 through 1975 and about 6 MW-days from 1976 through 1987. By comparison, a typical 1000 MW electric commercial power reactor at a capac-ity factorI of 60% generates about 700,000 MW-days per year.4 In October 1985 a low-level release of radioactive material within the Reac- ,
ter Room (Room 1140) was detected by the warning system attached to an air filter in Room 1140. The leak, traced to three possible fuel rods, occurred only during full power operation.5 When the leak was originally detected by the staff, Room 1140 ventilation was switched to emergency mode. All I
three r.uspect rods were removed from the Reactor core and stored in the Reactor pool, where they remain today. UC complied with all NRC require-1
) nents for this incident and normal Reactor operations were resumed.6 Staff j
concluded that virtually no radioactivity was released to the environment.5 f
- i
! Leakage from the rods has not occurred under storage conditions;7 neverthe- [
less, special care would be taken in monitoring these rods during fuel {
' I removal and packaging.8 i i
- i The University cited two reasons for the decision of 20 December 1986 to j i cease operation of tne Reactor and consider decommissioning: (1) the ;
- f i history of declining Reactor use and (2) the need to free the space occu- l 4
i pied by the Reactor for other academic and research uses.9 i
} !
I Site Location and Description l [
j The Berkeley campus lies near the foot of the Berkeley-Oakland Hills in Ala.
I l
meda County, about 2.5 miles east of Interstate 60 (I-80) and San Francisco r i
1 Bay (Fig. 1 insert, p. 5). Etcheverry Hall is on Hearst Avenue between
! Euclid Avenue and LeRoy Avenue on the north side of the UC campus (Fig.1, j 1 i i
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PROJECT DESCRIPTION
- p. 5). The site slopes downward to the west and is about 320 ft. (100 me-ters (m]) above sea level.
Operations related to removal of fuel rods (preparation of cask, removal of fuel from the Reactor and transfer to the shipping cask) and to decommis-sioning (dismantling and packaging of Reactor components and other waste materials) would take place inside the concrete-walled Room 1140. This room, the present location of the Reactor, is in the basement of Etcheverry Hall on the UC Campus (see Figures 1, 2 and 3, pp. 5, 7 and 8). No hand-ling of radioactive materials other than possible loading of packaged low-level radioactive waste (p. 53) would take place outside Room 1140.
The main portion of Etcheverry Hall to the west of Room 1140 consists of 5 stories over a first level (see Fig. 3, p. 8). The nearest buildings to the Reactor, other than Etcheverry Hall, are over 100 ft. from Roon 1140 in all directions.
A patio and volleyball court are directly above the Reactor, flanked on both sides by UC parking (see Fig. 4, p. 9). The 25-inch thick concrete roof of Room 1140 supports the patio.10 Approximately 10 inches of soil separate the roof from the ground surface in the grass-covered section of the patio above the reactor. The roots of the olive tree on the patio are not liktly to have penetrated the upper layer of the concrete roof sufficiently to allow rusting of the reinforcing steel and loss of structural integrity in the roof structure. The walls of Room 1140 are 2 ft thick.ll A branch of Strawberry Creek flows past Etcheverry Hall in an underground 48-inch diameter culvert 300 f t. northwest of the Reactor; an 18-inch dia-I
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PROJECT DESCRIPTION i
meter stom drain adjacent to the Hearst Ave. side of Etcheverry Hall t
drains into the underground creek just west of the building.
Shipments of fuel rods, radioactive demolition debris and nonradioactive debris would pass through local jurisdictions and along major-highway routes to distant disposal and storage sites.
Site Soil and Water Quality _
Past contamination of the site with radioactive materials due to Reactor operation was not expected, based on results of routine monitoring outside the building and results of sampling conducted by the NRC at the Corvallis, l Oregon, research reactor. Sampling of the soil outside the Reactor and of l
sediments in nearby Strawberry Creek, conducted for UC as part of this study (see Fig. 5, p.11 for site locations), confimed this expectation.
Creek sediments were sampled in order to address the possibility of cumula-
' tive impacts of past water pollution. The results are discussed below.
one half was analyzed by Thermo The soil and sediment sanples were split; Analytical Laboratories, Inc. (TMA), Richmond, certified by the California Department of Health Services (OHS) to perfom gamma scanst for radio.
isotopet analysis; the other half was given to Michael Denton, Deputy j
Decommissioning Engineer, for analysis by the UC Department of Nuclear En-i gineering(DNE). l No radioisotopes not nomally The two analyses produced similar results.
[
present in soil were found. No isotopest were found in elevated concentra.
sam-tions near Etcheverry Hall. UC Berkeley staff perfomed additional
)
i pling later in March. Analysis of these samples confirmed that all caepus l
i samples were in the Bay Area background range for the radioisotope cesium-
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Figure 5. Campus Map Showing Soil and Sediment Sampling Locations s o# c c . u,. .% . c . ii ~ e .a . * > < e - 5 ~-> ' """" " J s
PROJECT DESCRIPTION 137 (0.02 to 0.5 picoeuriest 137C s per gram dry soil, where a picocurie is 10-12 curie).
The radioisotopes found in the soil and sediment samples were:
. potassium-40 i (40K) ---- A natural radioisotope with a half-life of a billion years, found in rock, soil and living organisms, including hu-mans. This isotope is one of the main sources of background radiation.
THA reported values about fifty percent higher than the values reported by DNE, probably attributable to the difference between measurement of l dry (TMA) vs. wet (DNE) weight of soil.
. radium-226 (226Ra) --- A natural radioisotope with a half-life of 1.600 years. The presence of this isotope was deduced by TMA from detection of its daughter products (not routinely reported by TMAl2). The daugh-ters were also detected by DNE.
. cesium-137 (137Cs) --- A man-made radioisotope with a half-life of 30 years. Most of the 137 C s found at or near the earth's surface is due to f all out from past atmospheric tests of nuclear weapons. TMA reported about twice as much of this isotope as did DNE (probably due to measurement with respect to dry vs. wet weight of soil).
. beryllium-7 (7Be) --- A natural radioisotope with a half-life of 53 days.
This radioisotope is formed when cosmic rays hit nitrogen in the atmos-phere.lJ TMA found this radioisotope at levels just above the detection threshold. DNE did not report detected amounts of this isotope because of interference in the measurement.14 e thorium-232 (232Th) --- A natural radioisotope with a half-life of 14 billion years.
These results indicate that long-lived radioactive contaminants attributable to reactor operation are not present in cetectable amounts in creek sedi-ments or in soils.
First Phase: Fuel Removal and Packaaing Background. In the first phase of the project, the 111 fuel rods now in-side the Reactor would be removed, packaged appropriately, and shipped by truck to the Idaho National Engineering Laboratory (!.N.E.L.), a DOE f acili-ty about 50 miles from Idaho Falls, Idaho, as described below. These rodr.,
PROJECT DESCR!pTION weighing a total of about 830 lbs, would be transported in three approxi-mately equal shipments spaced a week to ten days apart.
UC proposes to schedule fuel removal after 15 November 1988. Fuel shipment would be completed before decommissioning begins.
The thermal design requirements of the BMI-1 cask 15 dictate a minimum fuel cooling period of 90 days from Reactor shutdown, based on a high level of Initiation of the project after fuel use which the Reactor did not have.
15 November 1988 would result in an actual cooling period of over ten nonths.
Nine unused fuel rods, now stored in a storage structure in Room 1140, would be shipped to UC Irvine or to 00E for use in another research reactor.16 Such shipment is permitted under the NRC Reactor Operating License. Each rod would be packaged separately, labeled and shipped in a performance-test-ed Type At container, in accordance with 00T regulations 49 CFR 173.415.17 These rods generate no radiation detectable by a geiger counter 18 at a dis-tance of 3 ft.
Defuelino Steos. The used fuel rods are kept submerged in the Reactor pool for shielding. While still under water, they would be transferred 3 at a time to a lead-lined transfer cask using remotely-operated tools and equip-ment.
The transfer cask would then be moved over to and inside a water-filled shipping cask which would not be removed from the truck on which it arrived.
The rods would thus be shielded uninterruptedly. The transfer cask would be lifted out once the rods were released inside the shipping cask. Radia.
f PA0 JECT DESCRIPTION '
i
)
i tion levels of the lvaded transfer cask would be monitored periodically during repeated trips of the transfer cask. ;
l I
, t When the shipping cask is full with 36 to 38 rods, the water would be l drained and the cask sealed. The drained water would be treated, if j
l i necessary, and disposed of by the methods for pool water, as described :
on pp. 28 and 29. Radiation levels near the surface of the loaded shipping l cask would be monitored. >
i The sane truck and cask would be used for 3 successive trips to the 1.N.E.1..
in order to remove all the fuel. The cask, designated as BMI-1, is a high- l f l I integrity Type Bt container designed fnr the transport of high-level radio-f l
active waste (more highly radioactive than the Reactor fuel rods) and 11- r 4
censed by the NRC under the provisions of 10 CFR 71. As a condition of 1
licensing, the capability of the B'il-1 cask to prevent loss of contents in !
l f f
the event of a severe accident has been verified via computer modeling in i i compliance with NRC test standards in 10 CFR 71.73 (see p. 39 for further f f i discussion of the test standards). The cylindrical cask metsures about 6 !
f t. tall and almost 3 f t. in diameter (see Fig. 6, p.15), weighs nearly 12 l l
! tons when carrying its maximum weight contents of 1800 lbs., and is lined j with 7.75 inches of lead sandwiched between two concentric layers of stain.
d h 1ess steel.15 l
l The empty cask would be shipped from Tuxedo, NY, on a 40-ft. truck fron l
which it would be transferred at a Tri-State Motor (the firm that would (
l truck the fuel rods) terminal in Tracy, CA, to a 20- to 24-ft. truck ca-pable of fitting inside Room 1140 of Etcheverry Hall. The smaller truck would be used for fuel shipments because of greater maneuverability on
' Berkeley streets and to avoid having to load fuel outside Room 1140.
-14
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' PROJECT DESCRIPTION l d
i Fuel Rod Disposition. Once the loading of fuel has been completed, the l 1
truck carrying the loaded cask would travel to Idaho via a route described i on p. 19. Upon arrival at 1.N.E.L., the fuel rods would return to the j custody of DOE (the Atomic Energy Commission, a predecessor of DOE, origi-nally loaned the rods to UC). In accordance with elaborate safety proce-l i dures,1 DOE would store the fuel rods under water 19 to await disposition, such as reprocessing (see below) or permanent disposal at another location.
l The option of reuse without reprocessing, while technically possible, is not within DOE's mission.20 UC has no legal authority or control over the J ultimate disposition of these rods.
The fuel rods are composed of a mixture of uranium and a nonradioactive j moderatort, zirconium hydride (8.5% and 91.5% respectively, by weight), en- !
j l
i t 1 cased in stainless steel. This uranium is enriched less than 20% in urant- !
i um-235(235). U Uranium enrichment is the process of increasing the propor.
tien of the fissionablet isotope, 235 0 , relative to the less fissionable l s
23SU , over that found in naturally occurring uranium. The natural level of l
] t 235U in uranium is 0.71%. The less-than-20% enrichment level in these fuel
- rods is higher than the 2-4% enrichment of most power plant fuel but lower 1
) than the 80 or 90% level used in some research reactors.
i Uranium becomes valuable as a source material for weapons at a high level of 1 enrichment (greater than about 90%)21 which is required to provide the crit-1 i ical r. ass necessary for a nuclear explosion. At an enrichmen t level of
! less than 20%, use of uranium from spent fuel for weapons manufacture would j not be possible without both reprocessing (removal of the steel casing, separation of the uranium from the moderator and fission products) and further enrichment. DOE will decide whether to complete the design for a PROJECT DESCRIPTION reprocessing method for TRIGA fuel in Fiscal Year 1990.1 There is currently no operable method for reprocessing TRIGA fuel for weapons or any other use.1 During Reactor operation some of the 238U is converted to plutonium-239 (239P u), a fissionable isotope of an element which can be used for reactor and weapons purposes. However, the plutonium in the Reactor core would not be conducive to weapons manufacture because of the small amount present
) (0.06 lbs. 22 compared to 9 to 18 lbs. of plutonium, depending on the iso-topic composition of the element, required to make a plutonium bomb 23).
Even if these processes were technically more feasible, the plutonium in the Reactor fuel rods could not be used for weapons purposes under current 4
law because an amendment to Section 57 of the Atomic Energy Act (Public Law
^
95-415,1983) prohibits the transfer or reprocessing of special nuclear ma-
' terialst produced in research reactors for use in the production of weapons.
Security for Fuel Shipnent
! The hRC classifies shipnents of spent fuel or other special nuclear materi-al as security risks of low, nediun or high strategic significance (value l
for w,Jpons purposes), according to the level of enrichment of uranium, the quantity of c:sterial, and other factors. NRC regulation in 10 CFR 73 require
! appropriate security precautions depending on the classification of the shi pment. For example, armed vehicle escorts are required along the entire route for a shipment of weapons, which have high strategic signf ficance, but not for sone shipments of low significance. Reactor fuel rods are con.
J sidered special nuclear material of low stategic significance under 10 CFR 73.2 (see Table 1, p.18 for the classification of these and other materials I with a similar quantity of 235U but different enrichment levels). Because j Reactor rods are spent fuel, additional NRC regulations apply. These I
17
PROJECT DESCRIPTION ,
Table 1. Categories of Uranium Enrichment and
' Their Requireda Security Levels for Transportation Purposes Use Enrichment Level Strategic Sienificance ,
t 20% or more 235U Noderate Researchb ,
less than 20% 235U Low Research (Etcheverry Powerc 24% 235g Low I
- a. Required by 10 CFR 73.2. 7
- b. Research reactors may be fueled by rods of high enrichment levels (80 or 90%) or relatively low levels (less than 20%). The Reactor has ex. j clusively used less.than.00%. enriched rods.
- c. Commercial nuclear power plant fuel rods. j
- d. Shipments must also meet weight requirements for this l chart applies to a shipment of 13gg U, about(g) grams the size of gggh c{
J of a single Reactor fuel shipment. '
i L
Source: 10 CFR 73, adapted by Bendix Environmental Research, Inc. (BERI) l
! i I
requirements, found in 10 CFR 73.37, require that the shipnents be accom.
panied along the entire route by an arved escort in a separate vehicle, (
that an escort be present in the truck, that drivers and escorts be trained l in security and safety procedures, that telephone contact be made every two l 1
hours, and that other precautions be taker.. t Transportation Routes for Shipments of Fuel and Radioactive Debris 1
00T regulations (49 CFR 177.825) require tmat spent fuel be transported via l
) ,
\
i interstate highways except where a state has designated an alternative i
route. No alternative route has been designated in areas relevant to this l
! project. ;
i
-18
__ . _ _ _ _ ._. . _ _ . - - - --_-_ ~ . - __ _ _ _ _ _ - - - - _ - - _.
PROJrci n
, : t10;;
Between interstate highways and t..e cestination or point of departure, fed-eral regulations requiring the most direct route (49 CFR 397) and minimiza-tion of radiological risk (49 CFR 177.825) apply. The California Highway Patrol (CHP) has authority to approve or deny the California segment of the proposed route and normally approves shipments tht 4 comply with the federal o
criteria in 49 CFR 177.825,25 sumarized above.
I With assistance from the Defueling Contractort, UC selected a preferred roJte based on these regulations and informal consultation with the CHP.
A route proposal was submitted to the NRC and the CHP on 9 June 1988.
The proposed route to the nearest interstate highway (I-80) is south along the Etcheverry alley, west on Hearst Ave., south on Oxford St. and west on University Ave. to the I-50 on-ramp (Fig. 7, p. 20).
The NRC recently inspected and approved an interstate route proceeding east from pleasanton via 1-580 and I-5 to I-80 in Sacramento.26 The proposed route from the University Ave.1-80 entrance was selected to minimize the distance from Berkeley to an interstate highway and the pre-apnroved route beginning in Pleasanton26 (Figs. 7 and 8, pp. 20 and 21, show this route).
The 2.5 nile route to I-80 passes through camercial and res;dentiti streets in Berkeley. Beyond the Bay ea, the route passes through areas that are predominantly rural or dotted with small towns, with the exception of Sacramento, CA, Reno, NV, and Salt Lake City, UT.
For security reasons, NRC regulations in 10 CFR 73.21 prohibit UC from no-tifying the public of the date of fuel shipment until 10 days af ter comple-tion of the shipments.
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Figure 7. Route for Fuel Shipment from U.C. Campus to Major Highway g we e... r- i a....,en irse s
_ a- _ ____ __ _ ___ _ _ _ _ _ _ _ _ _ _ _
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Figure 8. Tentative Route for Shipment of Fuel to Idaho
PROXCT DESCRIPTIO."
Second Phase: Decomissioning In the second phase of the project, the material made radioactive by prox-imity to the fuel during Reactor operation would be removed and shipped to disposal sites. The rotary specinen rack, the core shroud, portions of the aluminum pool liner, parts of the reinforced concrete monolith surrounding
! the reactor pool and slightly contaminated concrete dust, metal chips, plas. 1 f
tic and rags would be included in these shipments. Nonradioactive debris would also be removed in this phase, j
The Decommissioning Plan for the Reactor proposes removal of radioactive materials down to levels which would permit release of the site for unre.
stricted use, as defined in NRC Regulatory Guide 1.86 Par; C, Paragraph 2c, "Removal of Radioactive Components and Dismantling." In addition to meet-Ing the standards for maximum acceptable levels of surf ace contanination presented in Table 1 of Regulatory Guide 1.86, UC would also be required to meet a standard for external gamat radiation frem surf ace end subsurf ace radioactive materials. The Occomissioning Plan comits UC not to exceed a I
limit of 5 microremt per hour above background for external gama radia-tinn at a distance of 3.28 ft. (1 m) from any surface.
The NRC establishes this limit on a case by case basis. For other research reactors decommissioned in California, NRC has used a limit of 5 nicrorem per br. above background at 3.28 ft.27 The sane limit is expected to be applied to the Reactor.27 This limit is based on a goal of restricting the annual radiation dose to the nost exposed individual to 10 milliremt (mren) above background (the nost exposed individual is assumed to work at a dis-tance of 3 ft. from the most radioactive surface for an average work year of 40 hrs. per week, 50 weeks per yr.). The limit is nore protective than 22-
PROJECT DESCR!pTION the EPA standard of 25 mrem per yr, as the maximum whole body dose for members of the public exposed to emissions from NRC-licensed facilities (40 CF R 61.102).
If one million persons were exposed to that level for an ;
averge work year (as defined above), the 5-mir.rorem-per-hr. limit could result in a risk of 1 to 2 cancer deaths among this exposed population, j i
UC may chcose, conditional on the approval of the California Department of Health Services (DHS), not to decontaminate and remove certain pieces of l equipment, such as the two chemical hoods in Room 1140. Because the Depart-ment of Nuclear Engineering plans to cont nue its existing non-Reactor. i related uses of radioactive materials in this room after cecommissioning, The DHS and the NRC have agreed in I the hoods would still be necessery.
i principle that jurisdiction over these hoods could be transferred to the i existing California DHS Radioactive Materials License #1333-62 (for posses-sion and use of radioactive materials) once the current NRC Reactor Jperat-ing License has been terminated.28 i
l Af ter all fuel rods have been removed, the Decommissioning Contractort would set up a temporary office and emergency decontamination facilities, connect temporary utilities, provide employee health and safety training, and make l l
other preparations for decommissioning. l t
The contractor would then install a set of barriers (see Fig. 9, p. 24 for I
location of barriers) to separate the decomissioning area of Room 1140 t from the rest of the room where research activities would continue during (
decomissioning. This metal-frame, sheet-rock and heavy-duty plastic bar- f rier would confine airborne radioactive particles and control the movement f The exhaust from Room 1140 is filtered through high efficien- [
of personnel. i cy particulate air (HEPA ) filters.
t The room is equipped with several con- ;
?
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CHANGE ROON TRAILER 15.2 (S0'I ~ TEMRORRRY CONFINENENT p.CrFiCE NvctE
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LRsonATCRv ENGINEERING g,j .- /
"*C"c?'E ss
' j \, - LRB - (,,[p #1/j :
i(EP'0UARY ROOM 1107 3 7,* 9 6. 7m 3a -CONr!NEMENT BRRRIER aEsgl: 1 s
', 'i s ei.e. tri , aee- e
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\ RPCt1 1109 ROOM i108 # LCOMPUTEA ROCH I1C6 hhhbt[
s10AEROOM
___m e:! !- .......... Bound.ry oi Decommissionity Are.
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Figure 9, Boundary of Decommissioning Area source: x.is.,eno,n..,..noe.no,.en..oam.nt.:R._. g o _
.se.
PROJECT DESCRIPTION tinuous radiation alarms, one of which automatically switches.the ventila-tion system to emergency mode for additional filtration through an activated charcoal filter. All existing filtration and alarm systems would be re-
-ined throughout decommissioning.
A second barrier would be built across the top of the Reactor to seal off the Reactor structure and exposure room area (see insert, Fig. 9, p. 24),
where the demolition of radioactive materials would take place. The con-tractor would cover all potential air leakage points with plastic sheets and install a fan and HEPA filter system to exhaust filtered air f. . n this structure into Room 1140. The fan would create negative pressure inside the Reactor structure so that air would leak into rather L.ian out of this structure, minimizing the spread of radioactive or other dust. Thus, air from the area containing the most radioactive materials would pass through both the new filter and the existing filter bank before being exhausted from Room 1140.
Before dismantling begins, the pool water would be analyzed for radioactive i isotopes, treated, f f necessary, and discharged into the sanitary sewer vhen it meets NkC limits in 10 CFR 20.30] Appendix B and applicable EPA l
standards.
The Executive Engineert, with assistance from the UC 3eactor health physi-cist, would perform an initial radiation surve, ;o determine the 1ccation f of contaminated portions of the decommissioning area (see Fig. 9, p. 24 for the proposed boundaries of the decommissioning drea, subject to NRC j
f approval). The Reactor components and pool liner would then be removed, disassembled and placed in containers for shipping. 9f t faces would be decontaminated, if necessary, using materials that minimize the generation
PROJECT DESCRIPTION of chemically hazardous waste. Radioactive concrete wculd be removed, packaged and stored in the 2-story Room 1140.
On the basis of prior TRIGA reactor decommissionings, al', activated ma-terials are expected to be classified as low specific activity (LSA)t waste for shipping purposes. In the early stages of dismantling, the appropriate-ness of this classification for the most radioactive reactor parts would be verified through radioisotope analysis. Appropriate packaging for these materials is discussed on pp. 38 to 41.
Towards the end of the 6-week demolition period this material would be hauled away by 1 or 2 trucks in 10 to 15 trips over a 2-week period. The material would be trucked through Berkeley (see Fig. 7, p. 20) to a dispo-sal site in Beatty, NV, Hanford, WA or Barnwell, SC. The Decommissioning l Contractor would select a site based on distance, scheduling requirements and availability of space in a facility.
Dismantling of nonradioactive material would begin after the removal of all radioactive material and completion of a termination radiation survey re-quired by the NRC. Shipment of this material would be completed in 35-40 l
trips over a period of 6 weeks. The termination survey would be performed l
l by UC staff, with the assistance of the Executive Engineer, and repeated for confirmation by NRC contractors.
l t
UC is coordinating security and emergency planning activities for the I
project with City of Berkeley emergency services staff.
1 The entire process of removing fuel rods and decommissioning including NRC review and surveillance, is expected to take about one year from the start of fuel removal.
SAFETY ISSUES Hazardous Materials Two types of radioactive materiais would be involved in the proposed pro-ject: 1) the 111 used fuel rods, which contain the most radioactive mate-rials in the Reactor; and 2', reactor parts, concrete, and cther materials that have become radioactive from exposure to fuel rods during operation of-the Reactor. No radioactive gases are expected to be released from the rods or other materials.
The fuel gives off little radiation before use in the Reactor (radiation levels of the unused fuel cannot be detected with a geiger counter at a i
distance of 3 ft. f rom these rods 18). During operation of the Reactor a forms of many other portion of the uranium is converted to radioactive elements, called fission products, which make the rods radioactively "hot".
Th9 radioactivity of the rods continues to increase af ter first use in the 1
Reactor as the amount of fission products increases.
Once the Reactor has been shut down, the fuel stops fissioning. Decay of fission products in the period following shutdown decreases the total Between 23 December 1987, amount of radioactivity remaining in the rods.
the shutdown date, and 15 November 1988, the earliest date the fuel could be removed, the decay of fission products will result in a decrease of over 99% in the radioactivity of an average rod.29 The activity 29 of radioiodine, the isotope of most concern in short-term exposures because of its ability to concentrate in the thyroid, will be reduced by a f actor of 400,000,000 in the fuel rods between shutdown and 15 November 1988.29 The health hazard associated with short-term exposure 27
SAFETY ISSUES to the fuel rods would thus be greatly reduced between Reactor shutdown and the start of defueling.
The most radioactive reactor parts (the core shroud an the rotary specimen rackt , the parts in closest proximity to the fuel) were estimated to pro-duce about one tenth as much radiation as the unshielded irradiated fuel f five months after shutdown.30 The breaking and scraping of concrete during demolition activities would produce radioactive concrete dust that emits one one-thousaridth as much radiation as that emitted by the most radioactive reactor parts. Exposure P
to direct radiation from this dust is expected to be minimal. Workers will be protected from inhalation of radioactive dust. r Fine dusts and metal aerosols could be generated if metal parts (for in-stance, the rotary specimen rack) must be cut by grinding or burning. l These methods are not expected to be necessary because alternatives, such as packaging the parts whole in sufficiently large packages, would be pursued. According to the Executive Engineer, the rotary specimen rack, a donut-shaped piece of equipment measuring about 40 inches in diameter by about 24 in. high, would be shipped uncut in a single package.31 The Reactor pool water is run through a filter to remove particles and l l
[
through a deionizer to remova metal ions that could have become radioactive from Reactor operations. Pre /ious monitoring of this water indicates the presence of no radioactive materials in excess of existing stringent stand-Before disposal in the sanitary sewer, the water would be analyzed !
ards.32 for radioactive isotopes. If found to be contaminated with radioactive
. l SAFETY ISSUES materials it would be treated to meet NRC requirements in 10 CFR 20.303 and applicable EPA standards.
l Other radioactive liquids could be generated by decontamination of surfaces ,
in Room 1140 to remove radioactive materials, by use of water in the fuel transfer process and by water misting for dust control. Such liquids would be treated and disposed of in the sanitary sewer or cleaned up with absorb-ent naterials and disposed of with low-level radioactiv? wastes. The decom-missioning contractor would avoid to the extent possible the use of decontam- ,
inants, such as organic solvents, that produce chemically hazardous waste.33 Exposure Reduction Measures. The irradiated fuel rods would be shielded at all times by water (while in the Reactor pool and during the' loading, of the shipping cask) or lead (while in the transfer or shipping cask) to minimi'ze human exposure to the radiation they emit. However, radiation exposure to workers during defueling cannot be entirely eliminated.
Worker exposure to direct radiation from the irradiated reactor parts would be controlled by: (1) use of remotely operated tools and equipment in the handling of these parts to maximize the distance between the worker and the parts; and (2) restriction of the length of tirre any single worker may spend close enough to be exposed.
With implementation of measures including water misting of dust, use of respirators, training of workers in radiation pro'.ection methods, and installation of barriers and air filters radiation exposures to workers and the pub'iic would be kept below NRC limits.
29
l SAFETY ISSUES Radiation Exposure To Workers Potential sources of radiation exposure are: (1) direct radiation from used fuel rods, reactor parts and other activated materials; and (2) radio-activity in concrete dust, which could be inhaled, ingested or absorbed if appropriate precautions were not taken. While the movement of this dust can be controlled, its formation during decommissioning cannot be avoided.
Routine Exposures. The fuel rods would be moved with remotely-operated ,
tools and equipment and would be continuously shielded by water or lead.
With these protections, workers who remove and package fuel would be expected to receive radiation dosest of about 0.05 remt per person maximum during the 1-month period of fuel removal,34 about 4% of the 1.25 rem per 3-month period allowed by 10 CFR 20.101. This limit applies to persons
{
working in restricted areas such as the decommissioning area.
A trucker transporting Reactor fuel could receive a maximum dose of 0.21 rem (one half the total dose for two truckers presented in Table 2, p. 31),
or less than 20% of the permitted dose of 1.25 rem per 3-month period.
These calculations assume that the truck travels at an average speed of 40 miles per hour and that the radiation level of the cask is the maximum level permissable by 00T regulations in 49 CFR 173.441 (2 mrem per hour in the cab and 10 mrem at 6.6 f t from the package (s) outside the cab; see
- p. 52).
The Defueling Contractor, Proto/ Power-Bisco, Inc., estimates that the radiation levels of the fuel cask would be 1/25th of the DOT limit, with the result that actual doses would be lower than those presented in Table 2,
- p. 31.
-30
l
. l SAFETY ISSUES l
Table 2. Calculated Radiation Ooses from Routine Transport of Radioactive Materials (in person rem)a Radi"ion Oose Max Number Total Population of Shipmentsb Dose per GroupC Alternative / Group g jpmenta.c FUEL R00 TRANSPORT 0.011 3 0.033 Onlookers 0.012 General Public 0.004 3 0.015 0.045 Total Public 0.14 3 0.42 Truck Drivers (2) 3 0.009 Garage Workers (2) 0.0033 0.14 0.43 Total Worker Oose NON-FUEL WASTE TRANSPORT 0.0076 15 0.11 Onlooke rs 0.042 0.0028 15 General Public 0.010 0.15 Total Public 1
0.05 15 0.75 Truck Drivers (1) 0.05 Garage Workers (2) 0.0033 15 0.05 0.8 Total Worker Dose TOTAL FROM ALL TRANSPORT 0.025 0.20 Total Public 1.2 Total Worker 0.19 t
0.22 1.4 Grand Total NUREG/CR 1756, Table 12.41; adjusted for travel distance of a.
760 .ni. one way to Hanf ord, Washington, disposal site for non-fuel waste, and 1090 mi. to Idaho Falls, Idaho for fuel rods,
- b. Based on trip calculations, footnote 71.
- c. 00ses based on maximum permitted radiation levels for packages; '
all doses rounded to 2 significant figures.
Source: NUREG/CR-1756, Table 12.4 1, p. N.67 and BER1, August 1988.
31
SAFLTY ISSUES i
The dose of 0.75 rem to a trucker who transports all the LSA waste may over-estimate the dose for trips to Hanford, WA., because this calculation is based on the conservative assumptions that: (1) the radiation level at the surface of the LSA packages would be the maximum permitted by the 00T (10 mrem per hr. at 6.6 ft. from the package surface for packages carried by an open vthicle); (2) the maximum number of truck trips (15) would be required; and (3) the same driver would be used for all shipments. Radiation levels are in fact likely to be below the DOT-permitted level and as few as 10 ,
truck trips may be sufficient (the NRC has estimated that about 4 truck- l loads would be necessary for the decommissioning of a similar reactor 35).
The average per-worker radiation exposure dose from all routine decommis-sioning activities would be approximately 0.3 to 0.5 rem for about 5 months of work (7.7 total person-rem from Table 3 divided by 15 to 25 persons).
The average exposure rate of these workers could be a maximum of 0.3 rem adjusted for a 3-month period. The dose to any individual would not be allowed to exceed the permitted maximum of 1.25 rem per 3-month period for persons in restricted areas and would be kept as low as reasonably achiev-l able. The total dose to all workers for each activity, assuming the partic-l 1pation of 15 to 25 workers (including monitoring personnel), is presented in Table 3, p. 33.
Recent studies suggest that ionizing radiationt is 2 to 3 times more dan-gerous than previously thought.36 The basis for this interpretation is new evidence indicating that the populations of Hiroshima and Nagasaki w m ex-posed to about half the radiation dose assumed earlier 37 (the o r' fer dose estimate served as part of the basis for existing standards). Britain has adopted a lower standard and the International Commission on Radiological
Table 3 Calculated Occupatbnal Radiation Doses Range (b)
Total (a) Exposure Dose Rate Totafc)
Task / Activity Person-hour Person-hours mrom/ hour Person-rem
- 1. Contractor Move-in 412 84 0.2 0.017
- 2. Initial Radiation Survey 144 84 0.2-10 0.19
- 3. Installation of Confinement Barriers 472 354 0.1-0.2 0.068 4 Removal of Reactor Components and 808 606 2-4 1.6 Pool Liner
- 5. Removal of Material with Potential Surface Contamination and Other Activated Equipment 2372 1779 2 3.56
- 6. Cleanup and Removal of Tools and Equipment 1140 855 0.1-2 1.2
- 7. Packaging and Loading of Radioactive Waste 384 288 2 0.58
- 8. Perform Termination Radiation Survey 360 280 0.02 0.004 UC8 Decommissioning Staff 640 480 0.5-1.0 0.36 GRAND TOTAL 6732 4810 7.7(c) a) Based on tasks p son-hour estimates from Decommissioning Plan, b Based on survey data BRR and NUREG/CR-1756.
c Rounded to 2 digits.
SOURCE: Kaiser Engineers (from NUREG/CR 1756) 33
SAFETY ISSUES Protection is considering lowering its recommended standards by a factor of 2 to 3 to maintain the same level of protection.37 Based on the effectiveness of its regulations in 10 CFR 5'J, Appendix I, requiring that exposures be kept as low as reasonably achievable, NRC staff recommended no change in the 5 rem per year dose limit for wor.ker exposure in its 1988 revisions.
The estimated average dose received by a decommissioning contract worker exposed over the planned work period (equivalent to 0.3 rem per 3-month period; see p. 32) would not exceed a limit twice or three times as pro-tective as the existing limit for the maximum exposure of people in re-stricted areas (0.6 and 0.4 rem per 3-month period, respectively).38 The maximum dose for any given worker could exceed the average dose but would be kept as low as reasonably achievable, as required in 10 CFR 50, Appendix 1.
Accident Exposures. Workers could also be exposed to radiation during ac-cidents. Estimates of radiation doses from postulated accidents, along with estimates of the frequency of their occurrence, are presented in Table 4, p. 35. The estimated 50-year committed t dose to the wnole body for the maximally-exposed indi"idual from any of these accidenti is orders of magnitude less than the 50-year committed whole-body dose / rom background radiation in the Bay Area (10 rems, including radon exposure).
Estimates of potential lost time and f atalities due tc decommissioning accidents, based on statistics from similar projects, are presented in Table 5, p. 36.
Table 4 Estimated Occupational Lost. Tim a injuries and Fatalities (a)
Frequency (Accidents /10' person-hours)(b,e) Lost Time Lost Time injuries Fatalities injuries Fatalities Person hours Catsoory of Effort 5.2x10 8
5.2x10-8 2. 2x 10" HeavyConstruction(d) 10.0 4.2x10-2 4.8x10 8 2.6x10-2 1.4x10-*
5.4 3.0x10-8 Light Construction 1.7x10' 3.6x10-8 3.9 x 10" 2.1 2.3x10-1 Operational Support 2.7x10' 1.1x10-8 7. 5x10" (a) NUREG/CR 1756, Table 12.2-12.
(b) Estimatesof person-hours injuries, and fatalities are rounded to two significant figures.
(C) Lost-time injuries and fatality frequencies are from Operation Accidents and194 Radiation Exposure Experiences Within the U.S., AEC (d) Heavy construction invol'es demolition tasks such as removal of piping, equipm and concrete, SOURCE: Kaiser Engeeers (from NUREG/CR 1756) 35
Table 5 Sur-naryof Postulated Accidents and Radiation Doses to the Maximum-Exposed Individual (a) 50-Year Committed Dose Frequency of First-Year Dose (rem) Equivalent (rem)
Accident Occurrence IDI Total Body Lungs Total Body Lungs 4
0xyacetylene 6.3x10-5 1.6x10-'
Explosion Medium 4.4x10-5 1.2x10-'
l 8.4x10-' 2.4x10-' l.2x10-8 3.1x10-'
liEPA Filter failure Low Severe Transportation 8.3x10-'
Accident low 1.3x10-' 4.1x10 l.3x10-'
tow 7.6x10-' 3.9x10~' 7.7x10-' 4.2x10-*
LPG Explosion l Vacuum Filter-Bag 2.2x10-' 5.6x10-*
Rupture Medium 1.5x10-' 4.3x10-*
j I w Minor Transportation 3.2x10-8 2.1x10-5 Accident Low 3.2x10-8 1.0x10-5 I
Accidental Cutting of 3.5x10- 9.1x10-'
Activated Al in Air High 2.4x10- 6.9x10-'
4.0x10-4 NA NA NA Loss-of-Pool Water Low Contaminated Sweeping 5.7x10-i 2 Compound Fire Medium 1.0x10-8 2 5.3x10-"2 1.0x10-ir liigh 4.8x10- l.5x10- 4.9x 10- ' ' 3.2x10-
Combustible Waste Fire (8) NUREG/CR 1756 (Based on Table 12.3-5)
(b) The frequency of occurrence considers not only the probability of the accident but also the probability of an atmospheric release of the calculated magnitude. The frequency of occurrence is listed as "high" if the occurrence of a release of iallar magnitude is >10-2 per year, as "medium" if between 10-2 and 10-5, ,
as "low" if >10-S.
- m. g,6,, Erryneen prom mm 17W e .
F-l SAFETY ISSUES l
l No lost time injuries or f atalities from accidents are expected during the project. Testing of equipment before use, careful planning, training of l
workers, and attention to health and safety requirements are among the measures that would reduce the probability of an accident.
l Risk of Release of Hazardous Substances Accidents inside Room 1140 would not be expected to result in a release of radioactive materials outside its walls because the room has 2-f t thick concrete walls and ceiling, HEPA filter systems, alarms that indicate elevated concentrations of radioactive materials in exhaust, and an emer-gency ventilation mode capable of filtering air through activated carbon filters. At the time of the only unexpected release of radioactivity in the roon no radioactive materials were released outside of the room.
An accidental loss of water in the shipping cask during loadirl of fuel or i
accidental loss of shielding of several fuel elements could cause radiation readings in excess of acceptable levels on the Etcheverry Hall patio. How-ever, these levels would return to normal as soon as shitiding were res-tored, and no release of radioactive materials would result. Only an earthquake of greater magnitude than the largest quake thought to be pos-i sible on the Hayward Fault (magnitude 7.5 on the Richter Scalet ) could cause this structure to collapse.39 Nonetheless, such a collapse has been postulated in the Reactor safety analysis and is discussed in the Earthquake section, p. 63.
Packaging of Radioactive Material. Transportation accidents could result in ' , release of radioactive materials to the environment. The use of appropriate packaging provides protection against hazardous materials re-SAFETY ISSUES leases. The three types of packaging proposed for use in this project are described below.
The used fuel, classified by the NRC as a high-level radioactive material, Most LSA would be shipped in a Type B cask lined with 7.75 inches of lead.
radioactive waste, including all the concrete rubble, would be shipped in strong tighti packages, which are sealable metal or wood boxes.
The most radioactive reactor parts would be shipped in a shielded and more substantial package tnan the strong tight box. While the concentration of radioactivity in these parts is low enough to permit their classification
'as LSA radioactive materials, the quantity of radioactivity exceeds the maximum allowed in a strong tight package. These parts would therefore be shipped in an NRC-certified Type A t package shielded with 1.5 to 4 inches of lead equivalent (see p. 44 for Type A packages tests).
Out of 2.8 million packages of radioactive materials shipped yearly in the U.S., 0.1 million, or 3.6%, are Type B containers (about 10% of nationwide shipments of all types occur in California). These packages account for 90.2% of all rtdicactivity transported.40 1
Type A packages (a portion of which are Type A casks) make up 64% of all packages but carry only 8% of the radioactivity. The strong tight packages account for about 0.5 million packages, or 17% of the total and 1.6% of all radioactivity transported.41 To mininize the risk of release of high-level radioactive materials, Type B casks, including the BMI 1 cask proposed for use in this project, are The standard designed to meet the NRC design standards described below.
tests simulate the conditions of the most severe credible events from
'I SAFETY ISSUES commonly occurring accidents, such as punctures, collisions and fires.
' based on a National Academy of Sciences Connittee's recommendations.42 The f standard tests are: ,
e a 30 ft. free drop onto a flat, unyielding surface; e a free drop of over 40 inches onto a 6-inch diameter vertical steel .
- bar; i
l, e thermal exposure at 1,475'F for 30 minutes; r
l' o 8-hr. immersion in 3 feet of wattr; and i
. innersion under 60 ft. of water for 8 hrs.43 '
1 i The cask itself is not dropped or burned to demonstrate compliance with f
! I Instead, the cask is tested via computer modeling. Com-test standards. !
1 j puter modeled versions of the first four tests are performed sequentially {
on the same hypothetical cask to determine the cumulative effects of sev- l
^
eral stresses on one package.
a A 30-ft. drop onto an unyielding surf ace is equivalent to a crash at 30 miles per hour (mph) into an unyielding barrier, a crash of 39 to 42 mph f into a concrets wall,44 or a crash at higher speeds into more yielding sur- f l i 4
f l
faces. In an actual crash, energy would be absorbed by the trailer, the h j
I crushing of the truck cab and the breaking of tie down devices, as well as I by objects in the path, lessening the damage to the cask. l 5
i i
Critics of the NRC standards charge that the basis for establishing test standards--data on accident severity and on the frequency of accidents of a l '
f given severity--are not accurate or complete enough to permit adequate I
definition of severity limits.45 They also argue that cost-based compro-l nises are built into the test standards and that regulators underestimate l [
l f
! l 1
_l
SAFETY ISSUES t
the role of human error in cask production, spending most of their ifmited time reviewing computer simulation results rather than inspecting casks.46 An evaluation of the validity of specific criticisms of cask testing methods is beyond the scope of this report. A brief review indicates that, while these claims draw attention to important issues, they do not bring the safety of this project into question. The general conclusion of the crit-ics that transporters should not rely on packaging alone to assure safety but should carry out adequate emergency planning is fully supported by UC and other emergency services personnel involved in this project. The development and testing of emergency procedures specific to the needs of this project and the tiered response capability of local, state and federal response teams address this concern. physical tests on real casks, describ-ed below, indicate that casks maintain integrity under conditions more severe than those tested via computer simulations.
In the mid-1970's, Sandia Laboratories conducted a series of tests on retired casks to verify computer modeling results.47 A 125-minute exposure of a cask to a fire after an 80 mph crash into concrete produced a crack about the thickness of a dollar bill, through which molten lead but no radioactive materials escaped.
A truck loaded with a cask was crashed into a concrete wall at 61 mph with no effect on the cask. Another cask, crashed at 84 mph, was deformed as predicted by modeling, but released no simulated radioactive materials.
A locomotive broadsided a cask mounted on a truck at 80 mph, severely damaging the locomotive while slightly denting the cask and causing no release.
SAFETY ISSUES A research reactor fuel cask, dropped f rom a helicopter into the desert, hit the sand at 235 mph, buried itself in 4 ft. of sand, and suffered only paint scratches. It should be noted that the tested casks may vary in design from the BMI-1 but were designed to the same test standards.
Type A packages must be capable of withstanding a water spray test that simulates a 1-hr. exposure to 2 inches of rainfall, a free drop of 1 ft. in the most damaging position, compression of the package by 5 times its weight and the dropping of a 13-lb. vertical bar on the weakest part of the package. NRC-certified Type A casks, such as those proposed for cercain reactor parts in this project, unlike other Type A packages, are more sub-stantial than Type-A boxes, have lead-equivalent shielding, and require a quality assurance plan. All Type A containers must meet the minimal test standards described above.
Strong tight containers must meet a performance standard of no release of radioactive materials during routine transport. Because these boxes hold materials of low radioacti/f ty, they are designed to withstand less severe accident conditions than the casks described above.
Transportation Accident Experience. Both the DOT and the NRC require the reporting of accidents, radiation releases, cheft and other incidents involving radioactive material transport, but the reporting procedures of the two agencies (as specified in 49 CFR 171.15 and 10 CFR 20.402 and 403) differ.48 l A main source of information for this discussion is the Radioactive Materials Incident Report Database,49 which assembles data from state radio-logical control effices as well as 00T and NRC files. Because existing
SAFETY ISSUES data reflect inconsistent and often inadequate reporting methods, conclu-sions should be drawn from the data with caution.
The most common reports describe minor damage to an outer container with no release of contents, wet packages, liquid leaking from a closed trailer, most often from accumulated rain or snow, and erroneous radiation meter readings. Contamination of a cask prior to loading is also reported as an incident. On investigation these incidents are usually found to be harm-less.50 The accident record from 1971, when 00T reporting began, to 1985 confirms that Type B casks have performed in accidents as they were designed to per-form. In a total of 33 accidents (including hignway, rail and air trans-port) there were no cask failures or releases of radioactive materials.50 During the same period about 1,960 Type A packages (including but not limited to casks) were reported in accidents. Eleven of these packages, 0.5% of those in accidents, failed and released their contents.51 About 205 of the strong tight packages shipped during this period were reported to be involved in accidents (because trucks carry multiple numbers of containers, a vehicle accident may affect several packages at once).
This number represents 0.04% of the 480,00041 strong tight packages now shipped yearly and a smaller proportion of those shipped over 14 years.
However, 55 containers (27% of those in accidents) released their contents due to package failure or damage.51 Accidents involving spills of radioactive materials are cordoned off, when necessary, to protect the public. No injuries or deaths were reported fron
- ~
SAFETY ISSUES these accidents.52 Available data do not indicate an rediation exposure to the public.
potential exposures from postulated accidents involving the transportation of radioactive materials are presented below.
Typical Radiation Exposures. Exposure levels discussed in this document can be compared to the average exposure across the U.S. of approximately 300 mrem per year or 0.8 nrem per day from background radiation (radon is the source of an estimated 200 mrem of the annual dose rate)S3; to expo-sures of about 200 mrem per year from background radiation in the Bay Area 54.55 (radon is the source of about 100 mrem of this dose 55); to aver-age per capita exposures of 77 mrem per year in the U.S. fron X-rays 56; and to an average dose of 3 mrem from a round trip flight across the country.57 .
Accident Involvino a Type B Cask. Calculations of exposures due to the re-lease of radioactivity during a Type B cask accident are not provided herein because of the improbability of such a release. Both the breach of a cask and f ailure of the stainless steel surface cladding on the rods would be necessary to produce a release of radioactive materials to the environment. Even if the cask were to crack due to impact in an accident, the relatively soft IcAd would absorb most of the direct impact to the cask and the rods would not be expected to break. The melting point of stain-less steel is 2600'F68 and the technical specifications for the fuel rods indicate that internal pressure would not contribute to cladding failure at a temperature of 1832'F.59 Failure of the cladding in a standard test fire (1475'F for 30 ninutes) is, therefore, improbable.
SAFETY ISSUES Radiation Exposures from Ruoture and Fire involving a Type A Package. The contents of the Type A package would be solid and noncombustible reactor parts that are not likely to become airborne in an accident. If, however, a Type A cask were to rupture and the contents be exposed to fire for 30 minutes, the maximally-exposed individual's 50-yeart committed dose to the lungs would be 0.0027 rem.60 An individual who receives the average background dose in Berkeley (200 e- m) for 50 years is subject to an exposure of about 10 rem from natural sources of radiation.
Risk Reduction Heasures. The risk of on-site accidents and radiation exposures would be minimized through use of experienced and well-trained personnel, maintenance and pre-testing of equipment, attention to safety regulations, implementation of a quality assurance program for the reactor renoval project, and careful planning.
Additional measures that reduce the risk of a transportation accident, such as the use of trained and experienced drivers and escorts, scheduling of fuel shipments to avoid traffic, selection of routes that have been evalu-ated and approved by federal agencies, implementation of a quality control program for the BMI-1 cask and the provision of escort vehicles (including a Berkeley Fire Department punper truck) for fuel shipments would be pro-vided.
Emergency Response Multiple layers of emergency response capability are available at the local, state, and federal levels. The Reactor currently has an emergency response plan which specifies requirements for staff training and procedures for l
SAFETY ISSJES responding to accidents, security threats and other emergencies on site.61 Under this plan the Reactor staff performs drills twice a year simulating emergencies such as terrorist attack, radiation injuries and explosion.
The plan will be in effect until all Reactor-related radioactive materials have been removed.
General Transportation Accident Response and Preparation. If an accident involving radioactive materials were to occur on Berkeley streets, emergency response agencies would provide a tiered response geared to the level of hazard. Berkeley City agencies and UC would respond immediately. Addition-al response capability would be provided by the Radiological Health Branch of California DHS and other state agencies, coordinated by the California l
! Office of Emergency Services (OES).
1 If an accident requires a response beyond State capability, the NRC's emer-l gency response team would respond and the Radiological Assistance Branch of DOE would provide technical assistance and any necessary emergency services, including a decontamination team, radiological monitoring and medical help.62 Other federal agencies would play a supporting role.
l The regional 00E office retains the services of 10 or more contractors, including Lawrence Berkeley and Lawrence Livermore Laboratories, capable of providing radiological response equipment and trained personnel in emergen-cies. The coordination of stato and federal response capability was tested in the field and evaluated in October 1987 via a simulated nuclear power plant accident at Diablo Canyon.63 The CHP or the highway patrol of the affected state would normally respond first to a radiological accident on an interstate highway. In the Califor.
SAFETY ISSUES I
nia case, the CHP would call for assistance from California OES, which ;
alerts OHS and other state agencies, local emergency services and federal ,
agencies, as necessary. High.way Datrols in other states notify some combi- l nation of the state health department, the parties responsible for the f shipment (UC) and federsi agencies. Local fire or police departments may j
be called for immediate assistance in protecting the public. ;
I CHP would provide notification of the route, timing, contact persons and i
other information on the fuel shipments from the Reactor in advance to police chiefs of any city where non-freeway transportation would occur ,
and fire chiefs in districts along the route with populations greater than l
For security reasons, j 15,000, if the chief has requested notification.
CHP reveals scheduling information to first responders (police and fire units expected to arrive first on the scene) only. ,
According to DOT requirements in 49 CFR 172, a truck transporting fuel or f LSA waste would carry shipping papers (also known as a bill of lading) which provide information for contacting the responsible party (UC) and disciose the quantity and type of radioactive materials in the shipment, the activity in curies, the radionuclides that constitute more than 1% of ,
the shipment, the chemical and physical form of the material, the type of labels required, and other infor~ation.
The drivers of trucks transporting radioactive materials carry a list of procedures for notification o.f responsible parties and the highway patrol in case of emergency at any point on the transportation route.
In the unlike-Response . iransportation Accident involving the Fu11 Cask.
ly event that an accident involving the fuel shipments were to occur in SAFETY ISSUES Berkeley, the Berkeley Fire Departmen'., Campus Police and a health physi-cist from the UC Office of Environmental Health and Safety would be present on the scene because they would be members of the escort team. Campus po-lice would immediately notify both the Berkeley Communication Center and the campus dispatch center and take action to control crowds and traffic as necessary. The Berkeley Fire Department would take charge of the scene, with the health physicist pl aying an advisory role. The Communication Center, a combined dispatch system for Berkeley Police, Fire and Emergency liedical Services (EMS), would alert the appropriate City Departments, including Berkeley Health and Human Services (HHS) and, if necessary, Alameda County Office of Emergency Services (Alameda OES).
If the accident were beyond local capabilities, Alameda OES would call the State Office of Emergency Services (Radiological Defense Office), the coordinator at the state level. If the situation were beyond state capabil-ities, the federal National Response Center would be notified (via a 24-hr toll-f ree nunber) and would coordinate disaster response at the federal level.
The campus police vehicle would continue to escort the shipment f rom UC to Idaho Falls, if an accident involving the fuel cask occurred on the interstate, the UC escort would radio or telephone the appropriate high-way patrol and the shi7 ping contractor. The highway patrol would provide traffic control and make sure that the appropriate emergency services personnel were notified.
LSA Accident Response _. The response to a spill of LSA waste outside Room 1140 would follow a similar pattern, according to the severity of the acci-
-47
SAFETY ISSUES dent, except that escorts would not be present in the truck or in accompan-ying vehicles.
To expedite notification of emergency service personnel in the event of an accident on an interstate involving the LSA truck, UC would ensure that the truck is equipped with a Citizens Band (CB) radio. The driver would notify the highway patrol or police via the dedicated emergency frequency.
The UC Office of Environmental Health and Safety would provide assessment and monitoring assistance for any accident in Berkeley (emergency services personnel would immediately notify UC).64 Berkeley Fire and police Departments could respond in 3 minutes or less to any accident occurring between Etcheverry Hall and I-80. The Berkeley Fire Department would take charge of the scene. police would provide traf-fic and crowd control. If the spill were beyond the capabilities of Berke-ley agencies, state and federal assistance would be available as needed.
On-Site Accident Resoonse. If an accidental release of radioactive materi-als occurred inside Room 1140, workers on the project and research staff working in the southwest corner of the room could be exposed. Potential exposures from various types of accidents are listed in Table 5, p. 36.
The probability of all but one of these accidents is estimated by NRC engineers to be low or medium. Based on past decommissioning projects, only combustible waste fires are ranked highly probable (probability great-er than 1% per year; see Table 5, note (b)). The primary source of fuel for such fires, combustible barrier materials of wood and light-weight plastic, have in this case been replaced by me'.al tubes and heavy-duty, fire resistant plastic sheets to minimize the probability of such fires.
SAFETY ISSUES The calculated exposures resulting from any postulated accident would not result in exposures greater than the NRC limit of 1.25 rem per 3-month per-iod for restricted occupational exposure.
If an emergency involving radioactive materials occurred on the UC campus, the Reactor staff would notify campus police and the Office of Environmental Health and Safety. Campus police, who are trained and equipped to handle redical enrgencies, estimate their response time as 3 tn 5 minutes. Other emergency responders referred to on p. 45 would be called subsequently as necessary.
General Carous disaster plan. UC is currently revising its disaster plan and does not expect to complete this process before the Reactor removal projec't begins. Independent of this general process, the Reactor staff has developed procedures to address the major radiological accidents that could potentially occur during this project and has coordinated its response with other campus agencies and City of Berkeley emergency response staff. Revi-sion of the disaster plan is not a prerequisite of a safe response to Reac-tor-related e ergencies.
Accident Insurance. Up to $500 million of the costs of a release of radio-active materials from any project-related accident would be cover ed by insurance provided under NRC Title 10 Part 140, Appendix 9. The Price-Anderson Act of 1957, which provides this coverage, expired in 1987 and was reauthorized in 1988. UC carries a separate insurance policy with Ameri-can Nuclear Insurance Inc. to cover the deductible of $250,000 for Price.
Anderson Act insurance.65 The cost of human health and property damage caused by any Reactor-related radiological accident occurring in Berkeley or en route to storage and disposal sites would be covered by these policies.
SAFETY ISSUES UC recognizes the rich historical and cultural diversity that has developed in the City of Berkeley, and'also recognizes that the value of this diver-sity may not ordinarily be acknowledged in assessing the monetary value of physical propoerty damage to individual buildings or other structures. Ac-cordingly, UC supports the proposition that the unique c;mbination of cul-tural, historical, educational and other features that chara:terize the City should be considered in any calculation of damages in the highly un-likely event that physical damage to any significant number of structures occars as a result of deconmissioning the Reactor.
. Risk Reduction Measures. Procedures have been developed mutually by UC and the City of Berkeley to facilitate a prompt and well-coordinated response to postulated accidents associated with the Reactor removal project, includ-ing transportation emergencies. These procedures address the possibility of the on-site failure of a package loaded with LSA waste, the failt/e of dust confinement barriers, the failure of the crane used to move fuel, ex-posure from strong radiation sources such as a fuel element that accidentally becomes unshielded, or exposure from several rods due to loss of water from an open BMI-1 cask.
The possible consequences of a major earthquake on site, rupture or burning of LSA packages en route, and accidents involving fuel shipments have also been addressed. Reactor ctaff has provided descriptions of these proce-dures to City of Berkeley emergency services and will continue to coordinate with City staff.
The Defueling Decommissioning and Transportation contractors have emer-gency procedures for their specific responsibilities in this project. For example, Tri-State Motor Transit Co., the contractor proposed to transport SAFETY IS3UES the fuel rods, provides its drivers with training and procedures specified in a safety manual. The manual advises drivers about checking their equip-ment before loading and at 2-hour intervals while in transit, about secur-ing the load on the vehicle, about what to do and whom to call in een of an accident, how to report an accident, and how to handle various traffic and mechanical contingencies. Escore in the truck and in separett vehic-les would be trained in advance to handle security threats.
Through the contract bid and award process, UC would require all its con-tractors for this project to provide documentation of emergency procedures for their specific responsibilities and tc, pr2 pare additional procedures when needed.66 Radiation Hazards to Pedestriens and populations along Transport Routes Routine transport of fuel rods and othce radioactive wastes wculd not re-Salt in hazards to local pec3strians or to the general population along the routes, for the reasons described below.
l l
- The DOT sets standards for the level of radiation allowed at the surf ace of l
and at various distances from a vehicle carrying a radioactive load (Table 6,
- p. 52). The maximum radiation level allowed at a distance of 6.6 ft. from the sides of a fuel cask or the sides of a truck carrying packages of LSA radioactive waste is 10 mrem per hr. All shipments of radioactive material from the Reactor would comply with this standard.
The Defueling Contractor estimates the actual radiation level of a cask loaded with the Reactor fuel rods to be 0.4 mren/hr. at 6.6 f t fram the cask surf ace, or about 1/25th of the 007 limit used in this report. This SAFETY ISSUES ,
e Table 6. Exposure Limits for Fxclusive-Use Transport r" :
High Level and LSA Radioactive Materials l DOT requires that external radiation levels must not exceed:
- at package s". ce: 1000 mrem /hr (in closed vehicle only) 200 mrem /hr(inopenvehicle) c
- at outer surfaces of vehicle: ;
200 mrem /hr o at 6.6 ft from sides of vehicle: ,
10 mrem /hr e in occupied area of vehicle: ;
2 mrem /hr :
~
Source: DOT Regulations in 49 CFR 173.441, adapted by BERI i
- estimate is bash on calculations of fuel rod radioactivity and the attenu- ;
ation provided by the cask lining.
4 I
The total estimated population dose of radiation to the public from the shipment of all LSA waste is 0.15 person-rem, compared to 0.045 erson- !
3 rem from the shipment of all fuel rods.
1 If a truck carrying a load of radioactive materials with the maximum per- I mitted level of radiation, moving at a speed of 10 miles per hour (mph), ,
passed a pedestrian standing 20 ft. away with no intervening barriers, the ,
pede:,trian would receive a whole body exposure of approximately 0.0018 i i
mren This dose corresponds to the dose from about 5 minutes of the average year?y exposure to natural background radiation in the Bay Area (200 nrem per , rear). The same pec' strian exposed to all of the radioactive materials i
1 t 4 SAFETY ISSUES i !
. shipments expected for this project (3 fuel shipments plus 10 to 15 LSA i
shipments sum to a maximum of 18 loads) could receive about v 03 mren, t or the equivalent of about one and a htif hours of the local yearly back-i ground radiation dose. .
i Maximum radiation exposure of a pedestrian f rom routine transport could occur if a truck with the DOT-permitted level of radiation stopped for a traffic light for two minutes 67 about 20 ft. away from a pedestrian. The
^
pedestrian would receive a whole body dose of about 0.05 mrem, which corre- ,
sponds to about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 20 minutes of the yearly natural background l '
]
dose in the Bay Area and is 0.05% of the radiation dose from a t; pical a
I chest X-ray exam of 108 mrem.68
) :
i j pedestrians passing near Etcheverry Hall during fuel packaging activities j i woL1d not be exposed to radiation because all packaging of radioactive ma- !
)
I terials would take place inside Room 1140, protected from pedestrians by t t 2-f t. concrete walls and ceiling, high ef ficiency filters, and other risk f
! reduction measures. Where the 2-ft. wall is penetrated by a door or the !
I horitental tube storage structure, equivalent or greater absorption is provided by the structure itself, distance and/or earth adjacent to the }
t butiding. l l
LSA wastes would be loaded onto the truck in Room 1140 if a 24aoot or j smaller truck is used or outside in the Etcheverry alley if a larger truck !
I is used. UC and its contractor will make a decision on truck si,e. weigh-ing the advantage of fewer trips possible with a larger trun. 'He addi-tional public protection achiesed by loading in Room 1140, and u . potential for site contamination from the truck wheels spreading f.ontaminated dust !
{
SAFETY ISSUES from Room 1140 if the truck is driven into Etcheverry Hall. Oust would be cont olled.
If loaded outside, a forklif t inside Ettneverry Hall would transfer the load at the truck entrance to a second forklift that would remain outside, to avoid the possibility of tracking contaminated dust outdocrs.
People living along the interstate highway system would also be exposed to The NRC low levels of radiation from trucks carrying radioactive cargo.
used models to estimate the average dose to people living within 50 miles of a route, assuming that radiation reaches t' e maximum levels allowed by DOT.69 Expected radiation doses have been calculated (see Table 2, p. 31) using this average dose, for: (1) the populatici living along the route for fuel rod transport to Idaho Falls and (2) the population living along the route to Hanford, Washington (the further of the two possible westira states destinations for LSA radioactive haste; shipment to South Carolina would result in LSA shipment exposures that are about three times as high).
l This exposure estimate includes the average exposure of people in Berkeley.
The NRC's model for dose estimation assumes that the treck passes about 100 l
I
' ft. from the maximally-exposed individual, that the popu'.ation density along the transportation corridor is 311 persons / square mile, and that the truck maintains a speed of 40 miles per hour.35 of the route, NRC assumptions could be considered conservative for most which is rural. The population density through Placer County, CA (70 mi of ti;e route), for instance., is 96 persons / square mile,70 although popula-tion density tends to be greater along highways. Exposures would be under-estimated by this method for at least 20% of the California portion of the route because of population densities of 900 to 1400 persons / square mile 70 SAFETY ISSUES in Alameda, Contra Costa and S?cramento Counties. At 1400 persons / square mile, the total exposure would be 4.5 times greater than at 311 persons /
square mile. Population exposures for the entire route would be about 20%
lower than those given in Teble 2, p. 31, if the non-fuel waste were trans-ported 600 miles to Beatty, NV, instead of 760 miles to Hanford, WA., and about four times higher if the waste were shipped to Barnwell, SC.
No cancers would be expected to be caused by the project. The total pop-ulation exposure dose of 0.2 person-rem from project shipments (see Table 2, p. 31) could cause a risk of 0.00002 to 0.00004 cancer fatalities in the entire exposed population.71 If one assumes, conservatively, that the same individuals are exrosed to both the LSA and fuel shipments and that 300,000 people are exp& sed (300 people per mile for 1000 miles), the cancer risk per person would be 5 orders of magnitude smaller than that given above.
Risk Reduction Measures Numerous measures have been developed to reduce radiation risk to the public during fuel and waste transportation. The most significant poten-t'.41 source is the fuel which will be contained in a cask designed for mate-rials with higher levels of radiation than those of the fuel rods. The low level waste containers and monitoring program will be controlled through the Emergency Preparedness procedures being implemented with the cooperation of the City of Berkeley.
Potential Pollutants Radioactive and non-radioactive concrete dust would be generated by demoli-tion activities. Radiation doses to the maxinally-exposed member of the public and to the population residing or working sithin 50 miles of the
SAFETY ISSUES site were calculated by the NRC for the demolition of e TRIGA research reac-tor of similar size and type in Corvallis, Oregon.72 The radiation exposure pathways considered in that calculation are direct external exposure, inhal-ation, and ingestion of food products. Direct exposure from transportation activities is expected to be the principal source of public exposure ano inhalation is considered the most likely pathway for exposure from demoli-tion activities.
Air Quality. Both the first-year dose and the 50-year committed dose (the i
cumulative dose received over a 50-year period from radionuclides inhaled or ingested during a 1-year exposure and retained in the body) have been calculated for total body exposure and for exposure to the most affected organ, the lungs. Table 7, below, presents those estimates, adjusted for the population density of the Bay Area.
i Table 7. Calculated Radiation Doses From Atmospheric Releases c
During Routine Decommissioning and Fuel Rod Removal Tasks 8e First-Year Dose Fifty-Year Committed (mrem) Dose Equivalent (mrem)
Total Body Lungs Total Body Lungs itaximum-exposed 0.00000016 0.00000057 0.0000003 0.0000013 Individual General
! Populationb 0.00013 0.00061 0.00026 0.0018
- a. Sources: NUREG/CR-1756, V.1 (Tables 12.3-1 and 12.3-2) and V.2, Section N; Kaisar Engineers, Environmental Report for the Triga Mark !!!. Adapted by Bendia Environmental Research, Inc.
- b. Doses are calculated to a population of 4.5 million people resid-ing in a 50 mile radius of the Reactor.
- c. Dose calculations are based on estimated releases for operations listed in NUREG/CR-1756 V.2. Table N.2 4. preparation and shipment o' spent fuel as well as all major decommissioning tasks involving radioacivity releases are included in this task list. Release estimates assume use of HEPA filters.
SAFETY ISSUES Exposure of the public due to routina activities would be orders of magni-tude less than the 25 mrem per year dose specified in epa regulations (40 CFR 61.102) for protection of the public. In addition to complying with standards for effluent releases, project activities would have to comply with NRC regulations in 10 CFR 50, Appendix 1, requiring that expo-sures be kept as low as reasonably achievable (ALARA). Public exposure to radiation from releases of radioactive concrete dust to the atmosphere would be kept as low as reasonably achievable by procedures, such as water misting, and engineering controls, such as HEPA filters and negative venti-lation pressure within the Reactor structure.
Soil and Water Quality. Decomnissioning activities could cause contamina-tion of the surrounding site if exhaust air monitors or filters should malfunction, if packages, outgoing foot traffic or truck wheels should be contaninated by radioactive dust, or if containers of radioactive material should be accidentally broken. Testing of equipment and monitoring of radiation levels of packages would minimize the probability of such acci-dents. Security provisions would minimize the possibility of contamination by a saboteur. Additional sampling and analysis would be performed by UC staff or the Executive Engineer and confirmed by the NRC prior to release of the site for unrestri;ted use, as described on p. 8-6 of the Decommis-sioning Plan, to identify any such contaminated areas for remediation and to identify procedural failures leading to the contamination.
If pool water or other liquids are found to be contaminated, they would be ,
treated and disposed of as described on p. 28. l The BMI-1 cask is designed to withstand accident conditions and would not be expected to break in a najor highway accident, if radioactive materials 1 .. ..
- SAFETY ISSUES t
were released in an accident involving LSA radioactive waste, the reactor !
i parts and large chunks of concrete would be insoluble and too heavy to
. c contaminate surface water via freeway drainage. If dust from broken pack-4 ages became air- or water-borne 3 the radioactivity in the total amount of l, dust that could be present in one truckload is expected to be lown than concentrations in air or water allowed for the dominant isotopes (for i
I example, cobalt-60) at the edge of a restricted area by NRC regulations in 1
l Any spill in transit would be promptly contained, cleaned up, and the area <
)
s i decontaminated. The 3-minutes-o -less response time for emergency services j 1
s along the Berkeley portion of the preferred route minimizes the possibility j l .
of spreading contamination on Berkeley streets. :
l
]
- Waste Disposal Capacity I
The NRC's Final Generic EIS on Decommissioning of Nu: lear facilities 73 i (hereafter, EIS) considers the commitment of a small amount of land for waste burial to be the major environmental impact of decommissioning. The i I
l l
EIS notes that this impact is mitigable and that NRC regulation 10 CFR 61 {
governs the disposal of low-level radioactive waste. l f l5 This report considers the availability of disposal space for this project.
1 A discussion of the impacts of radioactive waste disposal at out-of-state ,
i sites is beyond the scope of this report but is addressed generically in Chapter 2 (pp. 2-20 to 2-22) of the EIS.
{ i 1
The fuel rods would not be classed as waste unless DOE should decide against }
j l j future reprocessing of these rods. DOE projects its need for storage space ;
for the next 20 yeari and does not anticipate any space limitation for fuel
- l i
1 . - - - _ - - . - - - - - -
SAFETY ISSUES rods of the type used in the Reactor.1 Although disposal space for LSA waste is limited and carefully controlled, space remains in all three po-tential disposal sites for quantities on the order of 3,000 cubic feet, the amount expected for this project. Space is expected to be available at local solid waste dispossi sites for the up to 15,000 cubic feet of nonradi-eactive waste that would be removed to complete preparation of Room 1140 for a new use.
Other Public Concerns 4
Activities involving the Reactor have been the subject of local campus and community controversy for years.
The City of Berkeley passed a Nuclear Free Ordinance (Measure K) in 1986 that restricts the use of nuclear materials for weapons purposes within the City, calls for the cessation of all reactor operation within 2 years, re-quires reports or other public notice of nuclear activities in Berkeley, requires the City to select the safest route for shipments of weapons and high-level radioactive waste through Berkeley and places other conditions on the use of nuclear materials for weapons purposes.
As a state agency and as an agency doing only unclassified research, UC is exempt from the provisions of the ordinance but will provide full disclosure to the extent permitted by NRC security regulations. UC would comply with Ordinance provisions on waste transportation to the extent the provisions are consistent with NRC, 00T and CHP requirements. UC is providing an opportunity for input on all issues from City of Berkeley representatives, other agencies and members of the public. The Reactor is licensed by the NRC under provisions of the Atomic Energy Act. Federal law preempts city and state statutes if there are differences relevant to licensed activities.
SAFETY ISSUES l
In two public meetings sponsored by UC on 22 February 1988, members of the campus community and residents of Berkeley and Oakland expressed concern l about safety (discussed on pp. 14, 29, 69-81), security (pp. 17, 77), ade-quacy of monitoring (pp. 4,14,73-77), safety aspects of the time of day and route chosen.for fuel shipment (p. 78), and other issues relevant to removing fuel rods and decommissioning. Some citizens recommended that a less-populated route be selected for fuel transport (see p. 2).
At a Berkeley City Council meeting on 17 May 1988, concerns were raised I about the adequacy of emergency and evacuation plans (p. 44), consequences of an accident (p. 34), public notice (p. 46), consideration of alternatives to fuel removal (p. 1), requirements for city services, and adequacy of fire fighter training for the needs of this project (p. 80). These concerns l have been addressed in this document, as indicated, and through specific procedures where po:isible. The potential use of used fuel rods for weapons purposes, which is outside the jurisdiction of UC, is discussed on p.16.
The emergency response issue has been addressed in a Reactor Removal Project !
)
i emergency preparedness document which supplements the existing Reactor 1
1 Staffs of cities along the local transportation route selected may be among the emergency responders if a release of radioactive materials were to occur in a transportation accident. Berkeley City staff, including l fire, police. Health and Human Services and emergency medical services, could be called on in the event of an emergency on site or along the trans-portation route in Berkeley. A Berkeley fire engine would accompany the fuel rod shipments through the Berkeley portion of the route. Berkeley fire fighters have received training in radiological emergency response and monitoring.
- I e . j SAFETY ISSUES UC would coordinate its emergency plans for project activities with City of Berkeley staff, provide additional training, and participate in a joint training exercise to test coordination between UC and City staff in emer-gency situations. UC would also hold a briefing session for City staff prior to the start of the project and notify the Berkeley Communications Center at the start and on completion of the project.
City services could also be needed if Berkeley officials should decide to temporarily close streets during fuel trsnsport.
Permits The BMI-1 cask is licensed by the NRC. NRC regulations in 10 CFR 71.12 allow
'Jel shipment by any licensee (UC holds Reactor Operating License No. R-101) who meets certain conditions. For example, the licensee must have a copy of the license of the shipping cask it proposes to use and obtain NRC ap-proval for a Quality Assurance Plan for the cask. UC has complied with these conditions (approval for the Quality Assurance Plan was received 10 March 198874) and would comply with the terms of the cask license, the Qual.
ity Assurance Plan, and reporting requirements, as specified in 10 CFR 71.
The NRC would therefore allow fuel shipment under the current operating license.
A quality assurance plan similar Q that prepared for the Type B cask would be prepared and approved by the NRC for the Type A cask proposed for ship-ment of the rotary specimen rack and core shroud. An NRC-certified cask is required because the quantity of LSA radioactive material to be shipped exceeds a Type A quantity.
SAFETY ISSUES The proposed transportation route for fuel shipments must comply with 00T regulations and be approved by NRC. The portion of this route in Califor-nia and the scheduling of the shipment must be approved by the CHP. Routes in other states would be handled according to applicable state procedures.
A route plan was submitted to NRC and appropriate state agencies on 9 June 1988.
The Decommissioning Plan, prepared by Kaiser Engineers for UC, must be approved by the NRC before a decommissioning order is issued. The Plan has been submitted to the NRC for review and is available in the Berkeley Main
< Library and UC campus Doe Library. The final Plan would be made available to the public.
Representatives of the City of Berkeley intervened in the NRC's license amendment proceeding (decommissioning requires a change in the facility license of the Reactor) on 12 April 1988 and have been given standing to file contentions in support of their intervention. The City and UC have agreed to a 90-day period during which they will seek informal resolution of the City's concerns.
UC has established and would follow a quality assurance program designed to assure that safety-related fuel removal and decommissioning activities comply with the operating license, all applicable safety codes, standards and regulatory requiremer,ts, and all safety-related reasures identified in this document.75 Tne UC Defueling Contractor would provide advance notice of the fuel ship-ment to CHP representatives (in accordance with 10 CFR 71.97) who, in turn, notify appropriate local agencies. To reduce the risks of theft and sabo-SAFETY ISSUES tage NRC security regulation 10 CFR 73.21 prohibits advance public notice of the fuel rod shipments.76 In its 1988 generic EIS on Decommissioning of Nuclear Facilities, the NRC concludes that environmental impacts of decommissioning are not expected to be significant but that site-specific impacts must be examined for each project. The NRC will conduct a site-specific evaluation based on informa-tion in the Decommissioning Plan and an Environmental Report submitted in January 1988 and on supplementary information solicited after analysis of those reports.
Seismic Hazards The Reactor site is approximately 100 ft. (30 m) west of the trace of the Hayward Fault and about 20 miles east of the San Andreas Fault. The Cali-fornia Division of Mines and Geology defines an active fault as one that has experienced activity within the last 11,000 years, a definition that ap.
plies to both the Hayward and San endreas Faults in the Bay A ea. On the basis of analysis of historic quakes, geologists consider the Hayward Fault to be active and capable of generating an earthquake of Richter magnitude 7 to a maximum of 7.5.39 In 1972 the California legislature enacted the Alquist Priolo Special Stu-dies Zene (SSZ) Act to reduce the hazards of fault rupture to structures near active f aults. The Act established as the SSZ an area ranging from 200 to 660 f t. in width around an active fault trace. The Act requires detailed geologic investigation to identify and map the active traces of a fault within the SSZ and prohibits the building of structures for human occupancy across an active fault trace, defined (unless proven otherwise) r_ __. ____ . _.
SAFETY ISSUES as the area underlying a 50-f t. width around an active fault. The Reactor is near the edge of but not within the SSZ for the Hayward Faalt.77 The probability of an earthquake greater than magnitude 7 on the Richter ,
scalet on the Hayward Fault is 0.5 to 0.7% per year.78 For the San Andreas i Fault, the probability of a similar earthquake is 0.3 to 0.5% per year.78 Assumino a c:xi.wri decommissioning period of 2 years, the probability of a major quake on either fault during decommissioning is 1.4% per 2 years for the Hayward Fault and 1.0% for the San Andreas Fault. The expected period of 'uel removal and demolition activities of 6 months would entail earth-quake probabilities one fourth as great, or a total probability of 0.6% for the two faults.
Because Etcheverry Hall is not located over the fault, there should be no hazard from fault displacement. Nor is the building in the slide zones of the Hayward Fault. The location of the Reactor on the basement level of a building designed to be earthquake resistant and positioned on solid rock rather than fill reduces the likelihood of radioactive material release in case of a major earthquake.79 This position makes it possible to discount the possibility of liquefaction, lurching, or landslide hazards.39 In this setting ground shaking, not rupture, would be expected in a major earthquake.
A 1981 seismugraphic evaluation of Etcheverry Hall concluded that in a major earthquake (7-7.5 Richter magnitude? on the Hayward Fault, damage to the exterior walls would be expected but there would be "virtually no possiblity of collapse".39 The structurd engineer based his opinion on observations of similar structures in che 1971 San Fernando and other earthquakes. Damage to the Reactor due to f alling objects from the upper structure was deemed
-64
SAFETY ISSUES unlikely given tne 90-f t. distance from the Reactor to the building's tower.
Occurrence af an earthquake greater than Richter magnitude 7 during the less-than-three-month period of fuel removal is improbable (maximun 0.37, proba-bility for both faults).
As part of its renewal of the Reactor Operating License in 1979, the NRC evaluated the consequences of an earthquake involving disruption of the Reactor core, broken fuel rods, and breach of the building containment.
The dose to a maximally-exposed member of the public was calculated.80 Release of airborne fission products was expected to cause a dose of 7.5 ren to the thyroid and 0.1 rem to the whole body to an individual standing inside Room 1140 and near its wall. These doses are within the limits given in 10 CFR 100 for the maximun post-accident radiation levels permit-ted at the perimeter of a nuclear f acility, in this case Room 1140 and the patio above.
The radioactivity of materials in Room 1140 has been decreasing since the Reactor was shut down in December 1987 as a result of radioactive decay.
The radioactivity of iodine isotopes, responsible for most of the thyroid The dose, will drop by a f actor of 400 million by 15 November 1988.29 radioactivity of fission products in the fuel rods will drop by a factor of over 100 by that date.61 The po'.ential hazards associated with a release of fission products during the project have thus been greatly reduced compared to the hazards during the period of routine Reactor operation, if it is a:su9ed, contrary to existing studies, that an earthquake of magnitude 7 occurred during denolition and removal of radioactive naterials and the steel-reinforced concrete roof of Room 1140 collapsed, the release 65-
- o SAFETY ISSUES of dust with low levels of radioactivity could result. Under such circum-stances calculations performed by Kaiser Engineers 82 indicate that the concentrations of relevant radionuclides would not exceed the limits spec-ified in 10 CFR 20.103 and Appendix B. Table 1, for airborne radionuclides in restricted areas. Concer.trations of certain isotopes would exc*:d the limits for unrestricted areas (10 CFR 20.106 and Appendix B. Table II) but would not cause a inhalation dose to an individual outside the periphery of Room 1140 and the patio greater than the accident limits specified in 10 CFR 100.
Removal of fuel rods from campus would eliminate any risk of release of fission products from the Reactor to the local environment under future severe earthquake conditions; completion of decommissioning would eliminate the risk of low-level Reactor-related releases.
A major earthquake during transport of radioactive materials could cause The l an accident that resulted in a release of LSA radioactive materials.
l response to such an event would be similar to the response to a traffic accident, described on p. 47. The BMI-1 cask would not be expected to release its contents in the collapse of a freeway overpass or other earth-quake-induced accident.
Traffic Figure 7, p. 20 shows the transportation route for radioactive materials.
Non-radioactive material would probably be trucked over the same route, since it is the most direct route to a freeway.
SAFETY ISSUES The project would generate truck trips to remove 3 types of material:
(1) fuel rods would be removed in 3 trips from Berkeley to Idaho Falls over a 3-week period; (2) nonfuel radioactive waste would be removed in 10 to 15 trips 83 from Berkeley to an out-of-state radioactive waste repository over a
- 2-week period; and (3) nonradioactive waste (mostly concrete) would be removed in 35 to 40 truck trips to a municipal dump, or other selected sites permit-ted for rubble, over a 6-week period.
All truck trips referred to in the traffic discussion are round trips. The shipp1,'q of each type of material would be accomplished with one or two trucks used repeatedly. The project would generate a maximum of 2 trips ,
per day (n Berkeley streets during any phase.
Existing traf fic levels per day on the preferred route are 7,700 vehicles, i
12,400 vehicles, and 28,300 vehicles westbound on Hearst Ave., southbound on Oxford St. and westbound on University Ave., respectively.84 The 2 max-inum daily project truck trips would be less than 0.1'4 of dail/ vehicle traffic on any of those streets, a statistically insignificant increase.
Because project truck trips, other than fuel shipments, would take place i between the hours of 8 am and 4:30 pm, they would not contribute to peak hour 64 traffic at 5-6 pm westbound on Hearst Ave. or at 5-6 pm northbound on Oxford St. Project truck trips could contribute to peaks at 8-9 an east-bound on Hearst Ave., at 8-9 am southbound on Oxford St., and eastbound 8-9 on University Ave at Shattuck Ave. and other central Berkeley intersec-tions.
If both of the daily outbound trips coincided with University Ave. peak hours (2-3 pn westbound near Milvia,1,100 vehicles per hour; 3-4 pm west-t
SAFETY TSSUES bound near San Pablo,1,500 vehicles per hour), they would increase peak hour traffic by less than 0.1%, an insignificant increase.
Fuel transport would be scheduled to avoid rush hours and heavy traffic .
to minimize the risk due to accidents.
i l
i 1
I i
I s
l
PROJECT-SPECIFIC PROCEDURES The following procedures have been incorporated into the project.
~
A. Peasures~ to Reduce Risks from Fuel Removal Hazards to the Public and ~to ~
Workers
- 1. All work involving fuel rods, except for transportation, would be per-formed within Room 1140, which has 2-ft. thick concrete walls and ceiling (2ft. of concrete reduces gamma radiation from typical fission products 1000-fold 84), a ventilation system equipped with HEPA filters with an effi-ciency of at least 99.95% in removing particles of 0.3 microns or larger from air, and a continuous air monitor equipped with a 24-hr. alarm to warn of radioactivity that exceeds acceptable levels, as specified in the Decom-missioning Plan, pp. 3-2 and 3-8. To make fully enclosed fuel loading possible, a 20- to 24-f t. truck capable of fitting inside Room 1140 would be used instead of the 40-f t, truck rzro commonly used to transport the cask (a 40-f t. truck would have to be loaded in the alley next to Etcheverry where there would be lower security and less radiation protection than inside the building), as specified in the Defueling Plan for the Triga Park i 111.91 Leading of LSA waste is addressed in paragraph 16,
- 2. The door to Room 1140 would be locked and access controlled (see mea-sure 36, p. 77), as specified by UC Reactor Security Procedures.
- 3. Trained and experienced personnel would perform fuel removal and packag-ing, as indicated in the Proposal for fuel Removal from the Triga !!!
Reactor at the University of California, Berkeley, November 1987 Proto-Power / Bisco Nuclear, Inc.
PROJECT-SPECIFIC PROCEDURES t i
4 The fuel rods would be placed in a lead-lined transfer cask while the i rods are immersed in the Reactor pool. The transfer cask would be placed l
, I directly into the shipping cask for transfer of fuel from one cask to the l 4
other, providing continuous lead shielding. Remotely-operated tools and ;
equipment would be used to load, move and unload the transfer cask. A drop
. cloth would be placed between the transfer cask and the pool and other sur-faces to collect water that might drip from the cask, as specified in the l
! Defueling Plan, p. 9, and by Proto-Power / Bisco Nuclear, Inc., UC Defueling
) Contractor, 22 Parch 1988. '
- 5. Prior to fuel transfer UC staff or a qualif:ed contractor would main- ,
l' tain and test the Room 1140 crane and ventilation system, calibrate monitor- l i
ing equipment (as indicated in the Defueling Plan, p. 8), and test the radiation alarm system (Reactor License No R-101 Technical Specifications l
) require periodic testing).
1 j 6. Fuel rods would be shipped in a container designed to carry high-level ,
]
nuclear material (of higher radioactivity levels than that of a load of BRR f
! fuel), as indicated in Certificate 5957 for the BMI-1 Shipping Cask and in l 4 ?
I the Defueling Plan, Proto-Power / Bisco Nuclear, Inc. }
I I 7. A Quality Assurance Program would be implemented for the shipping cask f to insure that the cask is maintained, prepared, labeled and monitored cor-1 rectly, as indicated in the Quality Assurance Program for Use of the BM1-1 l
- l l Shipping Container (approved by the NRC on 10 March 1988). UC would comply l with all applicable NRC and DOT regulations governing fuel removal and i l
i shipment, '
i I
l
PROJECT-SPECIFIC PROCEDURES
- 8. The surf ace of the transfer cask will be checked periodically for contanination with radioactive materials and will specifically be checked during transfer of the three potentially damaged fuel rods (see p. 4 for discussion of these rods), as indicated by Proto-Power /Sisco, UC Defueling Contractor, 31 March 1988.
- 9. The loaded shipping cask would be monitored by UC and/or its contractor to assure that radiation levels are below 00T exposure limits at the sur-
- f ace, at 6.6 f t. f rom the cask, and in the truck cab, as required by the Quality Assurance Program for Use of the BMI-1 Shipping Container and 49 CFR 173.443,
- 10. Radioactive cargo would be labeled "radioactive material" on sides, back, and front of the truck, pursuant to 49 CFR 172. The 2-inch high letters (49 CFR 172) would be readable from 50 ft. in either direction, consistent with the intentions of the City of Berkeley.
- 11. Devices to fasten the BMI-1 cask to the truck would be inspected before the truck leaves Etcheverry Hall, as specified in the Checklist for the Quality Assurance Plan for the BMI-1 Cask.
- 12. UC , through its defueling contractor, Proto-Power / Bisco Nuclear,
- Inc., would notify the governor's designee in each state through which the fuel transportation route passes. In California the designee is the CHP, The CHP in turn notifies police chiefs of each city where non freeway trans-portat;en would take place and fire chiefs of cities with a populaticn over 15,000, as reqeired by California Vehicle Code 33002, Div. 14.5.
PROJECT-SPECIFIC PROCEDURES
- 13. UC would provide a briefing session for concerned Berkeley public safety staff before the first fuel shipment and after completion of removal of radioactive material from the Reactor.
B.
Measures to Reduce Risk from Decocynissioning Hazards to Public and
~
~
Workers
- 14. All workers and f requenters of Room 1140 would be trained in radiation safety. Special training, including an orientation program, would be pro-vided for workers, covering topics such as the sources, types and effects of chemically and radiologically hazardous substances; use of personal protective and monitoring equipment; and information on health and safety regulations, as specified in the Decommissioning Plan, pp. 2-2 and 2-3.
- 15. Supervisors of project activities would be trained. As needed, in the following: hazard identification and reduction, emergency procedures, fire protection and prevention, special housekeeping require.ents, material handling techniques, safety procedures and enforcement policy. Records of attendance and level of accomplishment of attendees would be kept to ensure that appropriate awareness and competency have been demonstrated, as speci-fied in the Decommissioning Plan, p. 2-16.
- 16. All deccomissioning tasks invol ving radioactive materials, except transportation and possibly the loading of LSA packages into trucks, would I
be perforced within Room 1140 (see p. 69, il for description of Room 1140),
pursuant to the Deccomissioning plan, pp. 3-2 and 3-8. UC and the De- .
ccomissioning Contractor would determine whether to load LSA packages in the alley or within Room 1140 based on the goals of avoiding site contamin-ation and protecting pubite health. l
- PROJECT-SPECIFIC PROCEDURES
)
- 17. To control radioactive dust during demolition activities, metal framing i and sheets of heavy-duty, fire resistant plastic would be used to cover the s
i top, side entrance and leakage points of the Reactor and exposure room structure (Fig. 9, p. 24), sealing it off from the rest of Room 1140. A o
fan and HEPA filter would be installed and negative pressure maintained in-side the structure, so that air would leak in rather than out. Air fraa the structure would be exhausted into Room 1140, then filternd again before being exhausted from Room 1140, as specified in the Decommissioning Plar:
f- pp. 3-8. 3-9 and 6-3.
1
! A vertical sheet rock wall and sloping roof frame covered with heavy-duty, fire' resistant plastic sheeting would be installed in Room 1140 to shield i
the areas that would continue to be used for laboratory purposes during i
j decccmissioning from radioactive dust, as specified in the Decommissioning 4
' Plan, pp. 3-8, 3 3 and 3-19. Fire resistant metal tubing or other material j would be used for the frame.
I
- 18. Water misting systems would be used to control dust, as specified in f
- the Decommissioninc Plan, p. 6-1.
1 i
- 19. To protect workers from radioactivity and dust exposure, safety equip-ment would be used, including shoe coverings, plasticized coats or cover-j alls, and NIOSH-approved respirators with particle filters, for all activi-ties involving potential contact with airborne radioactive materials, as l
! specified in the Decommissioning Plan, pp. 2-12 to 2-14.
i l 20. Safety personnel would monitor concentrations of radioactivity in air in the Reactor and exposure room structure before entry to determine the f
l
! PROJECT-SPECIFIC PROCEDURES appropriate level of respiratory protection, as specified by Xaiser En-gineers, Executive Engineer for this project, 28 March 1988.
l 21. The air exhaust from Room 1140 would be continuously monitored by de- ,
tectors during fuel removal and decommissioning to maintain releases at the lowest practical level and assure that concentrations of radioactive materi-als in exhaust are below the EPA standard in 40 CFR 61.102, which limits emissions to unrestricted areas to amounts causing a dose equivalent of 25 mrem per year whole body dose to any member of the public, as specified in the Decommissioning Plan, p. 7 3, 3-8 and 40 CFR 61.102, t
- 22. Inspections and audits of health and safety measures (including the status of barricades, signs, hearing protection, and radiation and hazar-dous work permits) would be documented by the Executive Engineer in a Weekly Safety Report to the Decommissioning Project Engineer, as specified in the Decommissioning Plan, p. 2-17.
- 23. Safety equipment, inc* ding hard hats, safety glasses and safety shoes would be used to protect workers from noise and falling or flying objects, as specified in the Decommissioning Plan, pp. 2-19 and 2-21.
- 24. Adequate ventilation and regular breaks, as specified in the Decommis-sioning Plan p. 2-21, would be provided for demolition workers to guard against fatigue induced mistakes.
- 25. Worker exposure to radiation would be monitored by dosimetry t to assure that exposures do not exceed limits established by NRC 10 CFR 20.101, as specified in the Decommissioning Plan, p. 7-1.
I
-74
PROJECT. SPECIFIC PROCEDURES
- 26. Workers directly involved in the dismantling would undergo whole-body counts at the beginning and end of the project to detemine whether radio-active materials were taken in via ingestion, inhalation or absorption and retained in the body during the project.
- 27. Remotely-operated tools and equipment, such as a pneumatic drill for breaking up concrete, would be used to the maximum extent possible. The Decommissioning Contractor would decide whether to use such equipment based on use of the safest and most effective equipment known to the Contractor, as indicated by Kaiser Engineers, the Executive Engineer, 20 April 1988.
- 28. Pool water and other liquid wastes would be monitored, treeted for radioactive contaminants, if necessary, to meet the conditions of 10 CFR 20.303, and discharged to the sanitary sewe r. Amounts of liquid wastes that can be wiped up with absorbant materials would be disposed of with The Decommissioning Plan, p. 6-1, other low-level radioactive wastes.
specifies these disposal methods.
- 29. The Executive Engineer, with assistance from UC staff, would conduct an initial radiation survey, using survey data from UC's ongoing monitoring program and supplemental surveys taken in Room 1140 and in all areas cov-ered by the Reactor Operating license. The purposes of this survey are to detemine the location of radioactive materials in Room 1140, to confirm calculations of how much material will have to be removed, and to establish background levels of radiation in Etcheverry Hall and outside, as specified in the Decommissioning Plan, pp. 3-7 and 3-8.
t
- 30. Nine existing outdoor fixed radiation dosimeters, which have seen used I
to monitor background radiation near or on top of Etcheverry Hall, would con-m
f J PROJECT-SPECIFIC PROCEDURES i i
I i
i tinue to be used outside Etcheverry Hall until one year af ter completion of the termination survey to verify the results of that survey. f
?
- 31. Radiation levels in Room 1140 would be monitored during fuel removal j
, 1 j and decommissioning activities, consistent with the requirements of the ;
l Reactor Operating License No. R 101,' Technical Specifications and Technical !
t Specifications of the Oecommissioning Order. i
- 32. Radiation detectors would be placed in the corridor between Room 1140 4
I and the alley next to Etcheverry Hall to monitor radiation levels in this
]
corrMor during movement of radioactive materials, as indicated by Kaiser I I
- Engineers, 20 April 1988.
S l
- 33. The Executive Engineer, with assistance from UC staff, would conduct f
) a termination radiation survey, including sampling for radiation con-j tamination of plumbing and air ducts, to assure that the requirements of (
4 I NRC Regulatory Guide 1.86 have been met and that radiation has been reduced I i
to the level stipulated by the NRC. The survey would be performed in Room l !
1140, elsewhere in Etcheverry Hall and outside the building, as specified I j in the Deconmissioning Plan, p. 8-1. i i
- 34. The NRC would provide oversight and confirmation of the results of termination monitoring, as required by NRC Regulatory Guide 1.86. ,
f I i 35. As part of the normal UC surveillance of facilities that use radio- !
l l active materials. UC and/or its contractor would verify that the decommis-sioning area is safe for unrestricted use following removal of all nonradio-l active rubble, t
l !
I I
] (
! l
PROJECT-SPECIP!C PROCEDURES
- 36. Security measures for Room 1140 would include, but not be limited to, restricted access, a 24-hr. locked, supervised-entry-only door, and opera-tion of an alarm system connected to a 24-hr. police and emergency response network at any time when reactor staff is not on duty, to reduce the risk of theft or accidental exposure to members of the public, .is required by UC Reactor Security Procedures.
- 37. All decommissioning activities would comply with NRC requirements and other applicable standards and regulations, as specified in the Decommis-sioning Plan, pp. 1 48 to 1-53.
- 38. UC would notify the Berxeley Public Safety Com,nication Center (the City's erergency dispatch center) when demolition of the Reactor is to I begin and when the temination survey determines that all radioactive material has been removed.
- 39. All residences, businesses and institutions within 500 feet of Etche-verry Hall would be notified by hand delivered mail when the dismantling of the Reactor is to begin.
- 40. Qualified representative (s) of 'he City of Berkeley, accompanied by campus staf f, would be given access to P.oom 1140 and the nearby area to t perfom monitoring during decommissioning activities, as long as NRC regu-lations are not violated and monitoring does not interfere with routine ,
project activities.
t
- 41. Fire protection measures, such as the installation of additional smoke [
t detectors and use of fire resistant barriers, would be provided in Room
( 1140 to insure adequate protection under decommissioning conditions. [
j I
.n- i
I i
L PROJECT-SPECIFIC PROCEDURES
+
f I
C. Peasures for Safety and Security in ~
the Transportation of
~
Radioactive Materials i
I
- 42. UC and its Defueling Contractor have recommended a route and will recommend a schedule for fuel shipment departures, with the goal of minimiz- j ing radiological risk (in compliance with DOT regulations 49 CFR 177.825).
The route and schedule must be reviewed and approved by the CHP, which considers available infonnation on accident rates, transit time, and popula. ;
tion density and activities, is required by California Vehicle Code, (
t
$ 33002, Division 14.5. l t
- 43. UC and its Transportation Contractor will recommend a schedule based l
on a balancing of the need to minimize traffic with the need for visibility. l The shipment will be delayed, if necessary, to avoid hazardous weather con- f l
ditions, as indicateo by Proto-Power / Bisco Nuclear, Inc., Defueling Contrac. !
tor, 5 May 1988. i I
i
- 44. The CHP would be notified of the route and 48 hr. period in which the fuel shipNnts would occur and, in turn, would notify local authorities j along the route, as required by the California Vehicle Code, j 33002, Di vision 14.5. f f
[
as above and would, in turn, notify local authorities consistent with each !
state's laws. l
- 46. The fuel cask would be sealed with a tamper-indication device, pur- !
l suant to the requiremnts of 10 CFR 73.67(g)(iii). ;
i
__._ _ _ .. _ ._ _ _ . J
PROJECT SPECIFIC PROCEDURES
- 47. The fuel transport truck would be guarded by a trained escort riding in the truck throughout each trip to Idaho, as required by 10 CFR 73.37.
- 48. Truck drivers would be trained in safety, security, and emergency re-sponse proceduras in a qualified progiam, in accordance with 10 CFR 73, Appendix D and the policies of the 'iri-State Fotor Corpany, the firm with which UC plans to contrac'. to ship the fuel. The armed escort would be trained in the handling of firearms and in the handling of securit -hreats, in accordance with the same regulations and policies.
- 49. Along the whole course of the route, the truck carrying fuel wou'.d be escorted by an armed escort in a separate escort vehicle, as required by l 10 CFR 73.37.
- 50. While traveling through Berkeley, tne truck carrying fuel would be esecrted by a Co pus Police vehicla and a Berkelay Fire Department pumper engine.
L
- 51. A UC radiation health physicist, equipped with monitoring instruments, would ride through Berkeley in one of the campus police escort vehicles.
- 52. UC would cooperate witn staf f of the Berkeley fire, police and health ,
departnents to J.arive at rutually agreed upon transportation safety proce.
dures consistent with policies of NRC and CHP.
1
- 53. LSA waste would be trucked thr Berkeley to I-80 via the sane route r
as the fuel.
i 1
f
PROJECT-SPECIFIC PROCEDURES D. Measures to Reduce the Damage from Accidents Should h O J cur
- 54. The UC Office of Environmental Health and Safety would provide monitor-ing equipment and personnel in response to a transportation accident in ,
Berkeley.
- 55. UC will comply with adoitional emergency procedures whic;1 have been l developed with the City of Berkeley Fire and Police Departments for the response to accidents relating to transportation of radioactive materials and to the demolition process. These procedures s. splement the existing j reactor emergency plan. I i
- 56. UC would develop guidelines for emergency procedures to be followed by its contractors for this project.
- 57. UC would provide training to staff of the City of Berkeley Fire Depart-ment in the operation of radiological monitoring equipment and would participate in a joint radiological emergency response fleid exercise with City emergency personnel. UC will continue to work with City staff to ensure coordination of emergency response to potential project accidents.
- 58. A spill response kit would be carried on board trucks transporting t
LSA radioactive materials to ensure immediate protectiun of .!e public in case of accident.
- 59. If an accident were to occur, insurance providad under the Price-Anderson Act covers up to $500 million in damages to property or human health for a single accident. L'C carries a separate policy with American Nuclear Insurance Inc. to cover the deductible of $250,000 which would
PROJECT-SPECIFIC PROCEDURES provide full accident compensation to the City of Berkeley; its resiosnts, !
- and other affected parties.
- 60. State and federal assistance is available for a major accident as 4
described on pp. 45. ,
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FOOTNOTES *
- 1. Mygatt, Peter, Director of Office of External Aff airs, U.S. Department of Energy Idaho Operations Offica, written communication, 26 April 1988.
- 2. Lim, Tek H. Berkeley Research Reactor Annual Report of Operations, 1986, p. 4.
- 3. Lim, Tek H. , Reactor Supervisor and Decommissioning Project Engineer, writter commuaication, 8 March 1988.
- 4. One thousand MW electrical power generated by a commercial reactor is equivalent to about 3300 MW of the thermal energy produced by the BRR.
- 5. Vernig, Peter, Environmental Health and Safety Health Physicist, writ-ten ccoments of 15 March, 1988.
- 6. Pigford, Thomas H. , memo to Regional Administrator, U.S. ERC Region V, Re: "Written report of items previously reported by telephone by Tek Lim, Reactor Supervisor, on 17-21 October 1985", 23 October 1985.
- 7. Controls for Environmental Pollution, Inc. analyzed the water in the Reactor pool (where the suspect rods are stored) by gamma spectral analysis and reported on 29 Februarv N88 that no man-made nuclides were detected. Vernig, Peter, tele; . communication, 25 April 1988.
- 8. Patenaude, Richard, Proto-Power / Bisco, personal communication, 31 March 1988.
- 9. NRC regulations were thought by UC to preclude economical construction of a multistory building over a reactor according to the University of California, Berkeley Project Planning Guide for the Etcheverry Hall Reactor Oecommissioning and Removal, account 912536, May 1987, p. 5,
- 10. Gros sman, L. et al . Safety Analysis Report for the University of Cali- ,
fornia Berkeley Research Reactor, University of California, Berkeley, 1964, p. vii.
- 11. Ibid., p. 2-2.
- 12. Wessman, Robert, Manager of Nuclear Projects, Thermo Analytical Inc.,
memo, 5 April 1988.
- 13. Floyd, Jim, Radiochemist, Thenno Analytical Inc. , telephone commu-nication, 23 March 1988.
- 14. Denton, Michael, Deputy Decommissioning Engineer and Chief Reactor Operator, telephone communication, 31 March 1988.
- The 9ecommissioning Plan, Defueling Plan and other frequently used refer-ences are available on reserve in the Berkeley Mein Library and UC Campus Doe Library.
FOOTNOTES
- 15. BMI-1 Certification No. 5957, NRC, pursuant to 10 CFR 71, 27 August 1987.
- 16. Lim, Tek H. , Reactor Supervisor and Decommissioning Project Engineer, telephone communication 20 April 1988.
- 17. Patenaude, Richard, Proto-Power /Bi sco, telephone communication, 20 April 1988.
- 18. Peter Vernig, Reactor Health Physicist, telephone communication 27 Sep-tember 1988. Radiation produced by the fuel would not be detectable using a geiger counter with a thin window pancake probe, equipment commonly used for environmental surveys of low level radiation.
l l
l 19. The rode would be stored under water until 1990, then would be stored l in dry caniste;*s.1
- 20. Lyle, J.L. Field Processing Branch Chief, telephone conversation, 29 March 1988.
- 21. Benedict, Manson, T.H. pigford, H.W. Levi, Nuclear Chemical Engineer-ing, McGraw-Hill 8ock Company,1981.
- 22. Lim, Tek H. , Fuel Element Estimates - May 10,1988(revised), attach-ment to Letter from Tek Lim of 5 April 1988.
- 23. Willrich, Mason and Taylor, Theodore B. Nuclear Thef t, Risks and Safe-guards, Ballinger, Cs.mbridge, England,1974, p.13.
- 24. Patenaude, Richard, Proto-Power / Bisco Nuclear, Inc., confirmed by telephone 2 October 1988. The 111 Reactor fuel rods contain about 3,9001,300 about grams g 2352 U
$ .One shipment contains one third of that amount, or
- 25. Sergeant Bladow, California Highway Patrol, telephone communication, 4 April 1988.
- 26. Patenaude, Richard, Report of conversation with Charles Hillman of the Transportation Branch of Safeguards and Transportation Division of U.S. NRC, 3 May 1988.
- 27. Garcia, Emilio, NRC Emergency Response Coordinator, Region V, tele-phone communication,14 March 1988.
- 28. Lim, Tek H. , Reactor Supervisor, telephone communications, 9 February 1988 and 29 March 1988.
- 29. Pigford, T.H. , Memo Re Calculation of fission product activity in Cerkeley Research Reactor at shutdown and on November 15, 1988, dated July 29,1988. Radioactivity referred to in S 3 of p. 27 of the text is beta activityt from gross fission products; activity of radiciodine referred to in S 4, p. 27, and 13 p. 65 is beta activity. The per-cent reduction in gross beta activity of fission products was cal-
FOOTNOTES culated a} follows: 1.23 x 106 curies (beta activity at shutdown) 6 100 1.04 x 109 curies (beta activity on 15 November 1988) = 1.22 x 10 ;
x 1.22 x 106 / 1.23 x 106 = 99.2%.
- 30. The unshielded activity of the fuel rods in the core is about 200 rads /hr. at 1 m (from "C.-re Table," attachment to letter from Tek Lim, 5 April 1988 ) as compared to approximately 20 rads /hr at the surface for the rota ry speciren ra ck , five months after shut down of the Reactor (based on Decommissioning Plan, p. 1-36). At five months after shutdown the most radioactive concrete (in the floor slab under the Reactor core) would be 0.004 rads / hr., a factor of 5,000 less than the Reactor parts. Concrete further from the core shroud would produce lower radiation exposures. The comparison changes with the passage of time because oi varying decay rates, but the orders of mag-nitude given here are accurate for the time period of proposed decom-missioning.
- 31. Trinoskey, Paula, Kaiser Engineers, telephone conversation, 8 August 1988.
- 32. Vernig, Peter, Reactor Health Physicist, written comments of 15 March 1988.
- 33. Dodson, Wallace, Executive Engineer for Decommissioning, statement at Steering Committee Meeting, 20 April 1988, from meeting notes of Selina Bendix.
- 34. Proto-Power / Bisco Nuclear, Inc. Defueling Plan for the Triga Mark Ill Berkeley Research Reactor,1988, p.10.
- 35. Ko ..ek , J. et al. Technology, Safety and Costs of Decommissioning Reference Nuclear Research and Test Reactors, NUREG/CR-1756, V. 1, Nuclear Regulatory Commission,1982, Vol. 2, p. N-67.
- 36. Cla rke , R.H. Interim Guidance on the Implications of Recent Revisions of Risk Estimates and the ICRP Como Statement, NRPB-GS9: HPSO, London, 1987, and International Commission on Radiological Protection, State-ment from 1987 Como meeting, Radiol. Prot. Bull. 5, Supplement,1987, as cited in Barnaby, Frank, The Need to Revise Radiation Risk Estimates, Ambio 17:70-71, 1988.
- 37. Barnaby, Frank, The Need to Revise Radiation Risk Estimates, Ambio 17:70-71, 1988.
- 38. The comparison between the average dose and a more stringent limit for a person in a restricted area is not intended to imply that such a limit would apply to the average dose rather than the maximum dose.
- 39. Degenkolb, Henry J. Seismographic Report on Etcheverry Hall, 26 March 1981.
l l
FOOTNOTES
) 40. Mills, Mark P. Energy Issues in Perspective, paper presented at a l
Waste Transportation: A Seminar for Public Information and Public l
Affairs Specialists," Albuquerque, New Mexico,1984, p. 4.
l
- 41. Javitz , Harold S. , T.R. Lyman, C. Maxwell, E.L. Myers, C.R. Thompson, Transport of Radioactive Material in the United States, Sandia Nation-al Laboratorles, April 1985.
I
- 42. US Department of Energy. Transporting Spent Nuclear Fuel: An Over-view, 00E/RW0065, March 1986, p.15.
- 43. 10 CFR 71.73. 1475'F is approximately the temperature at which jet fuel burns.
- 44. Sandia National Laboratories. Relative response of Type B packaging to regulatory and other impact test environments, presented at the 6th International Syposium on Packaging and Transportation of Radio-active Materials, Berlin, W. Germany, November 1980, citsd in Resni-koff, reference 40.
- 45. Resnikof f, Marvin. The Next Nuclear Gamble, Council on Economic Prior-ities, 1983, P. 155,
- 46. Audin, Lindsay. A Review of the Effects of Human Error on the Risks Involved in Spent Fuel Transportation, Nebraska Energy Office, April 1987.
- 47. US Department of Energy. Transporting Spent Nuclear Fuel: An Over-view, 00E/RWOO65, March 1986, pp.13-15.
- 48. Fact Sheet, Radioactive Materials Incident Report Database, RMIR, 2 pp., undated, received f rom Transportation, Information and Communi-cation Libra ry, 8 April 1988.
- 49. Cashwell Cheryl . An Historical Summary of Transportation Accidents and Incidents Involving Radioactive Materials,3 pp., undated, received from Transportation, Information and Communication Library, 8 April 1988.
- 50. Cashwell Che ryl . An Historical Summary of Transportation Accidents and Incidents Involving Radioactive Materials,3 pp., undated, received from Transportation, Information and Communication Library, 8 April 1988, p. 404. Note that DOT reporting began in 1971, but NRC reporting did not begin until 1976.
- 51. McClure, J.D. , and A. Tyron-Hopko. Radioactive Material (RAM) Trans-portation Accident / Incident Analysis, Sandia National . Laboratories for 00E, March 1986, p. 14.
- 52. U.S. 00T Office of Hazardous Materials Transportation, Hazardous Materials Inforration System, 30 March 1988.
- 53. National Council on Radiation Protection and Measurements. Report No. 93, NCRP, Bethesda, Md. ,1987.
FOOTNOTES r
- 54. Jenson Young, Department Head of Environmental Health and Safety, Law-rence Berkeley Laboratory, telephone communication, 9 February 1988.
Young states that the average background dose rate in Berkeley is 80 to 100 mrem per year, excluding radon exposure.
- 55. Nero, Anthony. Professor of Physics, Applied Sciences Division, UC Berkeley, telephone communication,18 August 1988. Report of study radon in Lawrence Berkel ey Laboratory empl oyees ' homes and other studies in the San Francisco Bay Araa. Based on limited data, the ,
average radon measurement in Bay Area homes is about 0.5 picocurie per i liter of air, which translates to a typical dose rate of about 100 mrems of radiation per year from radon for a person living in a Bay Area home. Total yearly background exposure would thus be about 200 mrem.
l 56. Shleien, Bernard and Michael S. Terpilak, eds. The Health Physics and Radiological Health Handbook, Nucleon Lectern Associates,1984, Table 1-5.
- 57. National Academy of Sciences Advisory Committee on the Biological Effects of Ionizing Radiations. Considerations of Health Benefit-Cost Analysis for Activities Involving Ionizing Radiation Exposure and Al-ternatives EPA, 1977.
- 58. Weast, Robert C., Melvin J. Astle, eds. Handbook of Chemistry and Physics, 61st Edition, CRC Press, 1980, p. 0-187.
- 59. NRC. Amendment 2 to Facility Licence No. R-101 for the Berkeley Re-search Reactor, Appendix A, Technical Specification #2.1, Safety Limit '
Fuel Element Temperature,1979.
- 60. Results of calculations by Kaiser Engineers, presented in Lim, Tek H.
and Michael M. Denton. Emergency Preparations for Removing the Berke-ley Research Reactor, July 1988, pp. 20, 21.
- 61. Reactor Emergency Proceedures, 30 October 1984 (some sections were updated in 1985), supplemented by personal communicatia with Denton, Michael, Chief Reactor Operator, 31 March 1988. ,
- 62. Taylor, Charles, Emergency Preparedness Coordinator for DOE Region 7 (California, Hawaii and Pacific Region), telephone communication, 19 April 1988.
- 63. Cutner, Gary, Nuclear Power Emergency Response Coordinator, California Office of Emergency Services, telephone communication, 6 May 1988.
- 64. Peterson, Andris, Radiation Safety Officer, written communication, 25 April 1988. t
- 65. Deness, Steven, Associate Director of Risk Management and Safety, ,
Office of the President, UC, telephone communication, 21 June 1988.
- 66. Lim, Tek H. and Michael M. Denton. Emergency Preparations for Removing '
the Berkeley Research Reactor, July 1988, p. 2.
3
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FOOTNOTES
- 67. Post traffic lights arc set for cycles of 1 minute, so a two minute stop allows for congested conditions under which a truck would have to wait through two red lights to get through the intersection. -
L 68. Gofman, John and Egan O'Connor. X-Ray s : Health Effects of Common Exams, Sierra Club Books, San Francisco,1985, p. 86.
- 69. Konzek, J. et al. Technology, Safety and Costs of Decommissioning Reference Nuclear Research and Test Reactors, NUREG/CR-1756, V. 1, Nuclear Regulatory Commission,1982, pp.12-34 to 12-36.
- 70. Jones, Les, Research Manager, California State Division of Transporta-tion Planning, personal communication, 9 March 1988. Information on population densities in counties along Highway I-80 derived from California Department of Finance 1987 estimates.
- 71. This calculation assumes that one rem of whole body exposure carries a lifetime risk of 10 to 20 fatal cancers per 100,000 adults exposed to thtt dose; see Ellett, William H. Revi ew of "Predicted Cancer Fatai ties Due to Ionizing Radiation" in Low-Level Ionizing Radiation, Heari s before the Subcommittee on Energy and Production and the Subcommittee on Natural Resources and Environment of the House Commit-tee on Science and Technology,13-15 June 1979.
- 72. Konzek , J. et al. Technology, Safety and Costs of Decommissioning Reference Nuclear Research and Test Reactors, NUREG/CR-1756, V. 1, Nuclear Regulatory Commission, 1982, pp. 12-27 and 12-28, V. 2, N-2 and N-3.
- 73. Office of Nuclear REgul atory Research. Final Generic Environmen tal Impact Stat ement on Decommissioning Nuclear Facilities, NRC, May 1988.
- 74. NRC Quality Assurance Program Approval for Radioactive Paterials Pack-ages (for Fuel Shipment using the 8MI-1 Cask), Docket #71-0694, 10 March 1988.
- 75. Quality Assurance Manual for the Berkeley Research Reactor Decommis-sioning Project, April 20 1988, complies with American Nuclear Society.
"Quality Assurance Program Requirements for Research Reactors. NRC Regulatory Guide 2.5, Quality Assuranca Program Requirements for Research Reactors, accepts use of this ANC document which has also been adopted by the American National Standards Institute as ANSI Nd02-1976.
- 76. Lim, Tek H. , written record of conversation with Charles Hillman, Securit.y Specialist, Transportation Branch of the Safeguard and Trans-portation Divtsion, NRC, 21 April 1988; confirins NRC requirement that information about scheduling of fuel shipment cannot be released to the public until 10 days following last shipment.
- 77. Russey, Ga ry W. and Stephen R. Korbay, Harding Lawson Associates.
Geologic and Fault Hazard Investigation, Proposed Student Housing, UC, UC Office of Facilities Management,13 November 1986.
FOOTNOTES
- 78. Collins, Eric, Research Associate at UC Berkleley Seismographic Sta-tion, telephone communication, 2 February 1988. The chance of earth-quake of magnitude 7 on the Hayward fault is 20% over the next 30 ye ars .
- 79. Grossman, L. et al. Safety Analysis Report for the University of Cal-ifornia Berkeley Research Reactor, University of California, Berkeley, 1964, pp. 1-14 and 1-15.
- 80. NRC, Office of Nuclear Reactor Regulation, Safety Evaluation and Environmental Impact Appraisal, Supporting Amendment No. 2 to Facil-ity License Nv. R-101, University of Cslifornia at Berkeley,1979.
The exposure calculation is based on the assumption that .0015% of the total core fission product is released. That percentage is based on results of experiments conducted in 1966 and 1972 by General Atomic 4 for operating TRIGA reactors at temperatures up to 400' C.
- 81. Lim, Tek H. and Michael M. Denton. Emergency Preparations for Remov-ing the Berkeley Research Reactor, July 1988, pp. 22, 23.
- 82. Kaiser Engineers. Transmittal of Back-up Calculations, Etcheverry Hall, Decommission Reactor, July 14, 1988, p. 6 of 9.
- 83. The estimete of 10 to 15 truckloads (Wallace Godson, Kaiser Engineers, personal *ommunication, 22 February 1988) assumes a packing density of 40%, 3,000 cubic ft. of waste, use of 4 x 4 x 6 ft. containers (90 cu-bic f t. capacity), and trucks that hold 6 to 10 containers. The 3,000 cubic feet includes radioactive rubbie, reactor parts, and other mat-erials such as barriers and protective clothing. A range is given to indicate the uncertainty of the estimate of an amount of waste that
- would vary depending on how much of the dismantling and protective equipment must be disposed of as radioactive waste, whether the con-crete is broken in square slabs or irregular pieces, and other factors.
- 84. Derived from table in NATO AMEDP-6 Part 1, 1973, from The Health Physics and Radiological Health Handbook, Shleien, Bernard and Michael S. Terpilak, eds., Nucleon Lectern Associates, Inc., 1984.
1 I
i I
j
. 1 GLOSSARY Adiabatic: Any process in which there is no gain or loss of heat.
Uncontrolled fires are never adiabatic because turbulence causes friction losses.
Atomic Weight: The relative mass of an atom based on a scale in which a specific carbon atom (carbon-12) is assigned a mass value of 12.
Beta Activity: Radioactive decay in which a neutron in an atomic nucleus ,
is transformed into a proton (a positively charged nuclear particle) l through the emmission of a beta particle. Because beta activity is the dominant form of radioactivity of the neutron-rich fission products, it has been used in this report to indicate the reduction in activity of fission products over time.
Capacity Factor: The ratio of the average power load of an electrical power plant to its rated capacity (e.g. if a pleit with rated ,
capacity of 1000 MW operates at a pewer load of 600 MW, averaged over the year, '.ts capacity factor is 60%).
r CFR: Code of Federal Regulations.
Decommissioning: The measures taken following a nuclear facility's opera-ting life to safely remove the property from radioactive service and '
to dispose of radioactive materials.
Decommissioning Contractor: A firm hired by UC to carry out the work of '
l dismantling the Reactor, packaging waste and other decommissioning activities. Other firms would probably be hired to ship the debris l and LSA waste.
l I
Defueling Contractor: In the context of this report, the fim hired by UC (Proto-Power / Bisco Nuclear, Inc.) to manage the removal and shiprent of the fuel rods. Another firm would be hired to truck the fuel to Idaho.
Dosimeter: A device that measures the total radiation dose received in a given period of time.
Dosimetry: The measurement of radiation doses.
Enrichment, Isotopic: A process by which the relative abundance: of the isotopes of a given element are altered, thus producing a fom of the element that has been enriched in one particular isotope ancf deplet-ed in other isotopic forms.
Executive Engineer: The firm (Kaiser Engineers) that would manage the decommissioning process and conduct initial and final radiation survey s.
- Underlined words in definitions are defined elsewhere in the Glossary.
GLOSSARY Fif ty-year committed dose: The cumulative dose received over a 50-year period f rom a given dose of inhaled, ingested or absorbed radionu-clides that are retained in the body.
Fissionable: A property of certain isotopes enabling the nuclei of some of their atoms to split, generating radioactivity in the process.
Fuel Rod: A fuel rod for a research reactor like the UC Reactor is a slen-der cylinder about 25 in. long and 1.5 inches in diameter. It con-tains fissionable material (fuel) for nuclear reactor use inside a casing of stainless steel.
Gamma Radiation: Short wavelength electromagnetic radiation. Gamma rays are similar to X-rays, but are nuclear (originating from within the ,
nucleus o' an atom) in origin. This type of radiation is very penetrating.
Gamma Scan: An analytic method for identifying gamma ray-producing iso-topes present in a material (useful in distinguishing isotopes con-monly present as background radiation from those likely to be pro-duced in a reactor).
HEPA Filter: High Efficiency Particulate Air Filter. This type of fil-
' ter removes from air particles greater than 0.3 microns (1 micron =
1 millionth of a meter) in diameter with an efficiency of 99.95%
(NRC Certification of Compliance: up to 99.97% by thermal DOP test per MIL-STD-282,12 January 1988).
lonizing Radiation:
as it penetratesAny radiation through mattercap (able of examples: producing alpha, beta,charged particles gamma rad-iation, X-rays, neutrons, emitted from the nucleus of an unstable (radioactivej atom as a result of radioactive decay). This process disrupts atomic structures through which the radiation passes and cre-ates changes in biological tissue; high ionizing radiation doses may produce severe tissue damage. Radiation is the product of radioac-tivity.
Different foms of ionizing raajation have different penetration power (for instance, alpha radiation cannot penetrate the skin but is i
dangerous if an alpha-emitting isotope is ingested, while gamma rays have high penetration power and their sources must be shielded to protect humans from exposure).
Isotope: Atoms of the same chemical alament with the same number of pro-tons but different numbers of neutrons in their nuclei are called iso-top es. Isotopes have nearly identical chemical properties but differ-ent weights and physical properties. For example, carbon-12 and car-bon-14 are two isotopes of carbon; an atom of carbon-14 has two more neutrons in its nucleus than an atom of carbon 12. One isotope of an element may be fissionable while another is not, because of differ-
) ences in the stability of its nuclei.
i 1
GLOSSARV Low Specific Activity (LSA) Radioactive Material: Developed historically as a shipping category on the premise that less stringent packaging and shipping requirements than used for spent fuel rods and other high level nuclear waste could b6 Used for radioactive materials with low activity levels. The activity in LSA material is relative-ly unifonnly distributed and the average activity level per gran (in mil 11 curies per gram) for such materials cannot exceed the specifica-tion of 49 CFR 173.24. LSA material can be transported in "strong tight" containers if shipped in a sole use vehicle.
Microcurie (uCi): One millionth of a curie. A curie is a measure of radioactivity, defined as the quantity of any radioisotope which ht s 37,000,000,000 disintegrations per second.
Microrem: One millionth of a rem.
Millirem (mrem): One thousandth of a rem.
Moderator: The material used in nuclear fuel or in a nuclear reactor to moderate or slow down neutrons from the high velocities at which they are created in the fission process. ,
MW-day negawatt day): the amount of energy generated or used when that energy is generated or used at the rate of one million watts for the duration of one day.
Neutron: An tacharged elementary particle with a mass slightly greater than that of the proton, found in the nucleus of every atom with a mass greater than the common isotope of hydrogen.
Person-rem: A population dose equal to the sum of the individual expo-sures in rems summed over the total numbers of individuals exposed.
Picoeurie (pCi): A trillionth of a curie. A curie is a measure of radio-activity, defined as the quantity of any radioisotope which has 37,000,000,000 atomic disintegrations per second.
Radiation: In the context of this document, radiation refers to ionizing radiation.
Radiation Oose: A quantity (total or accumulated) of ionizing radiation received. The term "dose" is often used in the sense of absorbed dose, expressed in rads, which measure the total energy from a quan-tity of radiation _ absorbed in a gram of any material. This should be distinguished from the dose equivalent, given in rem, which is a measure of the biological damage to living tissue from the radiation exposure.
Radioactivity: The spontaneous emmission of radiation, generally alpha or beta particles, often accompanied by gamma rays, from the nucleus of an unstable isotope _ of an element that decays or disintegrates spontaneously, emitting radiation. Adjective: radioactive. Often shortened to "activity".
GLOSSARY Rad: Acronym for "radiation absorbed dose." The basic unit of absorbed dose of radiation. A dose of one rad means the absorption of 100 I
ergs (a small but measurable amount of energy) per gram of absorbing mat eri al .
Rem: Acronym for "roentgen equivalent man." The unit of dose for any ionizing radiation that produces the same biological effect as a unit of absorbed dose of ordinary X-rays. Rems are obtained by multiply-ing the absorbed dose in rads of a type of ionizing radiation by a ,
quality factor. This adjustment factor is necessary because some l types of radiation are more biologically damaging than others.
Richter scale: A logarithmic scale developed by Charles Richter to mea-sure earthquake magnitude by the energy released, as opposed to earthquake intensity as detemined by ef fects on people, structures and earth materials. The San Francisco earthquake of 1906 is esti-mated to have had a Richter magnitude of 8.2 or 8.3.
Rotary Specimen Rae.k: A rack used to hold specimens to be irradiated inside the Reactor. Because of their proximity to the Reactor core, this rack and the core shroud are predicted to be more highly radio-active than other components of the Reactor.
Sole Use or Exclusive Use: Feans sole use of a vehicle or other convey-ance by a single consignor and for which all loading and unloading activities are carried out according to the direction of that con-signor.
Special Nuclear Material: Includes plutonium, uranium-223, or uranium i
enriched in the isotopes uranium-233 or uranium-235.
Strong, Tight Container: These packages must meet performance criteria (i.e. there can be no release of radioactive content during transpor-tation), but are exempted f rom drop and compression tests required of other packages (Type A) and the even more demanding test criteria imposed on Typ_e, B packages. They are pemitted for use in the ship-ment of low specTfic activity radioactive material in sole use_ vehi-cles. Typically, they are sealable boxes made of steel or wood.
l Transportation Contractor: The firm (s) hired to transport radioactive
! and non-radioactive waste (fuel rods are not considered waste).
Type A Containers: Containers designed to meet performance standards (no release of radioactive contents) and to meet less stringent tests than type B containers. NRC-certified Type A containers must meet l
requirements for a quality assurance plan similar to the plans for
)
Type B containers.
Type B Containers: High integrity container designed to meet performance staadards (no release of radioactive contents) and to withstand a series of tests Including free fall onto an unyielding surface, puncture by a steel bar, high temperatures and immersion in water.
l
t Emergency Preparations for Removing the Berkeley Research Reactor Controlled Copy #
September 7, 1988 Rev. 1 Appendix B
Table of Contents 1
Summary....................................................
2 1.0 Project 0verview.......................................
2 1.1 Approach.............................................
2 1.2 Present Status.......................................
1.3 Project Description.................................. 3 4
1.4 Accident Prevention Program..........................
2.0 Emergency Response Organization........................ 6 2.1 University Organization.............................. 7 2.2 Contractors.......................................... 9 2.3 State and Pederal Agencies........................... 9 2.4 City of Berkeley.................................... 10 2.5 Emergency Communications............................ 11 2.6 Public Information.................................. 12 3.0 Guidelines for Additional Emergency Procedures........ 12 3.1 Emergencies in Etcheverry Hall...................... 12 3.1.1 Classes of Emergencies in Etcheverry Hall.... 13 3.1.2 Additional Procedures for Emergencies within Etcheverry Hall....................... 13 A. Disruption of LSA Box........................ 13 B. Failure of Confinement Barriers.............. 14 C. Crane Failure................................ 15 D. Exposure from Strong Radiation Sources....... 16 E. Water Leaking from the BMI-1 Cask............ 16 F. Earthquake................................... 17 3.2 Emergencies During Transportation of Radioactive Materia 1............................................ 18 3.2.1 Emergency Response on Berkeley Streets....... 18 3.2.2 Additional Procedures for Emergencies During Transportation........................ 20 A. Transportation Accident with no Release of Radioactive Material...................... 20 B. Transportation Accident Involving Release of Radioactive Material...................... 21 3.3 Supporting Analysis... ............................. 22 3.3.1 Exposure from Rupture and Fire................ 22 23
! 3.3.2 Fuel Shipment.................................
24 3.3.3 Earthquakes................................... 26 3.4 Shipment Notification...............................
List of Figures:
Figure 1. Emergency and Disaster Organization for the Berkeley Research Reactor................... 27 Figure 2. Plan Vien of Etchverry Ha11................. 28
Attachment:
Section 4, Emergency Procedures, from the "Operations Manual for Removing the Berkeley Reseerch Reactor" by Lim /Denton
September 7, 1988 Rev. 1 Emergency Preparations for Removing the Berkeley Research Reactor Prepared by:*
Tek H. Lim Michael M. Denton The University of California (University) is preparing to
' remove the Berkeley Research Reactor (BRR) now located in ,
Etcheverry liall. The purpose of this document is to inform City of Berkeley Fire and Police officials about the present status of emergency preparations for the reactor removal project and to seek their input and comments. Procedures and activities requiring coordination with the City of Berkeley Fire and Police Departments are specifically identified. This is not an essential or required document by the NRC and applies j specifically to the delineation of activities involving the ,
University of California, Berkoley, and the City of Berkeley.
This document is organized in three sections. Section 1, "Project Overview", presents background information on the DRR removal project, the University's approach to accident prevention and emergency planning, and the present status of emergency planning activities. Section 2, "Emergency Response
- With contribution from Proto-Power / Bisco, Xaiser Engineers and the Campus Office of Environmental Health & safety
2 organization", describes the organizations that are available to respond to an emergency during the BRR removal project, their capabilities, and their functions. Section 3, "Guidelines for Additional Emergency Procedures", sets guidelines for procedures that have not yet been written and presents accident analysis to support the guidelines.
1.0 Project overview _
1.1 Approach, The reactor removal project will be carried out under our existing Emergency Plan approved by the U.S. Nuclear Regulatory Commission (NRC).* The plan will be implemented through existing procedures and new ptocedures specific to the reactor removal project. Following standard practice, additional procedures will be developed by the University step by step as the project proceeds. Through the bid and award process, the University will also require that contractors adhere to established emergency procedures for their specific responsibilities and develop new procedures when needed.
1.2 Present Status On June 14, 1988 the University issued a draft operations Manual for Removal of the Berkeley Research Reactor. Section 4 of the draft manual contains detailed emergency procedures
' Emergency Response Plan for the University of California TRIGA Mark III Berkeley Research Reactor, October 25, 1982, revised June 21, 1963, August 13, 1984.
.m . _ _ _ .
3
- revised to apply specifically to the reactor removal project. A copy of these draft procedures is attached. They include responses to radiation incidents, evacuation procedures, civil disturbance, bomb threat, fire or minor explosion, and personal A r.j ury .
As is outlined in section 3.0 of this document, the University has prepared guidelines for additional procedures.
4 These new procedures will more extensively address defueling, dismantling, demolition, packaging and transportation of radioactive materials. Guidelines for emergency procedures for i
- transportation of spent fuel and radioactive waste out of the l City of Berkeley are given in section 3.2.1.
To support the development of the emergency procedures the University has analyzed the effects of postulated accidents in selected areas (transportation, earthquake, etc). These analysis l are discussed in section 3.3. ,
1.3 Project Description The reactor removal project has tuo phases. In the first l
phase, called defueling. the reactor fuel will be removed from i
the reactor and placed in an NRC licensed shipping cask for i
transport to the U.S. Department of Energy at the Idaho National Engineering Laboratory near Idaho Falls, Idaho. The used fuel, consisting of 111 rods weighing a total of about 800 pounds, will
- be shipped in three approximately equal shipments, a week to ten 1
days apart. The same cask will be used for each of the three i
I
4 shipments.
In the second phase, called decommissioning, tne material made radioactive by close proximity to the fuel during operation will be removed and transported away. This includes the reactor support structure, the rotary specimen rack, a portion of the aluminum pool liner, portions of the reinforced concrete monolith which surrounds the reactor pool, and some small amount of slightly contaminated concrete dust, metallic chips, wood, plastic and rags. On the basis of prior TRIGA reactor decommissionings, it is anticipated that these waste shipments will be classified as "Low Specific Activity" (LSA). The more highly activated meic3 components such as the reactor support structure and the rotar/ specimen rack are also expected to qualify as LSA material. This determination will be confirmed early in the decommis sioning phase, based on radiation measurements of the removed material.
At project completion a comprehensive radiation survey will be performed. When radioactivity has been removed to acceptable levels, the reactor license will be terminated by the NRC and the laboratory released for unrestricted use.
1.4 Accident Prevention Procram_
As with all industrial safety programs, the time and effort spent in preventing accidents has the greatest etfeet in reducing both human suffering and damage. For nuclear reactor decommissioning, extensive records are kert, each new tool or
5 technique tried is documented, and all activities are performed in strict accordance with written procedures.
The University's Decommissioning Plan (DP)* draws upon previous decommissioning technologies that have been proven successful. By so doing, the DP provides to the decommissioning contractor much of the data needed to prepare procedures that will ensure that the work will be accomplished in a carefully controlled ad safe manner. The work will be contracted out to firms with experience in this area.
Both existing procedures and provisions of the Decommissioning Plan specify that safety systems must be operational during fuel handling and demolition activities. When certain activities arise that require disabling of one or more of these safety systems, special procedures will be required. For example, when the truck access doors are opened, all other work within the reactor room must cease until the doors are closed again.
Shipments of radioactive materials will be scheduled to minimize the overall risks of accidents. During the I transportation of irradiated fuel within the City of Berkeley, a person with radiatinn safety expertise such as a health physicist, or a qualified designee, will accompany the shipment.
This person will be able to continually assess the safety of the operation and will assure that there is a knowledgeable, trained l
- "Decommissioning Plan for the TRIGA Mark III Berkeley Research Reactor", Kaiser Engineers, January, 1988.
I h
f 6
observer present to identify and properly rempor.d to a developing situation. This individual will act as an advisor stoff person f to the Berkeley Fire Department incident command in the event of a radiation emergency situation. To comply with 10CFR73.37, fuel shipment will be escorted by a University Police Department armed -
escort vehicle. To comply with recommendation by the Berkeley Fire Department, fuel shipment will be escorted by an engine i
compgny of the Berkeley Fire Department to be staffed by its .
Hazardous Material Personnel Team. The University escort will advise Fire Department personnel on any immediate accident j l
4 mitigation measures, pending arrival of senior University ,
officials. i During transportation of LSA material in the City of Berkeley, a member of the University Police Department or s qualifled designee, equipped with radio communication appara'us l
I will accompany the shipment. This person will be able t'.- expedite ;
J notification in the event of an accident or emergency.
Independent oversight of activities will be provided b 4. h4-office of Environmental Health and Saf ety (ZH&S), the N - 8: i Regulatory Commission, the Reactor Har,ards Committee and American ,
i l
Nuclear Insurers. t i ;
2.0 Emeraency Response Oraanization l
The University is responsible for assuring that the reactor i
removal project is carried out in e. manner which prstects the
! health and safsty of the workers and the general public. The i
i e
7 University will exercise this responsibility through its own organizations and through its contractors. Further assistance as required will be provided through cooperative arrangements with Federal, State and local agencies including the City of Berkeley Fire and Police Departments.
2.1 University Orcanization A chart of the University's Emergency and Disaster Organization for the Berkeley Research Reactor is shown in Figure 5 of the existing Emergency Plan, a copy of which is attached to this document. This emergency response organization will remain in effect throughout the reactor removal project.
The University Office of EH&S has 5 Health Physicists and 3 Health Physics Technicians. These professionals are capable of responding to radiological emergencies, on campus or off-campus.
In responding to an emergency, they will be equipped with portable emergency equipment. During office hours their response time is approximately 30 minutes. During after hours, the response time is betweer, 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Off-hours communication l r
is handled by the University Police Department, r The defueling and decommissioning statf includes a Nuclear Engineer, who cerves as Reactor Supervisor and Decommissioning i Project Engineers a Deputy Project Engineer; a professional executive engineer, and a Health Physicist. The Project Engineer l i
is an NRC 1.icensed senior reactor operator in the Berkeley Research Reactor.
yg .- s .-
8 The University official immediately responsible during emergencies related to the rer.ctor removal project is the Reactor Supe visor, wno will serva as Decommissioning Project Engineer during the removal project. The Project Engineer will take charge in the event of emergencies in the reactor laboratory complex. If the emergency involves fire, explosion, or life threatening injury the Project Engineer will coordinate with the Berkeley Fire Department's emergency response team. He will organize University coordination with the City of Berkeley Fire Department and Police Department and other agencies in the event of emergencies outside the reactor laboratory complex and along the transportation route.
The Project Engineer is responsible for the measurement, collection and evaluation of radiological data, both for normal day to day monitoring of conditions and in ths event of an emergency. He is assisted by the Office of Environmental Health and Safety (EH&S) and the Executive Engineer. A fu11-time Health Physicist is assigned during every step of the reactor removal process.
Specific functions of the University Police Department during an emergency are described in the BRR Emergency Response Plan. A University Police Department liaison is assigned to this project. This person is familiar with project requirements, operations and emergency procedures.
9 2.2 contractors In addition to University personnel, the defueAing and I
decommissioning contractors will have on their staffs radiation safety specialists and decontamination technicians. The contractor's role in an emergency situation will be outlined in ;
the bidding document. Contraccor personnel will be trained by the University specifically for the BRR removal project, tested on their knowledge of the applicable Federal-and State regulations and will have direct experience in the processing, handling and packaging of radioactive materials coming out of the BRR. They These !
I will also be trained on how to respond in an emergency.
personnel constitute an immediately available pool of trained and experienced radiological workers in the event of an accident >
during work in Etcheverry Hall or during transportation of the radioactive materials througn Berkeley. ,
l 2.3 State and Federal Acencies_ 1 The office of Environmental Health and Safety in !
coordination with the Project Engineer can request assistance froa several State and Federal agencies. Request for assistance will be initiated and handled by the Office of EH&S. These agencies can provide trained radiological professionals, drawn from their own staff or the laboratories and facilities of the larger government contractors in the area. For the Berkeley area, the Department of Energy (DOE) would provide their emergency response teams supplemented, if necessary, by
10 additional personnel from local DOE-funded latboratories such as the Lawrence Berkeley Laboratory. In addition to the technical these and emergency management expertise of the people available, area facilities also have instruments and emergency response equipment which could be brought to the scene of an emergency.
During regular office hours the response time of the Lawrence Berkeley Laboratory Radiological Emergency Responst Team to an accident in the City of Berkeley is usually less than 30 minutes i from the time the call is made to the San Francisco DOE Office.
During off-hours it might take an hour.
2.4 City of Berkeley Under an agreement between the University and the City of Berkeley, the Berkeley Fire and Police Departments already play important roles ur. der present emergency procedures for the Berkeley Research Reactor.
Specifically for emergencies in the reactor room complex the Berke. ley Fire Deparment will be asked to respond immediately if
' their services are required. They will be notified of an accident or emergency if their services might become necessary. In the l
event of a fire or explosion or a life threatening injury, the l
' Berkeley Fire Department will be asked to respond immediately and will take charge responding to the fire, explosion, or injury as soon as they arrive on the scene.
For emergencies outside the reactor room complex, the Berkeley Fire Department will take charge upon their arrival on l
i
. l
)
l l
11 the scene.
The City of Berkeley Fire Department will take charge at the scene in the event of any accident occurring on City streets. If necessary, the Fire Department will contact the City of Berkeley Police Department for evacuation and traffic and crowd control.
The City of Berkeley Fire Department has procedures to respond to radiological incidents *. University = g ,. o r t will be coordinated through the Project Engineer and 'M&S (section 3.2).
The University will provide training to the City of Berkeley Pire Department personnel specific to the reactor removal project.
2.5_Emeroency Cc'3munications.
The emergency communication center for the campus is the University Police Department (UCPD). The emergency communication center for Berkeley is the City of Berkeley Department of Public Safety Communications Center (BDPSCC). These centers are reached by dialing the following numbers:
From Campus: UCPD - 911 (or 9-911)
BDPSCO - 644-6921 From Berkeley: UCPD - 642-3333 BDPSCC - 911 The University Police maintains a call liet for the University
- ueneral Crder 15.24. Fire Department Response to Peauetime Radiological Incidents.
12 emergency response organization.
The Emergency Command Post for energencies in the reactor room complex is Room 1110C Etcheverry Hall. The telephone numbers are:
415-642-5213 i
415-642-5224 1
2.6 Public Information Reporting of incidents to the general public will be through the Berkeley Campus Public Information Office.
}so Guidelines for Additional Emercenev Procedures 3.1 Emerce7eies in Etcheverry Hall As was noted earlier, attached to this document are emergency procedures taken from the draft Operation Manual for j Removal of the Berkeley Research Reactor. There draft procedures, revised specifically for the reactor removal project, are similar to those already used f or reactor operation. They I should be adequate for most emergencies that might arise in Etcheverry Hall during reactor removal. -
l Potential energency events in Etcheverry Hall not covered specifically by these procedures are identified in section 3.1.2 together with guidelines for new procedures to cover these events. :
13 3.1.1 Classes of Emercencies in Etcheverry Hall As noted in Section 4 of the Emergency Plan, general emergency response plan for nuclear facilities classifies 3 emergency conditions into four classes; 2) unusual events, 2) alerts, 3) site area emergencies, and 4) general emergencies.
Class 3 and 4 emergencies would require evacuation outside the BRR's operations boundary
- which encloses the reactor room (1140 Etcheverry Hall) and the patio directly above this underground room. However, as was the case when the reactor was operating, during reactor removal there are no credible ovents which can lead to emergency conditions which extend beyond this operatio..s boundary. All emergency conditions within the reactor room are
> classified as either an unusual event (class 1) or an alert (class 2). This includes emergenciec resulting from a major earthquake or. the Hayward Fault (see analysis in section 3.3.3). ,
In renewing the University's operating license in 1979, the NRC concluded that restricting evacuation to the area within the operations boundary is consistent with their requiraments.
3 1.2 Additional Procedures f o r_ .}mercencies Within Etcheverry. !
Hall A. Disruption of LSA Box A failure in integrity of one of these boxes could result in contamination of a small portion of the reactor laboratory und release of small amounts of radioactive dust into the
- Defined in section S.4 of the Emergency Plan
L l
14 reactor room air. The procedure for handling the disruption cf a LSA box during movement of the boxes or during truck loading should include as a minimums a) ascessment of conditions by the P'oject Engineer I b) possible evacuation and securing of the ventilation system c) reloading the box to the truck or crane d) if necessary, reloading the box ,ontente in new container and proper disposition of the failed box e) contamination control and recovery (draft Opera-tions Manual: Procedure 4.1) f) alerting the Berkeley Fire Department describing the nature of the accident g) if necessary, request for response from the Berkeley Fire Department-describe the nature of the accident.
B. Failu.r.e of epnfinement Barriers
- Pailure of one of the temporary confinement barriors erected to control the spread of radioactive material could result in general contamination of the remainder of the reactor c room and the release of radioactile dust into the room air.
The procedure to handle tre failure of emnfinement barriers should include as a minimum:
a) radiological assessment by the Project Engineer
- See Decommissicaing Plan, section 3.1.3.3.
16 b) possible evacuation and securing of the ventilation system c) contamination control and recovery (draft Opera-tions Manuait Procedure 4.1) d) barrier reconstruction e) alerting the Berkeley Fire Department describing the nature of the accident f) if necessary, request for r e spo5tse from the Berkeley Fire Department-describe the nature of the accident C. Crane Failure Failure of one of the overhead cranes could result in suspension of radioactive materials in an undesirable location or dropping of materials onto the floor. The procedure for handling a crane failure should include as a minimum:
a) radiological assessment by the Project Engineer b) possible evacuation of patio ( ch s f t Operations Manual Procedure 4.3) c) restricting access to a portion of room 1140 d) handling of unshielded or dropped fuel element (Procedure D below) or disruption of LSA box (Procedure A above) e) assessment of crane repair options f) crane repair either while loaded or following
16 unloading by other r.eans g) alerting the Berkeley Fire Department describing the nature of the accident ,
h) if necessary, request for response from the Berkeley Fire De. par tment-describe the nature of the accident D. Exposure from Strona Radiation Sources The procedure for handling a fuel element or other highly radioactive component that has become unintentionally unshielded should include as a minimum:
a) radiological assessment by the Project Engineer of both Room 1140 and patio above b) recovery /reshielding c) restriction of access to a portion of rcom 1140 I
d) possible evacuation of patio (draft Operations Manuali Procedure 4.3) e) alerting the Berkeley Fire Department describ t,%g the nature of the incidents request for response l
l i
E. Watey Leakins from the BMI-3 Cask The water in the BMI-1 cask provides shi21 ding above the fuel elements during cask loading. The loss of this water l
l would result in high radiation levels above the cask and .
could possibly cause radiation levels on the Etcheverry Hall l Patio to exceed acceptable levels for public accessible
17 areas. The procedure to stop and secure a water leak in the BMI-1 cask during fuel removal should include as a minimum a) radiological assessment by the Project Engineer b) stopping of the lesk c) consideration of reloading fuel to the reactor tank d) possible evacuation of patio (draft Operations l
Manual: Procedure 4.3) e) alerting the Berkeley Fire Department describing l
the nature of the accident f) if necessary, request for response from the Berkeley Fire Department-describe the nature of the occident F. EarthquaPe.
The emergency. response procedure for an earthquake which has a discernible effect on removal activities should include as a minimum:
a) possible evacuation of roon 1140 Etcheverry by the Project Engineer if there is danger of structural failure or if significant amounts of potentially radioactive dust have become airborne b) possible securing cf the ventilation system by the Project Engineer if he deems necessary c) alerting the Berkeley Fire Department describing the nature of the accident
4 18 d) if necessary, request for response from the Berkeley Fire Department-describe the nature of the accident Upon arrival all personnel from responding agencies should report to the Emergency Command Post-Room 11100 Etcheverry Hall.
3,2._Emfrgencies Durina Transportation of Radioactive Material.
Additional procedures will be required for the University's r radioactive material transport contractors. These contracts have ,.
not yet been awarded, but the University has set guidelines for f emergency procedures that will be required as part of the bid and award process.
Guidelines for coordination with the city of Berkeley are outlined in section 3.2.1. Potential emergency events during 1
transportation are identified in section 3.2.2, together with j guidelines for procedures.
3.2.1 _Emelgeacy e Response on 3erkeley Streets Fuel shipments will be escorted by a University Folice j vehicle, a Health Physicist or his qualified designee and the {
Berkeley Fire Department Engine Company staffed by the Hazardous ;
i Material Team personnel in which case the police escort and/or a I member of the hazardous material team will be responsible for j reporting emergencies. For LSA shipments, which will be f accompanied by a member of the University Police or a qualified designee, the driver of the contractor's vehicle and/or the i i
l 1
l 19 accompanying escort will be responsible for reporting emergencies.
Responre to emergency incidents on City streets will be as follows:
A) The driver, University escort or a member of the Berkeley Fire Department shall contact the University Po31ce Department and the Berkeley Department of Public Safety Communications Center giving complete accident and cargo information B) The Berkeley Department of Public Safety Communications Center shall notify the Berkeley Fire Department, and the Berkeley Police Department.
c) If emergency medical attention is required, immediate medical care and transportation will be provided by the Berkeley Fire Department.
D) The University Police shall immediately inform the Project Engineer and the Office of EHES.
E) The Project Engineer shall notify the NRC and other emergency call list personnel as necessary.
F) EH&S shall notify augmenting outside agencies including DOE as necessary.
- 0) Upon his arrival at the scene, the Project Engineer will provide specific cargo information and assist City Emergency Teams in assessing the situation.
20 H) Other responding University personnel, including representatives of EH&S, shall assist the Project l Engineer in performing his duties.
Upon their arrival, City Emergency Teams shall take charge and initiate their emergency procedures.
3.2.2 Additional Procedures for Emeraencies Durina Transoortation The areas covered by theme procedures include the truck passageway from room 1140 Etcheverry Hall onto Hearst Avenue and all the travelled streets and highways within the City of Berkeley, i
A. Transportation Accident with no Release _of Radioactive tLa terial The emergency response procedure for a transportation I
accident with no release of radioactive materials shall '
i include as a minimum:
2 a) notification by Campus escort or truck driver to the Berkeley Police and Fire Departments and Campuu Police ,
I b) notification by Campus Police to project staff and EH&S and City of Berkeley Environmental Health and i Safety '
j i
ci radiological assessment by project staff and EHES to assure that there has been no release d) Fire Department Command Operations shall be l
21 l instituted upon arrival of the Berkeley Fire Department e) extinguish any fires f) stoppage of the flow of liquid fuels, lubricants, etc.
t g) if necessary, bring in replacement truck and reload.
f h) crowd and traffic control, and roping off or evacuation in accordance with Berkeley Fire Department and Berkeley Police Department procedures.
B. ILa_n_s_p.o r t a t i on A c c i d e n t Involvino Relesse of Radioactivo tLa_terial The emergency response procedure for a transportation accident involving release of radioactive material shall include as a minimum items from 3.2.2A above andt a) reduction of radiation levels for emergency workers if required b) erection of barriers if necessary c) covering of loose radioactive materials to .
preclude dispersal by wind or rain d) if required, use of containers for spilt waste e) retrieval of spilled bulk westes and potentially contaminated underlying soils as necessary, f) apply diking material if necessary.
22 3.3 Supportino Analysis 3.3.1 Execsure from Ruoture and_Pire of a Tyne A Packace The transported radioactive material will consist chiefly of irradiated metals and concrete, packaged in sturdy boxes designed for the transport of LSA waste. A severa vehicular accident t
could result in the rupture of one or more of the waste packages being transported on the "Exclusive Use" truck. However, the radiological consequences of such an acc.i. dent , in terms of the potential for rsdiation exposure to the public or the spread of radioactive material into the environment, would be minimal.
This analysis deals with the rupture and fire of a type A package containing the most activated structural component of the reactor. The activated metal components such as the reactor support structure and the rotary specimen rack are expected to qualify as LSA material and will be shipped as an exclusire-use LSA shipment in a DOT-approved Type A container. The container is not yet identified but will most likely have shielding equivalent to 1.5 to 4 inches of lead. Although these containers are not designed to survive severe accidents, they are very substantially built.
These activated metal assemblies are solid and non-combustible and are not likely to become airborne in an accident.
If, however, during an accident a Type A container were to fail and the contents become exposed to intense fire it is possible come of the material could be dispersed. In this case the
23 maximum exponed 50-year committed dose to the lungs of an individual standing 100 meters downwind from the source for the duration of the cloud passage is 2.7x10-3 rem". The whole body dose from an airborne radioactive cloud at 100 meters downwind for 30 minutes is 7,0x10-6 rem.* The direct radiation dose to an (
individual standing 10 meters away f rom the radioactive source for the same period of time is 8.0x10-3 rem.' These exposures are less than the annual natural background radiation dose in the city of Berkeley by a factor greater than 10. These calculations are based on activated LSA products inventory on August 1, 1988.
3.3.2 Fue3 , Shipment _
Three shipments of fuel, each averaging 37 fuel rods, wil) ,
be required ;o move all of the fuel to the DOE repository in ;
Idaho. The shipments will be packaged in a Model BM1-1 cask, I
Certificate of Compliance No. 5957, licensed through August 31, i 1990. This cask has been previously used in shipping similar I fuel rods. t At the last renewal of the casks's Certificate of Compliance, submitted on June 20, 1986, a revised Safety Analysis :
Report for Packaging (SARP), Revision G, was submitted to the l NRC. Like presvious revisions, the latest revised SARP analyzes f the cask's ability to maintain integrity and prevent the loss of contents in the event of a postulated severe accident, including the effects of a "standard fire" (a radiant thermal source at
- Kaiser Engineers calculations submitted 7/14/88 and 8/18/88.
l l
l l
l 1
l 24 1,475 0F lasting for 30 minutes). This SARP concludes that this cask will remain intact, preventing the escape of radioactive ,
materials under all credible accident conditions.
The dose rate at 2 meters from the cask, regardless of orientation after an accident, will remain at the same level as f
at completion of loading. This rate is estimated to be less than 0.001 rem / hour, which is well below the level of 0.01 rem / hour at 2 meters allowed by DOT regulations. Some worker exposure would be anticipated during the reloading of the cask onto a second ,
vehicle, but it would be well within accepted standards.
3.3.3 Earthauakes The Hayward Fault runs in close proximity to the reactor l
room. It is reasonable to expect that a major quake on the i Hayward Fault could resu.t in some damage to or within the i l f
reactor room. The seismic safety of the reactor has been previously considered in independent studies by the original architect, an engineering consulting firm, and campus experts.
All three studies conclude that the reactor room should withstand l
the maximum earthquake which can be expected to occur on the I Hayward Fault and that the roof would not collapse.
In renewing the facility operating license in September 1979, the NRC calculated the dose to a maximum exposed member of the general public from an event that totally disrupted the core ,
and completely breached room integrity.* This analysis
- Attachment to license renewal, Sep 26, 1979.
25 showed that under such conditions the maximum exposure which could be expected from airborne fission products was 7.5 rem to the thyroid and 0.1 rem to the whole body of an individual at the edge of the reactor room. These calculated doses are well within limits set forth in 10 CFR Part 100 for maximum radiation post-accident radiation levels at the perimeter of a nuclear facility exclusion area, which in the care of the BRR is the reactor room and patio above.
Since the reactor shutdown on December 23, 1987 the radioactivity of the fission product inventory in the fuel has been reduced by radioactive decay. By July 1, 1988, the inventory of iodine isotopes (the primary contributors to thyroid dose) has dropped by a factor greater than 20 million and the l
total inventory of fission products has dropped by a factor of I more than 100. Therefore, the potential consequences of a l
l fission product release are substantially less than while the reactor was operating. On this basis, no change in emergency
{ preparations is warranted.
During the demolition of the rsactor the major source of material which could cause radiation exposure outside the reactor room is dust from demolition activities. In spite of strict dust control neasures r e stovi ng the radioactive concrete will necessarily generate some dust. Under assumed accident conditions involving complete collapse of the room and the subsequent release of radioactive ausi, the concentrations of various radionuclides will not exceed the limits specified for
26 airborne radau.7uclides in a restricted area (10 CFR 20, Appendix B, Table 1*). Although the airborne concentrations for some isotopes exceed the limits for routine release to unrestricted areas (10 CFR 20, Appendix B, Table II), the whole body dose equivalent to an individual located just outside the operations boundary for 15 minutes would be 2.5x10-3 rem, again far below 10 CFR 100 accident limits.
L4 ShipmeJt Notification Designated officials of the City of Berkeley will be notified of shipment data and time for all fuel shipments by the California Highway Patrol. The Berkeley Fire Department will be notified by the Project Engineer or his designee each day LSA shipments are considered.
- Kaiser Engineers calculations submitted 7/14/88.
_______________________-______________________-____________________-_______a
36
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- 4. EMERGENCY PROCEDURES 4.1 RadintlenIncidents Revt3 Septanber 7,1988 Approved by:
The purpose cf this precedere is to define preenutionary and prot::tive measures uhi:h shdi to t: ke the etcal:tlen of an event end to mitigate the potenti:1 consectuences of the event. Att personnel work the site boundry. room 1140 Etcheverry Hall, cr:::sponsibic for proper r:spons: und:t this pro:: dure.
4.1.1 Min:rincidenu Minor in:Id:nts us dean:d at: c) surfste contamination of equipment er of a sms!! se: tion cf the res:
wh:r: th:re is no'h :hh huuds and no obnormal conditions beyond the connnes of the res:ter lab; and b Unusual Events' for radiation emergen:ics os defined in the DRR Emergency Respons: Plan. A minor might be c:us:d by puti:utst: emissions within th: lab from an experiment or a spill of a r In the event cf a miner in:Ident the en site personnel sha!!:
- 1. Netify th: Re::ter He:.hh Physi:Ist(2 5224) er in his :bs:nce ne Decommissioning Proj::t En;i
$213).
- 2. Iselate and 1:hel u:a to svold sprestin; cent:mination. Remain in th: ces.
- 3. With the assistan:e cf the Res:ter Heshh Physleist check personnet fer centamln: tion.
4 Cle:n th: contaminstlen to b::kground levels.
- 5. Keep the cres isolated until released by the Resetcc !!cshh Physielst.
- Area mentter reads cbove its high set point sis:kgas moniter re:ds above 1500 cpm. cir puti:ulats monit:r reads above 3000 cpm.
^
t 37 h
i 4.1.2 Ma}orincidan 1
Major in:! dents are deftried as: a) surface contamination of a significant pordon of the laboratory, s tamination beyond the limits of the laboratory; b) Alerts
- as defined in the BRR Emergency Response Ph in the event of a major incident the on site personnel shalh .
- 1. Vacate the laboratory, leaving contarninated materia'. Including clothing, behind. Depending upon cumrtances, personnel may evacuate through the normal access door or through the decontamination t
i 1
- 2. Netify the Reactor Health Physicist (2 5224) and the Office of Environmental Heahh and Safe!
2 3073) of the incident.
t
- 3. If necessary, activate the emergency ventilation system from the console prior to evacuation. Emerge f ventilation can also be engaged from the reactor office. If no one on site is trained on how to switchf l l 1
ventilstion system to emergency, notify EH&S.
4 All persens evacuating the laboratory will remain in the alt lock or decontamination room untill been checked by the Ren:to' Health Physleist nnether representative of EH&S or the Reactor Staff.
- 5. All persons, except monitoring and nscue teams under the direction of the Decentmiss
- 6.gineer, will remain outside of the Rea: tor Laboratory. i
[
Notify the Berkeley Pub!!: Safety Dep:etment Communications Center and the Berkeleyl j 6.
Environmental Health and Safety. 'lle Berkel:y Fire Depsttment will respond with a representative {t assess the situadon. i
- 7. The UC Of0cc cf Environmental Health and Safety shall assist in decentsmin
- den.i i
l 1 ;
l '
L i' [
i f
(
U i
- Substandal damagt of fud elements, loss of pool water accid:nt, or ou cf th: fo!!owing: area monitor [
reads abovs Gye times its high set point, stackgas monitor reads above 7500 cpm, sir particu!ste moniter [
reads above 25,000 cpm.
f i
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1 38 -
4.1.3 Personal Contamination in the event a person is contaminated:
- 1. Remove the person from the contaminated area to a place such as the decontamination room, reactor hall-way, or Etcheveny Hall driveway (if further transportation is necessary).
- 2. Tr.ke necessary first aid to save life er prevent serious injury.
- 3. Requ:st medical assistance through the Carrrus Police (2 3333 or 9 911) Derkeley Deps.rtmerit of Fabli:
Sefety Communications Center (644 6921) If needed. Medical care and transpotution of injured persons shdl be provided by the Derketcy Fire D:psrtrnent.
4 Notify the Berkeley Fire Department of injuries irmotving radiological contaralnatjen.
$. Report in:ident to Res: tor Health Physl:ist (2.$224) and EH&S (2 3073) immedistdy.
- 6. Do not attempt decontamination cf en injured persen without censulting the attending physl:l:n or Reacter H::!Lh Physicist, or EH&S technologist.
- 7. Initial decontamination of uninjured persons by washing in decontamination room may te begun prior to the errival of the Res:'.or Health Physicist or another EH&3 technologist. No other means of decentami.
nation should be attempted without consulting th: Reactor liedth Physicist er anot!er EH&S technologist.
. . 39 4.2 Evacuation ofItoom 1140 Etcheverry I!n!!
Rev: 2 August 16,1988 Approved by-This procedure speel$es the sedons required to !!mit exposures to abnormal levels of radiadon within the Rea:.
tot labnratory. It is the responsibility of all on. site personnel to evaluate the need for evacuating the room and to contact the Decommissionin8 Project Engineer (DPE), his Deputy, or designes hereafter referred to as the DPE.
It is the DPE's responsibility to reevahate the need for evaeustion and if he deems necessary order and assure orderly and prompt evacuation of11oom 1140.
In the event that radistlen levels are approaching a level that might recluire room evacustion the on. site person.
nc! shall:
- 1. Immedittely determine the nature cf the emergency
- 2. Conta:t the DPE and inform him of the situation.
The DPE shd! det:rmine if esa:ur.tlen is warranted. If W, he sh:11 instruct the on site personnel to:
- 3. Eva:uste the entire room immediately by issuing a verbst order end activating the emergen:y eva:ustion i alarm i
4 If d:cmed acetssary by the DPE, switch the ventit tlen to emergency l
- 5. Asscre that all persons leave the room immediately
- 6. Assure that all evneusted persons shall be connned, either in the decontaralnation room or in the alt lo:k between the two er.vance doors, until the following steps are taken:
- a. The rames and addreases of all persons are record:4 T
- b. Checks are made for radioactive contamination of individuals
- c. Checks are made for injury
- d. Data are obtalmd to asumate individual radiation caposure
- e. The Oface of Environmental 11ealth and Safety has been nodfacd of the evaccation
- 7. Inform the DPE and Reactor AdminIstater of the avscuation
- 8. If room evaeusdon was ordered, the DPE shall inform the Campus Publi: Information OfAce and the Welcar Regulatory Commission of the room eva:ustion.
- 9. If he deems necessary, the DPE shall inform the Berkeley Fire Department of cont:tmination hazards.
. t 40 f
4.3 Evacuation of Etcheverry ifall Patio Rev: 3 September 7,1988 l Approved by:
This procedure speclass the actions to be taken to prevent exposure of individuals to abnormally high levels of l '
radiation on the Etcheverry Hall Patto. The Decommisaloning Project Engineer (DPE) or his deputy, hereafter r
refstred to as the DPE,is responsible for making an assessment of the situation and informing the Director of the Ofoce of Environments! Heahh and Safety (EH&S). The Director of EH&S or his/her designee has the r
responsibility to reassess be need and if deemed necessary of ordering the evacuation of Etaheverry Hall Pati i
If in the opinion of the DPE a situation warrants the evacuation of the Etcheverry Hall Patfo, including the grass ,
1 lawn and north and south walkways, the following procedures shall be fo!! owed:
j
- 1. The Decommissioning Project Engineer (DPE) shall establish a communication lir.k with the Director of the OfAce of Environments! Health & Safety, or his designee, and with the Campus Poli:e. l
- 2. Upon advice of the DPE the Director of EH&S or hl designee shall order the Campus Police to eva:vate ,
Echeverry Hall Patio. l
- 3. The Poli:e superviser en duty shall assign an officer to be in charge at the scene and dispatch oracers te I
immediat:1y eva:cste Etch:verry Hall P:tio, including the grass lawn and the north and south walkways. '
He shall also send an ofacer to Room 1110 Etcheverry Hall (Emergency Suppert Center) for further instru:tions.
4 The usigned officers shah clear the entire patio, including the volleytell court, the north an<l south walk. f way, and the grass lawn of all persons, J
- 5. The ofacer in-charge shall post a NO ENTRY sign and rope off a restricted area that in:ludes the vo!!ey. f ball court, the nonh and south walkways to the volleyball court, s'id the grass lawn. [
l
- 6. The DPE shall also establish a communleation link with the Campus Publl: Information Of6ce.
r r
- 7. At least one police officer shall be assigned,24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, to assure that no individual has access to the restricted area until the emergency is serminated by the Director of EH&S. f
- 8. If patio evacuation was ordered, the DPE shall inform the Campus Pubtle Information Office and the f s
Nuclear Regulatory Commission of the evacuation,
- 9. If he deems necessary, the DPE shall notify the Dcrkeley Firo Department of contamination hasards. '
4
. 41 -
4.4 Response to Fire or Explosion Rev: 3 September 7,1988 Approved by:
The purpose of this procedure is to assure that a fire o assure th:t this procedure is followed.
In the event of fire or explosion in room !!40 Etcheverry, the following procedure sha personnel:
1.
Ite/she shall notify the Camps Po!!:e and Berkeley Fire Departinent by activating t or by dialing the emergen:y number 9 911. Pull boxes of the put. box shall be fo!! owed by a call to the Campus Police and/or the Berkeley 2.
If tha are is small or in its incipler.t st:ge, he/she may attempt to cont:In or exting able fire fighting equipment. Fire extinguishers are locat:d on the west wall ad ing doors, on the north wall below the res: tor console, and on the cast ws!! on the res:ter 3.
If necessary he/she may request the Decommission!ng Project Engineer (DPE) evneustion of the reseter 1sboratory by the main room exit tref Procee.kre 4.2). If possi ventilation should be a:tivated before eva:ustion.
d.
The most senior personn:) will remain in chstge until the DPE strives. The DPE t!.e iclice and the Berkeley Fire Department regarding radiation hazards.
5.
The DPE shall info,m the Res: tor Health Physicist (2 5224) and the Ofnee of Env
$sfety (EH&S) cf the incident.
6.
Radiation monitonng shall be performed throughout the emergency operation w EH&5.
l l
s.
42 4.5 Civil Disturbance Rev: 1 September *1,1988 Approved by:_
This procedure provides nettons whleh minimite the possibilit given to civil disturbances. However, each Nue! car Eng.ncering Department ernployee, studen should assume as his/her responsibility the task of notifying others present of any impending disturbanc In the event a disturbance does occur:
1140,1110,1106) shall be to:ked re.d
- 1. All Nuclear Engineering Arst Docr rea:ter comples areas (rwms vaented at the Orst hint of a disturbance near Etcheverry Hatt.
2.
The DPE or designee shall n:tivate the door starm and notify the c.,mpus police when th: rea:ter tab tery is vacated.
< 3. All personnel shall proceed to the Nuc!:ar Engineering Department of0:e,410$ Etcheverry Ha l
oth:r locatien spe:lSed by the DPE, or the Campus Po!!:e for further instru:tions.
NOTE: The use of the elevator during a eMI disturbance is not advised.
. . 43 4.6 Domb Threat Rev: 1 June 9,1988 Approved by:
The purpose of this procedure is to secure as much informstlen as possible about a bomb threst. It applies to any form of a bomb threat clear by phone, writing, or other means.
In the event a bomb threat is received, the person receiving the message shs!!:
1, If by phone, keep the caller talking as long as possibic and make written notes of the fotbwing:
- a. The time and date of the c:ll
- b. The assurned age and sex of the es!!er .
I
- c. Any disdngalshing speech charset:risti:s
- d. Wh:t was st.!d by the caller, as precisely and completely as possibt:
- c. Any ba:kground noisi that may help to identify the source of the ca!! l
- 2. Notify, as soon as possible, the Campus Po!Lcc (2 3333,9 911), Rea: tor Administrater (2 7071), De:cm.
missioning Proiect Engineer (DPE,2 5213).
- 3. The Campus Police shs!! investigste the call and take whatever police action may be deemed necessary and reasonable for the safety of the campus community.
4 The Nuclear Regulatcry Commission s5.sil be notined of any bomb threat to the re::t:r or to Et:heveny Hall. During workJng hours, this notineation shs!! be made by the DPE. During other pericds, notinestion shs!! be made by the individus! on the emergency call list (Appendix A) cents:t:d by the pol.
Ice.
I I
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44
\
- 4.7 Injury 4
Rev:3 ,
September 7.1988 f
Approved byr i
l '
The purpwe of this procedure is to list the proper steps which assure prompt response to an injury in the reactor !
room. All on site personnel are responsible for carrying out this procedure.
- t In the event of an injury, on slis personnet sha!!:
- 1. Apply emergency fir;t a!d to sustain life or prevent excessive biceding, t
) )
- 2. Call the Campus Police (911,9 911,2 3333) and the Berkeley Depanment of Public Safety Commun!ca. [
f tions Center (644 6921) immediately and give the location and nature of the occurren:c. Medi:s! care 1
ar$ transportation of injured persons shall be provided by the Berkeley Fire Department. l t )
- 3. The established campus policy regarding medical emergencies is that persons with non life threaten!n; injuries may be taken to Cowc!! Hospital on campus and s!! ambulance cases are to be taken to Alta Bates !
). l
] Hospital or as designated by the Alameda County Emergency Medical Services OfAcc.
- I l
4 University patrol vehl:les contain equipment to assist the responding ofacets in providing first aid u an l l injured person.
[ t l i
- 5. In ecmpliance with campus policy, emergency medi:al supplies are not kept in the rea: tor facility, 4
i 5
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45 4.8 Off. hours Emergency Alarms Rev: 3 Septunber 7,1988 Approved by- _
This procedure provides for uniform and coordinated response to potential emergency cond*Jons w ter room during off hours. Ahrm condidens are detected by the campus police who ha e the respon nodfying individunts on the Rea: tor Emergency Call List (Appendix A), and responding to the scene responding ofacer and emergency call list personnel have the responsibility to ascertain the extent len and take corrective a:tions as necessary.
An emergency condition which develops during off hours will normally be detected by at least one of t alarms in the Campus Police Othee. The three possible alarms are high radiation, open door, or low po Thes: o!stms and their Any em:rgen:y slum, reg:rdless of its suspected nature, shall be treated :s res!.
response procedurea are as fo!!ows:
Pool Water Alarm The pool water alum is a:dvated by a low water level in the reactor pool, if the pool wat:r 1: vel alar the fo!!owing procedure shall be fo!! owed:
- 1. The Campus Pouce ofocer on duty shall telephene the reactor laboratory (2 2636/3224/3213) to as the cause of the abrm, if it is known that persons are working in the laboratory.
- 2. If no one answers the call or if the phones are inoperadve, the officer en duty shall dispatch an ofacer to room 1110 Etcheverry Hall to investigste.
- 3. The efacer en duty shall then follow the procedure for calang persons en the Res:ter Emergency Call t.
(Appendix A).
4 The person es!!ed by the police shs!! repon to Etcheverry lisit immediately.
- 5. Hehhc shall determine the cause of the alarm or have it determined without undue delay and take the necessary corrective action.
- 6. If the situation warrants, other emergency procedures shall be followed.
- 7. If the situadon warrants, the Berl.eley Police Department shall be notlSed of too situnden.
- 8. If deemed necessary behhe then shall nodfy someone on the Environmer.ts! Hestth and Safety (EH&S) reactor emergency personnel list (Apperdit D).
- 9. If the situadon warrants, he/she sha!! nodfy other individus!s on the Reactor Emergency Can Liss
- 10. Hehhe sh U prepare a short written repen in the reactor logbook.
.46 ,
- 11. De Decomniissioning Project Engineer (DPE), Reactor Administrator, and th: Reactor Health Physicist shall be informed of the incident on the rext working day (see checksheet Appendix E).
- 12. If involved, the Ofoce of EH&S shallissue a report describing the incident and actions taken.
- 13. The Campus Police shall file a report of the incident with copies to the DPE, Reactor Administrator, the Ofoce of EH&S.
- 14. The DPE is responsible for rt.poning the incident to licensing agencies as required, with copies of writte reports to EH&S and the Reactor Hasards Committee. !
- 15. For false alarms, as determined by the responding person, items 86 through 9, and 12 through 14 will :n a
apply, however corrective action and/or determining its source sha!! be established and record rea 'cr and/or maintenance legbook(s) within the next working day. '
1 l Radiation Alarm i &
l The radiation alum to the Campus Police is activated by any one of the nine area radiation moniters, gas radia:Jon monitor, the air paniculate monite , or he wcter cdladen monitor. Note that the C 1 j receive only a single alarm and cre unable to determine which of the ndiation monitors activated the '
If the Campus Pollec necive a radiation alarm: i 1 !
- 1. The Campus Police officer on duty shall telephonc the reactor laboratory (2 2636/3213/3224) l the cause of the alarm, if h L: know n that persons are working in the laboratory. l
- 2. If no one answen the call or if phones arc inoperative, the officer on duty shall dispatch an offlect to '
j room 1110 Etcheverry 11a11 to investigst:.
j i The officer en duty shall then follow the procedur:s for calling on the Reactor Emergency Ca:1 !
3.
1
- (Appendix A),
- 4. The person called by the police shall repon to Etcheverry Hall immediate'y, 1
- 5. Hehhc shall dciermine the cause of the alarm or have it dciermined without undue delay and uke the necessary action.
6 If the situation warrants, other applicable emergency procedures shall then be followtd.
! If the situation warrants, the Berkeley Police Deparvnent shall be notlSed of the situation, l 7.
- 8. gecy he/she shall then notify the Office of EH&S special reactor une:g
- 9. Hehhc shall prepare a short written report in the reacter logbook.
i
- 10. The Decommissioning Project Enginect (DPE) or the Reactor Administrator and the Reactor Health Physi.
l cist shall be informed of the incident within the next working day (s:4 checksheet, Appendia E).
v I
.47 i
' 11, if involved, the OfSce of EH&S shall issue a report describing the incident and actions taken.
- 12. De Campus Police should Gle a report of the facMent with copics to the DPE, the Reactor
< and me Ofau ofEH&S.
13.
De DPE is responsible for reporting the incident to licensing agencies at required, with cop r:poru to EH&S and the Reactor Hazards Committee, 14.
For false alarms, as determined by the responding person, items #6 through 9 and 12 throug apply, however corrective action and/or determining its source shall be established a operations an#or maintenance logbook (s) on the next working day.
l, Door Alarm 4
The reactor room door alarm will be activated by cpening any one of the three entrances t J
tory or the door to the decontamination room in the altlock
}
Ca:npus Police shMI fo!!ow the following procedure:
l I 1.
The Campus Polke of6:er on duty shat! dispatch otocers to Et:heverry Ha!! to check entrances.
3 2.
The efaces on duty shall then fo!!ow the procedures for calling on the Reactor Emergenc j
) The person ca!!cd by the police shall report to Etch:verry Hall imm:diately.
1 3.
- 4. Hehhe shfl d:t:rmine the cause of the starm or have it determined without undue delay necessary corrective a: tion,
- 5. Hehhe shdi prepare a short wriuen report in the rea: tor logbook for the SRO in c j
ing day.
j 2 6. If the situation warrants, behhc shall notify other (tidividuals on the Reactor Emergen:y C l dit A).
' 7, if the situation wants, Campus Police and BRR security procedures shall then be followed.
\ The Decommissioning Project Engineer (DPE) or the Reactor Administrator sha!! be in 8.
incident within the meat working eny (see chechsheet, Appendia E).
I
- 9. De Campus Polke shall Glc a report of the incident with copics to the DPE, the Reac l
f and the Oface of EH&S.
10.
The D?E is responsible for reporting the incident to the licensing agencies as require wriuen reports to EHAS and the Rea: tor Hazards Committee.
l 11.
Fer false alarms, as determined by the responding person, items 86.7,9, and 10 will not apply, cortcetive action and/or determining its source sha!! be established and recorded in the op:tati j
maintenance logbook (s) within the next working day.
I L _ _ _ ___ _
48 Appendix At Emergency Call List June 3,1988 CEN1RIX Home Offte Extention ,
Reactor Supervisor / Decondssioning Project Engineer 2 5213 527 4314 Tek I im 2 5224 Chief Reactor Operator iDeputy Deconnissioning Project Engineer 2 5224 549 1788 Mi:h:c! Denton 2 5213 Reactor He:hh Physicist 2 5224 785 3098 Peter Verni; 2 61M ,
Scntor Rcattor Operator i Electronics Shop Forenun 2 1021 525 1196 H. Ja:kson ihrr:ll 2 5224 Prclessor 525 1838 Selig Xspha 2 5341 NOT1CC TO POLICC: To report an abrm phone Ext. 2 2636 and ask for the reacter console. If you are told that the rea: tor is not operating, then ask for the above individuals in the order listed. Ext 2 2636 is connected enly to the Rea:ter Console, th: Chief Rescist Operator's Office, and the Res: tor Superviscr's Offtet.
Ifno answee en Ext 2 2636 proceed as spe !fied in the Emergen:y Plan.
i Fcr evacuation of Etchtverry 11:11 Patto and non campus strccts and residences, authoritation is required bys Director cf EHL5 654 9136 Elaine Bild 2 9116 l t
Ahernate Radiation Sqre ty Oficer 2 6166 525-4535 Andtts Peterson For furthee assistancs contact Reactor Ad.dnistrator 2 7071 939 9324 T. Keaneth Fowler 2 5010 2 6160 .on tmergency Campus Po!!ce r 2 3333 cmergen:y only r
i
r
.49 i
Appendla D EH&S Emergency Call List I
June 3,1988 j i
--(415) 642 4073 Ofice of EH&S (normal working hours) -:-
After Hours Request for assistance. ..
-(415) 542 6760 through sampus police or (415) 642 3333 EHAS personnel available for emergeu:y response are divided in two groups: redladon!
hygiene,1.re safety. Name, titles, home phone numbers, and pager numbers are as follow s: !
Descriptive Title Campus Home ! ster Name
- i Direclor !
2 9176 6549136 Elalnc Dild Director EHis I Radistlen Safety Radiatien Safety Offs:ct 2 6166 526 4535 636 5763*
Andris Petenon 3 9105 785 4 098 Peter Vernig Rea:ter H:sith Physicist 2 5224 l Senior Hestth Physicist 2 6167 934 1892 Michsd Schoonover 6'28 8306 Heshh Phy:Ictst 3 9242 Mvk Yokoro j.
Industrial Hygtent and 11re Safcty ;
i Industrial Hyglanist 2 1925 838 4504 '
Ben Gonza!es 689 9559 Fire Mariha!! 2 4409 Eddie D' Andre 724 1250 l Indastrial Hygicalst 2 1977 Ri:k Kelly j Industrial Hygienist 3 8065 (707)426 55S1 Ross S :djee t
- Pagers are worn only during norm:1 working hours (8 5) l t
f l
?
t i
e
50 Appendix C Medient Assistance For injuries 5hlch are not serious, injutto personnel may be taken to Cowell Memorial Hospital on the Berkeley Campus. However, fer serious injuries er for esses of serious contamination padenu are to be taken to ,
Besicley's Alts Bates Hospital. If there is any question stout the seriousness of the injury or about t!.e seriou..
ness of the effett of a ndiadon einergenty, the poder:t is to be taken to Alta Bates Hospits!.
Emergency trusportstion of injured pe ens to a hospital shall be by ambulance from the Derkeley Fire Depart.
ment.
First a!d assistance can te provided by the Ca.npus Police. The Campus Police are trained in first a!d a.9d a'l polies cars are supplied with first aid kits.
Phene Numbers:
Campus Poliee .. .. ..- .. . . .... . . .. . . 64 247f4 C:.mpus Poli e Em r.eney Numbers . ..... . . ... . 642 3333 cr 9 911 1
4 Berkeley Departmen' of Public $sfety Communications Center.. .. .. . 6444021 Cowell Memerist Hes;iul. . . . .. . . . .. . .. .. ... .... .(A 2 31 ! 3 Alta Date: Hespits! ... . . .. . ... . _ . 540 0337 Informaticn 3001 Co;by ct Ashby, Berkeley . .. ......... . . .. ..... .. 5s01303 Emer;cr.ey 1
. l l
l 1
Appendix D: Augmenting Off Campus Organizations
- United States Department of Energy Emergency Response Team
_ . 415 273 7963 Request for Radiological Assistanee Team.
. ... .. . . 415 273 4237 24 Hour number . ...
California State Department of Ilealth The Ftate Bureau of Radiological health does not provide emergency assistance. However, the State must be ~
notified when a signi6c.at release of radioactive material has taken p!sce. This notifiestion will be handled the OfGee of Environmental Health and Safety.
. ... ... .. . .. ... 916 3917716 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> number (OfDcc of Emergency Services). .. . ..._....
Lawnnte Derkeley Laboratory (LDL)
The Lawrence Berkeley Labor; tory is a DOE contract organization and as suc5 it theuld not be djrectly involved in any response to an emergency on Campus. However, assistance from LDL nmy be obtained of the DOE Radiological Assistance Plan or on request from the Of6ee of Environments! Hestth and Safe 415 486 5251 LBL Environments! Health and Safety .. . .. . . . .. ..~..... ~...... ..
Other numbers:
.. .. .... ... .....~415 577 1031 Alamcda County SherifI's Off ee . .. .. ... .~.....
Callfornla Highwsy Patrol ....m. ....... ....m. ..... .. ....... ...... ..... ...... ... ... 415 65 8 9115 B erkeley F.B.I. Of 6ce ......... .... .. .. ~. ... ....... .... .. .. ~.. 415 4 52 3950
... .. . .... .. .. 415 540 0337 Alta Bstes Hospits1 .. ... . ... ... .. d Callfornla Environmentr.1 Protection Agency .~ ._m ... ..... . .. .... .. .. ... 415 273 7502
. 415 5771332 i xal Civil Detense OfSee of Emergency Services. ... .. . . ..
... .......... . .... 415 943 37CO Nuclear Regulatory Commission Complinnee Of6ee..... .. .
Campus Publie Irlormstion Of6cc . .. .... . ... . .. . ... . . .. . . 415 642 3734
. .. .. . .. . . .. .. ... 203 677 7305 American Nuclear Insurers ...m. ... ..
. $2 -
[ ..
l-a Appendix E: Off Hours Alarm Checksheet i,
April 11,1985 Date:
Time:
Alarm type and time:
Reponed by OfDeer:
Responding Of6cer:
Inspection and Results:
EH&S Person No!!aed:
Note to SRO on console:
UCPD Oface notified:
Reported to:
Reactor Administrator ,
Decommluioning Project Engineer Follow needed: ,,
i Comment: .
Responding Peergency Call List Personne!!
t
9
$~.
l L
DAVID R. PIGOTT ' 0!69.f 0 1 ~""'
JANE B.KROESCHE 2 ORRICK, HERRINGTON & SUTCLiFFE 600 Montgomery Street San Francisco, CA 94111 g g 3 R2'43 3
(415) 392-1122 la -
't I 4 ' x 4<v'C
" f' Attorneys for Licensee
- I $11H-5 UNIVERSITY OF CALIFORNIA, t BERKELEY 6
7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION _
8 9 ATOMIC SAFETY AND LICENSING BOARD 10 Befcte Administrative Judges Helen F. Hoyt, Chair 11 Glenn Os Bright James H. Carpenter In the Matter of ) Docket No. 50-244-OLA 13 )
UNIVERSITY OF CALIFORNIA, ) ASLBP No. 88-574-07-OLA 14 BERKELEY )
) CERTIFICATE OF SERVICE 16 I am a citizen of the United States and employed in San 17 Francisco, California. I am over the age of 18 years and not 18 a party in the within action. My business address is 600 19 Montgomery Street, San Francisco, California 94111. On 20 November 23, 1988, I served a copy of the following 21 documents: Joint Motion for Dismissal of Hearing Procedure 22 and Settlement Agreement, together with attached Appendices A and B, by placing a true copy thereof enclosed in a sealed
~
23 24 tope with postage thereon fully prepaid in the United f 26 77 28 //
5659k
n' o
1 States Post Office mail box at San Francisco, California, 2 addressed as follows:
3 Helen F. Hoyt, Chairman Docketing and Service Section Glenn O. Bright, Office of the Secretary 4 Administrative Judge U.S. Nuclear Regulatory Comm.
James A. Carpenter, Washington, D.C. 20555 5 Administrative Judge 4350 East West Highway Joseph Ruthberg 6 4th Floor Deputy Assistant General Counsel Bethesda, Maryland 20814 Office of the General Counsel 7 U.S. Nuclear Regulatory Comm.
Mr. Milton Gordon Washington, D.C. 20555 8 Office of the General Counsel Manuela Albuquerque, City Attorney 9 University of California Marjorie Gelb, Deputy City Attorney 590 University Hall Jonathan Rothman, Assistant Attorney 10 Berkeley, CA 94720 2180 Milvia Street, Fifth Floor Berkeley, CA 94704 11 Adjudicatory File Atomic Safety and Licensing' 12 Board Panel Docket 13 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 ."
14 Atomic Safety and Licensing i5 Board s
Appeal Board Panel 16 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 Atomic Safety and Licensing 18 Board Board Panel 19 U.S. Nuclear Regulatory Comm.
Washir.gton, D.C. 20555 I declare under penalty of perjury that the 21 foregoing is true and correct.
Dated this 23rd day of November, 1988 at San 23
+
Francisco, California.
r 25 ,. :
2d . Laura A. Micheli s e- !, ,
2 5659k