ML20011F135
| ML20011F135 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 02/19/1990 |
| From: | Hirsch D COMMITTEE TO BRIDGE THE GAP |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#190-9927 89-594-01-ML, 89-594-1-ML, ML, NUDOCS 9003010241 | |
| Download: ML20011F135 (85) | |
Text
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.p Comittee to Bridge the Gap' 19 February'1990 00CKEiED
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1637 Butler Avenue, Suite 203 USNRC los Angeles, California 90025
% _ FEB'21 P5 :35 0fTICE OF SECRETARY UNITED STATES OF AMERICA DOCK [11NG A SLHVICL f1 RANCH '
U.S. NUCLEAR REGULA70RY ODMISSION I
A70MIC SAFETY AND LICENSI!G BOARD Before Administrative Judge Peter B. Bloch In the Matter of
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Docket No. 70-25 ' N ROCKkELL INTERNATIONAL
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CORPORATION
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ASLBP No. 89-594-01-ML Rocketdyne Division
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i (Special Nuclear Materials )
' License No. SNH-21)
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DIRECI' CASE 00fMITIEE 20 BRIDGE THE GAP
' Introduction
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A.
The Legal Standards for Granting of Special_ Nuclear Materials Licenses Require that Rockwell's Request g Denied i:
According to the Atomic Energy Act, it is illegal to utilize or i
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produce nuclear materials without a license issued by the Commission.
(Section'101).
Applications shall be granted or declined based upon a determination of the technical qualifications, the character of the applicant, and such other qualifications of the applicant as the Commission may deem appropriate for the license.
(Section 182a).
9003010241 900219 L
PDR ADOCK 07000025 C
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For licenses for Special Nuclear Materials (SNM), the Commission has by
-regulation set out criteria for what must be in such applications and on what basis the Commission can and cannot approve such aglications.- 10 CFR 70.31(d) states:
No license will be issued by the Commission to any person within the United States if the Commisssion finds that the issuance of such license would be inimical to the common defense and security or would constitute an unreasonable risk to the health and safety of the public.
Health and safety concerns underlie all CBG's concerns in this proceeding.
It is our belief that issuance of the license renewal would indeed constitute an unreasonable risk to the health and safety of the public.
10 CFR 70.23(a) identifies a number of features required of applicants for SNM' licenses.
It is our belief that Rockwell fails to meet these standards and the Commission is obligated by law to deny the requested license.
%e concerns that follow are associated with failure to meet the following regulatory standards, in addition to the 10 CFR 70.31(d) standard above:
"h e applicant is qualified by reason of training and experience to use the material or the purpose requested in accordance with the regulations in this chapter."
"2e applicant's proposed equipment and facilities are adequate to protect health and minimize danger to life or property" 10 CFR 70.23(a)(3).
"The applicant's proposed procedures to protect health and to minimize danger to life or property are. adequate."
In what follows and in the simultaneous submissions by our fellow intervenors, in which we join, we will demonstrate that the Applicant has 2
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failed all three tests.
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1 The regulations further expressly require Rockwell to "make every l
reasonable effort-to maintain radiation exposures, and releases of radioactive materials in effluents to unrestricted areas, as low as is reasonably achievable." 10 CPR 20.1(c).. This Rockwell has clearly failed to do as well.
Finally, the~ applicant must have the character necessary to be entrusted with such dangerous materials. In particular, the regulatory agency and the public must be able to rely with high confidence upon the statements made by the applicant about its proposed activities, and by licensees about their actual activities.
10 CFR 70.9(a) states that information provided by an applicant for a license or by a licensee "shall be complete and accurate in all material respects." 10 CFR 70.9(b) goes further and requires prompt notification of any information having a significant implication for public health and safety or common defense and secu r i ty."
It will be seen that one cannot make the requisite finding of ability to rely upon Rockwell for timely and accurate representations about important health and safety matters.
Each of the concerns that follows touches upon these regulatory failures.
Rather than repeat the same regulatory language after each concern, the above is included therein by reference.
Other specific regulations that are involved. relative to specific concerns will be discussed in addition.
As to the relief requested, it should be noted that the intervenors are not actually requesting relief. It is the applicant which is requesting federal action, the granting of the desired license, and it is the applicant (Rockwell) that thus has the burden of proving that such granting of the license can be done without unreasonable risk to public health and safety.
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c It is our belief that Rockwell has fallen far short of meeting that burden, e
and that the only legitimate response by the NRC is to deny the requested license. We believe that each of the concerns that follows merits such a response individually, and that there is no question of that result when the concerns are considered collectively.
Thus, license denial is the response we believe is appropriate with regards each concern that follows, and that-reconsnendation is included by reference for each.
Rockwell has not met its responsibilities, past and present, under the regulations.
It is unlikely, given Rockwell's continued and pervasive evasion of these safety requirements, that Rockwell's behavior will change.
Therefore, CBG requests the only reliable relief:
denial of Rcokwell's application for renewal.
B.
Rockwell Cannot Meet Its Burden of Proof With Regards Safety Rockwell basically has only two alternative ways to attempt to meet its burden of proof that it can be entrusted to safely utilize requested Special Nuclear Materials. It can either demonstrate that the quantity of plutonium
-requested is so vanishingly small that it cannot conceivably pose a public health and safety threat even if accidentally released to the environment, l
no matter how inadequate its procedures, training, equipment, and past record. Or it can admit that the quantity requested is radiologically significant, but that its procedures, equipment, training, and experience are such as to provide high reliability that it can prevent an accident from occurring.
We will demonstrate in what follows that neither claim can be honestly made by Rockwell. Its assertions about the allegedly minor safety risks 4
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j, associated with the requested plutonium are based on assuming only a, billionth ol sj of the plutonium gets out in the allegedly ' worst case" accident.
We shall show that this 10 9 " fudge' factor is based on absurdly L
optimistic assumptions and misrepresentations of the study they themselves cite as their sole support. And we shall show that the quantity of material requested is so radiologically dangerous that release of any reasonable fraction of it in accident (such as fire, for example, because of the pyrophoric nature of plutonium metal) could be very serious from a public health and safety standpoint, far exceeding permissible regulatory limits of exposure.
We shall also show that Rockwell's past track record and current practices _ disqualify it from being able to provide the necessary assurance that it can handle these dangerous materials safely + Rockwell has not handled such materials safely in the past; it cannot be expected to in the future.
The best data for determining whether to entrust dangerous materials to a prospective licensee is an examination of its record in handling such materi' tis in the past.
Here Rockwell fails miserably.
Other Intervenors J
(particularly Jon Scott, Estelle Lit, Jerome Raskin, the Susana Knolls Homeowners Assocation, and the Southern California Federation of Scientists) have' detailed the recent revelations about extensive environmental contamination by Rockwell at and near the Santa Susana Field Laboratory. We will not repeat those evidentiary offerings here, but join them and include them herein by reference. Here we focus on the accident record at the site, primarily in the period prior to the recent revelations.
Were Rockwell to be able to demonstrate it could safely handle nuclear materials in the future, it should be able to show it has handled them for decades without producing environmental contamination. This it clearly i
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cannot do. The recent revelations by DOE, EPA, the State Health Department, and others, shows extensive environmental contamination by Rockwell.
%ey have not been able to handle the materials without their release into the environment.
Furthermore, were Rockwell to be able to claim an accident was of vanishingly small probability were it to be permitted to continue handling plutonium and other nuclear materials, it should be able to demonstrate that it had handled such materials for many years without any accidents. Perhaps a single accident would not in and of itself be automatically disqualifying, but certainly more than one or two would be such as to present clear evidence of an unacceptable likelihood of accident were the license renewed.
We believe that the extensive accident record of Rockwell and of this site provides clear warning of the prospect for serious accident if the license-is renewed.
One doesn't renew someone's driving license if they have an extensive
' record of car crashes and moving violations.
One certainly doesn't renew a nuclear license if the applicant has an extensive record of environmental contamination, serious nuclear sceidents, and a pattern of misrepresentation of important safety claims in its application, required to be put forward under oath.
Rockwell is not qualified to continue to use and possess nuclear mat'erials such as plutonium.
The FBI believes this, as witness the i
extensive warrant it obtained because of its belief that Rockwell was engaged in criminal activity and coverup at the Rocky Flats plutonium facility. The Department of Energy apparently believes this, as witness DOE's dismissal of Rockwell from Rocky Flats. The applicant's record of contamination, accident, and misrepresentation with regards its Santa Susana 6
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l Facility is' more than sufficient basis to deny the requested license.
And there is very little in Rockwell's favor to provide sufficient basis to meet its burden of proof for the requested license to be granted.
(1) The application assumes that in the " worst case" accident only a billionth or so of the available plutoniulii is released. This is an absurdly optimistic assumption and misrepresents the source cited g support it.
Rockwell's "On-Site Radiologic Contingency Plan," (Revision 22 December 1989) contains a discussion of the possible release of radioactive materials in the event of a fire.
The conclusion presented is that the danger.to nearby people is not high, but the reasoning is faulty at several steps.
The very possibility of release of radioactivity by fire is virtually dismissed in. the contingency plan.
The authors give a list of the
" comprehensive range of accidents" considered, which does not include fire.
They further refer to this list as encompassing both " credible and incredible accidents."
The consequences of fire, possibly the most threatening of situations, are only dealt with informally after the main discussion.
Therein the authors cite a 1968 study, " Airborne Release of Particles in Overheating Incidents Involving Plutonium Metal and Compounds" by L. C.
Schwendiman, J.
Mishima, and C. A. Radasch of the Pacific Northwest Laboratory, Battelle Memorial Institute, Richland, Washington.
'Ihis paper will' be referred to as SMR, and is attached hereto as an exhibit.
This study did indeed investigate the behavior of plutonium under several overheating situations.
Its authors, however, make clear the major limits of applicability of their data. The authors of the contingency plan have 7
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seen fit to misapply and quite liberally stretch the results of SMR to better support the Rockwell assertions about consequences of a _ fire involving plutonium at their facility.
1 Central to the argument of the contingency plan is the claim that the results of SMR show that "the amount of material release during the oxidation of ignited, unalloyed plutonium metal is small -- 3 x 10 -6 to 5 x 10-5 total wt % over the temperature range from ambient to 900 degrees C."
A natural reading of this sentence would be to assume that 3 x 10-6 g (0.000003 %) of the plutonium was the smallest amount released, and 5 x 10-5
% the largest. In fact these are results only under conditions of low air flows without rapping. Less favorable conditions resulted in releases thousands of t:
i higher. Rockwell picked the smallest release fractions from those measured by the investigators, rather than accurately representing the range, and ignored the caveats of the study.
The contingency plan claims these numbers describe release of plutonium metal oxidized at temperature ranges up to 900 degrees C.
In fact, only one of six trials was conducted at this temperature, the others being run at temperatures lower than the melting point of plutonium (641 C), or only marginally higher.
The determination of a realistic figure for plutonium release calls for a much closer reading of SMR than that apparently used by the authors of the contingency plan.
For example, subjecting the burning plutonium to mechanical shock, the amount released was increased to 0.03 weight percent:
an increase of four powers of ten over the nu.aber used in the contingency plan.
It is not unreasonable to suggest that in a fire that laboratory setups may get knocked about. In addition, SMR reveals that even without any additional disturbance, comparable releases of plutonium could be obtained under conditions of moderate air flow.
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The same creative accounting is used in the estimation of release of powdered plutonium oxides, such as could be produced by burning plutonium metal. The contingency plan claims that " release rates of 6 x 10-6 to 5 x 10-5 wt %/hr" are typical for such materials.
Again, this is the smallest number in the data; with just a little more wind, the measurement shoots up five powers.of ten to 0.56 weight percent per hour, a factor of 100,000 increase.
The authors of the contingency plan have made no attempt at all to incorporate the full range of results of SMR, content merely to quote stray numbers out of context.
Perhaps the most relevant measurement is the amount of plutonium oxide i
the researchers were able to recover after the experiment.
The published results indicate tnat up to 2.6 weight percent of plutonium was lost during the experiments: an amount six powers of ten higher than the amount assumed in the contingency plan.
Proceeding with the smallest numbers they could find in SMR, the authors of the contingency plan estimate the dispersion of the plutonium compounds. They assume the failure of two filtration systems, but then compensate by assuming 99% efficiency for the remaining stage.
Realistically, any circumstances, such ac fire, that might disable the first two stages of a filtering system would be likely to eliminate the third as well.
In the September 1957 explosion and fire at the plutonium facility at Rocky Flats, Colorado, the filters burned for 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and were destroyed.
In the May 1969 fire at the same plant, all the filters were also destroyed.
Failure of the filter hypothesized in the contingency plan as 99% efficient will lead to releases another two powers of ten higher than predicted in the l
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plan, for a total of eight powers of ten, or a factor of ten million.
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Finally, all the measurements cited are of relatively tame situations:
the plutonium netals, for example, are heated and have a stream of dry air l
directed over them. Nothing is said about more dangerous situations such as burning mixtures of plutonium and other chemicals. %e SMR study notes that the release rate "when combustibles contaminated with plutonium are burned is still under study." Such an explosive situation is likely to release considerably more plutonium than any of the scenarios investigated in SMR.
It is indeed the release of plutonium fyn, a fire that is of concern, i.e.,
1 plutonium released when there is a strong driving force such as a petroleum i
or solvent fire, that is of primary concern. % e authors of the contingency
. plan conveniently omit discussion of this possibility. This is a matter for which the cited Battelle study is not relevant, because they say subsequent research is needed, and would likely result in very much larger release fractions than those measured in the cited study which, after all, was just the release if 'a single piece of plutonium is ignited alone and then cooled down.
Thus the authors of the contingency plan have chosen to base their estimates of the fire-related danger of radioactive release on a single 20-year-old study, and have blatantly misrepresented the results of that study.
They appear to have made no effort to accurately assess the _ likely consequences of rapid combustion of plutonium as a solid, a powdered oxide, or a mixture with surrounding chemicals.
Instead, they have knowingly misused incomplete and inapplicable data, and misrepresented what data are in the study, to present a misleading picture of the risks associated with i
such a catastrophic fire.
It should be noted that only by use of the approximately 10-9 reduction factor does Rockwell get the estimate dose down to.04 mrem at the site L
boundary.
Doses of many hundreds of rem are the result if more reasonable 10
t release fractions were assumed.
10 CFR 73.9 rxyuires accurate information in applications 10 CFR 70.22(i) requires under certain circamstances dose estimates for eccidents to demonstrate a maximum dose of 1 Rem. Rockwell's submission in this regard is inaccurate and misrepresents the underlying data. Because of the unacceptable high doses that would indeed result if the calculation were done honestly, and because of the misrepresentations, l
the license should not be granted.
--s (2) Renewh1 of Rockwell's license could lead to further activities (in addition to cTean-up and decommissioning) at thTsanta Susana laboratory
[beyond ge proposed expirdion,i_n1 October I~9'ID.F
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10 CFR 70.22(a)(3) provides that the applicant must specify a period of time for which the license is requested. Rockwell is required to provide within their application complete and accurate information.
Rockwell has 1
not met this requirement.
10 CFR 70.9(a) requires that '[ijnformation provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee 4
shall be complete and accurate in all material respects."
Here again, because of Rockwell's unwillingness to make binding commitments about ending nuclear activity at SSFL except cleanup after
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October and not attempting to circumvent the process by requesting renewal or a new license, there is a question about the honesty of the representations made with regards termination date.
(3) Failure g describe the proposed activities adequately.
Carte blanche g experiment with plutonium g any way they see fit,1,s n
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f g permitted under the regulations.
10 CFR 70 22 (e)(2) requires Rockwell to indicate within the application the activity for which the SNM is requested, the place for which the activity is to be performed and the general plan for carrying out the activity. Rockwell has fciled to abide by this regulation by neglecting to provide anything but the barest sketch of the TRUMP-S project.
This icilure makes it difficult for intervenors and the NRC to address the saftty or propriety of the proposed project and for Rockwell to meet its burden in demonstrating the safety of the proposed activity.
The appropriate relief is license denial; short of that, direction to provide far more detailed description of TRUMP-S.
i b.
Transportation both _into and out-of _the Hot _ Lab.
We join the LAPSR discussion of this matter.
- 6. Inadequate measurement of radioactive materials in case of accident.
Past accidents at the site have involved radiation monitors going off scale, or releases of materisis for which appropriate monitors were not in place.
See, for example, discussion in "Past Accidents and Areas of Possible Present Concern Regarding Atomics International,' attached. 'Ihe SRE partial core melt, for example, resulted in unknown releases because of monitors going off scale and others being incapable of measucing the kind of readioactivity of concern.
Also, during routine operations, instrument calibration errors 12
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resulting in lower amounts of contaminatec being indicated than that actually occurring.
This is a common error in our experience.
The EPA Dempsey report of 1989, already part of the hearing file, provides ample JAscussion of the monitoring problems.
We join in the presentations on this matter by Jon Scott and the other intervenors.
Part 70.23(a)(3), discussed in the opening paragraph requires that Rockwell equipment and facilities are adequate to protect health and minimize danger. The NRC regulations require that Rockwell provide accurate reports on measuring levels of radiation.
Part 20.201(b) requires that
'[eloch licensee make or cause to make such surveys as... are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.' Rockwell has not conplied with this regulation.
7.
Release of radioactive materials during accidents due g faulty equipment or operator error.
i Such releases :an be from airborne particulates or gases, liquid outflow, or solid waste disposal. Fast accidents have resulted in such releases at the site.
See the discussion of past accidents in the i
attachnent.
This violates the safety regulations cited in the introduction as well as the radiation protection requirements in Part 20.
NRC regulations prohibit a licensee from releasing unacceptable amounts of radiation into the environment.
Part 20.103(a)(1) provides that 'no licensee shall possess, use, or transfer licensed material in such a manner as to permit
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any individual in a restricted area to inhale a quantity of radioactive material...*
The 40 CFR regulations that are stricter in terms of permissible dose also apply here.
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- 8. No, throughput limitations are included.
We join in the SCPS discussion of this matter.
9.
Inadequate training of personnel. Past accidents and contamination incidents at Atomics International over the years revealed inadequate training as a key contributor.
NRC regulations require that '[t]he applicant be qualified by reason of training and experiences to use the material for the purpose requested in accordance with the regulations.' 10 CFR 70.23(a)(2).
An AEC analysis of the SRB power excursion accident stated as follows:
j It is quite clear that the reactor should have been shut down and the problems solved properly. Continuing to run in the face ofd a known Tetralin leak, repeated scrams, equipment failures, rising radioactivity releases, and unexplained transient effects is difficut1 to justify.
Such emphasis on continued operation can and often does have serious effects on safety and can create an atmosphere leading to serious accidents, see Technology of Nuclear Reactor Safety, by Thompson and Beckerley, USAEC, attached I personally intervaewed a Rockwell employee who had complained of inadequate criticality and safety training. He said the training did not really explain what a criticality accident was or how to avoid it.
I confirmed that he himself did not understand the rudimentary aspects, even though I saw his course forms indicating Rockwell had passed him in the He thought, as did several of his colleagues, that criticality course.
control rules meant not putting too much on carts, so they put the U on nearby tables instead.
He had no real understanding of what a criticality accident was, nor why or how to avoid one.
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The accident and environmental contamination history are further exanples of inadequate training, mandating de ini of the license.
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Adegoate safety jn the source packaging prior g shipment g and from g Hot Lab see discust m:
' ' he recent shipping accident involving a Rockwell shipment that was over legal limits for contamination, discussed in PSR pleading.
- 13. Actual work g the TPUMP-S program can _ release _ radioactive g toxic materials into the atmgphere.
See discussion on release fraction in accident, above.
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- 15. Synergistic and additive mixing of, contaminants and multiple exposures from multiple sources is certainly possible and needs to be analyzed.
A simple additive example would be the exposure of a worker to three rems during his/her Hot Lab work but then becoming subjected to another three rems at the waste storage facility elsewhere on the site when delivering waste material.
70.22(a)(8) applies. We join with the SCFS and PSR comments on this point.
16.
The application itself, as amended, is deficient.
There are significant omissions gd misstatements.
10 CFR 70.22e and 70.9a prohibit this.
For example, much of the application deals with activities no longer proposed, but an analysis of the proposed activity is not included. See discussion above of 15
misrepresentations and omissions about the plutonium release fraction and the Battelle study; we join here with PSR and Don Wallace in their discussions of the misrepresentations in the RCP about medical and fire assistance.
- 17. g Environmental Impact Statement should be prepared.
Judge Bloch wrote that this concern would be ripe for litigation
- once the [NRC) Staff informs me of its current schedule (for completion of the Staff's environmental assessment.)" They have now done so--indicating that they intend to not continue any work on an EIS or an EA.
Rocketdyne's application for license renewal, Section H, recommends that an environmental impact statement need not be prepared. However, the statutory language in The National Environmental Policy Act (*NEPA') and 10 CFR 51 clearly mandates a full EIS for Rocketdyne's activities.
(A) The National Environmental Policy Act ("NEPA') requires that an EIS be prepared for all ' major Federal actions significantly affecting the quality of the human environment." (NEPA, s. 4332(C))
The renewal of Rocketdyne's license is a major federal action with significant impact on the quality of the human environment. As discussed fully in Brief of Jon Scott and other sections of CBG's brief, Rocketdyne's activities are causing contamination of soil, water and air.
Additionally, the potential for an s
evironmental disaster is a serious concern in light of Rocketdyne~
k inadequate safety and monitoring procedures.
Furthermore, TRUMP is a new project, which has not been assessed before.
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o (B) Although the language of NEPA alone is sufficient to require an
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EIS, Rocketdyne also fits under the more specific language of 10 CFR 51.20(7).
This section requires that an EIS be prepared for an '[ilssuance of a license to possess and use special nuclear material for processing and fuel fabrication, scrap recovery, or conversion of uranium hexafluoride..
(C)
Preparing A Finding Of No Significant Impact: The statutory language clearly requires that an EIS be prepared for a project such as the one before us. Even if an EIS is not prepared--and we believe it must--
there must be a " Finding Of No Significant Impact," in which case 10 CFR 51.32 requires the NRC to submit a full report stating precisely how it reached this finding. The NRC has done neither. Instead, in a memo to the presiding officer dated December 6,1989, the NRC Staff states that it is not continuing with its environmental assessment at all because (1) the projected termination of RockweII's activiities is October 30, 1990, and (2) the NRC wishes to ' conserve staff resources.'
NRC Staff's contention that neither an EIS nor EA need be prepared because Rockwell plans on ending the project in October shows little foresight.
A serious nuclear accident could occur in a matter of seconds, and even without an accident, the months between now and October ellow more than enough time for significant impacts on the environment.
While conservation of staff resources is an admirable goal, such a motivation is i
not a statutory exemption from NEPA requirements.
It would seem that using these resources to avoid potential environmental disaster would be money f
well spent.
An EIS must be prepared for the proposed renewal and the TRUMP S project before either can go forward.
High temperature treatment of plutonium-contaminated wastes near a populated area is a major federal 17
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i action that could substantially impact the environment; no analysis has been i.
performed.
Concern 18: SPECIAL NUCLEAR MATERIAL CDNIROL AND ACODUNTItG Special nuclear material control and accounting procedures are required by 10 CFR 70.58 and 10 CFR 70.51. (See Rockwell's Application, p. 3). That the accounting is inadequate is indicated by the large amount of SNM as
'MUF", Material Unaccounted For.
As of 14 years ago, the MUF for Rockwell had reached a level of 63 kg of U-235.
(See Exhibit 4, p. 8)
Concern 19:
INADEQUATE MANAGERIAL AND ADMINISTRATIVE CONTROLS.
Concern 20: RADIOACTIVE MONI70 RING IS GROSSLY DEFICIENT.
These concerns are well covered in the Scott pleading and elsewhere in this pleading.
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Concern 22: THE APPLICATION DOES NCfr SPECIFY THE ISOIOPE OF PLUIONIUM REQUESTED.
10 CFR 70.22(a)(4) requires that each application contain the "name, amount, and specifications (including the chemical and physical form and, where applicable, isotopic content) of the special nuclear material thhe applicant proposes to use..."
Rockwell hasn't done this.
Not all plutonium isotopes are equally toxic.
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I-Concern 23:
SECURITY PROTECTION AGAINST SABOIAGE AND WEFT IS INADEQUATE.
10 CFR 70.22(k) requires that each application for a license to possess special nuclear material of moderate strategic significance contain "a physical security plan that demonstrates how the applicant plans to meet the requirements of section 73.57(d), (e), (f), and (g), as appropriate" of Part
- 70. With such a large MUF inventory, a presumption must exist of some diversion and thus, of inadequate security.
p concern 25: ROCKWELL'S INADEQUATE RECORDKEEPI!G MAYES ASSURANCES OF SAFETY ANTalING BUT REASSURI!G 10 CFR 70.51(b)(1) requires licensees, other than licensees for special nuclear material of low strategic significance and formula quantities of strategic special nuclear material, to ' keep records showing the receipt, inventory (including location), disposal, acquisition, and transfer of all special nuclear material in his possession regardless of its origin or method of acquisition."
The DOE report of February 1989, the EPA Dempsey report, and the few NRC inspection reports we have been able to see (there are virtually none in the LPDR) all evidence a consistent pattern of recordkeeping failures.
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FULL SET OF INSPECTION REPORTS SINCE 'DlIS FACILITY BEGAN OPERATION SHOULD BE i
REVIEWED 'IO SEE ' DIE MAGNIWDE OF THIS PROBLEN.
Each record of receipt, acquisition, or physical inventory of special nuclear material must be kept during the time of possession and for three i
years after transfer. 10 CFR 70.51(b)(3).
Records of transfer and disposal of special nuclear material must be retained until the applicable license is terminated.
10 CFR 51(b)(5)-(6).
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i Each licensee authorized to possess more than 350 grams of plutonium must also conduct a physical inventory of all special nuclear material in his possession at least once a year. 10 CFR 70.51(d).
Each licensee authorized to possess special nuclear material of moderate strategic significance for activities other than as sealed sources must retain inventory records for three years showing the identity, loocation, and quantity of special nuclear materials. 10 CFR 70.51(e)(1)(iv).
Concern 26: FIRE PREVENTION AND RESPONSE IS INADEQUATE The general 70.23 regulations cited at the outset apply here.
nis is a crucial matter, as the RCP has no fire fighting method outlined whatsoever for a fire at the Hot Lab. %ey indicate pressurized water is not available and that they would attempt to put out the fire by purging the Hot Cell with nitrogen, but what if the fire is caused by or causes a breach in the Hot cell itself? The failure to think through and have procedures and equipment for a plutonium fire disqualifies Rockwell from pssessing the material to begin with.
Concern 27: EMISSIONS FROM ROUI'INE OPERATIONS HAVE BEEN EXCESSIVE 10 CFR 20 and 40 CFR 190 prohibit excessive emissions from routine operations.
The Dempsey report and even Rockwell's own environmental monitoring reports suggest excessive emissions. Note that Rockwell has been i
reporting TLD readings of 150 mrem, considerably over normal background; the readings had been increasing for a number of years, indicating the readings were not from natural background, which is basically stable, i
These releases -- including the contamination of ground water -- are 20 i
i precisely what has so worried the nearby community and create a strong reason for license denial in order to protect public health and safety.
Concern 28: SAFETl FFAWRES ARE INADEQUATE 10 CFR 70.23 requires these be adequate; the history of accidents and environmental releases demonstrates clearly that they are not.
Concern 29: APPLICANT HAS FAILED 70 ADEQUATELY ANALYZE COMMON FEAWRES AND TRENDS OF ACCIDENIS t
Jddge Bloch has already detailed the regulatory requirements for such analysis in his Memorandum and Order analyzing the more recent failure reports.
I note in particular that the fires at Rockwell's Rocky Flats plutonium facility strongly necessitate an analysis of similarities to demonstrate that such accidents cannot happen in Rockwell's Hot Cells here.
Concern 31:
THE FACILITY IS 700 OLD AND ANI'IQUATED 70 BE OPERATED SAFELY.
10 CFR 70.23(a)(3) requires that "[t]he applicant's proposed equipment and facilities are adequate to protect health and minimize danger to life or property..."
One must face the fact that this is a facility built in the forties and fif ties, with a design life considerably less than the current age. The facilities are just too old and antiquated to be operated safely.
k Concern 32: THE FACILITY IS IDCATED IN A SEISNICALLY ACTIVE AREA 10 CFR 70.22(f) requires that each application for a license to possess and use special nuclear material in a plutonium processing and fuel fabrication plant contain a description and safety assessment of the design 21
bases of the principal structure, systems, and components of the plant, including provisions for protection against natural phenomena..."
The Hot cell was built according to long-since upgraded Uniform Building Code standards for normal buildings, and does not meet current seismic standards for nuclear facilities.
If it is to be used for the proposed activity, it should first be required to be upgraded to withstand the maximum earthquake possible in this region, which is substantial.
ADDITIONAL INFORMATION NEEDED The Local Public Document Room, and the " hearing file" contained therein, have almost no documents about Rockwell.
The " hearing file" consists of the application and a few other pages of relaled material.
7he total material in the LPDR is a few file foldera.
However, the docket for the Rockwell f acility in the Public Document Room in Washington, D.C., is very much more complete.
It would make a great deal of sense in determining whether to relicense this facility to examine the record regarding how it has complied with the regulations and safety requirements while it had a license.
Therefore it would seem important that the docket currently in the PDR be made available as well in the LPDR, where the community concern is and the proceeding located.
If this is not to be done, at minimum all the inspection reports and annual reports for the facility since it began operations should be placed in the LPDR.
l 22
4 CONCLUSION i-Rockwell has a substantial burden to meet to demonstrate it can carry out the requested activities safely, and the evidence from its past activities and the misrepresentations in its current application suggest clearly it cannot meet that burden. It has severely underestimated the potential release fraction in an ae:ident, and its history of past accidents and environmental contamination and violation of regulatory standards shows it is unfit for a license to possess and use such dangerous materials.
The requested license should not be granted.
I affirm under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief, s
e c
Daniel Hirsch dated at Los Angeles, CA this 19th day of February, 1989 23
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l'OthEILD USNMC i
BEFORE THE l
ATOMIC SAFETY AND LICENSING EARD
'90 FEB 21 PS:35 U.S. NUCLEAR REGULATORY COMMISSION hvrtCE OF SECRf1ARY 0CKi1WG A Sli'VICL BRANC61 In the Matter of
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ROCKWELL INI'ERNATIONh.L 00RPORATION
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Docket No. 70-25-ML
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(Rocketdyne Division, Special
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Nuclear Materials License SIN-21)
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CERTIFICATE OF SERVICE.
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I hereby certify that copies of the foregoing DIRECT CASE OF COMMITTEE TO l
~ BRIDGE THE GAP have been served upon the following persons by U.S. mail, first class, except as otherwise noted and in accordance with the r
requirements of 10 CTR '2.712.
b Administrative Judge
- Office of the General Counsel *
- Peter B. Bloch U.S. Nuclear Regulatory Commission 1
Presiding Officer Washington, DC 20555 F
Atomic. Safety & Licensing Board U.S. ' Nuclear Regulatory Commission Docketing & Service Section*
Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Administrative Judge
- Washington, DC 20555 Gustave A.-Linenberge!, Jr.
Special Assistant Prof. Jerome _ E. Raskin, et al.
Atomic Safety & Licenting Bot.rd 18350 Los Aliros U.S. Nuclear. Regulatory Commission Northridge, CA 91326 Washington, D.C. 2055!i P.D. Rutherford
- Administrative Judge
- Manager, Nuclear Safety &
Christine N. Kohl, Chairman Reliability Engineering Atomic Safety & Licensing Appeal Board Rocketdyne Division 6
U.S. Nuclear Regulatory Commission 6633 Canoga Avenue e
Washington, D.C. 20555 Canoga park, CA 91304 Dr. Estelle Lit
- Administrative Judge Howard A. Wilber-18233 Bermuda Street E
Atomic Safety and Licensing Appeal Board Northridge, CA 91326 U.S. Nuclear Regulatory Commission c
Washington, D.C. 20555 Donald W. Wallace 1710 North Cold Canyon Road Calabasas, CA 91302 Administrative Judge G. Paul Bollwerk, III Atomic Safety & Licensing Appeal Board Dr. Sheldon C. Plotkin U.S. Nuclear Regulatory Commission Southern California Federation Washington, D.C. 20555 of Scientists 3318 Colbert Avenue Los Angeles, CA 90066
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p Cecelia Riddle Senior Librarian Chatsworth Branch Library 21052 Devonshire Street Chatsworth, CA 91311 Barbara Johnson President Susana Knolls Honeowners Ass'n c/o 6714 Clear Springs Road Susana Knolls, CA 93063 t.I*
Mary Nichols, Esq.
Natural Resources Defense Council 617 S. Olive #1210 los Angeles, CA 90014 I
John Scott 6 Roundup Road Bell Canyon, CA 91307 Dr. Richard Saxon Physicians for Social Responsibility 1431 Ocean Avenue Suite B Santa Nonica, CA 90401
- by express or hand-delivered for receip the 20
- Daniel Hirsch
/
Dated at Los Angeles, California this 19th day of February, 1990
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INVOLVIliG PLyODIUM 'MyrAL */Jih*O5@78DS '
L.C. Sehvendiman, J. Mi.shint, C. A. Radasch ti' Pacific Northwest Laboratory, atte11e He:oorial Institute s*
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AESTRACT Ever-increasing utilization of nucicar facls vill result in vide scale plutonium recovery procerting, reconstitution of fucis, transporta-tion, anct extensive ht.ndling of this material. A variety of circumstan-
'l ces resulting in overheating cnd fires in',olving plutonium mcy occur, re-
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leasing airborne particles. This work describ'en the observations from a study in which the airborne releace of plutonium and its corpounds van measured durin6; an exposure of the material of interest containing plu-tonium to temperatures which may recult from fires.
Aerosol released from small cylinders of metallic plutonium $gnited in air at temperatures from h10'C to 650'C ranced from 3 x 10-6 vt.5 to 5 x 10-6 vt.%. Particien smaller than 15p in dieneter represented as much as 0.03% of the total released. Large plutonium pieces weighing e
i from 456 to 1770 grams were ignited c.nd allowed to oxidize completely in air with a velocity of around 500 cm/sec. Release rates of from 0.0045 to 0.032 vt.$ per hour vere found. The median mass diameter of airborne material was k p.
Quem:hing the oxidation with magnesium oxide sand re-duced the release to 2.9 x 10 4 vt.% per hour.
Many experiments were carried out in which plutonium compounds as s
powders vere heated at temperatures ranging from 700 to 1000'C, with. cev-e eral air flows. Release rates ranged from 5 x 10-6 to 0.9 vt.% per hour, depending upon the compound, and the conditions imposed.
The airborne release fro:n boiling solutions of plutoniva nitrato were roughly related to encrcy of boiling, and ranged from h x 10 4 percent to
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2 x 10 1 percent for the cycporation of 90% cf the colution.
7 The fraction airborr.e when comb'uctibics conte.minated with plutonium Thic PDFer la baced en "Crh performed under i-
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The data reported can be used in assessilig the consequences of off-standard situe.tions involving plutonium and its compounde in fires.
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-e QD0!UTE RELEASE OF PARTICLES IN OVERKEATING TNCID1'IfT8 INVOLVIllo PLUTONIUl4 METAL' AUD COMPOUNDS L.C. Schwendiman, J. Histrima, C.A. Radasch Pacific Northwest Laboratory, Battelle Memorial Institute Richland, Washington 6
INTRODUCTION An the use of nuclear energy grows, the circumstances under which plutonium can be involved in an accident increase. Since the potential hazards t.ttendant to each different set of conditions must be realisti-cally asnessed, data on the behavior of plutonium under a variety of con-ditions are required. The authors have conducted a Series of studies to detemine the fraction of plutonium made airborne and characteristics of serosols produced by overheating plutonium Petu and several plutonium compounds. Plutonium in various phases of processing and,use commonly appears in three forms -- plutonium metal, plutonium compounds as pov-ders, and liquids containing soluble plutonium compoundo. All these forma can be found in various atmospheres and configurations. If we at-tempted to obtain quantitative data on all plutonium forms under all con-ditions, we would be faced with a never ending array of experiments.
Thus, we have attempted to study a representative cross-section of each fom under some overheating conditions. The results obtained are indic-ative of the nature and amounts of materials produced under these condi-tions. The values reported here are not to be taken as definitive in any specific case but must be interpreted in light of the conditions prevail-ing. We have thus far determined the fractional releases from:
1.
The. oxidation of small, ignited rods of ur.11oyed plutonium metal in low air flows.
2.
The oxidation of large, ignited pieces of plutonium metal in moderate air flows.
3.
Heating plutonium bearing powders in law air flovs.
h.
Ecating plutonium nitrate solutions and the solids remaining after evaporation in lov air flows.
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- o We are currently engaged in detemining the fractional release of plutonium in various forms mixed with flammable materials and dried on sand. 'these studies vill continue. The data obtained are expected to prove useful in assesring conseqvences of off-standara incidents involv-ing overheating of plutonium and its compounds.
_8UWARY Of these materials used in these studies, plutonium compounds in the
- form of powders released the largest amounts of plutonium aerocol. Plu-tonium oxalate powder had as high a release rate as was found under the conditions used in these studies -- 0 90 vt.% per hour whe.2 heated to 1000'C in air with an upsveop velocity of 100 cm per second. The high rate under this set of conditions appears to be due to a combination of circumstances which favored release. Lover rates of releane were ob-tained under other conditions imposed. Partially oxidized plutonium ox-alate was the most readily airborne under most conditions imposed during these experiments. The highest rate found for the partially oxidized
' plutonium oxalate. 0.82 vt.% per hour at 1000'c in 100 cm per second air, vas comparable to that found for the plutonium oxalate. '31gnificant plu-tonium release resulted using the partially oxidized oxa'. ate under a greater variety of less rigorour, temperatures and air velocities. Re-lease rates ranged from 0.057 to 0.82 vt.% per hour. P.'.utonium fluoride
.. release rates were the lovest for the compounds conside. red, 0.007 to 0.05 vt.$ per hour. The material remaining after heating vns a free-flowing entrainable powder.
Overheating plutonium metal created less airborne material. The amount of material entrained during the oxidation of ignited, unalloyed plutonium met'al in lov nir flows, 3.3 to 50 cm per second, are small --
3 x 10 6 to 5 = 10 5 vt.5.
The size distribution of the oxide produced
, can vary with the oxidation conditions and, since the oxide ir friable,
.the mechanical work to which it is subjected. Under the conditions of 1
the study, e.s much as 0.03 vt.% of the oxide was smaller than an aero-dynamically equivalent sphere with a diameter of 15 microns.
l In moderate air flows, 525 cm per see, 0.00h5 to 0.032 vt.% per hour vas released durinC the oxidation of large pieces of ignited, metallic plutonium. The Median Mass Diameter (!D4D) of the particles airborne dur-ing one of the experiments was h.2 microns.
Heating a finely divided fraction of oxide, greater than 15 and less than hh microns diameter, in a stream of flowing air entrained a nimilar amount - 5 x 10-6 to 0.025 vt.5 per hour.
Beating liquids containing soluble plutonium compounds released the smallest amounts of material. Using slov heating rates, the maximum
. amount airborne from a c'>ncentrated plutonium nitrate solution in a shal-low pool during a two hour heating-cooling cycle was 0.03 vt.%.
When a higher heating rate and greater volume vere used the maximum amount air-borne was 0.18 vt.% during a 63 miziute sampling period at a full rolling j
boll.
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2 I
The baetion released by overheatir.g the solids remainieg after evaporation of plutonium nitrate solutions is in the same range as from the oxides.
The maxiarum amount vec 0.125 vt.5 vith the remaining values renging from 0.00h6 to 0.0125 vt.%.
The amounts airborne shmted a gen-eral correlation with air velocity but more probably reflect the physical state of the source material.
DISCUS., TON AND RESULTS
- 2.
Plutonium Metal A.
Fractional Release from the oxidation in 5 Air Flows of Baall, Ignited Pieces of Unalloyed Metal.
Bix rods of uralloyed plutonium metal,1/k in. diameter and 3/h in. long, were ignited in a stream of dry air and the amount of plutonium entrained determined.
i The metal rods were fairly uniform in size and appearance.
Weichts ranged from 9.89 to 11.34 Crama. The metal speel-men was suspended above a quarts boat which was centered in a horisontal quarts combustion tubes.
Filtered air was drawn around the specimen and the temperature eleva;ed by a resistanc:,-type, clam-shell furnace.
After the metal was ignited, temperatures in the combustion tube vere main-tained at the desirci level by means of a variable transformer connected to the furnace power inlet.
The material entrained was caught on a men-brane filter.
Microacopic exonination of 'the filter indicated that this material is primarily submicron in aire.
i The filters were then dissolved and the plutonium content determined by alpha counting.
After cooling, the remaining oxide was collected, weighed and classi-fled.
All the oxides produced in these experiments were very similar in appearance - a dark brovn, loosely-joined mass with patches having a greenish hue.
Under magnification, two types of particles were distin-guishable, the larger portions were a dark brown, elongated rectangle and the remainder a yellowish-brown, very small particle.
The oxide was classified by means of a combint. tion sieve-air elutriator-cascade impae-tor technique.
to dislodge particles which mi ht be trapped in the oxide mass.During l
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The entrainment of particles under these conditions is not lar;;e.
During the oxidatiot-cooling cycle, the amount released ranged from 3 x 10-6 to 5 x 10-5 vt.%. Drawing air through the oxide mass entrained J
about'an equivalent amount but as much as 0.03 vt.f could be made air-
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borne with rapping.
The material airborne was of very small pt.rticle sine -- 70 to 80% had equivalent diameter less than 0.1 micron.
(See Table I.)
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B.
Fractional Release from Large, Ignited Nets 111e Pieces Oxidising in Moderate Air Flows.
As an adjunct to a separate study, the amount of plutoniu.n en-trained during the oxidation of four large pieces of plutonium metal was determined.
Three pieces of alpha plutonium of varying quality and.
shapes plus a hemi-cylindrical, as-cast, delta plutonium ingot were
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I; TABLE I UXIDE PRODUCED DURING THE OXIDATION OF ICIUTED UyjtTJnYED PIDTONIIM RODS
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A B
C D
E F
f Tercperature Range, 'C Amb-900 Amb 560 Amb-650 Amb650 Amb-560 Amb-560 Fractio:ial Release During 1
Oxidation & Cooling,.wt.5 2.8,x 10-8 3.1 x 10-5 5.3 x 1c-3 k.1 x 10-5 2.6 x 10-5 3,1 x 104 I
Sa:spling Time, Min.
155
-Tk 75 146 153 11T
- g Fractional Release During i
Elutriation, vt.5 8.1 x 10-6 2.3 x 10-4 8.9 x 10-4 8.5 x ity-"
0.0311 0.016 sampling Time, Min.
20 20 80
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90 80 80 Calc. Oxide Recovery, wt.5 98.8 99.8 97.k
- t00 99.4 100 i
Size Distribution Residual Oxide wt.5 oxide < 250 microns T.72 18.23 8.Ok 10.25 12.47, 12.22 t
t wt.% oxide < 125 microns
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T.66 3.05 k.27-5.03 k.95 l
vt.% oxide < Tk microns d.39 3 75 1.76 2.64 2 96 2.8k t
vt.T oxide < kk microns 0.99 2.63 1.17 1.76 1.09 1.81 l!
i wt.$ oxide 15-kk microns 0.66 0.80 0.68 0.63 0.60 0.76 l
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l ignited and oJ4dited under a 2-5/8 in. diameter by 17-3/8 in. long, bell shaped. VyeoA9 chimney. The entire upper surface of the metal piece was ignited with an are velding unit. The ignited piece was placed under the shimmer and air was drawn through the chimney at a velocity of 525 cm per l
secon6. Parti;1es airborne vere collected on a glass fiber filter and the plutonita determined by dissolution of the material collected and alpha particle counting. During the second run using alpha metal, sam-ples for particle siting were taken via a side arm sampler operating at a flow slightly higher than in the chimney. The samples were collected on membrane filters and selected portions mounted for electron microscopy.
The amount of fine particulate material airborne under these condi-tions varied from 0.00h5 to 0.032 vt.% per hour (see Table II). Covering '
the oxidizing material with magnesium oxide sand decreased the release rate several orders of angnitude. Release rates from the alpha metal were slightly higher than found for the delta metal. The IND of the par-ticles s,irborne during the oxidation of ignited, bare metal was h.2 alcans.
II. plutonium Compounds as powders Four plutonium compounds representing the type cf material commonly s
encountered were heated in an upsveep of air and the amount of material airborne determir.ed. The powders selected were the oxide produced from the ignited metal, partially oxidized plutenium oxalate, plutonium ox-alate and plutonium fluoride. The powders were pieced in a shallow de-pression, 1-1/2 in. diameter by 3/32 in, deep, in a stainless steel fur-nace cap. Air was drawn up *and around the source via a h2.2 sen diameter by 11 in long, V>cor chimney lined with 0.003 ir, mild steel shimstock.
The temperature of the material was raised rapid *.y to the desired Icyc1 and s.aintained during the 60 min. heating cycle by a 10 KHz,15 KW induc-tion heating unit. Teuperatures during the run were taken by a platinum-platinum 13% rhodium thermocouple. Air flow and samplin6 continued dur-ing the 60 min. cooling cycle. Particles passing through the chimney were caught by the glass-fiber filter sealing the upstream endrof the chimney.
Those particles which became airborne but deposited in the chimney were detemined by analysis of the shimotock liner. At the completien of each run, the residues and chimney filters were examined and characterized.
A.
Plutonium Oxide The source material for the study of fractional release from the oxide was the greater than 15 and less than kh micron fraction produced I
by the oxidation of unalloyed metal rods in lov air flow. The materini did not undergo any visible changes during the experiments.
The amount released by the oxide during heating in a flowing air stream appe.ars to be similar to that,(pzeviously reported for entrainment i
of particles from a hard surface.(1J 2J The release rates varied from L
3.? x 10-6 to 0.025 vt.% per hour (see Table III). The release rate at l
high temperature and air velocity is similar to that found for ignited, be.re metal in 525 cm per min, air and that re-entrained when air flow and
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i TABLE It OIIDATION OF IARGE IGIGTED PLUT0tfILW METAL PIECE IN FIOlmlG AIR (Air Yelocity 525 cm per see) 1 2
3 k
Alpha Air,ha Delta Alpha W -Shaped Section, Iow Density Metal, Oylindrical, As-Cast Metal Phase 2000 ppa Metallic Ingot, Metal Purity Eemi-Cylindrical-Dough Triangular i
__Physien1 Description Impurities
> 99 99 wt.$
As-Cast Irwet Pieces. Stratified P
j Vt. Plutonitet, grams 569.8 1770 997 455 5 Vt. Plutonitan Released, g 0.268 0.25T 0.03h 0.00132 Wt.% Released 0.0b9 0.01%
D.0034
'0.00039 8
Total Sampling Time, min 90 k5 22 60 1
l Release Rate, wt.%/ hour 0.032 0.019 0.00k5
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TABLE III 1
i ANot1NTS OF PILTONItN OXIDE ENTRAINED IN FLOWINO
AIR FROM THE' HEATED OXIDE l
(Source material was the greater than 15 and less than kh micron fraction from the air oxidation of unalloyed plutonium metal rods.)
Weight Percent Per Hour
'10 cm por s_e.e 117 cm per see Ambient Tc:nperature 6.1 x 10-6 0 56 i
800'c - 900'c 5.3 x 10-5 0.025 l
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i transfer of momentum are involved.[2] At ambient and elevated tempera-turen and lover velocities, the rate is similst to that found during the classification of this material. The high release rate found at ambient temperature and an air velocity of '17 cm per see is believed anomalous and the explanation is not readily apparent.
B.
Partially Oxidized Plutonium Oxalate The s'ource material used in these runs was production-line plu.
tonium oxalate oxidized for six months in' a dry, glovebox atmosphere.
i The powder was a tan, finely 63vidt.d free-flowing material.
Examined microscopically, the powder vr.s made up of cream-colored and brownish spheres with a IND of 32 microns.
t Of the four powders studied, the partially oxidized plutonium oxalate
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appears to be the most readily made airborr,e under the conditions used.
The release rate increased with both increasing temperature and air vel-ocitles (see Table IV). At an air velocity of 100 cm per sese, rates ranged from 0.057 vt.% per hour at koo'c to 0.82 at 1000 c. At 1000'c the release rate was 0.25 vt.% per hour with an air velocity of 10 cm per
.. see, increasing to 0.82 at 100 cm per sec.
The MMD of the pr.rticles air-borne was 25 microns during the run s<t 700'c in 100 cm per see air.
The values found for the material deposited in the chimney van much more scattered probably due to the proximity of the source material.
The val-uen for the material deposited in the chimney averaged avproximately 75 s
of the material carried through the chimney.
i Binee the material remaining after an accident can be a significant factor in the hazards associated with dealing vit'h the ccnditions pro-duced, the residues were examined.
For partially oxidized. plutonium ox-clate heated to 1000'c, the residues were hard-crusted cakes requiring a significant enount of force to break the surface. For the lover temper-ttures, the recidues ;ere bulky, yellow powders which '<ere readily dis-
,7persed.
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s.).
- c. Plutonium Oxalate No 1 mal production-line powder as received was used as source material for these runs.
It was a moist powder with the color and con-sistency of brown sugar and contained a few larger lumps up to approx-imately 1/8 in. in. diameter.
ticles were spherical with a MMD of 50 microns.Under magnification, the individue.1 par-Over the four months re-guired to conduct these experiments, the physical appearance of the cource material altered considerably to a free-flowing, olive-green pov-der.
The probable cause for the change in physical appearance is a loss cf moisture to the dry glovebox air (a devpoint of -70 F).
l Although the p3utonium oxalate produced the highest re3 ease rate found in these studies, 0 90 vt.5 per hour, this material does. lot appear tD produce an aerosol as readily as the partially oxidized material.
The release rates show a strong dependency on the air sweep velocity only i
producing significant rates at 100 cm per see (see Table V). Thic rela-tionship of release rate to air velocity is not surprising considering the steep slope of the particle size distribution of the source caterial.,
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TABLE IV PARTIALLY OXIDIZED PLtrT3NIW OXALATE MEASE RATES (Source material - production-line oxalate oxidized in dry air for 6 months.)
j Temperature Air Yelocity Heleace Rate. Vt.5/Hr.
('C)
_ (en/sec) firborne Depos!ted in Chimney j
Ambient 10 0.051 L.6 x 10-8 s
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100 400 10 50 100 O.057 0.0075 700 10 50 100 0 735 0.0h1 1000 10 0.25 0.023 50 0.62 e
100 0.82 0.057 l
- Less then lover detection limit, b x 10-3 vt.5/ hour.
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7 PLUTONI1M OXALATE RELEASE RATES e
- (Source materials as-received production-line material. )'
Air
- Temp.
Velocity Release Rate. Vt J/lfr
('0)
_(em/see)
Airborne Deponited in Chirney Ambient 10 50 0.0006'
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100
- , 0.38, 0.073, 0.054 0.006, 0.023, 0.025, 0.036 1
s i
kOO 10 50
.100
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.016 700 10
.00hh 50 100
.90
.0h7 1000 10 e
50
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,005 I
100
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- Beneath lower detection limits, < h x 10-8 vt.%/ hour.
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The very high value found for the release at 700'C in air with a veloci of 100 cm per seconi probably represents a combinktion of maximum shrin J-age of the particle without sintering.
size from $ to 60 microns in diameter. The particles airborne ranged i)
Only 35 to 55 of the material passing through the chimney appears to have deposited on the valls.
Crusts of varying thickress resulted free tha conditions imposed during this study.
underneath was a free-flowing powder.These crusta vere broken easily an ticles airborne appea's to decrease slightly with increasing tempe twflecting. the speeG at vbich the hard crt et is formed.
]
Thus the hektit rat.e may play a part in the amount end size distribution of the materia]
released.
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D.
Plutonium Fluoride The source material was normal production-line powder.
ceived, it was a green, finely-divided, free-flowing powder with a few As-re-large lumps.
26 microns and agglomerates with a IND of 3B microns.The pow The amount of material released by heating plutonium fluoride in moving air was lower than fount. for either type of exalate and also was dependent on the air velocity used - significant rates vere only detected in air with a vel-i ocity of 100 cm per second.
hour at h00'C to 0.05 vt.5 per hour at 1000'0 (see Table VI). Relea distribut. ion of the material reaching the filter appeared to decrease The 9ise with int;rcasing temperature.
free-flowing, easily dispersed material.The material remaining after heating was III. Lioulds Containing Soluble Plutonium Cornounds For our studies, various concentrations of plutonium nitrata in di-lute aqueous nitric acid veu,used.
Plutonium nitrate vap chosen as the.
source material since it is a frequently used soluble compound of plu-z tonium.[3J of plutonium as nitrate per liter.The stock solution was a dark brown liquid prepared in nitric acid as required.Various dilutions of this liquid were 1
A.
The Fractional Release from Shallow Pools of Liquid Heated in a Stream of Air Concentrated plutonium nitrate solution was evaporated in a shal-low stainless steel dish in a stream of dry air (devpoint of air was lesa
}
than-50'F).
nitrate sources for use during a later part of these studies.The i
j Release rates from shallow pools were obtained during thin operation.
The liquid containing 0 72 g of plutonium vas pipetted into the
{
shallow depression in str.inless steel cap for the induction furnace.
shallow cap was ce cered in a Pyrex 50 mm diameter containment vessel. The
. teflon holder positioned the dish and provided an undisturbed air pattern A
across the face of the liquid. Filtered, dry air was drawn across the
,t P
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)
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.,:e
- l 1
6
.y, o,
y ;-(
. R.;
AE
'e F
- TABLE'VI 4
'PIllT011TlN FLUORIDE RETE 4SE RATES E
(Souhce Materialt as-received, production-line fluoride.)
Temperature-Air Velocity
' Release Rate. Wt.5/Hr
(*C)
(cm/sec)
_ Airborne. Deposited in Chimney Ambient
'10 e
-a 50 100
. Is00 10 50 100 0.0073 700 10 50 100 0.022 0.0h8 1000 1:
r:
s e
0.05 0.02 0.016..
- Below lower detection limits, < h x 10-3 vt.7/h. -
i N
W
(
b i
+<
M
.4
......I.....
=.
~.
.c.....,
.........-u..
4.
4 face of the 31guld at 10, 50 and 1" r" yer second using the building vacuum syr. tem.
A water-cooled condu,,er was used to remove moisture in the air prior to trapping the airborne particles on a membrane filter.
Two variable transformer-controlled infrared heating lamps were used to maintain the desired tenperature which was measured by a chrome-alumel thermocouple inserted into a well in the cap.
dry, a second tilter was installed to determine the fractional releaseAfter th from the solids remaining on the dish at lov temperatures.
The filters were examined microscopically to characterise the particles airborne.
Due to the small amounts of material involved, very few particles were del,ected.
containment vessel washes and condensate. Alpha counting determin
- +
All releases were low (see Table VII). With a kB hour sampling period, the maximum amount airborne at ambient temperature was only 2 5 x 10-7 vt.5 which is near the lower detection limits for the analysis used.
The amount airborne remains under 5 73
- 10-5 vt.% until b temperatures are attained. At100'C,therater,were1to3x10giling vt.5.
Even less was released from the dried nitrate - a maximum _value of 2.62 x 10-6 100 cm per second.vt.% vas found at a temperature of 90'C in an air velocity of L
The solids remainics after evaporation, with the exception of run N5, l
vere dark green to brown in color, with a hard glazed, irregular surface.
Nany had cracks and craters where vapor had been released throu3h the
. partially hardened surface.
been trapped under the hardened surface was noted.In a few of the. sampl In run NB, an addi-tiene.1 214 hour0.00248 days <br />0.0594 hours <br />3.53836e-4 weeks <br />8.1427e-5 months <br /> drying in the dry glovebox e.fr produced long, thin crys- -
tals.
i The solids formed during run N5 were significantly different than
\\
solids fermed during other runs.
. ing most of the heating cycle (N h5 minutes).The liquid bubbled quite violent pearance of dried mud.
The residue had the ap-unevenly distributed over the cap surface..It was a brown, bulky material whi B.
Fractional Release During the Heatin6 of Pools of Liquid in a Flowing Air Stream l
Four evaporation rates were arbitrarily choosen as representing the various degrees of surface disturbance which occur during the heating-i of liquids. The regimes were designated:
t l-a.
Simmer no breaking of the surface and characterited by an-evaporation rate of 0.4 al per minute.
b.
First breaking of the nrface: intermittent disturbance of the surface with an evaporation rate of 0.6 ml per minute.
Steady breakin6 of the surrece: a slow, continual disruption c.
of the surface with an evaporation rate of 0.8 ml per minute.
d.
Vigorous rolling boil: a continuous release of bubbles and l
vigorous disturbance of the surface of the liquid.
tion rate in excess of 1.2 nl per minute.
Evapora-e e
.~~ ~..
t
x 4-L
- c.'
a 43 t
TABLE' VII a
-i FRACTIONAL RELEASE DURING AIR DRYING OF
~
LIQUID PW1'ONILR4 NITRATE -
(0.72 g plutonium as source)
_ t.%'Piutonium Released Air W
Run Temp.
Velocity.
~ During Following
)
('C)
(ca.,'s ec )
Evaporation Evaporation No.
R-1 Ambient 10
< 10 7 N-2
.75 10
< 10 6
< 10 6 N-3 100 10
'10-3 3 x 10-7 Nk Ambient 50 2.5 x 10-7 10-7 N~5 100 50 3 x 10-3 6 x 10-7 N-6 90 50 5 25 x 10-s. 1,9 x yo-s N-T
- Aricient
'100
< 10-8
< 10-8.
N-8 50 100 1.25 x lo-s
< io-a N-9 90 100 5.'73 x 10-5 2.62 x lo-G e
t g,*)
-I l
\\
l; l
I l
h
-14,
L e
- ~
Fracticnal r,15:sts vira dstsr:ninsd by drawin6 air up and around a 180 al Pyrex beaker holding the plutonium solution and capturing the
- terial airborne on a glass fiber filter sealing the exit of the modified b-liter Pyrex jar used as a containment vessel.
"y, fvo and a half n1 of a
- ted into 97 5 al of 0.2514. nitric acid held in the bea the surface area of the liquid was 17.3 ca.
Initially, t
into the containment vessel through an annular ring around the beake I
The beaker was secured by a stainless steel screen attached to the trans-ite vessel support ring.
An aluminum heating block slotted forLviewing surrounded
[r
- heating block and transformer controlled bot plate were supported on a The movable platform which was raised and lowered to provide rapid heating and cooling during the runs.
Condensate forming on the valls of the con-tainment vessel was collected in a trough along the inner bottom edge of the vessel.
This condensate vr.s analyzed for plutonium.
labelled " fall-out" and was collected on the inlet filter.*
made to determine the air velocitics in the contain: cent vessel at theAttempts l
various evaporation rates but they were too lov to measure with the in-struments available.
After some experimentation, a velocity of'2 9 cm 1
away and yet allow condensation of most of the mois ment vessel under the conditions used.
Only 90% of the liquid was bcilet.
1 off to reduce contamination difficulties associated with handling concen-trated solutions. During the last five runs, the exit filter was chanted l
after 30 ml of the. solution had been evaporated to determine the effect of concentration on fractional release.
{
The 14(D of the particles air-.
borne during run H vas found by alpha track counting to be k microns.
i The amount of material airborne roughV corresponds to boiling rate
- the amodnt airborne increases with the degree of surface disturbance.
The behavior of the liquid ejected during heating also plays an important role.
vt.% vith a vigorous rolling boil (see Table VIII). Release va
. The total amount escaping follows boiling rates,more closely as vould be expected.
experiments using two exit filters, the amounts of plutonium found on the In the second filter were consistently higher than on the initial filter.
1 The results from two of the runn appear anomalous.
highest boiling rate shows very little activity.
Run E at the The proper amount of plutonium may not have been added.
ged due to absorption of moisture. During run A, the inlet filter clog-resistance of the filter lifted the heaker from its holder creating a different air flow pattern during this run.
C.
Practional Release 'from !! eating the Solids Remaining After the Evaporation of Plutonium Nitrate Solutions in a Flowing Air
[
Stream.
The solids produced during air drying of plutonium nitrate were heated in the apparatus used to measure the fractional release from plu-tonium compounds as powders.
Air was drawn up cnd around the heated material at one of three standard velocities - 10, 50 and 100 cm per W
.S 4&
.......a..+-.e==..-
. c.
~P c
.^*
1 J
f N
t--
1
- ' TABLE VIII
,i
' FRACTIONAL RELEASE'DURIRO HEATINO OF PLUT0NItti l
' NITRATE ' SOLUTIOHS (2 9 cm per see air through container, 700 mg plutonium as source.)
)
Average Boiling
'Run Rate Wt.% Plutonium pi/mJg
_ Airborne Fall-Out No.,
l A
1.4 0.18 O.02 i.
B 09 0.08h 0.27 C
'O.73 0.024 0.012 D
0.6 4.5 x 10-4 4.5 x 10-4 E'
2.1 44.2 x.10-5
- 2 x 10-4.
F 0.5 1.3 x 10 4 3 x 10-5
~
. c.'
0 0.66 5.8 x 10 3 0.016 H
1.2 0.008'
'O.71 I
1.4 0.03 0.09 i
l J'
- 1. 4...
- 0. 11 17 1
1 8 Only 70 pg plutonium used during this run.
l I
l 1
l l
r%
l I
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--..=+.
~- *
~ 4 i-.-=*
- ~ ~ * * ~ ~ '
m.
- ~ -
p "i,
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(-
- second, The solids were heated to h00'C, 700'C o'r 1000'O for 60 minutes
- j.
and allowed to cool for 60 minutes. The particlas released were carried up into a h2.2 mm ID x 11 in. long Vycor chimney positioned 3/16 in.
+
above the. dish.
The amount carried through the chimney was determined by analysis of the shimotock liner.
The amount of plutonium ' airborne from the dried nf trate appears to be l
s independent of temperature and air flow. They range from 0.0046 to 0.012 vt.% which are similar to the values found for entrainment from the oxife (see Table IX). The highest value 0.12 vt.$. is from a residue which was fragmented prior to heating. Thus, physical state of the source a aterial can be a major factor in the' amount released.- Only run N5a produced a sufficient number of particles for size distribution. The M4D -
of the particles airborne was found microscopically to be 20 5 microns.
The material remaining after heating was composed of dispersible, ' grey to greenish colored, thin flakes.
,x CONCLUSIONS I
i Airborne release of plutonium ficm the metal, empounds, and from solutions wher. these forms are subjected to heat stresses and flowing air streams used !.n these experiments can range from an almost negligible amount to a few percent' i
In an assessment of the potential consequences of an airborne release in a given circumstance-the nature of the material involved must be known as well as the air flow and the temperature stresses to be imposed. Detailed data on the:se points are seldom avail-able and er.timates must usually suffice. The data obtained for the frac-i tion airborne can be used when the-air flow and heat stress-of the postu-lated incidents are similar to those used, however, the data must be re-garded as indicative of actual release-factors.
j Sor.e general conclusions drawn from the observations are as follows:
-1.
Oxidation of mets.llic plutonium vin cause to be airborne' from a very i
small fraction (10-6%) to a few hundredths of 15.
The higher release fractions were measured for massive pieces of plutonium.
2.
The variability in the airborne fraction released from compounds of
~
1 plutonium masked any consistent trend with temperature.
Aerodynamic con-sideratio'ns appear to be more dominant than heating per se to temper-atures to 1000*C. The influence of heating on the final physical form of the compound was quite marked. Residues hard and glassy to very fine powders were observed, i
s, 3.
Evaporation of plutonium con be achieved with an extremely ~ small air-borne release if carried out at lov evaporation rates. Airborne release accompanying a full' rolling boil from a 2-1/2 in. diameter beaker re-sulted in an airborne release rad 61ng to a few tenths percent.
h.
Although this investigation did not include a comprehensive study of particle sizes of the released materials, the particle size measurements made showed that for the releases mensured virtually all could be re-garded as particles of respirable cize.
- m I
b
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_-.8.
+
...-.-..n r
+
g O
J TABLE IX FRACTIONAL RELFASE DURING HF.ATI!!O OP SOLIDS RUMINING AFTER THE EVAPORATIO!1 OF PLUTOHIUM NITRATE SOLUTIONS Air Run Temp.
Velocity Wt.f Plutonium No.
1 (cm/sec)
Deposited in Chimney Airborne N1a 1000 100 0.0067 0.0125 N2a 700 100 0.004 0.0092 '
N3a Wha 400 100 0.0097 0.0068 55a 1000 50 0.032 0.125 N6a 1000 10 0.0016 O.0046 N7a 700 50 0.015 0.0075 N8a h00 50 0.0055 -
0.0064 N9a; 1000 100 0.0012 0.0071 O
G D
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D l
4
)
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y
7.
,.. -.,. r-
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3,
- N g
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- '?
. Some experiments performed and future experiments are designed to measure the airborne release from plutonium salta contained in combusti-ble materials which burn.
,r I_.
It is also planned to conduc* experiments to c
estimate the potential loss of plutonium from soil matrix material by l
heating.
These experiments should yield infomatica with which conse-quences of shipping accidents can be better assessed.
4 REFERDiCES (1)- K. Stewart. "The Particulate Material Fomed by the Oxidation of Plutonium", in Progress in Nuclear Energy, Pergamon Press, New York, (1963), Series IV, Vol. 5.
(2)
H. 01auberman, W.R. Bootman and A.J. Breslin.
" Studies on the Sig nificance of Surface Contamination," ir Surface Contamination, (B.R. Fish, ed.), Pergamon Press, New York, 0 967).
~
[3]
J.H. Cleveland. " Con:
book (0.J. Wick, ed. ) pounds of Plutonium," ch.12, Plutonium Hand-GordonandBench,NewYork,(1967').
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1 TCOMMITTEE TO BRIDGE THE GAP-a 1637 BUTLER AVENUE #203-
-i t
- LOS ANGELES, CALIFORNIA 90025-(213) 478 4 29 P
t h
i Zt$i ACCIDEJ 3 AND AREAS OF POSSIBI2 PPISEh"r 00N3RN EGARDING ATOCCS-INTERNATIONAL t
ci January 18, 1980 i
i e
- - ~ - -. -
~
k 10'CW REAC'PCR ACCIDEN"'S AT ATCMICS INTERNATICNAL '
~Nston To dato only sketchy radiction data fres th3 fellowing accidsnto has be3n made available to the public, thus making it impossible to determine accurately the degree,
- if any, to which the general' public was exposed by any of these accidents.
.g:
}ggigg, Date of Accident Description of Accidentt Source of Informatien
>+
.AE-6 3/25/59 Release of fission ras--contaminating containment room and several members of operating staffs the degree,- if any, of environmental contamination is uncienr from existing documents available. Reactor scrammed due to improper operating procedures which allowed it to ruch double its maximum allowable power.
(Source NAA-SR-MEMO 3757, "Reluse of Tission Cas from the AE-6 Reactor")
SRE 7/13/59 Power excurnien - reactor power increased uncontrollably. A serious sign of malfunction, yet the reactor was started up again 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later. An CC analysis concluded:
"It is quite clear that the reactor should have been shut down
- and the problems solved properly. Continuing to run in the fece of a known Tetralin leak, reputed scrams, equipment failures, rising radioactivity releases, and unexplained tzansient effects c
E is difficult to justify. Such emphasis on continued operation can and of ten does have serious effects on safety and can create l
an atmosphere leading to serious accidents."
-(Sources:. NAA-SR-5898, " Analysis of SRE Power Excursion": The Technoloav of Nuclear Reactor Safety by Thompson and Beckerley, USAEC)-
SRE 7/59 Partial meltdown - 13 of 43 fuel elements melted
-(see attached photo of melted rods), 10,000 Curies of radiation -
were relused (.3% of core activity inventory)t mostly into the c
coolant. Radioactive gases (xenon and krypton) were slowly F
released to atmosphere over a year's period. Amount vented l
to environs is unclear because some radiation monitors went off scale during Parts of the accident, others malfunctioned.
l.
a device to automatically route.high radioactivity to storage tanks didn't work, and some of the other monitors were incapable b
of measuring xenon and krypton because they are noble gases.
.AEC comment:
"It is dangerous, as well as being false economy, l
to run a reactor that cl urly is not functioning as it was designed to function. In the long run, reactor economics as
[
well as reactor safety will demand adequate continuing maintenance at all times, and this will include early shutdown and proper l
action whenever there is the least doubt concerning the situation, l
Management can and must establish this sort of attitude."
l
?
L (Sources: NAA-SR-4488, " Fuel Element Damage": NAA-dR-6890, " Distribution l
of Fission Product Contamination in the SRM i and AEC book cited above)
~
SNAP-8 1964 Tuel claddine melt - Reactor for the space progz:am suffered fuel cladding melting in akut 80% of the fuel rods and a " substantial release of fission products "
(Source: AI-AEC-MEMO.-12790)
S8ER 1969 Accident similar to the 1964 accident.
(Sources Ventura Star Free Press,1/11/80) h
((
..w 8w ENOWN NON-REAMOR ACCIDENTS AT ATOMICS INTERNN!!ONAL t.
Wash Coll'" Incident" 6/4/59 A fuel rod exploded when it was washed, while.still dripping sodium, with water in a " wash cell." Sodium explodes in the presence of waters the explosion created a " pressure surge" that lifted the shield plug out of the wash cell and creating, according to an AI report, " extremely high contamination levels within the entire building." The anximum contamiption level 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter the incident was 700,000dpn/100cm. Since air from this building was normally vented to the atmosphere, unless an automatic system, which occasionally malfunctioned and had to be replaced with a manual. systen, detected high radiation and rerouted the air to temporary holding tanks, there is at least a question as to whether any. environmental contamination -
resulted from this accident.
(Sources NAA-SR-4488, SRE Fuel Element Damage 4 port)
Radioactive Pi w
'59 or.'60 A radioactive
- pipe from W 3RE was taken outdoors Enlosion to be decontaminated by steam-cleaning or sanblasting.
With populated sections of valley allegedly in view,.the pipe exploded, was W wn off the fork-lift across a ravine.- A worker was allegedly exposed to radiation because his gasmask failed to seal properly and had to undergo extensive medical treatment.
(Sources' allegations about this incident are from an AI employee present at the time of the incident.)
T9tralin E ulosion 8/16/59 Tetzslin, a coolant that had caused the SRE partial meltdown by clogging the sodium coolant channels in the reactor,,
was stored in a sodium lab. The tetralin exploded, the sodium caught on fire, and the building was gutted.
(photo of inside of sodium lab after explosion is attached.)
i (Source: NAA-SR-4803,InvestigationofTetralinExplosion)
Sodium _P[ Igg sain one There have been several sodium fires at AI, including 5/19/71 at least one which exposed numerous workers to varying degrees of radiation.
(Source: Letter from S.F. Iacobellis, President, Rockwell International, to Los Angeles City Council members, Marc.) 19, 1976.
i Verker Ercosures There have been numerous worker exposures to radiation in accidents besides the ones already listed. This will be the subject of a future report.
l It should be noted, however, that the NRC in 1978, l
acting upon a complaint by an AI worker of inadequate radiation L
safety training Programs, issued a formal' Notice of Violation to AI, and that there has been at least one other AI worker since
(
L that time who has made a formal complaint about the inadequacy l-of such safety training.
l-
'. Leach Field L
Contamination A leach field at AI became inadvertently contaminated with radioactivity-according to one report, a high amount of Strontium 90-including contamination off AI's property. Apparently AI did not discover the contamination for about 14 years 'when it was finally discovered, the radioactive soil was dug up and shipped to Boatty, Nevada, a radioactive waste dump. How much if any radioactivitbpplSted durinkhain [s unclear.re it was discovered mi the eriod befo into water s or food
k s.
Known Accidents at Atomies International Reactors Off-Site g g, (organic Moderated Reactor Experiment)
Idaho Falls, Idaho Melting of fuel element cladding: 1000 curies of fission products released (apparently most or all into coolant, but we do not have access to any environmental radiation readings to know for sure). October 1958 (Sources. Am>11ed Radiation Protection and Control, by J.J. Fitzgerald,
}iY 1970, Gordon and breacht prepared under the auspices of the Division of Technical Infornation, USAEC)
- Eigg, Piqua, Ohio
-Ran only from January 199 to January 1966, but during that short time experienced constant shutdowns. Fuel elements were removed from Piqua and shipped to Santa Susana for inspection to determine cause of failure.
Reactor was designed, built and operated by AI for the government, providing power (sporadically) for the city of Piqua Chio. They had control rod problems, fuel element problems, and superheater tube leaks, among other malfunctions.
- (Source AI-AEC-12696)
}kUAm Hallam, Nebraska Shut down after only about a year's operation. It was shut doun because of swelling ani cracking of moderator cans (the graphite logs in the center of which fuel' rods are placed the graphite acts as a moderator to facilitate the chain reaction). This was the same problem that caused the SRE to be eventually shut down in 19@, just a few-months before Hallam was shut down.
An AI worker alleges that the moderstor cans were not built to specification and at Hallam had to.be " pounded in with four-by-fours". It is possible that this contributed to their cracking end/or swelling.
(Source: AI-AEC-12709) l
~
i IEFCFFlAIC !!CTE: Most _of the AI-related problems listed in this report occurred in the l
.p:ried 1959-1969. That does not mean there have not been problems since that time It means merely that the only documents we have been able to gain access to deal almos.t exclusively with the period up to the late 1960s. Repeated efforts to get more current data have failed.
- ~'
Curremt to7cernUlumwcaEmiams mw Kon,;.;ma omwcm ( -
5
- ;y f,,. Potential far "Oriticality Accident" -- Both NRC cnd AI documents ro:ognize the pot:ntial for c criticality accident-Lvery saml1 nuclear explonien resulting from too much enriched uranium accidentally being placed in a ccnfiguration wh:ro it can go critical, resulting in an uncontrolled chain reaction. While the potential blast is quite small.
the equivalent-of a few sticks of dynamite, the radiation dispersed in such an, accident, E
particularly in a' populated area, could be a serious hasard.
]
(Source: NRC Environmental Impact Appraisal of the AI Commercial Nuclear Fuel Fabrication Facilities, September 1977 AI training annuals for workers on how to avoid criticality accidents. Notes a detailed packet about the criticality danger at AI is aveilable upon request.)
"De-Claddina" of Svent Reactor Fuels - A significant activity at AI's Santa Susana -
. site is the removal, through an apparently potentially dangerous explosive method, of the cladding surrounding highly radioactive spent reactor fuels. They are, scheduled to receive th's fuel rods from the Fermi reactor that got within seconds of a total' meltdown near Detroit (the subject of the Readers Digest Press book Ve Almost Lost Detroit).
~ Potential Site for Storare of Hirh Level Radioactive Waste -Nuclear News, a nuclear industry publication, reports in its mid-September 1979 eiition, that the Department of Enere is considering using the part of the facility it leases from AI in Santa Susana as a place for " interim" stenge of spent fuel from commercial nuclear power plants.
Nuclear News indicates DCE is considering using an existing "small dry-storage facility" there for such additional storage. And UPI reported on January 9 of this year that the Senate Energy Committee has " filed a report providing details on a bill to allow the government to relieve utility companies of the spent atomic fuel piling up at'their reactors." So progress is being made to have DOS take over storage of that high level radioactive waste, and DOE is considering AI's Santa Susana site as one of several possible interim storage sites, j
(Sources UPI item. Washington DC, January 9,1980: Nuclear News, mid-September y?9)
Po sible sodium fires - As a chief researcher in the Liquid Metal Fast Breeder Reactor program, Al has been deeply involved in experiments with sodium, which is the coolant used by breeders. In particular, for a number of years they have had a' contzmet to publish quarterly progress reports on containing sodium fires.
Since sodium is highly flammable--capable of igniting in the presence of air or water--and since a fire could disperse radioactivity into the air and potentially over a wide area, the work with-sodium raises some as yet unanswered safety questions.
(Sources a review of Nuclear Science Abstracts and Energy Research Abstracts indicate considerable work both on the breeder and on sodium fires.)
Lack of_inderendent radiation monitoring-- The Radiologic Health Section of the State
- Health Department.a couple of years ago imposed additional radiation monitoring
. around AI, apparently, in the words of the California Secretary for Resources' State Task Force on Nuclear Energy and Radioactive Materials, "because of a history of detectible off-site contanination!" (emphasis added). This was done, the report continues, "so that the State can better protect the public health and safety."
However, the actual off-site monitoring was 'done for State Health by the feders1, Environmental Protection Agency, which has since discontinued its monitoring because of a lack of furds. State Health has not yet gotten around to instituting its own independent monitoring. Yet a State Health official said that the loss of the EPA monitoring was not significant because State Health did not consider the EPA readings very accurate anyway. Thus there is at present only AI doing its own monitoring, and publishing yearly composite figures without public access to raw data to identify hot spots or significant releases that get merged into site or year averages.
m,
L ;, t..,,.
r e-
[ Current Concerns (continued' from previous page) s L
(Sources Radioactive Materials in California, The Report of the Secretary for i
F Resources' State Task Force, p. 201-202 phone conversation 11/13/79with Eric Vold, Radiologic Health Section, State Health) i t,
j.;
1 Trsnsoortation of Radioactive 4terials --Significant quantities of highly.rsdioactive materials are transported in and out of Als opent fuel for decladding, raw uranium-235 in highly enriched (bomb-grade) concentrations for fuel fabrication, the finished fresh fue1~, and other radioactive materials about which we know little.
]
The potential for an accident while in trsnsport, pa:cticularly in the quantities i
involved, merits serious examination.
In addition, there are some indications that the transport of, far example, spent fuel even without any accidents involves some radiation exposure to large numbers of people. For example, Dr. Anthony Nero, a physicist in the Energy and Environment Division of 14wrence Berke 1 y laboratory, reports that "Somewhat 3
surprisingly, about half of this dose 4thg typical radiation received by the public within 50 miles of a nuclear plans / is contributed by irradiation of these populations by the transport of spent fuel." While Nero argues that the population dose in total is relatively low, the question of exposure of Ventura I
County residents from the transport of highly radioactive spent fuel and other radioactive materials under normal circumstances, as well as the possibility of accident, warrant further study.
(Sources A Guidebook to Nuclear Reactora/ University of California Press.
1979, Dr. Anthony Ng o Eglicactive Materials in California. sections on transportation)
Earthauakes and possible Release of Radioactive Materials - The 1977 Environmental Impact Aptraisal for Al states: "The two Al facilities are located within a seismically active region." The potential rolesse of radiation should such an earthquake cause, for example, a fire or accidental criticality, merits an-==%mtion of the degree of protection from earthquake-initiated problems.
(Source: 1977 Environmental Impact Appraisal, p. 2-9)
Decommissionina and Decontamination of Radioactive Facil! ties - A significant part
.of AI's work involves the removal of radioactivity from areas that have had nuclear facilities on them.. This of ten removes the cutting apart of reactor cores and
- the shipping to waste storage sites of tons of radioactive material. The full ramificatiens of D & D work has not been much studies, as few facilities to date have been fully decommissioned and decontaminated. The State Task Force on Radioactiv.e.haterials in California recommends much more attention be given to potential public hazards from such work.
. Additional questions:
Is the coonlination with local health and safety offichia adeounte?
Are enerrency Vlans and evacuation clans adeounte?
Are measures taken by AI to trevent n dioactive ruterials from beine accidentally or intentiog11v removed from AI adtounte?
What other kinds of hazards may votentially exis_t_?
O c
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,y The Technology of Nuclear Reactor Safety VOLUME 1 1
Reactor Physics and Control
'y:
EDl TORS 1
T. J. Thompson 1
J. G. BccLorley
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Prepared under the auspicer of the Division of Technical Information
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U. S, Atomic Energy Commission i
THE M.I.T. PRESS ll J i
Massachusetts institute of Technology Cambridge, Massachusetts s h
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i CH APTER 11 f
n Accidents and Destructive Tests t,
I; T. J. TilOhipSON blassachusetts Institute of Technology Cambridge, hiassachusetts "What is Past is Prologue" 1
5.0 N. S. Savannah-Control Rod llydraulic Sys-Cl! APTER CONTENTS *
. tem Leakage PREFACE.
5J PWR Containment Yalre flalfunction f
1 INTRODUCTION 6 dONCLUSIONS 2 CRITICALITY ACCIDENTS OUTSIDE OF RE-6.1 General Comments ACTORS 6.2 Conclusions and Recommendations 2.1 General
. 6.3 Nuclear Excursion Energy Limits 2.2 Allzd 1 Reactor Accident REFERENCES 2.3 ORNL Criticality Excursion 2.4 Ranford Recuplex Criticality Excursion-PREFACE 2.E The LRL Critical Facility (Kukla) Excursion 2.0 The UNC Wood River Junction Incident In reviewing the information available on the
.w 3 ACCIDENTS AND DESTRUCTIVE TESTS IN-various. accidents, it has apporred to the author VOLVING REACTIVlTY Cl!ANGES 1N REACTORS
.that the accident reports from WindscaleandChalk River were particularly utstanding. They pre-T ater 11011cr Criticality Excursion
"'E " * " " " '
3.3 ~ The NRX Reactor Accident "N'"
3.4 BORAX-1 Destructive Experiment reports were informative enough to supply the 3.5 'llanford Reactor Incidents ren u wR i an artHicial baMog of merlenu n that he might be forewarned of certain prob! cms.
3.6 The EBR-1 hicitdown 3.7. Accident at Windscale No. I Pile
- Since the intent of this chapter,is the same, the 3.6 The llTRE-3 Excursion author has tried to continue the tradition of those 3,9 The SRE Fuel Element Damage Accident earlier reports in an abbreviated fashion.
Decause a report of an accident loses much of T
Ac en N"""
- """"""""'I"**"*'
' 3.12 The SPERT-1 Destructive Series more important ones have been drawn using those 4 FUEL FAILURES from the origtaalreports thoseof other reviewers.
+
and those of the author, la a number of cases the 2T bRU Loss-of-Coolant Fuel Element conclusions of this chapter augment or even differ o-Accident from those of the original reports. In those cases -
3 TR sslon d
it should be understood that the nuthor is presenting
. (*4 g,, 9n Dre ed t his personal conclusions. It is hoped that the 5 OPERATING EXPERIENCE WIT!! NON-CORE authors of earlier reports and the groups involved I
1 COh1PONENTS will understand that the sole intent is to emphasize lessons to W leaM.
l 2
el Re ndling hiechanism at theShipping-i i
i port Reactor
]
5.3 thvimming Pool Reactor Experience 1 INTRODUCTION 5.4 hinterial and h!cchanical Failures
- 't 5.5 Antarctic Pressurized Water Renctor--Ry-While there have been relatively few accidents drogen Explosion of a serious nature involving nuclent reactors, yet cach one points out certain lessons worthpreserv-
- Except for a few changes andodditions madeln ing. It is the intent of this chapter to net down
~
the recorded facts concerning these accidents.
l proof, this ehnpter is based on information in the
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literature or known to the author prior to February emphasizing the causes of the accident and the lessons to be learned.
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T. J. Ti!OhlPSON 638 i i chamber, and the ton current from the principal operations themselves and extraprecautions. care, i
chamber fell more rapidly thanthat fromthegamma and alertness should be observed. Epler l41) compensation chamber. Thus, with increasing flux says " failure to test under planned conditions r
the net current would appear to drop to negative must result ultimately in an unplanned test."
(7) The safety system should have adequate values since the gamma compensation current is monitoring and alarmo or scrams on such items
'e subtracted. The result could. and did, appear as a negative period - when actually the period was as circuit continuity, proper high voltages, line voltages, etc.
positive.
(8) In general, it is better to utilire a smaller Comments. Conclusions. Recommendations signal from an ion chamber further away from the neutron source with a suitable amplifier, than it j
is to overdrive an ion chamber and risk operating
~
(1) There should always be at least two on-in a region whero the chamber response la far scale neutron signals preferably from different -
from linear with increasing neutron flux.
Aypes of chambers with different types of electrical circuits-for example, a fission chamber detector utill Ing a battery power supply and operating a 3.9 The SHE Prel Flement Damace Accident galvanometer, and an ton chamber with its own voltage supply and amplifier-recording unit. The lihi2) reactor instri. mentation system should satisfy the The Sodlum Heactor Experiment (SHE) was Principle of Diversity discussed in the chapter on built at Santa Susana, Callf. to aid in the develop-Sensing and Control Instrumentation. Secs.1.4.1 ment of the sodium-cooled, graphite-modcrated and 1.4.2,'
reactor concept for civilian power use. This (2) Safety system circuitry should not be made 20 hlw(t) plant went critical in April of 1957 a part of an experiment or of a control unit. Use of instruments for both safety and control reduces and first generated electrical power on July 12, 4
the number of independent safety circuits and thus lh57 As shown in T!g. 3-10 [43), the reactor region is divided into hexagonal cells of violates the Principle of Redundancy discussed in core zirconium-clad graphite 11 in. (27.9d cm) across the chapter on Sensing and ControlInstrumentation, the flats and 10 ft (3.05 m) high. The outer units Soc.1.4.2.
serve as reflectors and the inner ones contain (3) Records should be kept of all changes made fuel in a central cylindrical tube 2.80 in (7.11 to any part of the system including the circuitry, cm) ID. The fuel elements in the core in question Deforo any chan;,es are made,a review (by someone (Fig. 3-11) 143) were made up of 7 rod clusters, or some group completely knowledgeable of the cach rod a 6 f t (1.83 m) column of 6 in. (15.2 cm) i given reactor and tte points at issue) should be carried out of the el'fect that the proposed chango long uranium slugs in a 0.010 in. (0.25 mm) thick will have on the existing system. This review stainless steel tube. The 0.010 in. (0.25 mm) f armulus was bonded by NaK and there was a should also consider anypreviour niterations which helium-filled space above. The outer six rods may affect the situation, were wrapped with a strinless steel helical wireto (4) Reactor instrumentation should be designed
' to trip, or at least sound en alarm, on fast prevent rods from touching each other or the negative periods as well as fast positive periods.
process channel. The ikw of the sodium co:..mt (5) Tho use of automatic controle to carry out is upward through the core and out to the ner a rise to power may be somcwhat questionable exchanger.
"The dcrign and construction philosophy of unicas the system has been repeatedly checked 1
and found to be completely re!!able in taking the system emphasized the use of conventional, commercially obtainable components wherevor I
apprapriate action m the event an unexpected input possible. To this end,thecoolant eirculatingpumps j
.li algun! is obtained. In particular, in approaching are simple adaptations of hot oil pumps. The stuff-a new and higher power level slow and careful ing box (see Fig. 3-12) [43) was' replaced by a manual opert.tlon by competent operators is likely cooled annulus aroundtheshafttofreezesodiumand to be the more conservative approach. Especially thus seal 11guld sodium in thepumpcasingfrom the I
this is true when the instrumentation is untested supporting bearings on the shaft.and the drive la the desired operating range. hianual operat!on.
motors. The primary and secondary systems each using slow steps would probably hava given the have a 6-in. and 2-in. pump and three of these operator a chance to catch the problem in time.
have had erratic operating experience...Tho 6-m.
1 '
lt is difficult to build judgment into an automatic 1500 gpm* pump in the primary system...was j
~
startup method which is as sound and broad as l-that of an alert and knowledgeable human unless the main offender in the fuel-element damage the situation is quite routine. (The situation here incident that occurred in July 1959. Difficulties L
t had been experienced from time to time with it 4
y contrasts somewhat with that discussed in Sec.
binding almilar to that of the 2-in. pump, and.
3.6 where extremely rapid operations were re-4
'I quired. Even there, the system. when automated on two occasions,'the auxilary coolant (Tetratin) in the freeze seal has leaked into the main sodium N
should have been fully checked out and tested and coolant stream. This was dotected by identifying 4' ;
then operated on a series of small extrapolations hydrocarbon vapor in the atmosphere above the
.f in performance.)
I (G) Electronic circuitry and chambers should reactor pool. The first of these occurrences, be tested under the operating conditions in which
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f they will be used. If this is not pesible. It should I
be recognized that they are being tested by the
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ACCIDENTS AND DESTilUCTIVE TESTS 33 639 m'autions care,
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ulatingpumps Fic. 310 Cross section of the SRF,
.ps. The stuff-aplac!d by a m uotn noo in April 1958, resulted in an insignificant amount 1 sing from the 4}S of leakage before the freeze seal was repaired.
zerodium and
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F Ed the drive This leak was Caused by a pinhole In the freeze-wwuuu ruto EmNsoN : PACE seal Casting. The sCcond such leak occurred in systems Each h
t May 1959 and resulted in somewhere between hree cf thise.
Ntt noo,sAcKtf (NoK FILLto) 2 and 10 gal of Tetralin being admitted to the pri.
W.The 6-in.
'T mary sodium stream (44). This leak was traced to pyitim...was.
saNct stuos on nont damage -
d failurt of a thermocouplewell.TheTetralin-cooled shaft seal was then replacedwith a NaK-cooled seal
- Difficulties
-o Moa tml arranged in such a way that two independent barriers ac time;r, tith -
- h would have to fall before mixing of NaK nnd the
_. pump, and, I,h scytN noo cttutNT primary sodlum could occur. As will be mentioned G(Tetrslini b
later, however, sufficient Tetralin had nircady been m:in sodium I,1(I
-ooiomasfun admitted to the system to create the condition that
>y id;ntifying r 00'0* NeK DoNo damaged the fucI Ossemb]!c8 l45),"
i
(;O aboys the
- j Some comments on plant performanecpertinent oc3urrences, y,
"C A'A ofsla stuo on to safety or to fission product retention taken h,/
from reference [43) nre mentioned here although most of them had no direct bearing on the occident FIC. 3-11 SRE fuel element.
- Itself,
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case l$ $
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'IEM4RARRE *T FIC. 5-11 $RE pump shah freeze seat, i
"-Unalloyed uranium metal is an unsatisf actory On December 12. two elements which had been ii excessively hot were removed and washed. Both 7
fuel material for a high-temperature reactor be-had black material on them. " Jiggling" by moving cause of a tendency to swell Fuel rods irradiated 3
to about 1000/hlwd/ ton...showed an increase in the element up and down one inch or less (in I
diameter of 2 to 4 mils. The,..NaK annulus...
Its position in the reactor) was found to improve had been occupied by the swelling uranium and heat transfer, but washing helped evenmore. Power '
was increased to 12 h1w (December 18) and 14 hiw i
d the can slightly distended."
(December 19) and the run continued to December l
s "blodification and maintenance of the sodium system have been accomplished with case and
- 23. After shutdown 15 elements were washed and.
safety. Piping can be cut and welded by first more cold-trapping" was done. The run continued freezing the contained sodium. There have been again from December 27 to January 29 at 20 htw no sodium fires during any operation involving maximum power with jiggling. ' On January 7 a.
cutting or welding piping containing frozen sodium.-
samplo of the cover gss showed the presence The cold traps and hot traps have performed of napthalene (andthereforeTetralin)inthesystem,.
well in removing sodium oxide; no difficulty was something not suspected before-although thore had j.3 experienced in maintaining the oxide concentration been a prior leak "in June 1958."*" (It was not t
known if any Tetralin had entered the primary below JO ppm."
"The major difficulty with the instrumentation sodium syritem from the earlier leak caused by has been n series of spurious scrams caused by a crack in the bearing housing casting on the main fluctuations in voltage from the power supply."*
prirnary pump.) The run was terminated on Jan-
. Reference [43) presents six pages of graphlo op--
uary 29 "because = the desired exposure of 600 Alwd was attained."
eroting and scram history for the reactor.
Since the circumstancea involved tathe accident Bug.) The run started on February 14 and con-extended over the entire period.of time from tinued until February 26. The reactor was run i
i November 29, 1958 to July 26, 1059 it seems ap.
at 20 h!w with continuing difficulties with fuel.
propriate to outline briefly the pertinent facts exit temperature spread leading to shutdown and l
+
chronologically as la done in more detail in refer-more washing-and cold trapping. " Reactor op-i ence [43] Quotations are from that reference, cretions were resumed February 20. Examination of the records of the shim-rod positions (which ilun.8 After a shutdown of about two months for was made after run 14) indicated that an increase repairs and nTodifications (involvingseveraltrans, in reactivity of 1/27c had occurred.~. Such an in-fers of the sodium from the reactor to the fill crease Is expected because-of the xenon decay i
I tank which was known to have considerable sodium during a shutdown of this length, llowever, a l
j
~
oxide), the reactor was taken to 3.6 htw on Nov.
preliminary calculation of this effect indicated an ember 20,1059, The fuel outlet temperatures,wh!ch expected increase in reactivity of 1L lt is be- -
usually showed a spread of less than 100*F (62'C) lieved that this disc repancy is due to approximations l
showed much higher values (415-800*r or 250, made in calculations of the xenon correction.
i 500*C). This was attributed to high oxide content.
Similar discrepancies are noted in later runs...."
.]
"There were two reactor scrams caused by d
4
- Frequent spurious scrams and warnings tend I
to dull the operators' sensitivity and to lead op-
" Cold-trnpping to purify Na or NaKisdiscussed ignore anomalous behavior. At the I. I
. same time, proventing scrams is also a dangerous in the chapter on Chemical Reactions, j
erators to
- "TLe evidence would seem to indicate three practico. Somewhere between these two extremes Tetralin leaks - one in April. May, or June 1958 l
j there is a reasonable level for the rate of scrams (the reports differ in the time), one in December j
per year, but it must be judged on an individual 1958 during rim 8 (no mention is made of tho basis, depending on the stage in the reactor op-source of this-one or its repair), and one during erations, the type and uso of the reactor. conac-quences of a scram, complexity of thereactor,etc.
run 13 in h!ay-June 1959 t
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- THOMPSON ACCIDENTS AND DESTRUCTIVE TESTS J3 641 excessive temperature drop across a moderator to be slightly dirty, but in good condition." An can and several scrams caused by power line attempt was made to wash one element, but during transients. The reactor has a long history of the operation a pressure excursion occurredwhich
[
scrams due to the latter effect." Run 9 "was severed the hanger (see Fig. 3-11) and lifted
~ terminated after the desired exposure of 125 Mwd the shield plug out of the wash cell. It is believed was achieved." After shutdown, the fuel element that hydrocarbons from the breakdown of Tetralin in reactor channel 56 was examined. The orifice could cause sodium to be trapped in the holddown plate had a thin black deposit. The fuel element tube on the hanger rod by blocking the sodium r
was washed and replaced in the reactor.
drain holes. This sodium then reacted with the wash water. "As a result of this incident, no Runs 10.11,12 (hlarch 6-7, h1 arch 16-April 6 further washing was done." It was decided to hiay 14-24) These runs showed some continued
" strip" the Tetralin and organics which would improvements in the fuel exit temperature spread, volatilize by passing nitrogen gas through the "An examination of therecordsof shimrodposition sodium system. The process had been bsed on (mede after run 14) shows that at the start of October 12,1958 to remove Tetralin from thosys-run 11 a loss of reactivity of 1/4% had occurred, tem after the first leak. Tha stripping began June The loss may have been due to the replacement 17 and continued until July 5. The sodium system of a thimble." In Run11 afurtherseries of scrams temperature was 350'F (177'C) initially and was bich had been due to flow fluctuations occurred and a reactivity raised to 425'r CI6*C) by the end to help the wash;d.- Doth discrepancy of 1/3'i attributed to xenon occurred removal. In all 400,000 ft3 (11,300 m3) of nitrogen ig" by m:ving again. During Run 11 the radiation level in the were used and 3 pints (1.42 liter) of Tetralin h cr less (in main sodium gallery seemed high although this and 1500 cm3 (91.5 in.a ) of napthalene crystals ad 13 improve was not observed until ten days after the run. At were removed. The system was then purged for s m;re, Power '
the end of this run a filter was installed in the ten hours with 4700 ft3 (133 m3) of helium and
- 18) and 14 hiw -
primary system which collected considerable car-argon. The primary pump was reinstalled with 1 to DecImber.
bon containing material. During Run 12 a planned a NaK-cooled freeze seal in place of the Tetralin-re washed and outlet temperature of 1065'T (574'C) was reached cooled seal, and the system was prepared for run continued for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 6 h!w power and steam was produced operation.'
t 29 at 20 hiw at 1000'F (538'C). A check after shutdown showed Jaruary 7 a no.ncasurable change in fuel dimensions.
Eun 14 (July 12-26,1959) The run was begun thy presence with the anticipation that the situation would be tinth3 system, Run 13 (hlay 27-June 8) Except for a sodium flow similar to that experienced in Run 8. The reactor tough ther3 had rato scram, the run was considered normal at was made critical at 06:50, July 12. At 08:35
" (It was not a power of 20 Itiw until 09:00, blay 30. Then, as the reactor was slowly increasing in power to 8 tha primary several abnormalities were seen including, a slow 0.5 h!w large fluctuations of 10*F (5.6'C) wero ECk caused by three-day rise in inlet temperature from 545'F noted on the moderator delta-T recorder. Nor-g on the main (2BS'C) to 580*F (304'C), an increase in log mean mally, even at 20 h!w these were less than 5'F.
mated on Jan-temperature difference across the latermediate The fuel exit channel temperatures started to show aosura of 600
, heat exchanger indicating impaired heat transfer, a spread of about 200'F (111'C). Operation con-a rise in temperature over a 20-min period from tinued at less than 1 h!w until 11:42 when a scram 660-945'F (460-507'C) in one fuel rod, some occurred due to loss of aux 111ary sodium flow.
p 14 and con
- increases in exit fuel ternperatures, a jump of Criticality was reestablished at 12:15 and op-set:r Tras run go*F (17'C) at 22:30. hiny 30, for moderator dolta erations continued at slowly increasing power levels sies. with fuel T compared to earlier 18'F (10'C) fluctuationo, with fud extt channel temperatures from 510
' ahutdown and and one or two other temperature probe effects, to 770'l- (265 to 410'C). Fluctuations of 30'F a," Examination In addition, "although it was not noted at the time (17'C) in the moderator dalta-T at 1.5 h!w were R a ctor ep*
because the reactor was on automatic control, observad. At 15:30 reactor room air monitors initions (which an examination of the record of shim rod position showed a sharp increase in activity. The radiation Et En increase (made after Run 14) showed that a shim rod motion level over the sodium level coil thimble in channt!
A Such an in-corresponding to a reactivity increase of about 7 rose to 500 mr/hr. Air filterandstack activities 4 xenin decay 0.3% had occurred. This change was gradual and inc reased. The reactor cove.r gas pressure was
.1However, a extended over a period of about 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Following lowered from 2 psig to less than 1 psig in an 4G indicated an this, the reactivity showed a steady increase of 1L It is be-shout 0.1% over the next three days of operation."
/pproximations By June 2, it was obvious that the heat transfer
- After the final accident during Run 14, the G C2rrection.
characteristics had been impaired in the primary use of nitrogen at this point caused considerable Ct:r runs...." -
system and the cause was believed to bea Tetralin concern about the possibility of nitriding of the Ams caused by leak. The odor of Tetralinwandetectedinthe pump stainless steel and zirconium and thus promoting casing of the main primary pump. The run was fuel af.d moderator can failures. Tests seemed terminated on-June 3, and after a 10 day interval to indicate that nitriding will occur in preference
, Kla discussed.
to allow radioactive sodium to decay, the pump to carburir.ing at 1200'F (649'C)incarbon-bearing a
2.
was removec'. A leak was discovered in the wall sodium with a nitrogen cover gas. Apparently it lindixte three of the thermocouple well of the freeze gland will even occur after a helium purge has supposedly
> tr Jun11958 seal (see Fig. 3-12) where a dislodged piece of swept all of the nitrogenout. Thenttrogenevidently ls in Denmber hard plating material wore through the wall as is held by the carbon and enicium impurftles.
b made cf the the shaft rotated.
hicasurements, coupled with tho known solubility and ond during
" Seventeen fuel elements were visually ex-of carbon in sodium [46) showed that the system l
smined by means of a television enmcra and found had been saturated le carbon ever since Hun 8.
lL
--.. l}
.i
,Q 642 T. J. TilOhiPSON 0-e!! ort to reduce lhe level. By 17:00 the radiation level over core channel 7 reached 25 r/hr.
Accordingly, at 17:30 power reduction began, at
,,,,;,,,,4 ;,,,,,4,,g,N fy%-
3 i
i 20:57 the reactor was shutdown, and the sodlum
'/
~
probe was removed from channel 7 and replaced
[' 8'
/~
" " " " '** N by a shield plug.
/
The reactor was brought to criticality at 04:40
/
July 13 with exit fuel temperature scram set-
/
points lowered to 800'F (427'C). At 13:30 ft was g
/
/j/ \\
/
observed that the modcrator delta-T followed a E
se rise in the sodlum outlet temperature and that 4
-}
the moderator temperature did not respond prop-d
<*/
erly to an increase in sodium flow, it was con-3 cluded that little sodlum wr.s leaking across the grid plate for moderator coolant. At 17:28 a j
io, planned increase in reactor power from 1.6 Mw i
began in order to deliver heat to the electrical tw tus a 10 )
+
5 i
substation. "At the start the power level per-sisted in rising somewhat faster than expected Fic. 3-13 Machine calculauen I of the SRt. power escursion, Zero even though control rods were being slowly in-uine u m2t on m n, m 3
serted in an attempt to hold it back." O'he solid I
curve in Fig. 3-13 (43] Indicates the course of it was decided to pressurite and vent the re-the power trace during this time.) By 18:07 with actor atmosphere once to reduce the radioactivity the power at 2 Mw, a negative period of about caused by the xenon in the cover gas. At 05:50 45 see was observed and power fell to 2.4 Mw July 15 the pressure was reduced from 1.8 psig
?
in about 3 min. Control rod withdrawal was (1.12 atm) to 0.6 psig (1.04 atm), repressurized I
started, the reactor was critical at 18:11 and to 3.0 pelg (1,20 atm), and then reduced to 1 psig power rose to 3.0 Mw by 18:21. Then, as the (1.067 atm). Lowering the core pressure caused n
power was increasing more rapidly, rod insertion an increase of about 0.017 in reactivityand raising began, but, in spitt of this, power continued to the pressure had the reverse effect. This 16 not rise. At about 18:24 three positive transients a normal effect on this reactor. " Operation was I
woro observed with about 50-see periods and at continued at a power level of rpproximately 3 hts."
18:25 a 7-1/2 sec period was Indicated. The A review of fuel exit temperature spread on
}
reactor should have started an automatic power July 15 showed that it would be uscless to try
- set-bs.ek at a 10-sec period, but did not,fomatto and the "to get the Edison turbine generator 'on the line' operntor scrammed it manually. The au since the maximum power level attainable would g
I electronic period scram did not act, as it was probably be less than 4 Mw."
This would not set for n five second period. The peak power permit operation at the desired high inlet tem-Indicated was 24 Mw.' (No particularly high tem-peratures while circulating through the steamgen-peratures were recorded during the transient.)
erator. Alterations were made and on July 16 at
+
Later examination of the perlodset-backmech-07:04 the reactor achieved criticality at a rod I
anism (a mechanical actuation by means of a cam p sition showing a substantial loss of criticality f l I
in the period recorder) showed that it worked since the beginning of the run. Intermittent opera-
- 'l properly only if the period decreased at a slow tion continued at less than 2 Mw until July 20 rate, but would not operate if the period decreased mal kats on pnssun encots, plugging tem-a peratures, and sodium level va riations wero carried covery from tho scram was madecautiously, ut. On July 18, the motor-generator set which Criticality was attained at 19:55 Approximately supplies the vital bus stabilized power failed 4
2-1/2 hours afterthescram,reactorpowerreached and operations were resumed with the unstabilized 2,0 Mw*" Rod rositions wero now S2in. (132.l cm) sns n
y 0, b nactor mer out rather than 40.5 in. (125.7 cm) as before the was increased to 2.5 Mw to raise loop tempera-scram, but the difference was, at the time, at*
tures gradually to 700'F 371'C). On July 21 tributed to xenon. The rods returned to 50.5 in*
at 02:10 a sorsm was cau(sed by a fast period
,L 028.3 cm) by 02:00 at a power of 4.0 Mw. It indication. (Apparently it was attributed to un-
~1.i was decided that the excursion had not affected the stabilized power.) The reactor was critical again reactor adversely. Operations continued until13:00 at 02:25. At 06:45 radioactivity in the reactor be-I when a scram was caused by a short-circuit gan to build up. At 09:45 flow was lost in the main introduced into the demand circuit for the primary secondary loop causing a scram. The secondary pump being prepared for a flow oscillation test, lo p was restored to service, the vital bus put Ir The reactor was made critical quitorapidly (13:11) back on the repaired motor-generator set, and 1
and operations continued, operations continued at power levels up to 4.5 Mw, sodium flow rates up to 1500 gpm (94.5 liter / sect.
a 1
- The final report [43a] corrects this value to and reactor outlet temperatures to 7DD*F (421'C).
t about 14 Mw, noting that "The 24 Mw value was On July 23, it was decided to shut the reactor i
obtained by a linear extrapolation of the log N down and it was scheduled for 17:00 July 24. tintil 09:
recorder chart from power levels of about 2 Mw, 00 July 23 reactor outlet temperatures were i
and linear extrapolation is not valid."
kept between 700 and 600'F (371 to427'C)although
)
i a few reached the 900 to 2000'F (482 to 538'C) l s
%~
. 2 ~.,.
-ww -=-
mmr w&*
1:
n
.__9g l
_m
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- ACCIDENTS AND DESTitUCTIVE TESTS is 643-range. At 09:50 July 23. a reactor scram was graphs t = 0 at 17:28 hours. July 13,1959. The r
c.
caused by a fast period indication, it was at-dotted line of Fig. 3-13 shows thecourse the power s/ ' '
tributed to an electrical transient and the reactor trace would have been expectedto takelf the normal 1
l was critical again at 10:13.
reactivity coefficients and control rod worths were
/
Botween 00:00 and 08:00 on July 24 it was in effect. These calculations were made using the
-/
noted (while jiggling elements to dislodge foreign ADtEll IBh1 Code.
material) that the elements in channela 10, 12, 35 By introducing seven ramp and step changes in
./
- /'
and 76 were stuck while it was known 10 was free reactivity. Fillmore was able to get the agreement
/
on July 22. A scram was caused by a fast period shown in Fig. 3-14. no general features can then indication at 12:50 on July 24 and was attributed be explained at least semiquantitatively. The to an instrument tranalent and the reactor was slow but steady rise at a rate of + 0.04% in a g j V
made critical at 13:14. Accidental loss of auxiltary 3 minute ramp in spite of gradual control rod i
primary flow caused a reactor scram at 15:40, insertion and the negative Doppler effect is at-the mcderator which has a reactivity coefficient o tributed to an abnormal rise of the temperature of The reactor was critical again at 15:56. Cold-trapping was put back in service when the outlet temperature reached $10* F (266'C)and the primary
+ 1.7 x 104/'F (+ 3.1 x 104/'C) and perhaps also -
plugging temperature gradually dropped from 455 to some sodlum vapor formation in partially to 350'T (230 to 117'C) within about seven hours.
plugged channels. (The sodium void coefficient is r escursion. 2ere On July 26 it was noted that thefuel in channels positive although the fuel temperature coefficient 12 and 35werenolongerstuckand76 was somewhat was considered to be -1.1 x 104/'T or - 2.5 x free, but 10 was still stuck. The reactor was 10 5/*C.) The fast negative excursionisattributed d vent the re-i finally shut down on July 26 at 11:20 after logging to rod insertion reducing the lacrease in power-16 hlwd in Itun 14. Post-run examination of the rate and causing the collapse of sodium bubbles s radi: activity core 'showed that 10 of the 43 assemb!!cs in the and vold regions, thus improving coolant contact gee, At 05:50 I core had undergone severe melting of thecladding.
with the fuel. This cooling in turn reduced fuel i
! rom 1.6 psig repressurlaed The top and bottom halves of these ten elements temperature and caused a gainof reactivitybecauso -
a were separated. The rone of failure was between of the !bppler effect, and perhaps sodium void j
.uoed to l glg one-third and two-thirds of the length of the ele-collapse, so that the control rods needed only to assure caused.
ment measured from the top. The accident showed be withdrawn a little to again start the reactor up ity and ral;ing
- t. This is not that iodine released from the elements was very on a slow steady rise. This was followed by a Operati:n was effectively retained in the sodium coolant. In fact.
fast transient which added + 0.3% in a 5 to 10-mately 3 h!w."
no activity except the noble gases was detected in sco ramp, it is postulated that this was caused ar) spread on the cover gases (45),
by the more or less simultaneous voiding of '
In reference [47] Fillmore has considered the about 10 partially plugged fuel elements. Study useless to try er 'on the line' i
translent which occurred on July 13 in detail, of the damaged fuel clements [48) seems to show
.ainabis would The general features of the transient include a that thermal cycling occurred at temperatures his would not '
slow but steady rise in power partially com-above the a-S phase transition of uranium which igh inlet tem-pensated for-by control rod insertion. a sharp would lead to fuel ruptures and also steel-uranium
.he at:amgen.
drop in power, followed by another short interval eutectic formation, it is therefore postulated that on July 16 at of slow but steadyrise.andafinalfast rise termin-several channels underwent one or.more cycles lity at a rod ated by scram. These features are shown by the of heating and sodium vapor formation followed by of criticality solid line in Figs. 3-13 and 3-14 (43). On these void collapse. The cycles in the various elements
.l I
mittent tpera-until July 20 i
3o plugging tem-i I
I I
[
e l
'f 3
swirecarried i
i o
7 8
stor set which '
j
(
S 6 2
8 3
power failed te unstibillaed
-l a-w eact:r power loop tempera-l B
. On July 21 E LO I
a fsst piriod w
i e
rilmted to un-F-
AC7UAL Powf R
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critical again U
[
C#""*
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ae react:r be-Jet in the main l'he secondary 1
I I
I
.vit:1 bus put go t
w2r ad and o
e a
3 3
up t) 4.5 Mw.
TIME (see a 10 )
l 4.5 lit:r/sec).
190*F (421'C).
Fic. 3-14 Machine calculanon lit of the sRE power excursion. Numbers indtem the following sequence:
tutth3renctor' (1) start ramp ap/at of 0.H a 10-41/sec. thus introducing total ap ot 4 0.0077 %: a) hol.l orst ramp coa $ tan' at. o.007% and start secoms ramp a p/at of- 0.3 = to-4I/see: a) hotJ orst two ramps constant.
P July 24. Until start third ramp of, 0.1 a lo J/sec, thus introductre total ap of, 0.01;; (4) holJ all three ran ps con-cratures were l'
stant (at. 0.0077%. - 0,00n% aml + 0.02% respectnely),introJuee step ap. - 0.06%; (5) introJuce step
,27'C)although a p.. o.020 (6) antroduee siep ap. - 0.005E p) sairaduce step ap. 0.0JL tore ::me 17:28 on July (482 to 538'C)
- 13. 1959 l
I 7
-,, e n
-.w y
,, - y m,.. # =
__m
- - - __ a(
644 T. J, TilOMPSON are postulated as acting independently at first poor safety characteristics. For inciance, if the with periods of the order of 2 minutes. But the slidewire breaks, the recorder goes to one ex-rise in power to 5 Mw was sufficient so that "all treme of its travel, This can lead to an unsafe cycling channels were affected" and volding in situation, (especially if the recorder is being used i
a!! occurred more orless simultaneously. Further, to drive an automatic control unit for the reactor-one can postulate that there was a reactivityinter-as happened in one case). In addition, there was action between channels and that voiding in one evidently much to be desired in the normal be.
~,
led to heating and voiding in others and so on.'
havior of the system. Reference 143) mentions _
several' times the fact that "the reactor has a Comments. Conclusions Recommendations history of spurlous scrams due to apparent period -
transients". This problem is often encountered (1) Systems should be designed utilizing com-during the initial tests of a reactorandis often due patible components, materials, and fluids in all to' either improper grounding of electrical com.
Jessible cases, la this partloular case, the choice ponents, electrical noise from other equipment on of Tetralin for cooling a bearing which could leak the same power line, or power. surges, or all 1
into the sodium system was a primary cause for three. Usually it can be climinated in a short-the accident. If this is not possibic, then"Where -
time without sacrificing period trip sensitivity, materials are potentially incompatible under nor-This instrumentation system had been used since mal service' conditions special means must be 1957 and by 1959 the problem abould have been provided to separate them. Where there are com-solved. The fact that the operators are described patib!!!ty changes with abnormal operating con-as achieving criticality after scrams in time ditions, e.g. temperature, special attention is re-intervals of.15 to 25 minutes would seem to in-quired for monitoring and controlling such con-dicate that no thorough investigation of possible ditions." l4 Sa }
causes could have been made. Infact if Fillmorc's (2) At the time the choice of fuct had to be explanation of the fast transient effect is correct, made for this reactor the knowledge of fuel per-there may be some reason to bolleve that some formance was not so good as.it is now and there of the several period scrams which occurred in
- were not so many choices. It was known, however, Run 14 were genuine, although "No evidence was that tu'anium metal had an a-S pisase transition uncovered to indicate that there w ere indeed genuine
+
with accompanying swelling at about 1220* F (660'C) scrams other than during the transient at 18:25 on and that uranium formed an eutectic with stain.
July 15" [4Ba).
less steel at about 1340'F (725'C). Thus, while hicDonald and DeVan (49) give the opinion that, the use of a utainless steel-uranium metal ele-
"the reactor instrumentation under the immediate ment may have been the only cholco, nevertheless surveillance of the operators was inadequate to phase transition and eutectic formations greatly indicate excess!ve fuel element temperatures, the lowered the temperature at which fuel element blocking of coolant passages, and fission product failure and melting occurred. Designers should leakage. As a result, the operators did not con-always try to select materials and combinations sider such indications (where they existed) serious of compntible materials that will stand up as well enough to warrant shutting down tho reactor.
l as possible under abnormal conditions. During Since the SRE la a ' developmental facility built the planned 1065'F (574'C) run (Run 12), the
- to investigate fuel materials' it would appear that central fuel element temperaturcs must have
. additional instrumentation, as well as closer tech-been quito close to the n-$ phase transition nical management, might have reduced the damage 3
point in a number of elements, to the SRE core."
(3) It is not good practice to use, even as (5) From the evidence available inthis accident q
temporary additives, materials or gases which it would appear that fission products other than may remain in the system and cause deleterious the noble gases are retained well in nodium. This, efftets later, Thus, the uso of nitrogen as a in a sense, affords an additional safeguard unless stripping agent for Tetralin led to a concern over
- the sodium should then become exposed-to air nitriding later The total cost of thetime spent and in such a way as to become a fire hazard, i
the tests run was probably greater than if a chem-(6) The circumstances which eventually led to leally inert noble gas had been used in the first this accident began as early. as spring, ID58, place.
when the first Tetralin leak occurred. A second (4) There were several instrumentation prob-leak occurred in Run 8 on Novembor 29, 1958 lems. The principal one involving a period set-and problems continued until July 24, JD59 During back has been described. Thopracticeofincorpor-that time so many difficulties were encountered 1
ating such an important item of equlpment as a that, at least in retrospect, it is quite alcar period setback as a part of a recorderts question-that the reactor should have been shut down and able. Recorders require easy access for main-the problems solved properly. Continuing to runin tenanco sad ink-refilling,' and often have very the face c' a known Tetralinleak, repeatedscrams, equipment failures, rising radioactivity releases, and unexplained tronalent effects is difficult to
- This description, if correct, illustrates the justify. Such emphasis on continued operation can type of react!vity effect which can be very serious and often does have serious effects on safety and since the mechanism depends upon a positive can create nn atmosphere leading to serious ac-Internal feedback, increasing without limit, until cidents. It is dangerous, as well as being falso terminated by disassembly - unless terminated economy, to run a reactor that clearly is not
!!rst iy an external means such as control rods, functioning as it was designed to function.
j
~'*"*L.,-w
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' ACCIDENTS AND DESTHUCTIVE TESTS 53 645 j
1 instance, if 'he -
In the long run, reactor economics as well as
~
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see to one :x -
reactor safety will demand adoquate continuing M
id to an u; safe maintenance at all times, and this will include n
.8
' a
'" ' g \\
rr is being used
. early shutdown and proper action whenever there Q 'd,l,j j
at the react';r-is the least doubtconcerningthe situation, h1anage-8,',
- 1 M 8,*q g,,, d.ly g tion, there was '
j ment can and must establish this sort of attitude.
J
,,,m 2e norm:1 be-ies ire its ***,its
.o*
1 es
- [43] mentions
' es in i >4 in i+ W in in in a
-s 4
6i 6,
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o
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- ranotir bas a.
1 VO Westinghouse Test Reactor Accident l50-53]
j b ** " "
i
'sa m a r$
ipparent period l
- *
- 0 ""
1
"' " ~
en encount; red -
The Westinghouse Test Hemetor is a light-andis often due water-cooled and -moderated reactor utilizing y',,',,,' %* t,,Y O C hI
,1'.,7 1
destrical com-highly enriched uranium fael. The fuel clement
,. c,.;y,..
,. gy,,, n g i tqA its A 't ' o si'*
,d',-.Es'v.T-v[*vn sr equipment on consists of three cylindrical layers surrounding ist surgia. - cr all a central thimble. Each layer is made up of 0.032
...'e-,
e
'"t'"
.ted in a short in. (1.32 mm) of aluminum-uraniumalloy,cladwith
- f6
<*m' rip sensitivity, f
0.0365 in. (0.927 mm) of aluminum on either side.
c'
-8
'-8 1 seen tsed since At the center of cach fuel element is a thimble which permits tho insertion of a sample. Unless a
'.'2.
7.
Na l,,
'e suld havs been i
A are discribed i
special experiment is involved thecentralsections
-l
- rams in time l
are loaded with either alumbium or cobalt slugs.
The use of these aluminum and cobalt slugs helps
-id seem to in-ton ci possible with the shimming of the reactor for control ric. 3-15 WTit core cross e cuon. Normal circles indicate fuel
"I" ( 8 * * * **b "M '"* * ""'"3 "d '
'3'*'"n"c*lo"steg an x a're" plugged those enclos't'ig a 't cre higtw'
- t,if Fillmorc's purposes.
Circles e
- eet is correct, A diagram of the core is shown in Fig. 3-15 pressure uitmues, ne coments of the irra.itauen volumes are d'n't'd g* darkened areas at ivr and bottom of samvtdual fuel ele-nev)3 hat some
[50] The nine control rod positions are indicated
[ilc[*(,ig. frtp$os's": .' 15 a'NinN.IN:,NeUhal$'
Oh occurred in-by the black circles. Each control rod consists p
o evidence was of an aluminum-clad cadmium cylinder with a nadicate rosiuon strip et teitom. expersm nt. Upper umbedr35 enumated to be imr numben denoic amber of trams or eindeedge uine normal fuel element follower. Thus, on the full 4cnt El 18h25 on withdrawal of a control rod from the core a C'*r" re'fN*us"ed n fet ne'hk 'o'deNpIsEto
'OS t
regular fuel element containing IDD g of U235 is emined se the above nsun.)
n2i opinion thats left in that position, in Fig. 3-15 the number
{
before the dash indicates the top to bottom row (6.4 atm) and a core pressure drop of 15.5 psia
' the in'midiate -
a inadequate to starting at the top of the diagram, and the number (1.05 atm). The core inlet and outlet temperatures.
l after the dash indicates the position numbered were 115 and 125'F (16.1 and51.7'C)respectively, nperature, the from left to right in any given row. The number Tho normal surface heat fluxunder theseconditions tission product s did n t con-beneath the line indicates the number of grams of was estimated to be '1.13 x 1@ Utu/hr-fts (35.6 ~
ixisted)sirious U235 estimated to be present at the time of the watt /cm*) with a flow velocity of 21.3 ft/seo.
a th) reactor.
accident. Each of the fuel elements originally (6.50 m/sec). Theso numbers were caleviated for il facility built contained IDD g of U235. The core has a 36 in.
57 fuel assemblics in the core. At the tin'e of the uld appear that (0.914 m) active height and a main active diam -
accident there were 76 fuel assemblics ir. the coro es closer tech-l eter ~ of approximately. 28 in. (0.711 m) with an including control rods.
Bud the damage aluminutn-water ratio of 1. Atthe originallicensed The site ventilating systems, the various wasto puwe.r of 20 h!w the average thermal neutron flux collection tanks, the evaporator-condenser tanks,
. in this accident
.in the core was approximately 5.2 x 1083 neutrons /
and several other components all vent their non-Eta (ther than cmN sec.
condensable gases to a 100 ft (30.5 m) vent stack -
3 sodium. This.
The fuel element that failed (Position 6-5) located between the Process and lleactor Service Pfeguard unless contained a special experiment designed to mon!-
Buildings, exposed t3 air i
tor fast neutron fluxes. The experiment consisted At the time of the accident the reactor staff aaned.
of a set of 7 hairlike nickel wires, each seP-was engaged in a series of teste to determine ventually IEd to -
arately encapsulated in a quartz capsule and held the feasibility of increasing the power gradually
- c. spring. 1058,
.in recesses of a 3/8 in. (9.52 mm) diameter to 60 h1w(t). Reference [50) provides a detailed Sed. A second aluminum rod. The rod in tarn was encased in chronology of events. The quotations in thofollow-f Eber 29,1058, a 1/2 ' in. (12.7 mm) OD aluminum tube with ing abbreviated account are taken from there.
4 4,1D39. During 1/8 in. ~ f3.18 mm) weep holes drilled through According to the license amendment of January B.
re encountered t
the wall at 4 in. (10.16 cm) Intervals. This 1960. to permit operation at a maximum of 60 Mw(t),
.is quito clear assembly was placed in the central thimble of the certain restrictions wereimposed. These restrict-thut down and fuel element in the normal manner. A flow orifice lona were [50]
inuing to runin at the bottom of the thimble section limited "1. Westinghouse shall retain the bubble for-
. peated sc rams, i
the flow to that required for cooling this rod, mation apparatus and the special detection lvity reltases, t
Other experiments were located in Positions 5 6, channel described in the application in is diffleult to 7-3, 7-6, 8-5 and 11-1. Other fuel elements the reactor during the power escalation
$peration can contained aluminum und cobalt, as indicated in program until stable operation at 60 h1w(t) ls on safety and -
Fig. 3-15 power level has been established; i 13 serious ao*
The coolant flow is down through the core and
- 2. The ratio of -the maximum heat flux in l as being falle up through the thermal shield The design specifi-the reactor to the burnout heat flux shall plearly; 13 not l
cations required a flow of 15,000 gpm (D50 liter /sec) never exceed one-half;
.ction, at 20 hlw with a core outict pressure of D3 psia
- 3. The reactor shall not be operated in such pm
_- m
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m p__-
m i.
m-g5e-wrsuomsenww.
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'***J* 'M Rcekwell teem seson international
. March 4, 1980 In reply refer to 20ESG-1753 Mr. Victor R. Husbands Agency Director Resource Management Agency County of Ventura 800 South Victoria Avenue Ventura California 93009
Dear Mr. Husbands:
In cooperation with the Ventura County Board of Supervisors, we have responded to the list of questions presented to the Energy Systems Group on February 6,1980, by the Resource Management Agency of the County of Ventura.
We have responded to the first two questions asked by the Ventura County Resource Management Agency. Our understanding is that the remaining three questions asked by the County of Ventura will be answered by the appropriate. governmental agencies.
. As for the remainder of the questions directed to the Energy Systems Group by the various organizations, we have responded to those questions we believe are, of primary concern to the Board of Supervisors.
Our responses has t, been carefully constructed, adhering to the following criteria:
Ac*dyles<'
1.
We followed the instructions in your February 6 letter to determine which questions we would respond to.
"We are rnb askino you to review all the cuestient and respond to those W]$go
- p 41rectly offectina your agency. Our Board's concerns are gt with the "ac'11 ties at sanu susana in Ventura County..."
1.
At the January 22, 1980, Board of Supervisors' meeting, the
(
Board stated that their concerns regarding Energy Systems
/
Croup operations at Santa Susana were with the health and safety of Ventura County residents. We were reminded that the Board wanted to avoid entering into a public debate concerning the political, environmental, and social aspects of nuclear power.
-.s........_;_=..--
f
/.'
soEsa-nsa Rockwell March 4,1980 International
~
Page 2 i
?
l n
We believe all the cuestient relevant to the haalth and safety of Ventura IoW#'
To'unty residents have been rescended to fully and comolttAly and that our repiles reattirm the facts that we presented to the Board at your January 22 meeting.
t Very truly yours, (1, L.'
/
/ J. D. Gyl 4, Director External Affairs Energy Systems Group i
emh:304 l
T e
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i i
4 I
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~.
Enclosure 80ESG-1753 QUESTIONS BY THE COUNTY OF VENTURA RESOURCE MANAGEMENT AGENCY Questh 1.
Have there been any accidents involving nuclear material at the Rockwell Company's Santa Susana facility which represented a significant health and/or safety risk to people living near the site?
Response - See also responses to Questions 6, 7, and 8.
There have been no accidents or incidents involving nuclear materials at the Rockwell International Santa Susana facilities which have resulted in hazard or risk to the general public near the site.
Question 2.
Has Rockwell Company and its antecedent, Atomics International, been a responsible operator? How does the safety record of the Santa Susana facility compare to similar facilities operated by others?
Response
The Energy Systems Group of Rockwell International and its predecessor organizations have compiled an outstanding record in the health, safety, and environmental control areas.
The overall safety record for our operations has consistently been far better than the record of U.S. industry in general.
During the 25 year period, 1954-1978 inclusive, the average accident frequenc worked) y (the number of lost-time accidents per million man-hours for ESG was only one-seventh of the U.S. industry average.
- We were a finalist and a grand runner-up in the National Safety Council's Sweepstakes Competition in 1966, 1971, and 1973.
We were the winner of the Grand Sweepstakes Award in 1977 and then became the first organization to repeat as grand sweepstakes winner in 1979 in competition with 650 organizkticas in the southern California area. We submit that this record testifies to the high safety standards which our company has maintained over several decades.
Throughout our many years of operations with radioactive and nuclear fuel materials, we have had an excellent record with regard to employee radiation exposure.
The radiation exposure to ESG employees whose activities involve potential exposure has averaged less than 6 percent of the permitted exposures which can be accumulated each year for 50 years.
m
Qur environmental monitoring program is conducted routinely to sample and analyze the air, vegetation, surface water, ground water, and soil at the ESG sftes and in the surrounding area.
Data from this program, which are published annually and are a matter of public record, show that no releases of radioactive materials in excess of the regulatory guides has ever occurred, and no detectable radioactive materials exist in the surrounding areas offsite as a result of ESG operations.
\\
4 4
QUESTIONS BY THE COMMITTEE TO BRIDGE THE GAP
/
F0 Yh a c/,
g N
pp l
Question 6.
At the time of the acci the_crimary radioactivity that y
escaped the reactor vesiellitelf was in the form of radioactive J' '2 krypton and xenon cases.
The following have been alleged; please s
conrirm or cont.racict and provide specifics:
T 3
y a)
Some radiation monitors--specifically thos. in the holdin
-5 s
fanks--went err-scale at the time of the accident, i.e.,
nto T
,# (
g7 a range Tor which the monitor had not been calibrated, thus g
NI ncotA making accurate measurements difficult, g k t' di hg3 h b)
Most or all of the radiation monitors were incaoable of d- @dV>y measurino nenia cas3s sucn as krypton and xenon.
Please state wntch, if any, could measure these gases and which could not.
.nfSL k p c)
An automatic bypass system failed at the SRE, requiring the N
gas from the system that vented these gases directly to thes mg.),c.t'g A )
)
atmosphere to a holding tank first.
t b 3
Response
The SRE accident, which occurred in July 1959, resulted in fuel l
damage to approximately 30% of the fuel elements in the nuclear reactor.
This fuel damage then resulted in the release of fission products into the primary coolant system in the reactor vessel.
l The major portion of the radioactivity was contained in the sodium coolant, but some of the radioactivity was collected in the cover gas in the volume above the coolant inside the reactor vessel.
This radioactivity in the cover gas consisted principally of radioactive krypton and xenon and was the same type of radioactivity l
which collected in smaller quantities during normal operation of
{
the experimental power plant.
The cover gas was normally transferred to large holdup tanks in the factitty for the specific purpose of collecting and retaining radioactive gases.
After decay, the gas was exhausted to the atmosphere through a filtered ventilation system with large quantities 2
i
.o _..
of air for further dilution of the radioactivity.
The releases were well below those permitted by regulations in existence then and today.
l Essentially all the radioactive gases collected in the cover gas during the accident were transferred to the holdup tanks.
Because of some leakage through the shield on top of the reactor core, very small quantities of the cover gas and radioactivity leaked into the reactor building. Monitoring of the contamination levels and of the radiation levels to which operating personnel were exposed indicated that no personnel received radiation exposures even approaching those permitted for radiation workers.
In addition, the contamination was contained within the reactor building and resultea only in the requ' rement for careful survetua65 and i
decontamination efforts on the part of operating personnel.
During the releases of the radioactivity from the holdup tanks, g.(d;d'o there were two instances in which the stack monitor readings f q.j.,,
indicated activity concentrations in excess of the allowable gg g a values.
In both of these cases, the increased concentrations of
- ,g.
9 activity were observed for very short periods.
Intermittently high J/
levels were observed for periods of approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on each
~
MW of the two occasions.
While these values for the stack effluent 1o.
.w.
exceeded the allowable values for continuous release, the releases 3.! e.M occured for very short periods-and posed no ha:ard.
Further, when averaged with releases for the calendar year, they were completely acceptable and did not affect the capability of continuina to vant
.th_e_ radioactivity to tna atmosohere in acceptaole concentrations.
In further corroboration of the acceptability of the radioactivity releases from the SRE following the accident, the continuous program of routine sonitoring of soil, vegetation, water, and airborne activity in the Santa Susana area was continued.
This i
program which had been underway since 1954 as an environmental monitor}ngprogram,includedmonthlysamplingat14different locations for soil and vegetation and 4 locations for water.
A 4e}, e et W4 continuous air itor was-also operated.
The results of all the g gc.
environmenYal' data collected in this program showed that the SRE
'M operations, inc u ing the accident in 1959, had not been responsible
- 3 for the release of any41Eificanpquantities or racioactivity to b g[,p 4
~
2 the environment.
L y
y ggj}
Question l
7.
Exactly how much radiati_on., and what kind, was released by the SRE acc1 cent.
Please show the rawlata from which these estimates are gdV
& g M [ M made and give a prob eilitv er error for the estimates.
i Please include a_1pha, bj.ta, and camma radiation in the estimate as well as total curTe count released and the amounts of each nuclide released.
l Please give the range of radiation at which the SRE monitors l'
were sensitive and their probability of error.
3
_.a..__
'(
. o' r
o Resconsa See the answer to Question 6 1bove.
f Question hee #
I 8.
Please answer the same questions as Item 7 for:
(a) the AE-6 release of fission products (b) the " wash cell" incicent of 1959, and (c) the SNAP-8 (55ER) accidents of 1964 and 1969. ( 2. < c 4 o c <t f.4 d s l
Response
a)
The release of fission products from the AE-6 reactor occurred on March 25, 1959, as the result of an operational error during routine operations associated with the reactor.
The AE 6 is a small, aqueous, homogeneous nuclear reactor which contains the nuclear fuel in the form of a water solution.
The reactor is operated with the fuel solution contained in a stainless steel sphere at negative pressure with respect to the atmosphere.
During the operation, there were times when the pressure inside the reactor core increased slightly because t.
of the evolution of gases inside the core.
This evolution resulted from the decomposition of the water in the core into b-hydrogen and oxygen. When a slight pressure buildup inside j
the reactor vessel occurred, the excess gas was removed by evacuating the system into a large tank.
s k
This incident occurred when an operational error was made I
during the transfer of the gases from the reactor core.to the
,s tank.
This resulted in the release of a small amount of I,
fission products into the reactor room and in the contamina-
~T
'l tion of three members on the operating staff.
The contamination k
was cleaned up quickly and effectively, and the levels of w %
contamination were so low that there were no measurable radia-S 3
tion exposures to any of the personnel involved and there were N
no releases of radioactive material outside the reactor faci--
/
lity.
Corrective action to correct that type of incident was k
initiated immediately and effectively, and there have been no similar incidents since that one in March 1959.-
i s
M k b)
The wash-cell incident occurred on June 4, 1959, at the Sodium Reactor Experiment.
This incident involved the reaction of T
the sodium on one of the' reactor fuel elements with water in the wash cell. The wash cell was a specially designed cell in g
which the fuel elements from the Sodium Reactor Experiment y
were inserted and washed with water to remove any sodium which had adhered to the surfaces on the element after its removal 2
from the reactor.
In this particular incident, there apparently l
was enough sodium still clinging to the fuel element to cause a reacticn with the wash water to produce sufficient pressure i
4
f l
hy!th
- [
inside the cell to force the shield plug and the fuel element connecting rod associated with the element out of the cell h onto the floor of the reactor room.
Some radioactive contam-4.
insted material was released to the reactor room rioor.
p/[6
/
9 K6 wever, there were no releases or ractoactivity off the reactor site and nojh reful radiation exposures to any of the operatina norsonnel.
The shield plug and rod were reinserted y into the wash cell with the fuel element, and the cleaning of Q
the element was completed in accord with normal wash-cell procedures.
c)
The two events involving the SNAP reactors involved two generations of SNAP experimental reactors which were operated by Atomics International at Santa Susana.
The SNAP program
[f T
was a program with the ob,jective of developing compact nuclear
$v power plants for space applications.
The S8ER was an experi-4 d ( g mental reactor of a first-generation type developed by Atomics International and operated from June 1963 to April 1965.
The S80R was a second-generation. reactor which included improve-
[n ments resulting from the experience and technical information sdeveloped during the operation of the S8ER.
The 580R was-s y,t operated from June 1968 to December 1969.
The events referred
}
- ,, elements.to here resulted from some cracks in the cladding of the t
T1 Both of these reactors contained metal-alloy fuel elements h*h(whichwereenclosedinHaste11oytubeswithweldedand bdg During operation of the machines, some cracks developed in.the Haste 11oy tubes, and these permitted some of the fission q
products from the fissioning of the Uranium 235 to diffuse T.
4 into the primary coolant system.
The reactor core vessels
- N f
contained a sodium potassium alloy which was used as a coolant hg for the reactor fuel elements.
The fission products diffused through the cracks in the stainless steel tubing into the coolant but were completely contained within the reactor system.
Consequently, there were no fission products released outside the reactor system, and there were no releases to the reactor facility or to the environment.
Question l
9.
Did AI build the SNAP-9A? If so, please give details about what happened to it.
Response
[ld kg 2e f #
( Roc elMidnotbuildtheSNAP-9A.
Question l
10.
Is it true that a leach field was contaminated by AI with radio-activity accidentally?
If so, please give details.
Please give 5
4 f
f)&
9 amounts of radioactivity and kinds, and confirm 4= ^=* the accidental contamination amtanded off AI's property.
How lone did the contamination rema'n undetected? What studies have been done to determine how much'of i
the ractoactivity traveled from the contaminated site elsewhere in the interval it remained undiscovered? 'A Og g.c*'g}M 49, ss s e.,M w phy racNed,y*
h kw;.s
/
>sys a m WL Q+t "62/'Nw, Resoonse One of the leach fields at the Santa Susana site became contaminated
,?
through operational ur.gr.
Some contamination entered the leach i
h ew ' '
field together with the sanitary sewage.
The radioactive material G
was contained within the field as verified by core sampling of the i
entire field area. When the contamination was discovered, action was initiated to remove the contaminated material and dispose of it i
at an approved low-level radiation area disposal site.
No radio-active material was released from the Rockwell site, and the leach field is no longer used.
Question 11.
Has there been some contamination regarding the SRE retention dam?~
Please give details explaining why a radiation monitor had been i
placed there by State Health.
Response
There has been no indication of any additional radioactive con-tamination in the SRE retention pond as a result of operations.
A radiation monitor was placed nearby the retention pond by the State i
Department of Health as part of their program of independent moni-7 toring of the Rockwell activities in the Rockwell facilities.
The I. "
@[g 1
location near the SRE retention pond is coincidental, since a t
primary requirement was an electric power source for their instru-mentation, and there happened to be one available near the pond.
In addition, the Department desired the monitor to be near the Rockwell property boundary.
Question 14.
It has been alleged that the wash-cell incident was caused in part by washing a sodium-dripping fuel rod with water. Was water used to wash the rod? Was the fuel-handlina cask used instead of the
'1 wash-cell plug as the plug I'or_the wash i: ell du'rina T.nis amaratTon?
g[
What were Ine radiation exposures to wor gr_a_and_to the aeneral ident?~
~
environs during thfs a (ical treatment for'3 months for radiationIs,it true1th d,
sent tack East for med exposurer riasse give details on any part of the previous state-ment that is true or not true.
Response - See response to Question 8.
6
Question' 15.
Please give details about the SNAP-8 and 58ER 1964 and 1969 accidents.
What caused them and what was the degree of damage?
Response - See response to Question 8.
Question
- 16. Were the big doors of the SRE building open durina the time of the Gann-en11 incinant?
If so, how much of the radioactivity released e
p p y'7 got out of the building?
N y
Response - See response to Question 8.
Question
- 17. Has anything from the SRE been buried on site?
Response
No radioactive material has ever been buried on the Rockwell site at Santa Susana.
Question 18.
Are there helicopter overflights'of AI measuring radioactivity?
If so, what hot spots have been detected, if any? Please be specific.
Who does these overflights and for what purpose?
Response
Radiological surveys of the Rockwell International facilities were conducted in June and July 1978 by the Energy Measurement Group of EG&G, under contract to the U.S. Nuclear Regulatory Commission.
The highly scientific equipment used by the surveys accurately detected radiation at the Headquarters facilities in two regions associated with the fabrication of test reactor fuel elements and the storage of low-level radioactive materials.
These sources resulted in radiation exposure rates which are well within allowable levels but approximately 20% higher than surrounding background.
Neither source was detectable at the Rockwell property boundary.
44 *
% s:ch a b y '.s Irv p A
^'Q At the Santa Susana field laboratories, threegources were located a
v during the survey.
These sources resulted from activities at the Rockwell International Hot Laboratory, at the Sodium Reactor Experi-ment Building, and at the radioactive vaste storage building.
While these showed radiation levelsQopewhat n1anadthan background radiation, they are well within all able levels and no radiation above background levels was d ed in the areas off the Rockwell ite.
W'hy 1
I a.s k $;^f W p
66 K)
% 0 rS f'
e
l#
0 if l
+
1
.I g
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Question 21.
How much radioactive materiar is unaccounted for at AI? What is the total MUF (material unaccounted for) for AI for its operating
)
history? -
~
~
~
T
Response
The cumulative inventory difference of strategic special nuclear p
natorial in operations,at Rockwell fnternational during the 28 year period 1948 to 1976 is T.5 kg of U-23% as published in U.S. Energy 8
Research and Development. AdministratTTn and U.S. Nuclear Regulatory
,g >.7 f,,.e,Stg l
Commission Reports on Strategic Special Nuclear Material Invento
}
Differences.
This amount is attributable to normal operating e
N losses, unrecoverable process residues, and deliberate discards as p
p
-wasta.
The inventory difference for the period September 30, 1976, yt p,A,
to September 30, 1978, as published in later DOE and NRC documents, o*
totals 0.6 kg of U-235.
Question 4
\\%
- 22. Why did the plutonium processing facility at Santa Susana become shut down?
Is it possible that the facility will be reopened?
Response
l The plutonium facility, which was designed, constructed, and licensed by the Nuclear Regulatory Commission for research and development work on plutonium fuels, has been used for that research and develop-sent activity, as authorized by the license.
It is presently being used for the fabrication of fuel pellets with depleted uranium carbide' for irradiation tests in the Government's new Fast Flux Test Facility at the Hanford project in the State of Washington.
[9 Question 24.
Does AI have any role in the fuel for the Fast Flux Test Facility in Washington State? If so, please give details.
Response
Although we have provided numerous pieces of equipment for the FFTF, including the design and construction of the fuel storage facility, the only role that Rockwell currently has regarding FFTF
)
fuel is in the fabricetion of depleted UC fuel pellets for testing in the FFTF.
Question 25.
Is AI planning to receive the spent rods from the Fermi reactor for decladding? If yes, please give details.
g) [heaV fr J.tlle p
4 p A s. A4. i%y, Wy Nyu qanjso :
" 7Le.
gcoernsd rev.m A5 m ccama ;ae %, u. 'sa.a"%,%>d%f% &
a
Response
Because of our unique capabiFity and facilities, the Department of Energy is discussing with Rockwell International a program to declad the irradiated fuel from the Fermi reactor.
As indicated in our letter of January 21, 1980, to Mr. Donald Koepp of the County Staff, any activities involvin irradiated fuel from nuclear reactors are carried out at the Energy ystems Group Hot Laboratory in accord with procedures and operational techniques licensed by the' Nuclear Regulatory Commission.
Question
[ 26. What is the maximum credible accident nossible from the decladding uon7 G've details; please cite the studies upon which this-imate is based.
Question b
t 27.
What is the maximum credible accident from the fuel fabrication I
V work cone at AJ7 Please give cetails and cite sources.
Responses to Questions 26 and 27 The maximum crodible accidents, wnich could result from our activities I
involving spec'al nuclear materials such as the decladding operations and nuclear fuel fabrication, have been analyzed in creat detail in tS 7
7 the technical documents supporting the application to tne nuclear
$1' Regulatory Commission for our Special Nuclear Material license, i
w which authorizes Rockwell International to conduct those activities.
These rather extensive studies havet been reviewed in complete t
detail by the Nuclear Regulatory tummission Staff, and they have concluded that the consequences of such accidents do not result in unacceptable risks, not only to the Rockwell employees and our facilities, but also to the surrsunding environment and our neighbor-hood.
The results of these rather extensive analyses and the corresponding conclusions are available in the Nuclear Regulatory Commission Public Document Room.
Question l-28.
Is fuel fabrication done at the Santa Susana site? Please give details.
Response
Other than Rockwell's role in the fabrication of depleted uranium carbide fuel pellets for testing at the FFTF, we are currently not involved in the fabrication of nuclear fuels at the Santa Susana site.
However, as we indicated in our presentation to the board on 9
1:
)
i h,
/,/
e T
January 22, there are facilities at the Santa Susana site which are licensed by the Nuclear Regulatory Commission for fuel fabrication i
work.
Any activities in thost areas are conducted in accord with i
strict requirements imposed by the Nuclear Regulatory Commission's license and are monitored regularly by both the Nuclear Re Cormission and the State Department of Public Health and, gulatory in some cases as appropriate, by the U.S. Department of Energy.
m.)
QUESTIONS BY THE ALLIANCE FOR SURVIVAL Question
_./
,/
6.
What work are you doing regarding the breeder reactor?
Response
As indicated in our presentation to the Board of Supervisors on January 22, Rockwell International operates for the Department of Energy a major complex at the Santa Susanta field laboratory known as the Energy Technology Engineering Center.
These facilities have been operated for the U.S. Department of Energy since the facility was established in 1966.
These activities involve nonnuclear component tests and engineering services on a wide variety of liquid metal components under development for use in the breeder reactor program, together with a wide range of other energy-related programs such as solar power, ocean thermal energy conversion, and g(er geothermal energy.
Question 8.
How much of your waste is shipped by truck and how much by rail?
Where does it go?
Response
, L;ripN All the radioactive waste generated at Rockwell International is transported by truck operated by DOT-approved carriers to federally approved burial grounds.
Question l
21.
The SRE Fact Sheet states that the reactor-generated more than 37 million kilowatt hours of electrical energy in over 27,300 reactor 1
i operating hours.
Early in 1967, the AEC approved a deactivation plan for the SRE, and implementation was begun. Why? After decon-tamination, what use will you put the reactor to? At what stage of decommissioning are you in now?
Response
The primary purpose of the SRE in the Government's sodium graphite reactor program was to establish reactor characteristics and sodium 10 L-.-
system behavior under steady-state and transient co'nditicns; also to determine the reliability and accessibility of reactor and primary coolant system componints.
The plant successfully served this purpose in operation from July 1957 until February 1964 During the last year of its operation, the reactor achieved an i
7 availability factor of 90%.
QW 6 g( # / [ The AEC decision to deactivate the reacto emphasin on the breeder reactor program, was ~ announced in December k[If # 4,b 1966.
"he SRE was a nonbreecing T.ype of reactor, (d.p, The' facility was mothballed until late 1974 when work was begun on h
/
,4 facility ano site preparation and the design and fabrication of remotely operated tools to cut up and remove the reactor vessel and its internals.
All cutting and geometry parameters were preprogrammed i
by use of a vessel mockup.
Decommissioning of the SRE is in its final stages, after which it may oe used for,other purposes.
i
/I.,fr E Question 9
23.
At the time of the 1971 fire at SSFL, did you employ the use of county and/or city fire personnel? Are L.A. and Ventura County fire department personnel trained in fighting radioactive fires?
Who trains them for this purpose? Have you had occasion to use their services at any time?
If so, when?-
Response
It was unnecessary to call on either the city or county fire depart-ment personnel in connection with the fire at the Rockwell Hot Laboratory in 1971.
That fire was controlled and completely extinguished by Rockwell staff and fire department personnel.
How-ever, both the Los Angeles City and Ventura County fire department personnel cooperate continuously with the Rockwell fire personnel and frequently visit our facilities for familiarization with the facilities and the activities performed in them.
Question 24.
In the event of an accident or fire, do you have a standby evacua-tion plan for the workers? For the community? Vttere is it filed and with what agency?
Is it available to the oublic?
i d
Response
The Energy Systems Group maintains detailed emergency plans for various types of emergencies as required by licenses issued by the Nuclear Regulatory Commission and by the Department of Energy for whom contract work is performed.
These emergency plans are directed to controlling and containing any emergency which might occur at 11
the Energy Systems Group facilities.
Analyses of potential accidents indicate that there would be no requirement for evacuation of people in communities adjacent to the Rockwell facilities.
Question 25.-
In reply to a report of the 1971 fire, you stated in a memorandum to the Councilpeople of Los Angeles that approximately 52 employees I
were involved in the accident.
Has there been continuing medical followup of these employees? Have any of them shown signs of cancer or leukemia? Where and by whom have they been checked?
What is the name of the facility?
Response
This question was answered in our letter of January 21, 1980, to Mr. Donald Koepp of the Ventura County Staff.
Question 26.
Morningstar Lab monitors your liquid effluents.
Do they monitor your radioactive water?
If not, who does?
Response
Morning Star Laboratory provides the external independent analysis of water which is released from the Rockwell International Santa Susana site to verify compliance with applicable regulations.
Question-L 27.
Does the Water Regulatory Commission make independent, on-site, unannounced water checks?
If so, how often?
t
Response
The Water Resources Control Board does, indeed, make independent periodic checks of the water released from the Santa Susana site.
Question l
- 28. Who monitors the station 2-U2 miles downstream? What happens in between the site and the stition? Why is the station situated 2-1/2 miles downstream? Any monitors on water coming out of the facility?
Response
l The monitoring station 2-1/2 miles down the Bell Canyon stream is one of the locations at which samples of water and soil are taken l
l 12
1
[
as part of the Energy Systems Group eavironmental monitoring
)
program.
This particular location was approved by staff of the State Department of Health and the Los Angeles Regional Water Quality control Board as a location with easy accessibility and far enough removed from the Rockwell International property to provide measurement of the natural background.
As has been stated in a number of previous communications, all water at the Santa Susana facility is sampled and analyzed completely prior to any release.
Question
- 29. Where do you deposit your' radioactive water?
Response
i Water containing radioactivity is either evaporated to reduce the volume and concentrate the radioactivity in a sludge or solidified by the addition of concrete or bentonite clay, and the radioactive solids are then disposed of at an approved burial ground.
$fbl Question
(
'~
- 31. Until recently, you were allowed to bury low-level radioactive d
substances on site.
How r.uch has been buried? Where do you send it,to now?
Response
Rockwell International has never buried any radioactive materials on its property at Santa Susana.
('&
Question
- 33. What plans do you have to protect the workers and community in the event of an earthquake? Are these plans available to the public?
Do you have evacuation plans for either or both sites? Do police, fire, and other agencies have copies of such plans?
Response
As indicated in the answer to Question 24 Energy Systems Group has comprehensive plans which include response in the event of an earthquake.
These plans are reviewed periodically with appropriate members of the local police and fire departments, as well as staff
/gmN from the Nuclear Regulatory Commission, the Department of Energy.
and the State Department of Health.
L l N; 34
)
L Ouestion L
l 35.
Your environmental Monitoring Report for 1978 shows average yearly j.
figures.
Where can information be obtained reflecting day-to-day 1
\\
13
j I
I c
events, including possible large releases of radiation in a short j
period of time?
)
Response
The environmental monitoring report shows average values for various I
types of radioactivity and gives details of day-to-day variations in airborne radioactivity.
As indicated.in the report, the data show no contribution to the radiation levels from the activities by j
Rockwell International.
Any large releases of radioactivity from
$ 'p%]-
our facilities would be reported in accord with the reporting f
requirements of the Department of Energy, the Nuclear Regulatory Commission, and the State Department of Health.
)
Question 1
37.
Do you share your SSFL site with 00E7 Does 00E do monitoring for you? Are you under contract to do work for 00E7 For what?
Response
This question was responded to on Pages 3 and 4 of our presentation to the Board of Supervisors on January 22, 1980.
Question
- 38. What are the names of the federal and state agencies that monitor you? How long ago did they start? How frequent? What are the results and where can they be found?
Response
This question was responded to on Page 7 of our presentation to the Board of Supervisors on January 22, 1980.
Resoonse to Alliance for Survival Statement on the Spill i
There was a spill of contaminated water at one of the facilities at the Santa Susana site on Wednesday, January 9, 1980, at about 4 p.m.
Approximately 100 gallons of water containing about 4 millu-curies of old mixed fission products were spilled and flowed down into a retention pond on the site.
The contaminated water was pumped from the retention pond to holdup tanks, from which it will be disposed of as radioactive liquid by approved means.
The area which became contaminated by the spill was cleaned up immediately after the spill.
T,he radioactivity was confined ta tha immediate area and the catantion cond, and no measurable activity above i
natural background was released from the site.
Corrective action has been taken at the facility to prevent any future spills of this N
type.
Y f,
J A f sd e4e c-i 14
6 The incident was not a " reportable incident" as defined in the Department of Energy reporting requirements or in either the state regulations or the Code of Federal Regulations.
However, in accord m
with our normal practices, the incident was discussed in complete
$ '8 j,W, i detail with the staff of the San Francisco Office of the Department 2/
4 of Energy on Thursday, January 10.
(
gj QUESTIONS BY THE STOP URANIUM NOW GROUP f,J./ /0_
e y e.a b c. s Question W g ipya/
Rockwell's 1978 monitoring report shows avera 1.
Where can data reflecting day-to-day events (ge yearly figures.
such as large releases of radiation in short time periods) be obtained by average citizens?
Response
Please see the response to Question 35 for the Alliance for Survival.
Question 2.
Has any radioactive material ever been buried within the area covered under CUP 2487
Response
No radioactive material has ever been buried on the Rockwell site at Santa Susana.
Question 3.
Has any radioactive material that was ever wholly or partially the responsibility of Rockwell ESG been disposed of within the State of California or in the waters of the Pacific Ocean off the California coast?
Response
f-.ki(5 Since approximately 1960, all radioactive material from the Rockwell
!t facilities has been disposed of in approved radioactive burial j7 sites in Nevada, Idaho, or Washington.
Prior to 1960, some small f[' q/
amounts of radioactive material were. disposed of in a deep channel
~
in the Pacific Ocean off the cost of California in accordance with disposal practices approved by appropriate federal agencies.
Question 10.
Rockwell Energy Systems Group also operates the facilities at Rocky Flats, Colorado, and Hanford, Washington.
The management at both of these facilities has come under serious criticism.
In Hanford, 15 l
- n..:..
w..
- - ^ -
l e
s the governor of Washington closed the storage facility citing sloppy techniques in the transportation of radioactive materials.
And in Rocky Flats independerft reports by health offietain indicate an aTarming increase in the averace incidence of cancer for areas near sno piant.
In what ways can the management of Rockwell assu~re
' fin.' the res' dents of Ventura County that these occurrences do not
&4 4
reflect their own capabilities in the area of health and safety?
4-
Response
Vr. b l 9
The statement made by the S.U.N. group that Rocky Flats' independent g%
,,)b M4 Teports by health officials indicate an alarming increase in the -
-flaveraoa inmanca er cancer ror areas near sne plant is not true.
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I)'.gttj;4 FtWmal environmental assessment or tne nocxy e sats Plant nas oeen unde way since 1974.
The assessment has undergone intensive review ty M',f su by local, state, and federal agencies and has received public Vg, ppe comment.
A draft of the final Environmental Impact Statement is
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,"y currently undergoing review and is scheduled for public release in a
jJd.l(p %c f the near future.
Among its conclusions, the Statement finds that:
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... the health effects from routine Plant operations on the population surrounding the Plant are imperceptible in a popula-O tion which experiences health effects from other sources."
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,N 4d^;/g/C The Rocky Flats plant is a Government-owned facility located about 20 miles northwest of Denver, Colorado.
It consists of a 350-acre kj7 complex of manufacturing, chemical processing, laboratory, and p t,-
support facilities situated in the center of a 6,500-acre natural
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preserve on which is also located the 40-acre National Wind Energy \\
Test Center.
The Company empicys approximately 3,100 people at the d site.
The Rocky Flats plant has a program of intensive medical surveillance to monitor the health of plant employees.
Considering the fact that radioactive materials handling and processing is a major -
operational responsibility, it is significant to note that the Company's comprehensive health records show no evidence that the incidence of specific or general health maladies for Rocky Flats employees is different from that of the general population.
Intensive employee training and a comprehensive safety awareness program, combined with continued attention to equipment and facility safety, result in an occupational injury / illness record that is significantly better than that of the average for all manufacturing industry in the United States.
Extensive precautions taken at the Rocky Flats plant work areas to reduce radiation exposure to a minimum have proven highly effective.
The plant health and safety history has been excellent and continues
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to be so.
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r The Department of Energy's Hanford site is located on a 570-square-sile reserve in eastern Washington State near the cities of Richland,
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Pasco, and Kennewick.
Rockwell is in charge of management and operation of key activities at Hanford, including chemical processing, waste management, and site support services.
The Company employs approximately 3,600 people at this location.
The Hanford employee safety record also reflects an extremely r
effective program devoted to occupational safety considerations.
l The occupational injury / illness record is also significantly better
- than that of the average for all manufacturing in the. United States.
Under Company management, the long history of Hanford's excellent health and safety record has been continued.
The storage facility closed by the Governor of Washington is a licensed burial ground operated under a license granted by the State of Washington to a commercial vendor.
Rockwell International has never had any involvement with the operation of that facility.
Rockwell's operations at Hanford and Rocky Flats demonstrate management's unyielding dedication to insure the safety and well-being of its employees and the surrounding general public.
The public record in both areas illustrates Rockwell has, indeed, instituted and maintained safety and public health programs unparal-3 leled in United States industry.
The public record shows that the Energy Systems Group of Rockwell International has maintained the highest standards for its employee i
and public health and safety programs to insure the continued safety of the residents of Ventura County.
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i emh:34 17
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