US NRC Manager Comments on NRC Document: Opposes Emergency Preparedness for Nuclear Fuel Facilities (Comment Deadline Monday, 13 July 11.59 pm – NY-DC-ET)

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Cherokee, criticality event, dangers of nuclear, downblending HEU, emergency management, Emergency Procedure, environment, Erwin, fire safety, Kerr McGee, NFS, NRC, NRC comment, NRC cornerstone, nuclear accident, nuclear energy, nuclear fuel chain, nuclear fuel cycle, Nuclear Fuel production, Nuclear Fuel Services, Nuclear Naval Reactors, Nuclear Navy, nuclear power, nuclear reactor fuel, Oklahoma, public safety, Sequoyah, Tennessee, toxic gas, uranium hexafluoride, US NRC, worker safety

The US NRC is requesting comment for its “Fuel Cycle Oversight Process” http://www.regulations.gov/#!docketDetail;D=NRC-2015-0149 The only “public” comment, currently uploaded, is by Kevin Ramsey, an NRC manager, and calls for the deletion of the Emergency Preparedness “Cornerstone”.

http://www.regulations.gov/#!docketDetail;D=NRC-2015-0149
http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0149-0003&attachmentNumber=1&disposition=attachment&contentType=pdf Here is the draft “Cornerstone Development” document for comment: http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0149-0002&disposition=attachment&contentType=pdf

http://www.nrc.gov/info-finder/materials/fuel-cycle/nuclear-fuel-services.html
Looking above and at the comment, which Kevin Ramsey submitted, one might be forgiven for thinking that he is a manager for Nuclear Fuel Services in Erwin, Tennessee. But, he appears to actually work for the US NRC. Serious problems, including incidents, which could lead to criticality accidents, at the Erwin NFS site meant that it was under NRC oversight for over a decade (2004-2015) – perhaps under his oversight? It is operated by Babcock and Wilcox, and has made nuclear fuel for Naval Nuclear Reactors, since the 1960s. And, Kevin Ramsey is an old Nuclear Navy man himself. What an incestuous little world! NFS has also reprocessed weapons-grade uranium into nuclear reactor fuel. https://en.wikipedia.org/wiki/Nuclear_Fuel_Services See: http://www.nrc.gov/reading-rm/doc-collections/event-status/event/2008/20080512en.html After being released from oversight in March, an incident happened in April of this year: http://www.wise-uranium.org/epnfs.html

Has there been a Major Emergency at a Fuel Facility which would impact offsite areas?

Yes, at least one major accident that impacted offsite. And, multiple ones within site, including deaths.

“CASE REPORTS/ The effects of uranium hexafluoride exposures were impressively displayed in a 1944 accident involving 21 workers. One individual died in 15 minutes due to severe steam burns and the effects of uranium hexafluoride and its degradation products, hydrogen fluoride and uranium oxyfluoride. Another worker died 70 minutes after exposure due to progressive respiratory distress. Most of the other 14 persons requiring hospitalization had corrosive irritation of the eyes, skin, and respiratory tract but were well enough to be released in 48 hours. Three more seriously exposed individuals were retained for observation for 10-14 days owing to pulmonary edema and nephrotoxicity. The peak urinary uranium excretion values in these three patients ranged from 0.15 to 0.50 mg/L. All three persons experienced some urine volume suppression for 3 days, and albumin, red cells, and casts were found in their urine. In one of these patients, mild elevation of blood urea and nonprotein nitrogen was seen for 3 weeks after the accident. Two of the three individuals with acute toxicity were examined 38 years later. No physical changes related to their exposure and no uranium deposition were detected. An observation from these cases and other exposed workers suggests that the pulmonary edema may have slowed the absorption of uranium from the lungs and lengthened its biological half-life.” http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb:@term+@DOCNO+4501

In 1986 there was one at the Kerr-McGee owned Sequoyah Fuels Corporation, which impacted offsite. It resulted in the death of one worker; hospitalization of 37 or the 42 onsite workers. At least 100 people were examined by health care providers, many from the community, and 21 were hospitalized for short periods [presumably those off-site, as 37 onsite were hospitalized]. At the time, “Sequoyah Fuels Corporation lacked a systematic procedure to deal with the emergency. The Gore Police Department was called, and they notified the Sequoyah County Sheriff’s Department and Oklahoma Highway Patrol to close down I-40 and Highway 10, the side road that passed directly in front of the plant. The general public was notified through the local radio, by workers calling home, and by Sequoyah Fuels Corporation’s Manager of Personnel and a representative of Gore Civil Defense going home-to-home prior to the media being informed. A hotline at Sequoyah County Department of Health also was established. Sequoyah Fuels Corporation had not arranged in advance with Sequoyah Memorial Hospital to treat workers in such an emergency.” (Emphasis added) Read more: “The Sequoyah Corporation Fuels Release and the Church Rock Spill: Unpublicized Nuclear Releases in American Indian Communities“, by Doug Brugge, et.al., Sept. 2007, Vol 97, No. 9 , American Journal of Public Health (Entire article here: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1963288/)

The USNRC did studies of on and offsite impacts, which included recommendations for an on-site Emergency Operations Center “Ruptured ModeA 48Y Cylinder at Sequoyah Fuel’s Corporatron Facility: Lessons-Learned Report NUREG-1198“, p. 13-14 says:
“3.1.4 Facilities and Equipment
3.1.4.1 Discussion

The January 4, 1986 UF6 cylinder rupture incident occurred outside and upwind of the process and administration building. Uranyl fluoride and hydrofluoric acid fumes were swept into the process building ventilation system. Within minutes, the entire building became uninhabitable. With the exception of an emergency kit at one of the access road guard posts, access to virtually all emergency equipment was lost during the incident. Additionally, the one available emergency kit located at the guard post did not have adequate and appropriate equipment.

First aid supplies, the site ambulance, radiological survey equipment, protective clothing, respiratory protection equipment, a source of water for decontamination and skin flushing (because of hydrofluoric acid contact) and essentially all communication equipment were lost, as well as the onsite radioanalytical laboratory. Also, employee emergency assembly areas (lunch room and break room) designated by the Radiological Contingency Plan were uninhabitable. Self-contained breathing apparatus were not readily available for employees leaving the plant areas through the noxious fumes.

In addition, with no offsite radio network and very limited telephone capability, local police could not recontact the facility for updates of the emergency status. Without communications to the plant, local police had difficulty in determining which individuals responding from off site should be allowed through access control points.

3.1.4.2 Recommendations

(1) Consider requiring a designated Emergency Operations Center (EOC) on site and an alternate EOC either off site or in another onsite location which is unlikely to be impacted by the incident. The EOC and alternate EOC should contain adequate communications capability and accommodations to provide for coordination of the onsite emergency response activities and notifications and coordination with offsite supporting organizations. The EOC or alternate EOC should be accessible 24 hours a day.

(2) Locations of emergency equipment and kits should be reviewed by the NRC and licensees so that in the event of an emergency in a given facility location, or inaccessibility of a large portion of the facility, access to adequate emergency equipment and facilities, including emergency decontamination facilities, can be assured. Equipment caches should be in multiple locations.

(3) Consideration should be given to providing strategically placed “air capsule escape units” to allow workers to escape from portions of a facility in which there exists a potential for exposure to toxic fumes for more than a few moments.

(4) The facility communications system should include a radio system compatible with local police or other offsite responder communications systems. In addition, the licensee should attempt to identify beforehand to local and state police, insofar as practical, offsite individuals who would be called on for support in the event of an emergency at the site. Radio communications with police officials during an emergency can resolve specific issues.”

Click to access ML070080302.pdf

But, current NRC Manager Kevin Ramsey has submitted a comment calling for the deletion of the NRC Emergency Preparedness “Cornerstone”! (see the entire comment, submitted by him, at the bottom of this post): “the fast moving nature of accidents of concern – formal evacuation planning is not considered necessary, appropriate, or feasible. Actions to move people out of areas of dense smoke/fumes or get them to seek shelter indoors are routine for fire and police personnel. Such actions would be expected whether response organizations had formal emergency plans or not.

The cost of emergency preparedness at fuel facilities cannot be justified in terms of protecting public health and safety. Rather, the NRC justifies it in terms of the intangible benefit of being able to reassure the public that, if an accident occurs, local authorities will be notified so they may take appropriate actions.

By failing to reference the published position of the Commission on emergency preparedness at fuel facilities, the cornerstone development document fails to acknowledge that our regulations in this area are not risk significant and there is no basis for a cornerstone on emergency preparedness. Since the basis for the regulations is the ‘intangible benefit of being able to reassure the public,’ I believe that emergency preparedness inspection findings should be a subset of the public safety cornerstone and the emergency preparedness cornerstone should be deleted.” He adds that “accidents at fuel facilities pose a very small risk to the public. Offsite radiation doses large enough to cause an acute fatality or even early injury are not considered plausible.” http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0149-0003&attachmentNumber=1&disposition=attachment&contentType=pdf (Emphasis added)
The Sequoyah accident shows the emergency cornerstone is very much needed, and that injuries can occur both on and offsite.

The US NRC Cornerstone Development document, which NRC Manager Kevin Ramsey so harshly criticizes, says:
“The consequence of accidents can be mitigated through appropriate emergency response actions. Therefore, the staff included accident prevention and mitigation as the objectives of the cornerstones and a specific cornerstone on emergency preparedness whose objective is to verify that emergency response actions are adequate. In addition, controls used to prevent or mitigate accident sequences must be available and reliable” p.9
“Emergency Preparedness — The objective of this cornerstone is to verify that the licensee is capable of implementing adequate measures to protect public health and safety in the event of a radiological or chemical emergency (for those chemicals under USNRC jurisdiction)“. pp. 10-11
“State and local government authorities maintain offsite emergency preparedness programs and implement protective actions to protect public health and safety. Where required, there may be a Letter of Agreement between licensee and local authorities to provide support.“(p. E-3) http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0149-0002&disposition=attachment&contentType=pdf

Of related interest: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/emerg-plan-prep-nuc-fac-fs.pdf http://www.nytimes.com/1986/01/09/us/after-72-mishap-us-told-plant-to-set-emergency-plan.html

Some excerpts discussing impacts of the Sequoyah Accident:
“NUREG-1189 Vol. 1, Assessment of the Public Health Impact From the-Accidental Release of UF6 at the Sequoyah Fuels Corporation Facility at Gore, Oklahoma, Docket No. 40-8027 License .No. SUB-1010, Main Report, U.S. Nuclear Regulatory Commission, Ad Hoc Interagency Public Health Assessment Task Force”
“6.1 Public Health Impact from Uranium Release

As discussed in Section 1 of this report, the release of UF6 into the atmosphere results in the hydrolysis of this compound with moisture in the air to form uranyl fluoride (U02 F2 ) and hydrogen fluoride (HF). It is these latter two compounds that constituted the principal plume contents and the exposures to affected individuals. U02 F2 is a soluble form of uranium. Thus, the predominant target organ for the acute uranium intake as a result of this release is the kidney, and the toxicity is primarily chemical rather than radiological. When the U02 F2 particulates eventually deposit on the ground, the chronic effects from the intake of uranium through various pathways are from chemical toxicity as well as radioactivity. The chronic effects from radioactivity are expected to be very minor. However, for completeness of this assessment, the following public health impact assessment includes both chemical toxicity and radiological aspects.” (p.54)
“…the workers involved in this incident encountered exceptionally high uranium exposures and intakes (as estimated by urine uranium levels). These exposures were at levels at which one would expect at least some transient renal injury in a significant proportion of those exposed. No conclusions could be drawn with regard to more permanent and serious injury to some of the more highly exposed workers because they were exposed to levels at which there are no reliable data relating to human exposure.

Based on currently available information, workers exposed during the incident should be monitored carefully for evidence of pulmonary and renal injury. Medical surveillance of these individuals should be performed for a period of 1 to 2 years or until such time that renal and/or pulmonary function is determined by physicians to be acceptable in their professional opinion. These individuals should receive periodic evaluations, preferably every 6 months.“(p.57)

“6.1.1.1.2 Evaluation of Offsite Individuals

The uranium bioassay data for offsite individuals are meager. Of the approximately 100 offsite people who gave urine samples, the only information one can glean from the limited bioassay results is that some offsite residents (at least 6-7) did receive low-level uranium exposures. No systematic approach was used to obtain the urine samples so that it is not known whether the available bioassay data reflects the exposure to the most highly exposed offsite individuals. In addition, no average intake for the surrounding population can be determined from the bioassay results because of the nonrepresentative nature of the samples.” (p.57)

“Individuals who may have responded to the scene of the accident, such as police officers, were not identified as a separate subgroup. These individuals could be at a slightly greater risk due to the potential for exposure to contaminated areas as a result of their response. It is known that at least one individual, 52P, falls into this category. The results of urine bioassay for this indi-vidual indicates an exposure less than the minimum sensitivity of the urinary uranium measurement system.

Estimates are also made in Section 6.1.2.1.1 of potential uranium intake for individuals at various downwind locations using the source term given in Section 3.4 and plume modeling as described in Section 4.1.2. The uranium intake for a maximally exposed individual located downwind at 1-40 and exposed to the plume for 1 hour is about 4.2 mg. It is unlikely that an individual would have remained at 1-40 and inhaled the irritating plume for 1 hour. However, this is the hypothetical-upper bound limit. The uranium intake for 1 hour exposure of nearby residents downwind 1.6 km SSE from the SFC site is about 1.4 mg for an adult male. A comparison of these intakes with the lower threshold limit given above indicates that some individuals may have approached or, in the worst case, exceeded the lower threshold toxicity limit for an adult male. It is possible that some sensitive members of the public suffered from short-term changes in kidney function due to the chemical toxicity of uranium. Available scientific evidence does not indicate that clinically detectable, long-term changes in kidney function occur at these low levels of exposure; however, the possibility of chronic effects cannot be completely excluded. Although no definitive statement on the appropriateness of a population study can be made at this time, the feasibility and potential merits of a study of offsite individuals who were exposed to the plume deserves further consideration.“(p.58)
…
“Atmospheric dispersion factors and deposition rates for a normalized release were provided by the Lawrence Livermore National Laboratory’s Atmosphere Release Advisory Capability (LLNL-ARAC). These values were calculated using meteorological conditions prevailing during the accident. Numerical results for selected points in the plume path downwind, at sampling stations, near residences, and at distances up to 72 km (48 miles) were estimated.

The plume resulting from the accident traveled in a generally SSE direction and roughly covered a 22.5 degree compass segment in that direction.“(p.60)
[…]
“6.2.1 Acute Exposure

As a result of the sudden release of fluoride at the SFC facility, humans, animals, and vegetation on and off the site to the south-southeast were briefly exposed to extremely high concentrations of airborne fluorides until the plume was widely dispersed by the existing winds. Estimated exposures, assuming a 50 (p.65)
[…]
“Information on the exposure of offsite individuals is limited. Mathematical modeling of the plume has indicated that concentrations of HF as high as 15 mg/m 3 , approaching dangerous levels, may have been reached in some offsite locations for a short period (<20 min.). Given the uncertainties involved in atmospheric dispersion modeling, it is not possible to rule out exposure to dangerous concentrations for potential offsite individuals.

Although about 100 offsite individuals reported to the Sequoyah Memorial Hospital for screening and to give urine samples, data on them are limited. To fully evaluate the impact of the release on offsite individuals would require a systematic survey of all those potentially affected and a full review of pertinent medical records. Because these data are not available, definite conclusions about the public health impact of the release on offsite individuals cannot be made. However, in the absence to date of evidence of acute injury to the ex-posed local residents and because experience with HF exposures does not indicate chronic injury from small exposures, it is not at this time recommended that an immediate public health investigation-of exposed and potentially exposed offsite individuals be made. Because the highest exposures occurred in individuals who were onsite at the time of the release, it is recommended that further evaluation of offsite individuals only be conducted if monitoring of onsite workers, as discussed above, indicates the development of chronic effects related to acute HF exposure.

Acute exposure to fluorides can also lead to non-irritant health effects.” p. 66
[…]
“6.2.1.2 Animals and Wildlife

Domestic animals and wildlife could have been directly affected by acute exposure to the high concentrations of toxic HF in the air.

Machle et al. 35 exposed guinea pigs to various concentrations of HF in air. Animals exposed to 1500 mg/m 3 died within 5 minutes, whereas those exposed to 500 mg/m3 for 15 minutes survived but showed signs of weakness. Concentrations below 100 mg/m 3 and 24 mg/m 3 could be tolerated for 5 and 24 hours, respectively, without fatality. High concentrations induced paroxysms of coughing, bradypnea, and a copious discharge from the nose and eyes.”
[…]
However, because modeling indicates that short-term HF concentrations (<20 min.) could have been as great as 15 mg/m 3 , wildlife species occurring near the release site could have experienced some acute toxic effects, although mortality due to the HF release is unlikely. To survey wildlife populations for toxic effects would be difficult and probably not very productive. Even if some mortality occurred, only a small fraction of the local populations (that fraction in the path of the plume) would have been affected. ” http://pbadupws.nrc.gov/docs/ML0700/ML070080310.pdf

The following are the two pages submitted by US NRC Manager Kevin Ramsey: “Submitter Name: Ramsey, Kevin Posted: 07/09/2015 ID: NRC-2015-0149-0003


(Yellow highlight and red underline added by us for emphasis).