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Apollo Fuel Fabrication Plant Litigation

In 1998, SRA was tasked with addressing the uncertainty in the source term for the Apollo Fuel Fabrication Plant. The Apollo Plant was a commercial fuel fabrication plant located in the town of Apollo, Pennsylvania. It is the subject of a lawsuit concerning alleged injuries as a result of releases from DOE sites located in areas that are typically more remote from population centers. In addition, the Apollo Plant made news headlines in the mid 1960's, when, according to an article in the Wall Street Journal, the total material accounted for (MUF) exceeded 600 kilograms of highly enriched uranium (HEU). This was rumored in the news media to be the source HEU for a clandestine weapons program undertaken by Israel. The highly classified studies of this diversion formed the basis of the materials accountability programs throughout the US, both in defense programs and in the commercial power program.

To perform this task, SRA reviewed SCIENTECH, Inc. efforts which included the assembly of relevant release information into a tabular format. This format allowed data to be summed into release information. SRA reviewed the information, and added data such as release point and measurement parameters needed to address the uncertainty in the releases. The format of the data was improved through creating linked spreadsheets to permit easy manipulation for study. The data was also fit to distributions. The distributions permitted examination of the data for any correlation with operations and other parameters such as MUF. The distributions also permitted extrapolation of the data for any periods of time where data was missing or otherwise unavailable. The data was subjected to uncertainty analysis using methods established for both the CDC managed dose reconstruction for the DOE owned Fernald Feed Materials Plant and methods used for addressing the source term for the K-25 site located near Oak Ridge, Tennessee.

SRA also studied the MUF for the Apollo plant, and identified unclassified information that could be used to partially address gaps in the data due to classified elements related to fuel fabrication for the naval propulsion program. Finally, SRA staff reviewed and commented on the source term and uncertainty analysis provided for the Plaintiff's attorneys by A. Makijani, their expert witness.