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Nuclear Safety [Vol. 35, No. 2, July-December 1994]

Nuclear Safety is a journal that covers significant issues in the field of nuclear safety. Its primary scope is safety in the design, construction, operation, and decommissioning of nuclear power reactors worldwide and the research and analysis activities that promote this goal, but it also encompasses the safety aspects of the entire nuclear fuel cycle, including fuel fabrication, spent-fuel processing and handling, and nuclear waste disposal, the handling of fissionable materials and radioisotopes, and the environmental effects of all these activities. Table of Contents for this issue follows. GENERAL SAFETY CONSIDERATIONS: 179 Consideration of Postaccident Consequences in the Determination of Safety Objectives for Future Nuclear Power Plants in France, D. Queniart, A. Sugier, and J. Lochard; ACCIDENT ANALYSIS: 187 Nuclear Safety Research: The Phebus FP Severe Accident Experimental Program, P. von der Hardt, A. V. Jones, C. Lecomte, and A. Tattegrain; 205 Containment Performance Analysis of the Advanced Neutron Source Reactor at the Oak Ridge National Laboratory, S. H. Kim, R. P. Taleyarkhan, and V. Georgevich; 213 Assessment of Fission Product Deposits in the Reactor Coolant System: The DEVAP Program, G. Le Marois and M. Megnin; 222 Erratum to “A Review of the Available Information on the Triggering Stage of a Steam Explosion," Vol. 35, No. 1, CONTROL AND INSTRUMENTATION: 223 Effects of Normal Aging on Calibration and Response Time of Nuclear Plant Resistance Temperature Detectors and Pressure Sensors, H. M. Hashemian; DESIGN FEATURES: 235 Defense in Depth Against the Hydrogen Risk—A European Research Program, F. Fineschi; ENVIRONMENTAL EFFECTS: 246 Technical Note: A Preliminary Analysis of the Risks to Hong Kong Resulting from Potential Accidents of Daya Bay Nuclear Power Plant, Z. Shi and X. Wei; OPERATING EXPERIENCES: 253 Reactor Shutdown Experience, Compiled by J. W. Cletcher; SPECIAL SECTION ON TMI-2 VESSEL INVESTIGATION PROJECT: 256 Three Mile Island—New Findings 15 Years After the Accident A. M. Rubin and E. Beckjord; 269 Relocation of Molten Material to the TMI-2 Lower Head, J. R. Wolf, D. W. Akers, and L. A. Neimark; 280 Insight Into the TMI-2 Core Material Relocation Through Examination of Instrument Tube Nozzles, L. A. Neimark; 288 Physical and Radiochemical Examinations of Debris from the TMI-2 Lower Head, D. W. Akers and B. K. Schuetz; 301 Results of Metallographic Examinations and Mechanical Tests of Pressure Vessel Samples from the TMI-2 Lower Head, D. R. Diercks and G. E. Korth; 313 Margin-to-Failure Calculations for the TMI-2 Vessel, J. Rempe, L. Stickler, S. Chavez, G. Thinnes, R. Witt, and M. Corradini; U.S. NUCLEAR REGULATORY COMMISSION INFORMATION AND ANALYSES: 328 1993 Accident Sequence Precursor (ASP) Program Results, L. N. Vanden Heuvel, J. W. Cletcher, D. A. Copinger, J. W. Minarick, B. W. Dolan, and P. D. O’Reilley; RECENT DEVELOPMENTS: 339 Reports, Standards, and Safety Guides, D. S. Queener; 345 Proposed Rule Changes as of June 30, 1994; ANNOUNCEMENTS: 234 Thirty-First Annual Meeting of the National Council on Radiation Protection and Measurements; 356 1995 International Incineration Conference; 358 Fifth International Controls and Instrumentation Conference; 359 ANS International Topical Meeting on Safety of Operating Reactors; 359 Fifth International Conference on Nuclear Criticality Safety; 360 International Conference on Probabilistic Safety Assessment Methodology and Applications; 351 The Authors; 357 Reviewers of Nuclear Safety, Vol. 35.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Qualifying the Instrument Thimble 11 Test Position in the Advanced Test Reactor Critical

The Advanced Test Reactor (ATR) is a versatile nuclear research reactor located at the Idaho National Laboratory (INL) in Eastern Idaho, United States of America. It is one of the most powerful and flexible research reactors in the world and is primarily used for materials testing, isotope production and basic nuclear science research. The ATR is a light-water-cooled, beryllium-moderated reactor with a nominal thermal power capacity of 250 MW utilizing specially designed fuel, arranged in a serpentine pattern to create 9 flux traps. The special design of ATR allows for the neutron flux within each of the flux traps providing flexibility for experiments, programs and allowing experiments with different dose requirements to be irradiated simultaneously. The Advance Test Reactor Critical (ATRC) is a full-scale replica of the ATR core but is housed in a pool instead of a pressure vessel. ATRC is usually operated at less than 600 watts [1]. There are 12 dry instrument thimbles located around the outside of the core tank where a variety of measurement equipment is housed to facilitate reactor operations. Currently Instrument Thimble 11 (IT-11) is not utilized in ATR or ATRC. A range of measurements is ongoing to qualify IT-11 as a test platform for nuclear instrumentation research, development and further experimentation.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Initial Findings in Qualifying the Instrument Thimble 11 Position in the Advanced Test Reactor Critical

The Advanced Test Reactor (ATR) is a versatile nuclear research reactor located at the Idaho National Laboratory (INL) in Eastern Idaho, United States of America. It is one of the most powerful and flexible research reactors in the world and is primarily used for materials testing, isotope production and basic nuclear science research. The ATR is a light-water-cooled, beryllium-moderated reactor with a nominal thermal power capacity of 250 MW utilizing specially designed fuel, arranged in a serpentine pattern to create 9 flux traps. The special design of ATR allows for the neutron flux within each of the flux traps providing flexibility for experiments, programs and allowing experiments with different dose requirements to be irradiated simultaneously. The Advance Test Reactor Critical (ATRC) is a full-scale replica of the ATR core but is housed in a pool instead of a pressure vessel. ATRC is usually operated at less than 600 watts [1]. There are 12 dry instrument thimbles located around the outside of the core tank where a variety of measurement equipment is housed to facilitate reactor operations. Currently Instrument Thimble 11 (IT-11) is not utilized in ATR or ATRC. A range of measurements is ongoing to qualify IT-11 as a test platform for nuclear instrumentation research, development and further experimentation.

46 - INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AN↗

2019 Public Debate on the French Waste Plan - 20181

For the first time, a public debate has preceded the preparation of the National Radioactive Materials and Waste Management Plan (PNGMDR). This debate, which took place over 5 months from 17 April to 25 September, was held by decision of the French National Public Debate Commission (CNDP), an independent administrative authority responsible for public participation in major projects and plans/programmes with environmental impacts. To organise and lead the debate, the CNDP appointed a Special Commission. (authors)

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EXFOR-NSR PDF database: a system for nuclear knowledge preservation and data curation

Current needs of nuclear science and technology include complete, well-documented, and easily verifiable nuclear data. The complete data records require supporting nuclear bibliography, presently stored in dedicated libraries, in addition, to actual data. Additionally, experimental nuclear reaction data (EXFOR) and Nuclear Science References (NSR) databases contain compilations based on primary (journals) and secondary (conference proceedings, theses, preprints, etc.) publications, and data received from authors via private communications. The secondary library materials and private communications often represent a bottleneck for nuclear data verification, compilation, evaluation, and dissemination activities. To address this issue, bibliographic materials were scanned into PDF (Portable Document Format) files and uploaded in a relational database. The traditional scope of nuclear databases that includes meta-data and numbers derived from data in specialized formats was broadened to accommodate the large volumes of original nuclear data publications. The complete PDF publication files were stored in a relational database as Binary Large OBjects (BLOB). This unique collection of nuclear data compilations and supporting publications generate many opportunities for machine learning applications. The Web interfaces for authorized and public access to the EXFOR-NSR nuclear publications database were implemented at the U.S. National Nuclear Data Center, https://www.nndc.bnl.gov/ and IAEA Nuclear Data Section, https://www-nds.iaea.org/ . The current system is complementary to major nuclear libraries and narrowly focused on nuclear data compilation and evaluation procedures. The contents of the PDF database, details of implementation, and Web interface are described. New capabilities for data curation, knowledge preservation, worldwide dissemination, and natural language processing (NLP) applications are given.

73 NUCLEAR PHYSICS AND RADIATION PHYSICS↗

Metal alloy microparticle tagging of UO 2 fuel pellets for nuclear forensics

A tagging strategy for UO 2 fuel pellets will be discussed which involves the creation of alloyed metal microparticles that can be tuned to create a unique identification (“barcode”) indicating provenance of the pellets. These specialized markers would contain high temperature resistant materials, such as Ti, Mo, and Cr, in small quantities such that they do not interfere with the performance of the pellets but are recoverable by standard analytical techniques. The Amazemet rePowder ultrasonic atomization system was used to manufacture the microparticles, and sample pellets were fabricated and sintered containing these dopants. Various techniques, such as Scanning Electron Microscopy (SEM) and Electron Probe Microanalysis (EPMA), were used to evaluate these sample pellets to determine if particles (and their alloy compositions) were recoverable. Details on how the particles were manufactured and characterized will be detailed, as well as results from their incorporation into test pellets. Next steps will involve the scale of this technique using more conventional mass production methods, as well as the implementation of other alloys.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Radiation Damage in Materials—Helium Effects

Despite its scarcity in terrestrial life, helium effects on microstructure evolution and thermo-mechanical properties can have a significant impact on the operation and lifetime of applications, including: advanced structural steels in fast fission reactors, plasma facing and structural materials in fusion devices, spallation neutron target designs, energetic alpha emissions in actinides, helium precipitation in tritium-containing materials, and nuclear waste materials. The small size of a helium atom combined with its near insolubility in almost every solid makes the helium–solid interaction extremely complex over multiple length and time scales. This Special Issue, “Radiation Damage in Materials—Helium Effects”, contains review articles and full-length papers on new irradiation material research activities and novel material ideas using experimental and/or modeling approaches. These studies elucidate the interactions of helium with various extreme environments and tailored nanostructures, as well as their impact on microstructural evolution and material properties.

36 MATERIALS SCIENCE↗

Overview of System Integration Analysis Activities for Integrated Waste Management

Spent nuclear fuel (SNF) generated by the current fleet of commercial nuclear reactors is being stored at reactor sites in spent fuel pools (SFPs) and in dry independent spent fuel storage installations (ISFSIs). The U.S. Department of Energy Office of Nuclear Energy (DOE-NE) Integrated Waste Management (IWM) program is examining a suite of IWM system options and conducting supporting analyses to enable future informed choices. The IWM program is currently organized into the following four major areas: (1) IWM facilities and equipment concepts and development, (2) transportation capability analysis and support, (3) information technology solutions and support, and (4) system integration analysis and support. This paper focuses on the activities ongoing in the IWM system integration analysis and support area. Two main research activities in this area are: data and tools development, validation, and maintenance; and special studies, analyses, and assessments.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

An Updated Analysis of Clad Degradation

This report provides an analysis of the clad barrier function associated with the direct disposal of dual purpose canisters (DPCs) under hypothetical conditions in a shale repository and in an alluvial repository, including the effect of a postulated criticality event inside a disposed DPC. Should a postulated criticality event occur in a hypothetical shale repository, cladding will primarily degrade by general corrosion. Stress corrosion cracking, hydride cracking, creep failure, pitting and crevice corrosion, rod pressurization, and clad unzipping are calculated to have little impact on cladding persistence. At the higher temperature expected during a postulated criticality event in a saturated shale repository, general corrosion of cladding would be rapid - on the order of 0.034 microns/yr. A few hundred years after onset of a postulated criticality event in a shale repository complete general corrosion of fuel assembly grid spacer walls and guide tubes will likely result in settling of fuel rods upon each other. This rod consolidation should displace the water moderator and possibly terminate a postulated criticality. The primary potential degradation pathway for cladding in a hypothetical alluvial repository is localized corrosion by fluoride, which cannot occur in a shale repository. Fluoride-enhanced corrosion of cladding would be accelerated under the slightly higher (< 100°C) temperatures associated with a postulated criticality event. The impact of criticality in both cases (shale and alluvial) would be to increase the amount of failed cladding. But it would require very specialized transport pathways.

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Nuclear Material Control & Accounting for Pebble Bed Reactors (FY 2023 Summary Report)

This report discusses the work done under the US Department of Energy NE-5 Advanced Reactor Safeguards and Security Program during FY 2023. It provides a summary of material control and accounting (MC&A) for pebble bed reactors (PBRs) and addresses some of the main challenges with current PBR MC&A approaches that will inform safeguards and security by design efforts. The efforts to date have focused on tristructural isotropic (TRISO) pebble fuel material accounting and control including working with partners in industry, loss and production of nuclear material as part of reactor operations, burnup modeling and measurements, uncertainty quantifications for such modeling and measurements, statistical approaches needed, and measurement methods. The unique fuel management and utilization in a PBR, where the fuel in spherical form is introduced and circulates through the reactor, poses special challenges for MC&A. This contrasts with traditional water-cooled reactors in which the fuel is contained in large assemblies and can be easily identified and counted. Even online fueled reactors, such as the CANDU reactors (none of which operate in the United States), are significantly different because the fuel is still contained in relatively large assemblies, is uniquely identified, and the number of assemblies that pass through the core on an annual basis is much fewer than the hundreds of thousands that circulate in a PBR, none of which are uniquely identified. Additionally, the nature of the TRISO fuel results in very low heavy metal loading with each pebble containing less than 10 g of uranium and on the order of less than 1 g of fissile material. This low fuel density and the robustness of the TRISO particles are major features of the TRISO fuel from a safety basis as each TRISO particle and pebble acts as a containment for the nuclear material and fission products during normal and accident conditions. This also results in very low plutonium loading per pebble during normal operations, which is on the order of 0.1 g at full burnup. A major feature of PBRs is that they will allow for significantly higher burnup, on the order of 160 GWd/THM compared to the burnup of traditional LWRs, which is on the order of 45 GWd/THM. This is achieved by monitoring the pebbles as they circulate through the reactor and allowing them to be reintroduced into the core until the desired burnup is achieved and they are removed from the reactor and enter the spent fuel storage areas.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

A Review of Online Monitoring within Used Nuclear Fuel Recycling Processes

The processing of used nuclear fuels and related materials is often complex and variable. The ability to quickly optimize conditions to the material being processed can aid in increasing efficiency and safety, but requires very quick determination of the conditions present in the feedstock, the process, and the product. Furthermore, accurate quantification of materials such as enriched uranium and plutonium aids in maintaining material accountancy and avoiding nuclear proliferation risks. Traditional analytical methods require process samples to be collected and analyzed in a laboratory, which often takes days to weeks. Online monitoring is suitable for collecting this information nearly instantaneously, enabling much faster optimization of the process or detection of material diversion. Online monitoring is also beneficial as it is typically based on robust and nondestructive analytical methods, so no material is removed as samples. This review examines online monitoring relevant to used nuclear fuel processing for the determination of both chemical and physical parameters. The chemical parameters include quantities such as concentration, isotopic composition, and speciation. These values are often well suited to spectroscopic or spectrometric measurements as they are fast, nondestructive, and easily implemented in an online manner. Physical quantities are often more varied and include temperature, pressure, tank fill levels, and others. Due to the specificity of these quantities, specialized instrumentation is often used. However, this instrumentation is often amendable to online monitoring.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Monsanto Research Corp Model 2493 Series Special Form Re-Evaluation

The purpose of this memo is to characterize Monsanto Research Corp. (MRC) model 2493 series radioactive sealed sources as US Department of Transportation (DOT) Special For Radioactive material. with the goal of achieving shipment, consolidation, interim storage, and final disposition.

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Structural properties of plastically deformed SrTiO 3 and KTaO 3

Dislocation engineering has the potential to open new avenues toward the exploration and modification of the properties of quantum materials. Strontium titanate (SrTi⁢O 3 , STO) and potassium tantalate (KTa⁢O 3 , KTO) are incipient ferroelectrics that show metallization and superconductivity at extremely low charge-carrier concentrations and have been the subject of resurgent interest. These materials also exhibit remarkable ambient-temperature ductility, and thus represent exceptional platforms for studies of the effects of deformation-induced dislocation structures on electronic properties. Recent work on plastically deformed STO revealed an enhancement of the superconducting transition temperature and the emergence of local ferroelectricity and magnetism near self-organized dislocation walls. Here, in this work, we present a comprehensive structural analysis of plastically deformed STO and KTO, employing specially designed strain cells, diffuse neutron and x-ray scattering, Raman scattering, and nuclear magnetic resonance (NMR). Diffuse scattering and NMR provide insight into the dislocation configurations and densities and their dependence on strain. As in the prior work on STO, Raman scattering reveals evidence for local ferroelectric order near dislocation walls in plastically deformed KTO. Our findings provide valuable information about the self-organized defect structures in both materials, and they position KTO as a second model system in which to explore the associated emergent physics.

36 MATERIALS SCIENCE↗

Oxidation Behavior and Property Degradation of Nuclear Graphites

During its multidecade operation in the core of nuclear reactors, graphite components are subjected to aggressive and continuous exposure to a high field of ionizing and neutron irradiation, high temperature, and various types of present and postulated chemical attacks. High density, high crystallinity polygranular synthetic graphite is unique among other materials for its extraordinary capacity of resisting and adapting to the aggression inflicted by high temperature, high energy neutron bombardment and ionizing gamma radiation. But, as a carbonaceous material, even though of very high purity, graphite is reactive towards common oxidizing agents: oxygen, carbon dioxide, water. Safe operation of HTGRs relies, among other aspects, on engineered safeguard systems for efficient and continuous protection of graphite components against oxidation. Graphite oxidation behavior was, and continues to be, an important direction of theoretical and experimental research, engineering analyses, models and simulations, and design and safety regulations. The avalanche of publications, reports, experimental data, computer codes, and regulatory documents related to oxidation behavior of nuclear graphite is now accelerating to new levels, prompted by the increased interest for nuclear energy as a clean, carbon-free energy source. Even though public’s perception of nuclear energy advantages may still be influenced by the memories of past accidents of nuclear reactors from generations II and III, the community of informed scientists and engineers, regulators and statemen knows that generation IV of nuclear reactors is designed at very high safety standards, doubled by great advances of scientific knowledge and technological progress. One of routes of these recent advances is directed at better understanding of graphite oxidation behavior, its relationship with graphite manufacturing and microstructural properties, along with the effects of various environmental factors and process variables. Together, the recent progress in manufacturing, properties characterization, and modeling of intricated physical and chemical processes that concur to the oxidation behavior led to development of powerful simulation codes able to analyze various scenarios of normal operation and hypothetical off-normal events, and thus to clearly specify the allowable parameters envelopes for the designers, constructors, and operators of current and future modular HTGRs. This review begins with an introduction on manufacturing methods, structure, and properties of nuclear graphite, including basic requirements that this specialty graphite type must satisfy for nuclear use. It continues with a chapter on environmental effects on nuclear graphite, where emphasis is placed less on irradiation and much more on oxidation phenomena, their safety implications, and the basic traits of chronic and acute oxidation by air (oxygen) and water (humidity, steam). Particular attention is placed on the three graphite grades of interest for this document (IG-110, NBG-18, PCEA). A chapter on properties degradation induced by oxidation follows, with focus on density, dimensional, and mechanical properties changes. The next chapter is intended as a brief review of various approaches used for modeling of graphite oxidation behavior. It summarizes the progress of oxidation models, from the early attempts to complex computational approaches interfaced with specialized computer codes designed for nuclear reactor simulations. Last, a list is presented of knowledge gaps where more research is needed. A short summary concludes the review.

36 MATERIALS SCIENCE↗

Review of recent activities with MOOSE, an open-source finite element & finite volume multi-fidelity simulation framework

Modeling and simulation are an increasing part of engineering. This is undoubtedly driven by the high costs of constructing experimental facilities, but also enabled by the exponential increase in computing powers over the last decades, which allows computational models to be closer than ever to reality. One of the main drivers for the development of MOOSE is supporting advanced nuclear reactor simulations. A challenging aspect of modeling advanced nuclear reactors is the plurality of physics involved, including neutronics, thermal hydraulics and fuel performance. These physics are all coupled to some extent and are generally solved in a sequential but iterative fashion. The United States (U.S.) national laboratories have been developing MOOSE, an open source multiphysics framework since its inception at the Idaho National Laboratory (INL) in 2008. This framework enables seamless coupling of multiphysics simulations and facilitates the implementation of new physics and material governing laws. It is continuously expanded with novel numerical methods and new pre-implemented physics module. Numerous applications, developed within the Department of Energy (DOE) laboratories, academia, and industry, including outside of nuclear engineering, have been developed to study specialized physics problems. International collaborations are welcome on this open-source modeling and simulation project.

22 - GENERAL STUDIES OF NUCLEAR REACTORS↗

Impacts of processing decisions on TNSL cross sections and their applications

Thermal neutron scattering law (TNSL) data describe low-energy neutrons scattering off of bound materials, and can have a significant impact on modeling any system with slow neutrons, including nuclear reactors. Previous work to introduce TNSL data to neutron transport codes at LLNL focused on COG and TART, with the limitation that these codes require highly specialized data processing and formatting. We have recently increased efforts to process TNSL data with the LLNL nuclear data processing code FUDGE. FUDGE reads and writes the evaluated and processed files using the generalized nuclear database structure (GNDS). This process uncovered some significant difficulties in processing TNSL data, and unearthed assumptions made in current TNSL data processing that we have found inadequate. (authors)

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

TNSL Overview

Thermal neutron scattering law (TNSL) data describe low-energy neutrons scattering off of bound materials, and can have a significant impact on modeling any system with slow neutrons, including nuclear reactors. Previous work to introduce TNSL data to neutron transport codes at LLNL focused on COG and TART [1], with the limitation that these codes require highly specialized data processing and formatting. We have recently increased efforts to process TNSL data with the central LLNL nuclear data processing code FUDGE, to be stored in the generalized nuclear database structure (GNDS) for use in any general transport code with the ability to read GNDS data. The first step in this effort is to verify that the TNSL processing with FUDGE yields results comparable to results obtained using the LANL nuclear data processing code NJOY. The next step is to verify the transport of thermal neutrons in Mercury (a Monte Carlo code) and Ardra (a deterministic code) against one another, as well as against the LANL Monte Carlo neutron transport code MCNP. This verification step has not been completed, due to a number of discrepancies between results obtained using differently processed data. There is ongoing effort to understand differences between FUDGE and NJOY. Finally, we map out our current capability to validate TNSL data against benchmark systems.

73 NUCLEAR PHYSICS AND RADIATION PHYSICS↗

A section 110 evaluation of the huron king test chamber, area 3, nevada national security site, nye county, nevada

The U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office tasked Desert Research Institute (DRI) with the identification and evaluation of the Huron King Test Chamber as part of their cultural resources program obligations under Section 110 of the National Historic Preservation Act. The Huron King nuclear test was a vertical line-of-sight weapons effects test that took place in Area 3 on June 24, 1980. Unique to this event was a specially designed aboveground test chamber that held a model defense communications satellite in a vacuum tank meant to replicate the space environment. Sponsored by the Defense Nuclear Agency, the purpose of the experiment was to understand the response of the satellite and its materials and equipment to an electromagnetic pulse and attendant radiation. Between July and August 2022, DRI conducted an archival review on the Huron King experiment and its associated test chamber. Subsequently, pedestrian fieldwork was undertaken at the Huron King Test Chamber by DRI on September 29, 2022. During fieldwork, the outside of the test chamber was documented using a Nevada State Historic Preservation Office Architectural Resource Assessment form. This effort included verifying the substructures that compose the test chamber as determined by the archival review, as well as obtaining a detailed photographic recordation of the exterior and assessing its current condition. Notably, the site where the Huron King test took place has been abandoned and almost entirely naturalized. All of the portable instrumentation trailers, communications and data cabling, and winch systems used to retract the test chamber following the detonation were removed after completion of the experiment in 1980. Only the subsidence crater and the test chamber remain as physical evidence of this experiment. Based on these findings, DRI recommends that the Huron King Test Chamber is eligible for listing in the National Register of Historic Places (NRHP) at the local level under Significance Criteria A and C and that it meets Criteria Consideration G for properties less than 50 years old.

54 ENVIRONMENTAL SCIENCES↗