ML20044B704

Partially Withheld Commission Paper Informing of Denial of 791003 Request for Enforcement Action

ML20044B704
Person / Time
Site:	05000077
Issue date:	03/04/1980
From:	Malsch M NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML19290F683	List: ML19290F682 ML19296F736 ML20038A425 ML20044B699 ML20044B701 ML20044B702 ML20044B704 ML20044B705 ML20044B706 ML20044B707 ML20044B708 ML20044B709 ML20044B710 ML20044B713 ML20044B714 ML20044B715 ML20044B716 ML20044B717 ML20044B719 ML20044B720 ML20044B721 ML20044B722 ML20044B723 ML20044B724 ML20044B725 ML20044B727 ML20044B728
References
FOIA-92-436 SECY-A-80-030, SECY-A-80-30, NUDOCS 9303030150
Download: ML20044B704 (41)

Text

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4 UNITED STATES 0

N UC1.E AR REGULATORY CcfAMIS$loN t

s m -so-30 ADJUDICATORY ITEM w cs e, 19e0 COMMISSIONER ACTION The Commissioners For:

From:

Martin G. Malsch, Deputy General Counsel DIRECTOR'S PARTIAL DENIAL OF 2.206 RELIEF (IN

Subject:

THE MATTER OF CATHOLIC UNIVERSITY OF AMERICA)

Catholic University of.:c. erica Research Reactor Facility:

To inform the Commission of a denial n a

Purpose:

7 I

'"J request for enforcement action which Review Time Expires:

March 11, 1980 Discussion:

By petition dated October 3, 1979,.P. Telly

)

Fitzpatrick requested, pursuant to 10 CFR 2.206 of the Commission's regulations that:

(1) the license issued to Catholic University for operation of its small (0.1 watt thermal) research reactor inspection and investigation be suspended; (2) an of alleged violations of the operating _ license be _

conducted; and (3) an order be issued to Catholic University to show cause why the license should not remain suspended pending a thorough review of the licensee's operations.

The petition was addressed to the Director of the Office of Nuclear Reactor Regulation; however, it was referred to the Director of Inspection and Enforcement for action because the subject matter of the petition appropriately within the jurisdiction of was more that office.

Tri;rmatbn in IMs rrrrd. 5 L'E 3d The bases of Ms. Fitzpatrick's requested action h 2:::W:e cir, r.: F.:e:- g w

,.c;q were a number of alleged incidents at the licensed ki. Exem;ucss 8

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f acility including:

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(1) storage of gasoline, an explosive material, within the facility, in violation of license Technical Specifications; (2) storage of licensed material in a chemistr laboratory and a personal of fice in viol eZ' 9303030150 921125 of license Technical Specifications; b4 PDR FOIA

[Y'Nt GILINSK92-436 PDR p.

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Malsch, CGC s

2 (3) receipt of radioactive material by persons unauthorized to possess it; and (4) inadequate security program.

In response to Ms. Fitzpatrick's petition, an inspection and investigation were conducted at Catholic University on October 29 and 30, 1979.

Also, both petitioner and her attorney were interviewed.

As a result of the investigation the Director concluded that the allegations by Ms. Fitzpatrick were either untrue or, in the several instances where the allegations were factually correct, the factual circumstances did not involve any violation of NRC requirements.

The Director's den 1 and the attached investi-5y /

J ation reporA grg f

^

Recommendationi L_

.-___;~

i Martin G.

Malsch Deputy General Counsel Attachments:

1.

Director's Decision 2.

Investigation Report Connissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Tuesday, March 11, 1980.

Commission Staff Office comments, if any, should be submitted to the Commissioners NLT March 7,1980, with an information copy to the Office of the Secretary.

If the paper is of such a nature that it requires additional time for analytical review-and coment, the Commissioners and the Secretariat should be apprised of when coments may be expected.

i DISTRIBUTION Commissioners Comission Staff Offices Secretariat

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Dear Mr. Dougherty:

Ey petition dated October 3, 2979, you requested on tehalf of P. Kelly Fitzpatrick that the Nuclear Regulatory Commission suspend the operating license for Catholic University and institute an investigation of activities conducted under their license.

An investigation and inspection of the Catholic University f acility was conducted.

The results of that investigation are detailed in Report No. 50-77/79-02 which is attached to the enclosed Director's Decision.

For the reasons stated in the decision, the other requests maae in your petition are denied.

A copy of this decision will be placed ir the Ccm.ission's Public Document i com at 1717 H Street, N.V., Weshington, D.C.

r Sincerely,

' [

Victcr Stello, Jr.

Director Office of Inspection and Enforcement Eaclosure:

Director's Decision under 10 CFR 2.205 CC:

The Catholic University of America Vashington D.C.

20017 Hrs. P. Kelly Fitzpati-ick 1325 Quincy St., H.E.

Washington, D.C.

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4 DD 80-8 i

UNITED STATES OF AMERICA j

NUCLEAR REGULATORY COMMISSION

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t OFFICE OF INSPECTION AND ENFORCEMENT VICTOR STELLO, JR., DIRECTOR r

In the Matt'er of Operating License R-31 j

CATHOLIC UNIVERSITf 0F AMERICA t

DIRECTOR'S DECISION UNDER 20 CFR 2.206 i

By petition dated October 3,1979, P. Kelly Fitzpatrick requested, pursuant to 10 CFR 2.2CE cf the Cc mission's regulations that: (1) the license issued to Catholic University for operation of a reactor be suspended; (2) an f

inspection and investigation of alleged violations of the operating-license be r

ccnducted; and (3) an order be issued to Catholic University to show cause why i

the license should not remain suspended pending a thorough review of the 9

licensee's cperations.

The petition was adcressed to the Director of the -

t Office of Nuclear Reactor Regulation; however, it was referred to this office i

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for action because the subject matter cf the petition is more appropriately l

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~ Nctice within the jurisdiction of the Office of I spection and Enforcement l

of receipt of the petition was published in the Federal Recister on Novecber 1, 1979 (44 Fed Feg. 62970).

The bases of Ms. Fitzpatrick's requested action are a number of-alleged-incidents at the licensed f acility inqluding:

7 (1) storage of gasoline, an explosive material, within the f acility, in i

I violation of license Technical Specifications; 1

(2) storage of licensed material in-a chemistry laboratory = and a personal office in violation of license Technical Specifications; j

(3) receipt of radioactive material by persons unauthorized to possess I

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(4) inadequate security program.

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l In response to lis. Fitzpatrick's petition an inspection and investigation were conducted at Catholic University en October 29 and 30,1979.

In the

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course of the investigation, an investigater from the Region I office inter-l viewed Ms. Fitzpatrick and her attorney.

The findings of the investigation f

are set forth in Investigation Report No. 50-77/79-02, a copy of which is l

i attached and incorporated herein by reference.

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The findings of the inspection can be summarized as follows:

j 1.

Alle;ation:

Gasoline and fumes in the reactor room.

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I Finding:

Gasoline and fumes leaked from an air compressor ecperarily stored in a room next to the reactor room; no violation cf Technical Specifications is involved.

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2.

[1]e;ation:

Storage of spent nuclear fuel in unauthorized y

.ocanons.

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findi c:

Nuclear f uel was not stored in an unauthorized location.,

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3.

111e;atien:

Unauthorized receipt of radioactive material shipment l

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Findinc: No. instance was found when a shipment of radioactive sterial wcs received by an unauthori:ed individual.

I 4.

Jile;aticn:

Reactor room is without intrusion alarms or l

j surveillance devices, j

Finding: These ceasures are not specifically require? by the cniversity's security plan; no items of noncompliance with regula-tions regarding security were found in this inspection or on a i

previous one in January 1979.

-l 5.

All e;ationi' Real possibility of diversion of nuclear materials or sabotage of reactor.

l Finding:

No evidence to support this allegation.

l s

6.

Allegation:

Inadequate instruction to security officers in regard

o personnel radiation monitoring.

j Finding:

Personnel conitoring equipment is not required by NRC j

reculations for the security officers.

In spite of this, security cfficers are provided personnel monitoring equipment and instruction to thEm was determined to be adequate.

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j 7.

Allegation:

Improper security clearance for security officers.

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i Findinc:

In one instance, a security guard was dismissed from i

perforaing deties in the reactor area following a National Crime Information Center check.

However, this situation did not violate any HRC requirements nor any requirements of the university security plan.

i On the basis of Mese findings I have concluded that the allegations made by Ms. Fitcpatrick were either unsubstantiated in fact or if the facts stated in the allegations are true, they do not constitute violations of NRC regula-tions.

Therefore, Ms. Fitcpatrick's request that the operating license for Catholic University be suspended and an order issued to the licensee to show cause as to why its license should not recain suspended is denied.

A copj of this decision will te placed in the Cctmission's Public Document i

L Root ac 27I7 H Street, N.W., Washington, D.C.

20555.

A ccpy of this document l

i will also be filed with the Secretary cf ite Commission for its review in

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i accorcance with 10 CFR 2.2C5(c) of. the Commission's regulations.

l In accordance with 10 CFR 2.206(c) of the Com ission's Rules of Practice, this cscision vill constitute the final action of the Cctmission 20 days af ter the date of issuance, unless the Ccamission on its cwn cotion institutes the j

re 'iew of this decisior, within that time.

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J mn Victor Steli67 ~Jr.',

Director Of fice of Inspection and Enforcement I

Dated at Bethesda, Ma'ryland 1

this 227tE-dey of ' February,1980 5

Attach:ent:

l Investigation Report No. 50-77/79-02

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R EGION I

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o DEC 1 2 1979 ocket No. 50-71 i

Catholic University i

ATTN:

Dr. Y. C. Whang, Chairman Mechanical Engineering Departmen:

620 Michigan Avenue, H. E.

Washington, D. C.

20054 Gentiemen:

Subject:

Investication 50-77/79-02 This refers to the investigation conducted by Dr. C. O. Gallina of this office e

i on 0:tober 29-30, 1979 of activities authorized by NRC License No. R-31 and to the discussions of our findings held by Dr. Gallina with Dr. Jordan and Dr.

Ebert at the conclusi:n cf the investigation.

1 Areas examined during this investigation are described in the Office of Inspection

and Enforcement Investigation Report which is enclosed with this letter.

Within these areas, the investigation consisted of selective examinations of crecedures

.and representative re:ords, interviews with personnel, measurements maid.e by the investigators, and observations by the investigator.

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Within the scope of this investigatien, ne items of noncompliance were cited.

However, an inspection of your Radiation Protection Program, which was performed concurrently with this investigation, identified two deficien:y level items of nor. compliance.

inese iter:s are described in detail in NRC Inspection Report No.

50-77/79-03, which has been forwarded to you under a separate cover.

In accordance with Section 2.790 of _the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this letter and the enclosed investi-gation report will be piaced in the NRC's Public Document Room.

If this report

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contains any inforation that you (or your contractor) believe to be proprietary, it is necessary that you rake a written application within 20 days to this office to withhcid such information from public disclosure.

Any such application ;

must be accompanied by an affidavit executed by the owner of the information, i

which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Coatission as listed in subparagraph (b) (4) of Section 2.790.

Tne information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.

If we do not hear from you in j

this regard within the specified period, the report will be placed in the Public j

Document Room.

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DEC i ?' 1973 j

Catholic University 2

i No reply to this letter is required; hcwever, should you have any questiens i

concerning this investigation, we will be pleased to discuss them with you.

Sincerely, w-[/i,

[w I

y[ f. Grier H

Director

Enclosure:

Office of Inspection and Enforcement Investigation Report Nun er 50-77/79-02 cc w/enti Dr. E. D. J:rdan, Direct:r of Information Systems and Planning W. Keene, Radiation Safety Officer bec w/ encl:

IE thii & Files (For Appropriate Distribution) i Central Files Public Document Room (PDR)

- tiu lear Safer / Infomation Center (HSIC)

Technical Information Center (TIC)

PEG:I Reading Roca Director, Region IV (Report Dnly)

District of Colurbia 1

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urrM UF INSPECTION AND E'iFORC5 MENT Region I Report No. _50+77/79-02 Docket No. 50-77 License Nc. R-31 Prierity Catesory G

Licensee: _ Catholic University of America (CDA) 520 Michigan Avenue, N.E.

Washington, D.C.

20017 Facility t'ame:

Catholic Universitv of America i

Investigation at: Washin; ten, D.C.

Investigation conducted:

C to"r 29-30, 1979 i

Investigaters:

w.dd C.

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//-/t 79 C. O. Gaii -i, investica:1on Specialist e,

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date signec y

4. 'E. Piumies, Raciation Specialist t w / n / ~? 9 ca:E signed t

data signed t

care sienec

proved by

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$pps

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[ J.j'i. Allan, Deputy Director, NRC-Region I JJ-JC y; i

Q ca:e signeo nyesticaticn Sun ary:

nvestication on October 29-30,1979 (Investication Reoort No. 50-77/79-02) reas investicatec:

ine investiga:1on coverec severai allegations reiating to ne operation of :ne AGN-201 research reactor and related radiation safety and i

ecurity programs.

The allegations were made in writing as part of a petition.

iled with the USNRC cn Cctcher 3,1979, in accordance with the provisions cf 10 R 2.206.

In addition, other allegations were included in correspondence to i

e President of CUA dated Se:tember 25, 1979, vestigators on Cc cber 29, 1979.

and during an interview with NRC-

'te bv one NRC investicator and one NRC inspector.The investigation involved 14 i tsulfs:

Of the seven {7) allegations investigated, five (5) were found to be

suos tantiated.

nimal impact on reactor operations, safety and/or security, a y licensee or NRC requirements.

ted in this report.

No items of noncompliance or deviations are TE:

An inspection into overall reactor operations was conducted concurrent l

~K this investication and resulted irr two {2) deficiency levelitems of non:iom-iance related to posting requirements as delineated in 10 CFK 119.11.

1

ails of this inspection and the related items cf noncompliance are do--=-*cd The NRC Insoettien Oe---t h " ' ' " "

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e TABLE OF CONTEffiS s

I I.

Backcround i

A.

Raasen for Investigation B.

Identification of Involved Crgani:ations II.

St rarv of Findines i

4 A.

Investigation Findings S.

Management "eeting III. Details A.

Inteductica and Eackground Inferration E.

Scope cf Investigation C.

Persons Interviewed During the NRC Investigation i

i D.

NRC Findings and Conclusions l

IV.

Exhibits

. A.

Fetition submitted to NRC by'Ms. P. Kelly Fitzpatrick dated October 3, 1979 1

S.

Mec.o frcm Er. Edmund D. Fellegrino to Dr. Edward D. Jordan dated l

Sep aTher 25, 1979 I

C.

Mene from Dr. Edward D. Jordan to D'r. Edmund D. Fellegrii.

' ' ad septimber 25, 1979 D.

Radiation Safety Cc=ittee Minutes documenting Meeting held on Octcber ;

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BACKGROUND A.

Reason for Investication 1

On October 3,1979, pursuant to 10 CFR 2.2C5, Ms. P. Kelly Fitz atrick, a forr,er secretary-dispatcher for the security department at the Catholic Univer.,i'y cf AT. erica (CUA), petiti:ned the Director of Nuclear Reactor

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Regulation (NRR) of the Nuclear Regulatory Ccx,ission (NRC) to (1) suspend

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cperatin; licer.se R-21 (te:ket No. 50-77) currently held by CUA and autho-ri ing it to cperate a nuclear reactor, (2) make an im,ediate on si'a inspection of the licensee's facilities to investicate alleged license

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violations and other safety hazards and, (3) issue an order requiring the licensee to appear and shcw cause as to why its operating license should i

n:t re.ain suspended pendin; a thercugh inspecticn, review, and approval by the NRC of the licensees reacter and related facilities, operating and materials handling proceduras, and physical security procra=.

A copy of the petition as submitted by Ms. Fitzpatrick is a"=-'ad as Exhibit A of the investigation report.

Pursuant to Item (2) of the ab:ve referenced petition, the NRC Office of Inspectica and Enforcement-Reci:n I initiated an investigation of Ms.

Fit: patrick's allegaticns en 0:tober 29,1979.

B Identification of Involved Orcanizaticris 1.

Catholic University of America (CUA)

E20 P.ichigar, Avenue, h.E.

Washincton, D.C.

20017 A university licensed by the NRC t: cperate a reactor under NRC License Nc. E-21 (D:cke No. 50-77).

l 2.

Ms. P. Kelly Fitzpatrick 1325 Q.incy Street, N.E..

Wash,ington, D.C.

20017 A student at the Catholic University of America, former secretary-dispatcher within the security department at CUA, and author of the above referenced petition.

2.

James E. Dougherty, Esq.

1416 South Street, N.V.

Washington, D.C.

20309 l

An attorney representing Ms. Fitzpatrick in the above petition to the NRC.

l

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II.

SU M RY OF FINDIN35 A.

Allecations and Investication Findines The investigatien involves allecaticns which were introduced by Ms. P.

Vally Fitzpatrick as part of har petition presented to the NRC en Dctober 2,1979, pursuan to 10 CFR 2.205 (see Exhibi A).

These allega:icas are described and nt:rbered as Items i thr ugh 5 belcw.

An additional allegation l was presented to the licensee during a meeting held by P.s. Fitzoatrick and l

her attorney with the President of the University en September 25,1E79.

l This allegation is described and numbered as Item 5 below.

A copy of a memo docementing this meeting and the additional allegation has been included, as Exhibit B to this investication reocrt.

An additional allecatien was

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investicate's curinc' an interview with Ms. Fitzpatrick and p: :sente: :: NR:

r her attorney held en Dctober 29, 1979.

This allecation is described and numbered as Item 7 below.

N0it:

ine alle.caticns listed belcw have been sumnarized for clarity.

The actual allega icns are cited in detail in See ion III of this investigatien i

repo rt.

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_A_li e:ations r

1.

On August 10, 1979, a compresscr, stored in the reactor rccm by unauth-l j

cri:ed individuais, was found to be leaking gasoline.

Corrective action was no: taken in a timely manner and the presence of gasoline in the reactor re:= vi: lated the licensee's Technical Specificatiens prohibiting the storace of expicsive materials within the confines of the rea ::r facility.

The NR: investi. cation found no evidence and/0r inf rmation to substar.-

tiate this allegation (Details, Paragraph D.1).

i 2.

The ncensee is planning to store spent nuclear fuel in an area other than within the reactor rcom in direct violatien of the requirements of the operating license.

J i

The NRC investigation found no evidence and/or information to substan-i j

tiate tais allegation (Details, Paragraph D.2).

Due to the licensee's lack of coordinated and safe procedures for receiving and handling of radicactive materials, radioactive nater 3.

l have been shipped to persons not authorized to possess them.

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l The NRC investication found n0 evidence and/or infonnation to substan-titte the allegation (Details, Paragraph D.3).

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The reactor rec = is without surveillance devices, burglar alarms er other equipment which c:uld detect the entry er presence of a burglar

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or vandal.

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The NRC investigation found this allegatien to te substantiated but without any lessening cf the everall security p:sture of the reactor facility due to other security measures (frequent security checks).

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50 itens of ncnccmpliar.ce were identified with respect to the licensee's!

security receirements (De:2ils, Paracraph D.4).

The security devices refo red to are not required by the licensee's security plan.

i 5.

The incidents noted in the petition indicate a threat of not only an

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j cperating accident and ::nseq;ent release tf radiation, but also the i

possibility that nuclear materials micht be diverted or the reactor i

s abotag ed.

More serious violations than these listed may have existed in the pas u.

j l

The NRC investi;ation 'cund n: evidence and/or inicnr.ation to substan-i j

tiate this allesation (Details, Paragraph D.5).

5.

Security officers are civen dosimeters that are not adecuately sensitive !

and are instructed en h:w to minimize the readin;s of these devices.

Officers do not know how to use these devices.

i i

The NRC investication found no evidence and/or information to substan-tiate this allegaticn (Details, Paragraph D.5)'.

7.

Security officers are allcwed to perform seturity duties without

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i prcper clearance checks by the university.

One guard who routinely i

inspected the react:r area was later dismissed because he could not get a prcper clearance.

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I The NRC investication found this aliegatien to be substantiated but i

without any lessening of the everall security posture of the reactor facility and without any items of noncompliance with respect to the B

licensee's security requirements (Details, Paragraph D.7).

B.

Manacement F.eetinc i

A manacement meeting was held with licensee re:resentatives at the conclusion !

t of the investigation in order t: ciscuss the results of the investigation and the findings of the inspection conducted cen:urrently (see NRC Inspection l Re;crt 5C.-77/7t-03).

The follcaing licensee representatives attended the tanagement reeting held at 3:30 p.m. on October 30, 1979.

Dr. E. D. Jordan, Reactor Administrator Dr. D. D. Ebert, Reactor Supervisor 4

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III.

DETAILS I

A.

Introduction and 9.ackcround Inferr.ation 1.

Keactor e

The research react:r cperated by CUA under SF2 Operating License R-31 is a horcgenecus nuclear reactor Model AGN-2Dl, Series No.101, and is iccated en the lower level of the Fan;bern Euilding at the licensees facilities in Washington, D.C.

The licensee is authorized to operate the reacter et steady state p:wer levels not in excess of 0.1 watts

{the nt.al).

The reactor was placed in shutdown condition on February 22, 1975 and not c: era:ed again until Pay 9,1979.

The current cperatin;;

iicense is valid tnrcuch N:vember 15, 1997.

I 2.

F.elevant Actions of the Licensee and Petiti:ner Frior to Submission cf tne Fe:1: Ton The licensee stated that it was first aware of Ms. Fit: patrick's c:ncerns regardir; reactor safety shortly after the Three Mile Island incident of March 25, 1979, when a letter appeared in the school newsparer ::n=erninc the presen:e of a reactor at the university.

F3. Fit: patrick (and any cther student having similar i con: erns) were invited to tour the CUA reactor and have their i

concerns addressed by cocnizant personnel.

To the best cf the l

licensee's recollection, Ms. Fitzpatrick did not respond Xo this.

i i nvi ta ti on.

(Minutes cf Radiaticn Safety C :.mittee dated April 11, 1979, cocument the University's willingness to discuss AGN-j 201 reactor sa'ety aspects with an.v rerson er grou*e c ncerne'.)

i Dn or about Au;ust 1,1979, Ps. Fitzpatrick voluntarily terminated !

her temporary part-time duties as Secretary-Dispatcher in order l

to return to school.

In early September of 1979, Ms. Fitzpatrick asked if she ceuld attend the rea: tor safety / security course along with her attorney.

Due to security reascns, Ms. Fitzpatrick was denied admission to the course inasmuch as she was no longer a member of the security i

force and even when she was a member, served only in a temporary status.

Ms. Fit:catrick and her att:rney were personally invited to tour the reacter and cover any non-security related areas with Dr. Ebert, Reactor Supervisor, in order to better understand the operation cf the reactor and to have any safety related concerns addressed personally by the cognizant, responsible supervisor.

According to the licensee, the invitation was declined.

9

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Dn Septe-ber 25, 1979, Mr. James Dougherty, met with the President of CUA, 1

i Pellegrino, to discuss her c:ncerns and her demand that the reactor be shut down immediately.

Dr. Pellegrino ordered Dr.

Edward D. Jordan, Director of Info: r.ation Systems and Planning 3

Office, to conduct an irrediate investigation of th Fit: patrick's ;

conterrts and report the results of that investigation by the end of that day, Septt:ber j

25, 1979.

A copy of the memo do:urenting i

this neeting, Dr. Fellegrino's directive, and Ms. Fit: patrick's i

concerns has been attached as Exhibit B to this investigation report.

On Septenber 25, 1979, Dr. C:rdan repcr:ed his findings to Dr.

Peliegrino indicating that there was no basis for Ms. Fit: patrick's.,

A copy of the results of this investigation are attached !

cont arns.

as Exhibit C to this investigation report.

On September 27, 1979, Mr. Steven P. Frankino, Dean of the Law School, who was also present at the aforementioned meeting with Dr. Peilegrin, conta:ted Mr. Fit: patrick's attorney and reviewed i

each cf Ms. Fit: patrick's concerns based on the results of Dr.

Jordac's investigation.

Esar Frankino stated that Ms. Fit: patrick's:

attorney informed him that the results of the investigation were unsatisfactory with respect to their concerns.

Dean Frankino stated that he also discussed another demand made by Ms. Fitzpatricki safet]. Committee.na alv that she and herattornev be Dean Frankino stated that he could not speak unilaterly for the committee at this time but would contact Ms.

Fitzpa: rick's att:rney as se:n as a resolution to the issue could be arrived at by the c mmittee.

NOTE:

'Jnen contacted by NP.C investigators on D:t bar 29, 1979, Ms. Fitzpatrick and her attorney implied that they had no knowledg.

1 of any investigation conducted by the university. -

Dn Dct:ber 2,1979, Dean Frankino contacted Ms. Fit: patrick's attorney and notified him that the Reactor Safety Committee could not accept the:n as members but the Comittee offered to meet with them at Ms. Fit: patrick's convenience to discuss in detail any concerns she might have.

Ms. Fit:catrick's attorney declined the invitation and stated his intentien to file a petition, on Ms.

Fitztatrick's behalf, to the NRC on October 3,1979 pursuant to 10 CFR 2.205.

l

W On October 3,1973, the above referenced petition was filed with the NRC.

Dn October 4,1979, a ::eeting of the Fadiation Safety Ccr=:ittee was held to again review Ms. Fit: patrick's conce ns.

Docur.antation of this meeting is attached as Exhibit D of this investigation re;crt.

E.

5::oe of Invasti;atien The investigation included an examinati:n of pertinent documents and records at the licensee's facility; actual measurement of radiation leveis; interview and conta:ts with individuals; and, observations by the investigators.

'I C.

Pencns Directly Interviewed and/or Contacted During the fiRC Investigation l

1.

Licensee Perscrael_

l Dr. E. D. Jordan, Eea:::r Administrator Dr. D. D. Ebert, Eeact:r Supervisor l

Mr. S. F. Frankin, Dean, Law School Mr. W. E. Nork, Director of Security and Safety i

Ks. S. Harris, Adminis ritive Assistant to the Director of Security and Sefety Ms. M. Kindrat,. Administrator, Food Program j

.is. I. M. Cale, Administrative Assistant to the Dean of Engineering i

and Architecture Ms. C. C. Smith.. Traffic Clerk 2 ;

-,,s_..._

i 2.

N:n-licensee Personnel l

Ms. P. K. Fitzpatrick, Student at CUA Mr. J. E. Dougherty, Esq., Attorney D.

NP.C Findines and Conclusions f

~

1.

. Allegation No.1 a.

Allecation 1

During the night of August 9-10, 1979, a security officer on patrol noticed gasoline fumes in the reactor room, located in the basement cf the Fangborn Building.

No corrective action was taken until approximately nine o' clock the next morning when a i

pool of gasoline was discovered on the ficer of the reactor room. j l

l

i 4

b 9

It was later learned that the gasoline had leaked from a portable air compressor which was being stored in the reactor rocm. The l

comoressor had been placed in the room by a workman who was not employed by the University.

It is not known how or why this individual cbtained a::ess to the facility.

This incident thus appears to constitute a paten; violation of the terms of the i

license inas mch as Section 16.4* of the Technical Specifications prohibits the storage of explosive ::2:erials within the confines of the reactor facility.

b.

NRC Findines NRC investigators reviewed tre above referenced incident by means l

of interviens with invcived indivicuals and a review of related security log entries.

ane following chronology of this event was subsequently developed, j

1 At 0230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br /> on August 10, 1979, a CUA security guard reported I

the smell of gasoline c::ing from an air compressor being stored in the Thermal Science Laboratory adjacent to the react:r facility..

The guard stated that the gasoline, wnicn apoarently had leaked from the compresser, left a spot of coproximately 3 to 4 inches in diareter on the floor and was leaking at a drip rate cf approx' mately one drop every 5 minutes.

Campus security immediately i

notifed campus maincenance to remove the compresser from the i

area.

Ct= pus maintenance could not move the -compressor directly,

sin:e it beior.ged to an cutside contractor and was attached to s

other pieces of equipment _being utilized. to perform construction..

m:difications within the Thermal 5:ience Laboratory.

The centractorl was notified ictediately and requested to move the cc pressor.

Contractor personnel arrived at 0500 h0urs and moved the compressor,

outside of the building where it remained throughout continued construction activities.

At 1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br />, the Radiation Safety Officer notified campus security of the details of. the removal

~

operation.

The NRC investigators noted that (a) the security logs clearly described the leak as o: urring in the rocm next to the reactor 3

area; (b) the leak was small and monitored untii cleaned up;'(c) appropriata corrective actions were taken in a timely manner; l

and, (d) at no time was the reactor facility involved in any w2y and consequently did not constitute any violation cf Technical Specification limits an:/or conditions.

At no tire did an unauth-orized workman enter the reactor facility.

• Specified in Section 16.3.3 of current ~ Technical Specificaticns.

i i

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~

r t

i t

c.

NRC Cenclusion The NRC investigation found no evidence and/or information to subs;antiate this allegaticn.

HDTE:

While no hazards were identified within the reactor rect, -

it was noted that toluene fr:m liquid stintillation analyses w2s store.d as low level radicactivity in this room.

The NRC investi-gatien noted that although the licuid was stored in senled bottles secure sole-use facility would be more desireable for su in closed drums and tha the ro m was well ventilated, that a The licensee agreed and stated that this matter was being pursued i

2 prior t: the investigatien and would.be implemented in the near future (see Exhibi; D).

2.

Allegatica N. 2 1

a.

Allecation The Technical Specifications also provides in Section 16.4*, that nuclear fceis ar.d nu: lear fueled experitents must be stored in a locked safe within tne reacter room.

However, spent nuclear fuel frem the rete:cr is current'.y bein; stored in a chemistry laboratorn on campus.

M:rever, the petitioner has in her possession documen sh:ving thi: the licensee is planning, Or wts planning within the past few m:nths, to store spent nuclear fuel within the personal office cf Dr. F. W. Chang.

Some modificatien or Dr. Chang'.s c771ce,.or this purpose has been succes:ed in connection w1 h this proposal.

These practices ~ and/or plans appear to constitute further dire:: viciation by the licensee cf the specific recuire-ments cf its Operating license, f

b.

NRC Findin:s The NRC investigators asked' Ms. Fitzpatrick if they might examine the do:uments referred to in the petiticn showing that the licensee; was planning 'o modify a personal office for the purpose of s.t: rage of spent fuel.

Ms. Fitzpatrick stated that she did not_

pcssess the dccuments referred to above but rather observed references to the proposed modifications while filing minutes of the Radiation Safety Cc:mittee.

ML Fi:: patrick stated that Mr.

William Nork, Director cf Security and Safety, told her that she ceuid read these documents before filing because he was aware of her cencerns and believed that these d::uments might indicate how the University was reacting to safety matters in general.

1 b

e l

t

{

s i

The NRC investigators examined the file in question and did in fa:t find several references concernin; the potential modification l of Dr. Chang's office but not with respect to the storage of

~ pent nuclear fuel but ratner to the University's desire to s

obtain a new area to st:re icw level radioactive waste materiais resulting from the utilization of radicactive natarials in varicu;}

research endeavers en campus.

j Entries in the minutes cf the Radiati:n Safety Ccamittee were fcund for the meetings cf March 14,1979, April 11,1c79, and April 27,1979, each referring to the storige of low level radio active wastes with the primary advantage being the ease of modifi-i caticn of the ventilatica system in order to tie into Dr. Chang's. [

office.

A reference to the modificatien was also made in the meeting minutes of the Radiation Safety Cc= nit'ce on October 4, i

1579, and Dr. Jordan's memo to Dr. Feliegrino dated September 25, 1579, in response to Ms. Fitzpatrick's concerns (see Exhibits

& & D).

i The NRC investicators explained to Ms. Fitzpatrick that an AGN-t 201 reactor does not produce spent fuel in the cost familiar i

sense of the term and confirmed that all nuclear fuel, including fuel bearing control rods and an experimental fission plate were properly secured within the confines cf the reacter facility.

j The NRC investigators also confirmed that' Dean Frankino explained j the a; parent misconceptions presented by Ms. Fitzpatrick to her l

attorney en September 27, 1979, but could not determine why~ the c:ncern was still contained as part cf the petition on C::ober 3, 1979.

c.

NRC Cenclusien The NRC investigation found no evidence and/or information to.

v substantiate this allegation.

l 3.

Alleretion No. 3 1

a.

Alle:ation 1

Petitioner has witnessed the receipt of, shipped radioactive

{

raterial by persons not authorized to possess it.

petitiener has :

been told of at least one instance in which a shioment of radio-active tritium was accepted by an academic office'within the University and not delivered to the appropriate offices for i

e O

l l

4

7 several-days.

Petitioner alleges generally the licensee's lack of coordinated and safe procedures for the receiving and handling of radioactive substances.

i b.

NRC Findings Sectica 15.5.1.10 cf the licensees Technical Specifications requires that the Radiation Safety Officer (RS0) enforce the regulations, rules, and procedures as set forth in the Radiaticn j

Safety Manual.

The Radiation Safety Manual. currently in effect at CUA, Section 2.5.2, " Receiving," states that "all shipments of radioactive material arriving at CUA during normal working hours shall be delivered to the RSO.

Shipments arriving outside of i

normal working h:;rs may be accepted by the Office of Campus Security.

Such packages shall be deposited in the Radiation j

Safety Office by the security guard making the next regular inspection of that area."

i i

In a letter to Dr. Feilegrino dated September 25, 1979 (see l

Exhibit E), Ps. Fitzpatrick stated that.005 curies of radioactive >

tritica was celiverec to the security cffice addressed to the

)

"Radiacion Safety Officer, Catholic University," while she (Ms.

r Fitzpatrick) was 3ecretary-Dispatcher.

When she refused to accept it, Ms. Sally Harris, Administration Assistant, signed for i

it and stored it in the effice refrigerator until the RSO was located.

The NRC investigators reviewed the security log books and ncted an entry at 1230 hrs en July 3,1979, taken by Ms.

Fitzpatrick covering the above referenced receipt of material.

An interview cf Ms. Earris indicated that the material was at no time placed in the office refricerator and was delivered personally by Ms. Harris to he F50 within minutes of its receipt at the Security Office.

During an interview held on October 29, 1979 with Ms. Fitzpatrick and her attorney, Ms. Fitzpatrick stated that a similar incident had occurred on October 2,1979, when radicactive tritium was i

delivered to Ecom 102 in the Fangborn 9uild'ing instead of the l

Radiation Safety Office and was accepted by the secretary to the Dean of Engineering rather than the RSO.

The NRC investigators noted an entty in the Security Log for 0955 hours0.0111 days <br />0.265 hours <br />0.00158 weeks <br />3.633775e-4 months <br /> en October 2, 1979, which stated "Ms. Gale from 102 Pangborn called to have a delivery put in room.

Material is radioactive and should not be left out."

The HRC investigators interviewed Ms. Gale who stated !

that en the day in cuestion, a messenger wanted to deliver a l

4 I

t

(

?

)

8 shipment of radioactive tritium to her but she refused it.

She asked the cessenger to wait until se:urity was notified to pick it up but the messenger refused to wait and said he would look for the R50 or leave it in his office.

Ms. Gale said that she i

then informed security to contact the R50 and ensure that the material reached its proper destinatien.

The NRC investigation confir:ed -hat this shipment was re:eived properly.

The NRC investiga :rs f0:nd n: ir. stance wher. a shipment cf radio-active material was received by scre:ne unauthorized to receive it or in any manner which would endanger the health and safety of these receiving or handling it.

No evidence or information was j

un::vered whi:n indicated that any ur.due delay was experienced in

~

the handling of this material espe:ially ne several day delay contained in the criginal allegation.

C.

NEC con:1usion The NRC investigation found r.c evidence and/cr information to i

substantiate this allegation.

i 4

ElleCation NS. 4 i

t.

Allegation

)

The reactor room is without surveillance devices, burglar alarms.

cr cther equipment which ccuid cetect the entry or presence of a burglar or vandal.

Because the contents of the licensee's security!

pre; ram are no: publically available, it is not known whether su:n equipment is re:uired.

j b.

NRC Findinas l

The NRC investigators noted that the reactor room.is without surveillance devices, burglar alarms, er other equipment to i

detect unauthorized entry but because cf the nature of the reactor desicn and the snail amount of nuclear fuel present, such devices are not needed.

Although details of the university's security plan are withheld from public dis:10sure, an inspection of the licensee's security areas on January 23-25, 1979 indicated no I

itars cf n:n :=pliance (NRC Inspection Rep:rt No. 50-77/79-ull.

i ine security items referred to above are not.specifically required '

by the licensee's Security Plan.

l l

l J

i l

j

1 e

i

?

The RRC investigators noted that routine security checks are f

perforced by Ca.: pus Security in this area.

The investigators took several dates at rendem from 1979 check lists and noted that over the 155 hours0.00179 days <br />0.0431 hours <br />2.562831e-4 weeks <br />5.89775e-5 months <br /> covered by the sample, 79 security checks had been made as docu.ented by personal dosimetry ices for the guards.

}

This averaged cut to one check every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

c.

NRC Conclusion The NRC investigation fcund this alie:ation to be substantiated but without any lessening of the overall security posture of the' reacter f acility.

No items of noncompliance were identified.

The security devices mentioned were not recuired by the licensee's Security Flan, j

5.

Allecatica No. 5 a.

_All e:a tion The incidents noted in this petition indicate a threat of not cnly an operating accident and consecuent release of radiation, but also the possibility that nuclear materials might be deverted or the reac:cr sab:taged.

In addition, there is no reason-to assume that ever the many years in which the licensee has cwned 4

and perated the reac cr there have not been other, perhaps more e

serious violations.

~

b.

NRC Findines Alth:uch the ir. idents delineated in earlier segments tf Ps.

Fi::patricks petition were found to be unsubstantiated or incen-sequential, the NRC investigators reviewed the everall health, safety, and security programs currently part of CUA reactor utilization program.

The NRC reviewed the results cf past inspec-tier.s for the ' years of 1977 to 1979 and identified 'only one (1) i ceficiency level item of noncompliance resulting from the failure cf the licensee to report the inoperability of nuclear instrumen-tation.

inis item in itself was further minimi:ed by (a) the i

fact that the reactor was shut down since 1975 and (b) the problem l was with the lucite containers holding the instruments and not e,e ins =ent itsen.

ine results of this review is as follows:

3 I

i i

a I

4 i

l 10 I

Recort No.

Dates

}reaCovered Results 50-77/77-01 Fay 1 //

r.eacter Operation No items cf ncnc0mpliance J

50-77/76-01 April. lS78 Safeguards No items of nonccmpliance-

~

50-77/78-C2 April 1978 Reacter Operation One (1) deficiency level item of noncem-l pliance - nuclear instre-

~

mentation

+

50-77/79-01 January 1979 Security No items of noncompliance Concurrent with this investigation, an inspection was conducted of current reacter operations including areas of posted informatien!

organization and administration, review of log books and records, design changes, review of experiments, reactor operator training, reactor procedures, maintenance, radiation control, radwaste renagement and emergency planning (see NRC Inspection Report No.

50-77/75-03).

During this inspecticn, two (2) deficiency level items of noncompliance were identified related to (1) failure to post information as specified by 10 CFR 19.ll(a) and (b) and (2) failure to post form NRC-3 as specified by(10 CFR 19.11(c).

The investigators noted that these items were a) miner in nature, (b) resulted in part due_to.a building modification which had re cved pcsting locations and (c) in no way impacted on reactor

~

operation or its associ.ated.. safe.ty.

c.

NRC Cenclusion The NRC investigation fcund no evidence and/or information to substantiate this allegation.

Furthermore, based on the results cf this revies and concurrent inspection, the NRC found no threat ;

to the security of the reactor or the health and safety of the students at CUA cr mambers of the general public.living near the university.

l 6.

Aliecation No. 6 4

a.

Allegation Security officers in two separate reactor training-c"ourses were told that the radiation measuring badges are not sophisticated l

enough to give an accurate reading.

In ene class the instructor banged the badge against the palm cf his hand saying that it was i

.o O

6 l,

i 11 i

one way.tc change the reading.

The majority of officers do not know how to use the badge correctly.

b.

NRC Findin;s The NRC investigators noted that due to the icw levels of radiation!

in the reactor ro:: as d:: mented by dcsimetry legs, no personnel monitorinc equipment was required in at:Ordance with 10 CFR 20.202(a)li) inasmuch as guards would n:t likely receive a dose in any calendar cuarter in excess of 23 percent of the applicable values as specified by 10 CFR 20.101(a).

This fact notwithstandinc) the security guards were equipped with personnel monitoring devices of the self-reading p cket d0simeter (ion chamber) type which were t:re than ade:uate t: determine the amounts cf radiaticn; one would reasonably expect to encounter in this reactor facility.

I The licensee stated that tne dosimetcr sign-in sheets were also used as further verification that security responsibilities were being perf:rmed.

NRC investigators reviewed these logs and found no indication cf nisuse er otner than minimal (if any) radiation readi n;s.

inis Eter fact was due primarily to the icw levels of radiation present in the reactor facility and not to any inherent insensitivity cf the d: sir.eter.

The li:ensee stated that guards were cautiened against dr:pping the dosimeters, as such physical sho:ks (decenstrated by banging the d:simeter against the hand) 6 will cause the dosimeter to read higher. amounts of radiation than _i actually received.

Although the guar s were told that these higher reatings would be entered as their actual exposures, NRC investi:ators noted no higher than ~n rmal Exposures in the re:Ords reviewed.

Security guards en:cuntered were familiar with the proper use and reading of the pocket d:simeter.

c.

NRC Cenclusien The NRC investigation found n evidence and/or information to substantiate the allegation.

7.

Allegation No. 7 a.

Allecation i

Security guards are allowed to perform security duties without l

proper clearance checks by the university.

One guard who routinel !

inspected the reactor area was later dismissed because he could j

not get a proper clearance.

i i

^

e I

i

12 b.

NRC Findinos r

NRC investigators interviewed carpus security canagenent personnel ;

and detemined that although routine checks are performed before a cuard can undertake his regular duties, an additional check is provided by the Washingten, D.C. Police Department (D.C.P.D.)

utilizing the Natienal Crime Infor.ati:n Center (NCIC) cc= cuter system.

A successful check by the D.C.P.D. results in a special ccmissicn given :: the officer as a "special pelice cfficer," in i

D. C.

Tne licensee stated that new guards are not all wed to check on the reactor area until they have received a special training course in radiation safety and that in ecst cases, the 7

schedulin; cf this course usually all:ws the NCIC che:k to be com:leted prier to a guard having received the radiation safety course and consequently prior to werking near the reactor.

If a condition is disc:vered by One NCIC check which would preclude an individuals e picyrent as a security Officer, the individual would norr. ally be dismissed prict to having sened as a guard covering the react:r area.

Tne licensee stated that in one case a guard had completed the radiation safe:y course and was ce icraing duties within the reactor ares when the NCIC check identified a condition which i

would prevent the granting of a "special ccanission." The guard was dismissed en this basis c've to procedural and administrative policies set forth in this area and net by any poor or improper perforr.ance by the guard.

Tne licensee stated that this conoiti_on-in no way affected the overall security of the reactor area.

Tne NRC investigators reviewed the licensee's Security Plan and other security aspects of the licenses facility and noted that the above instance was not in violation of any NRC requirements or requirements set forth in the CUA Security Plan and procedures.

Tne NRC investigators also noted that due to the size and nature of the reactor, the plans then in effect, were more than co=nen-i surate with any preceived threat.

~

c.

NRC Cenclusion Tne NRC investigation, while finding the allegation substantiated,,

did not identify any ite.s of n:n:0=ciiante with respect to the iicensee's Security Pian or any condition which significantly 3

impacted on or diminished the licensee's overall security posture for the reactor.

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.-m.e located in the basement of the ?anchcrn builcinc.. 'No corrective a::icn was ta.ien until at.roximatelv. nine o' clock the next n rn:.nci.eze.n a. toe. c:. c. a s o : :.n e was c:.secverec. on the :,cor c.3

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-e in the rcen'b.v a work =an who was not enclo.ved b.v. the Universitv.

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the facilit.v. rne spill was subsecuently cleaned up and the cen.eresser removed. Section 15-4 cf the "'echnical S.cecificat-a

reactor specifica11.v. prohibits the stcrac.e of ' ex.olosive mat-erials within th'e confines of the. facility.

This incident thus a.n. nears to constitute a catent violation of the ter=s of the license.

4. The Techr.ical Specifications appended to the license k

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1. -a'e ar.d..uc1ea.

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experinents nnst be stored in a locked safe within the reactor l

room.

E= wever, spent nuclear fuel frc= the reactor in curr-i ently being s:cred in a che istry labcrat:ry on ca= pus. More-cetitiener has in her.cessession dccuments showine that cver o e.. s e'- - - - : a n.. -.. c., < - -

ae c ' c...:.. - - '. 5. 4.. ~'e as..#ew

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w of Dr. P. W. Chang. Some modification of Dr. Cha.ng's office su-:es~.e-s c

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-rets loner has w:.tnessec tne recelo.t o: shic.oec racac-3 active caterial 'y persons not authori ed to pcssess' it. Petit-l, v

ioner has been told of at least one instance in which a shirment!

radioactive t--itium was accepted by an academic office within j

e

+

the University anc not celivere: to the appropriate orf:.ces fer several days. Petitioner alleges generally the licensee's i

lack o,. coercinatec anc sa,e procecures :or receiving and ganc.3. ng rac:.cact:.ve se stances.

1 1

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burglar alar =s, ~cr other ec.uie. nent which would detect the ent.e er tresencs of a burE a or vandal.

Because-the contents l

of the licensee's security program is not publicly available, it is not kncvn whether such ecuipment is recuired.

7. Petitiener is unaware of the extent or 5ravit.v of the health and safet.y hacards tresented b.v the incidb.ts and i

circ ta.ces described above.

It appears, hcwever, that in P

at leas: two cases the licensee has violated the. express te_m of the cpecating license issued it by the Corrission. Cu=-

i ula t:..ve,v, these :.ncacents :.nc:.cate a threat oc not only an ooerat m e. accident and censecuent release of radiation, but i

also the real possibility that nuclear materials might be diverted c the ceacter itself sabotaged. In addition, there r

is nc reas:n to assume that over the many yeacs in which the licensee has on.ed and 6perated the reacec there have not been.i i

oth e, perhaps =cre serious violations.

8 6

S. On behalf of herself and other students and residents l

?

e in the vicinity of the licensee's reac cr, Petitioner recuests that the Cc= ission, pursuant to its obligations under the Atc=ic Inerc.v

..ct, (1) suspend immediately the Universitv's t

coeratin e. license, (2) conduct a cromo inscection of the lice-.see's f acilities to dete=ine the existence of any i r.ed-

}

iate haca-ds, (2) prevent the licensee frcm resuming reacter operations vr.til it has appeared before the Cc= mission and 1

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de. enstrate:i th a t the reae:Or can and v:.21 ne operpec. :;

cenpliance with the terns of its license and in a canner protective of the pt61ic health and safety, and (4) take any i

ether action which it may deem necessary or appropriate.

i Ey P. Kelly Fitzpatrick, t

3v her attornev, g

Dated: Octcher 3, 1979

%.es3.DoughMty 1416 S.

St., N.W.

Washingter.,

D.C.

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t I hereb.v allec.e that the facts allec.ed in the fere-ceing ?etition for Energency and Re nedial Action are true l

t and cenect to the best of =y knowledge and belief..

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WASF NCTON D.C. 2:C64 j b@t.,;o d UO c.m:1cm;nzsuc

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.Septed er 26, 1979 9:0D a.=.

Dr. Edward D. acrdan Di meter Ir.fer.atien Systec.s and Planning Office E.xecutive Offices

Dear Dr. J:

rdan:

Tnis r.:rning Miss Kelly Fitzpatrick and her legal ccunsel visited re to register ccacarn about certain aspects about the operation of our reactor.

I am attaching the statement of the conditicns which have c:ncerned Miss Fitzpatrick in her cwn hand, Frid y :f-t:-is ::;ek.tc;ethe with the cenditiens she has, demanded we c:mply w I am perscnally c:n,cerned ab:ut the facts in this case and I am

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asking yce wi.h this letter to investigate these matters frd.ediately and to have a report in my office before the end cf this day.

Please se.nc a re;;rt alsc :c Daan Frankino, cur University Counsel.

Dean Frankino will represent the University's interest in all further c:nvarsa:icns and discussions with Miss Fit:pa: rick and her lawyer.

/

I u:uld appreciate your pers:nal attention to this matter.

You will notica in Miss Tit 2 patrick's handwriting th'at nu:.ber five is r.issing.

inis is because Miss Fitzpatrick has decided to eliminate

'this in her iist of c:ncerns and he.nce. this has not been fon:arded to you.

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1 WASHINGTON D.C.:cc64 cmcI c7 Txt CIncTox or :N7ca.wT:ca srs v.s neo n.ncs:

= cs.s=2 Se.:t -her 26, 1979

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P 5acr:

792 atien *:nd Reae:cr safety Dr. ->- c D. ~ e,,. e g-l no utuo To:

r..

. Presides:

In esp =se to the c:c1csed s:ste=ent:

1.

A ship:en ef five zillicu-ie5 ef :adieactive (tritiu=) thy -idine was o-dered en June IS by T: s. Nrrdene and Todhunter (Depart =ent of Eicle.r.v. ) for reser:rch use.

~he raterial was shipped hv New Eng1cnd s

Nucletr Cc peratien en Jt:.e 20 znd received (and. receipted fer) by the University R:diz:ica safety Officer en June 21.

It was wipetested and delivered by t he F;iittien Safety Officer to Dr. Tedhunter.. Due to c er cr en the ptr: of New England Nuclear Cerpmtien, a duplic :e ship =en vas en: en July 2 tad received by the Rzdiarien Safety Officer en July 3.

Tnis ship en: was also

==:inely wipe:ested.

~'he e w-a less tht: 60 picec =-ies of vipable activity en both the e: e:ur zz.c _n:

.:r, s.= : c=s e:. :.....:.: package -.:elc : de..:.u ts estzbli.shed by Fede :.1 ' law.. The Radiatica safety Officer. advised New 5 s-Itad Kuclez: Cc perarien 'ef receie: cf the duplicate shipment.

New Engiz.d Nuclear Cc perarien requeste

~ urn by collect air d

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.r The pacicte vzs picked up f::= the Radiaticn Safety Officer by 5:ery JL: Freigh: for ship =ent to New England Nuclear Corporaticn.-

?.:ery /ir F tight subsequently-returned the packa^ge to the University due te zn e: or in the bill of lading.

On this occasien,.beczuse the ?;iistien Sciety Officer was unzvcilable, i: was delivered to the Office of n - fc Security zeccrding to standard precedure.

It was receipted fer by Ms. S. Hz ris, Ad=inistrative Assistant to the Di ec cr of Secu-ity.

Ms. Harris' call to the Radiatien Safety C&_~ ice was tzten by D. D. Eber: and at his reques: Ms. Har is prenptly delivered the package to hi=.

He placed it in the Ezdiatien Safety Labe ::o y fc-the R2.diatien Safe:y Officer's. ac.icn.

On i

July II it vt.s :gti: picked up by Emery Air F eight and shipped to New Ingiznd Nuclezr Cc pcrz icn.

2.

'Ihe University dees no: hzve a Dean of Civil Engineering nor is there 2 reccrd of a=y radicactive =sterial received by the Civil E..gineeri=g Dep.t- =en: du-ing the -Surser.

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3.

C12sses are held fo'r rev ger-ds, a:

Se=ri y, dic 2 is.clude use of pecie:*he eques: of the Direc c ef -

desi=eters.

Althcugh, there level radiatics e:pesures, these devices cre accep nu cl ez r p.c y: 1 1 : c 7 C.

hsic.

The gu1rds zre shev:

high rez. dings c= be ind:ced by physical shock (such as d:cp zad h=ce, the desi:::ers shcu.1d be ha dled with care, nevertheless d ey c=:

Ins :ueriens fcr yreper use are 21sc pested a: ins:

cced to rec:rd zny ::ading which is observed.

-le check-in desk of e e Re2c:er A.oc=.

We believe thE:

ep12 ing de reguia- (aben:the Nucle - Eeg Itt: y Cc:-issien wculd pp 10 visits per day) guard inspectic s with : int.: sic 21a:= syr:e.

This v=1d e14 * =te frequen: visits to the Reac:cr Ecc= by the garris ::d vr:Id 21sc be cer:-effective.

I rec =:end -d:: this be deze cs sec. cs possible.

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~n dici had been s:cred ever-right in de adj ce :dete=

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izbemery, incident Ther:21 Science te crast::cticn werk being cc: ducted by a c~: :::cr i: 2e her:21 Scienee Labcn: cry.

ne R:diatien 525ety Officer requested $ c in 25 e which was cr=. lied vid. bthe cc: presser te s:: red elsewhere Y the cent:2c cr.

S.

T:e 3_. ved naviste secrzge is ::

de le2.cter Rocs : d the E:uiicchenic:1 Lec atery.in twc locations, viz.

presen:

. ~s:c ed u=s:iely bu:

R duzste is nc:

f:=ri zs sc a 1s pcssible.:=re sui ~.icle s:crase locztica shculd he 1

he c.ive si:7 nl.iztics safe y,.nin= :=d the reac:cr progrz:

- er.:larly irrpected by de Raclezr Eeralate y Cc=:issics.

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Edve-d D..?ctd::, Direc:cr Infer:2:ier Systers 5 Plznning Office cc:

R. S:eyen p..trz:sino Dern, Cel

':s Schoci cf 1. w M:,. Xtr en I. Xeene R2dd::ic: Sciety officer Dr. Dzvid D. Ebe.:

Scric: Eeac:cr Ope 1:cr Dr. l'. -io Czs ellz Acting C.__, Mech 2mic21 Z:g g

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4 WASHINGTON D.C. ::c44 Om3 CF T.-G D RLT. OR CF :.N;FCFRCCN SrS B'S AND PLANN~NC

== 6ss.::=.:

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7tadictien Szfe y Subec

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.3 ** 0-~.~b*.- 4, 19'e.o D-, Edwz-d D. Jcrdan, Chai=zn, Dr. Hall I..

Crznnell, Members P esent:

l'r. Ezrren E. Keene, D. Lecpcid Mzy, Mr. Williz: G. Nork,,

D. 3ohn Tolhun:er Members Kesent:

D. David D. Eber, Col. E. F. Scith Gues s 7:esen::

M 5:even Franki.0, rean, ice Sdoci 5 University Cr Mr. F.icha-d C. Applesz.e, Vice Fresident for Admin 6 Fin..

72e Chri 2n czlled the teeti g :c crder a: 4:50 FM in Dr. Jordan's Office of the Exect:ive Office Euilding.

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..u-University, the news redia and purper edly to de NTtC by a Ms. Kelly Fit:ps:d in the~ Schoc1 of Arts 5 Sciences rnd ferner pt :. time exployee in a s r.:d er :

the Office cf Czzpus Secu-itv.

Tne Chai---

prcvided a ecpy cf Ms. Fi : patrick's cizins to each cenber tcgether with a ccpy of a ter randu: frc: Fresiden: Felleg-ino

present, rec.:esting dz: Dr. Jcrdz. investigate the allegz:icns and Dr. Jordan's respense.

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Tne Fir: patrick clai=s znd Dr. Jcriza's resn. ense :: the Presi. den: setti:.g i

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In the ccurse ef this dis =ssion the folleving additional infor=ttien with respect to the firs: of Ms. Fit:pz: rick's allegatiens (the ship =en: of i

5 =illic=-ies cf Stin ) was p cvided:

In acecrdznce with 10CFF.20.205 Cel-ii), ackzges centaining no =cre r

1.

thzs 10 =illicurdes cf radicactive =aterici censisting solely cf tri:Luz, need no he ch.ec.y.ec cr ccn:2: int:1cn.

,s..z.s norntns:1=c~.ng, the package vzs checked for con:acinz:icn as tre all incc=ing ship-

=ena of radicactive r.;;erials.

The packzge bere z wa=ing Izbel "Padicactive - 1&ite I" in accordance 2.

of Trznsper:stien (DOT) regu12:icns.

(According to DOT,<

with Depart =ent "de label ale s persens handling packages tha: the package ray If the background color of the label is all receire specizlihtndlin.

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white, the radiz:icn is.:.ini:21 znd nothing special is required for ths: pacinge".

According to Title 49, CF:., pt : 173.359 the dose Ts e

..s.

limits for a package bearing a 'Ynite - I" Inel a e 0.5 rilli-Roentzens per hc= a: any point en an accessible surface of the package and zero =illi-Roentgens per he r a three fee f := any'er:e_nal Srface cf the pad 2ge.

This lini: is 25% of the 2 tillire= per hour exposre limit fer unrest-icted areas set by 10CFPJ0.105 (b1).)

3.

h~ nile $e p actice of having the Office of Cz=us Secu-ity accept ince:ing packages cf adicactive =aterial for place ent in the P2dia:ien Safety Labe atory is not an ideal solu icn because of the li=ited traird:g of the guards (provided incident to their duties to inspec:

the reat:c :~se:), it is a solutien ac:ep:dle to the NRC.

ne rae.. t:ct e::::e,. by :. ::.n= consists c: ee:a pa-::cles with a y

4.

a n

r:N energy of 15.6 kev which is insufficien: to penetrate any shipping ccn:ainer.

Tnere was gene ci cencr e ce a:eng these present da: the ideal sclutien to the p=ble: of handling incering ship =ents od radioactive mate-ial would be the existence of a cent-al receiving facility on the ca=us.

It could include app :pria:e 5:crzge facilities fer such packages and the persennel ec Id be kep inferred cf apprcved handling ins: uctions.

In a='ifica:icn of parag-aph 5 of Dr. Jordan's response to Dr. Pellegrino, M. Keene noted th2: the need for a ore suitable 10:atien for s:crage of radicactive vaste s ens no: enly frc: the linited p :ential from airborne radica :ive rate-ial and cc ses:en: Icw-level

n:- ' a-icn of surfaces in teaching labers ries (the reat:c ree: and the nuclear ins: uction 16 crate y), but also f := the presente of fu es f :: velatile hydrocarbens (pri.arily toluene i.. lic,uid scintillation raterials) which are :cxic chemicals even in the absence of radicactivity.

A 7:cperly ventiltted, secu e, sele-use facility should be provided.

P. Nerk prcvided the c H::ee with background inf:=atien conce: :ing :he ge-...:..... e_u. e.y_,.... e. Ms.

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y Se:n-ity, a pcsitics she had recently resigned to take tnether position.

Dean Fran i:0 briefed the co- ' tee en the meeting of Ms. Fitzpatrick and her counsel with Presiden Pellegrino and en subsec,uent discussiens be:veen himself and Ms. Fi : patrick's counsel.

He also stated that he had contacted the SEC who, as of ezrly afterncen, October 4, htd not received a ce= plain: in-the =a.:ter.

ne =eeti.g adjerned a: 5:30 FM.

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Warren c.

xeene P2diatien Sa.fe:y Officer ec: To attached lis

Dr. Li--md D. Pellerrino cc:

r Preside :

1 Dr. C. Joseph h esse F. ec:::ive Vice President I

Dr. John J. M Ay Act.'.=g Prevost

6. Richard C. App 1rgete Vice President h Ad-in & Finance W. 5:even Frriri=o 4

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