ML20052A743

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Submits Operations Rept for Period 741021-750430
ML20052A743
Person / Time
Site: University of Virginia
Issue date: 06/11/1975
From: Farrar J
VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To: Moseley N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20052A734 List:
References
FOIA-81-483 NUDOCS 8204290112
Download: ML20052A743 (8)
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Sh*bhb U.JIVERSIT( OF VIRGI 41A SO!OOL OF E IGl EtRI.'G AD APPLIED SCl&!CE

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CtIARLOITESVILLE 22901 DlT'ARTEIT OF JUCIZAR EdGIilEr:RIJG TELEPH0dB 80h-92h-7136 REACT 0tl FACILITY June ll, 197.5 -

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Mr. Norman C. Moseley, Director

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Dear ifr. Moseley,

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V6 hereby submit, e required by Section 6.7.E of our Technical Specifi cations cur report on the first 6 months of operation of the CAVALIER reactor, License R-123, Docket ilo. 50-3)6. This report ineludes operations from initial criticality on October 21, 197h through April 30, 1975 except that the inform-ation supplied in our 60 day report sub:sitted on January 3,1975 is not duplicated here.

1.0 l>ering this period the reactor was operated for % 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br />. Most of this tice was devoted to training fourth year undergraduate nr.d graduate students in rer.ctor operations.

Several foil activations vere also perfor=cd r,s an cyperit.ent in fast neutron flux ner. surer.ient for third year undercreduate students.

2.0 g og y.1 Occurrences a) An ebnormal occurrence ucs experienced on February 6,1975 when it was discovered during' testing of the rod control system that the =cenet release tines for rods #2 c.nd #h exceeded the 100 nsec time required by Section 3.6 of the Technical Specifications. The Reactor Scfety Cc nittee and the Region II Reculatory Operations Office vere notified and reactor operations were suspended for corrective action and review. The support arn bolts for rods #2 and #h vere found'to be loose ecusing a slicht mir.nlignment of the rod with the drive systen. After realignment and testing of the control rods the reactor was placed back in service on February 26, 1975. Rod drop tests were conducted every two vecks for the next two nonths and the support am counting bolts vere checked daily.

Ho further problets with rod drop times have occurred. Bod drop times measured during t.hir, period are given below.

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(msec)

(msce) 2-6-75 1

60 505 565 2

120 500 620 3

80 500 580 4

120 520 640 2-2s-75 1

62 525 587 2

68 497 565 3

83 499 582 4

52 527 579 3-4-75 1

40 552 592 2

80 488 568 3

82 51h 596 4

72 501 573 3-18-75 1

57 520 577 2

89 502 591 3

70 516 5 86 4

92 524 616 4-1-75 1

Sh 515 569 2

93 497 590 3

98 519 617 h

62 546 608 k-15-75 1

57 Sob 561 2

79 550 629 3

96 520 616 4

86 547 633,

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b) A second abnormal occurrence vec experienced on April 1,1975 when the Log G instrument failed to indicate upscale as the reactor was brought to a pouer level of % 20 watts.

Investigation revealed that the signal lead had not been properly connected efter naintenance uns performed on-the previous day. The Reactor Safety Cornittee and the Region II Regulatory Operations Office vere notified.

Sincethisparticularinstrumentdoesnotcobeonscaleuntilthe reactor is super-critical we have made the following change to our operating procedures.

Uhen the Los G channel is re=oved for naintenance, in addition to checking the calibration of the chtnnel, a portable source vill be used to check the response of the system from the detectors to the Log G drawer. This change has been made in our procedures and approved by the Reactor Safety Cc::=ittee.

3.0 The reactor was operated during this report period for N 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> with an integrated power of % 477 vatt hours.

h.0 The following is a list of unplanned shutdouns during this report period.

10-22-7h 2 scrc=s while leveling pover at 1 untt due to noise spikes frcm operation of rod control reJ ays.

11-1-Th Scran due to instrument noise.

11-8-74 Period scrcm - occurred while cujusting Log G detectors after power calibration.

11-8-Th Period scram due to instrument noise, ll-11-7h Period scra= due to instrument noise.

h-h-75 Scram - due to building pcuer failure.

h-h-75 Seras - due to building peuer failure.

h-26-75 Period scram due to instrument noise.

4-29-75 Period scram due to instrument noise.

5.0 Maintenance _

Two najor cain'tenance operations were undertaken during the reporting period. ilev nsgnetic clutches e.nd notor couplings were installed in the rod drive mechanisms.

A series resistence vas ndded to each tagnet clutch circuit to allow operation with reduced clutch voltage. These items were discussed in the 60 day operating report, Section 7.A.

The Alternate Reactivity Insertion System Tank was repaired after detecting several pinhole leaks in the tank seam velds. This iten was reported in the 60 day operating report, Section 7.B. '

t l----------

6.0 Environtental Monitorin.;

During this report period the health physicist took air and' vater samples both at the facility and outside the site boundary.

The followin6 table lists these locations and the specific activities obtained from these samples.

Location Sample Specific Activity Average of 8 Sanple_s

~9 Reactor Site Water 2.31 x 10 pei/ml

-12 Air 2.63 x 10 uci/cc

~9 Filter Plant Water 1.12 x 10 pei/cl

~1 Air 1.5 x 10 poi /cc

~9 Barracks Road Vater 2.95 x 10 pei/ml

~1 Air 1 99 x 10 pei/cc T-0 Personnel Monitoring During this report period approximately 128 personnel including faculty, staff, and students vere monitored by film badges supplied by the R. S.

Landauer Co. The highest exposures vere by two staff mecters who are directly associated with the operation of the facility and the hcudling of campla= -

in ectivotion c.nnlysis work. The exposures are from operation of the UVAR TeacDZr.

Exposure Individual A 220 nrem Individual B 60 mrem During this period the facility had approximately 1089 visitors. These visitors vere monitored with direct and indirect reading dosincters and received no significant exposure.

Sincerely, "N

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J. rP. Farrar Operations Supervisor JPF:ce cc HRC-Unshington Reactor Safety Cetmittec Senior Operators NN O 9%%M -

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04/14/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0!!!C SAFETY AND LICENSING BOARD In the !!atter of

)

)

arf 1ED FORCES RADI0 BIOLOGY RESEARCH

)

Docket No. 50-170 INSTITUTE

)

)

(Renewal of Facility (TRIGA-Type Research Reactor)

)

License No. R-84)

NRC STAFF'S STATE!!ENT OF POSITION ON UNSTIPULATED CONTENTIONS OF PETITIONER CITIZENS FOR NUCLEAR REACTOR SAFETY, INC Pursuant to the Stipulation dated itarch 30, 1981 and signed by the Staff, the Armed Forces Radiobiology Research Institute ( AFRRI or Licensee) and Citizens for Nuclear Reactor Safety, Inc. (Petitioner) on fiarch 31, 1981, the Staff herein sets forth its statements of position regarding those contentions of the Petitioner which were not stipulated to, and which were subaitted with the Stipulation as Attachment B.

BACKGROUND On Deccaber 9,1980, Petitioner filed a Petition for Leave to Intervene in this proceeding.

On December 24, 1980, the Staff and the Licensee filed responses to the Petition, opposing the Petition on the issues of interest and standing.

The Petitioner then filed an Amendment to Petition for Leave to Intervene on January 16, 1981.

The Staff responded to the Amendnent on January 26, 1981, and concluded that the Petitioner had cured the defects of intere}t and standing in the original Petition.

In the Staff's Response, 4 x;gput PA

it was noted that the Staff intended to meet with the Petitioner and the Licensee to attempt to stipulate admissible contentions.

Following a number of meetings, on 14a'rch 27, 1981, the Staff, Peti-tioner and Licensee met, and as a result were able to stipulate as to the ad111ssibility of six of Petitioner's proposed contentions.

Agreement was not reached on seven additional contentions.

Both sets of contentions were i

I' filed with the Board in the Stipulation signed by the parties and the Peti-tioner on liarch 31, 1981.

As a consequence of these efforts and the parties' and Petitioner's agreement upon a stipulation of contentions, the Licensing Board now has before it the tasks of (a) ruling on Petitioner's " Amendment to Petition for Leave to Intervene", dated January 16, 1981; (b) approving the Stipulation dated liarch 31, 1981; (c) ruling on the adnissibility of In the balance of the nonstipulated contentions advanced by the Petitioner.

this pleading, the Staff submits its position concerning the nonstipulated contentions as set forth in Attachment B to the Stipulation.

DISCUSSION As a general matter, for the contentions proposed to be adnissible,

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r'ml they must fe ' ? +"'

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a' g ve s[ and comply with the requirements of E

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.a o M A Notice of Hearing has not yet been issued in this proceeding, since the Licensing Board has not yet ruled upon any request for hearing See 10 CFR 9 2.105(e).

o and/or petition for leave to intervene.

Notice of opportunity to request a hearing, which identifies to sone extent the subject of the proceeding, has been published in the See " Armed Forces Radiobiology Research Institute Federal Register.

TAFFRI); Consideration of Application for Renewal of Anended Facility License", 45 Fed. Reg. 78314 (November 25,1980).

. 10 CFR 2.714(b) and applicable Comission case law.

See, eg., Northern States Power Co. (Prairie Island Nuclear Generating Plant, Unit Nos. I and -

2), ALAB-197, 6 AEC 188, 194 (1973), aff'd, BPI v. Atomic Energy Comission, 502 F.2d 424, 429 (D.C. Cir.1974); Duquesne Light Co. (Beaver Valley Power Station, Unit No. 1), ALAB-109, 6 AEC 243, 245 (1973); 10 CFR l 2.714(h).

10 CFR 9 2.714(b) requires that contentions which intervenors seek to have litigated be filed along with the basis for those contentions set forth with reasonable specificity.

A contention must be rejected where:

(a) it constitutes an attack on applicable statutory requirements; (b) it challenges the basic structure of the Commis-sion's regulatory process or is an attack on the regulations; (c) it is nothing more than a generalization regarding the intervenor's views of what applicable policies ought to be; (d) it seeks to raise an issue which is not proper for adjudication in the proceeding or does not apply to the facility in question; or (e) it seeks to raise an issue which is not concrete or litigable.

Philadelphia Electric Co. (Peach Bottom Atomic Power Station, Units 2 and 3), ALAB-216, 8 AEC 13, 20-21 (1974).

The purpose of the bases requirement of 10 CFR l 2.714 is to assure that the contention in question does not suffer from any of the infirmities listed above, to establish sufficient foundation for the contention to l

warrant further inquiry of the subject matter in the proceeding, and to put the other parties sufficiently on notice "so that they will know at least generally yhat they will have to defend against or oppose".

Peach Botton l

.4-sary for the From the standpoint of bases, it is unnecesh h

supra at 20.

petition "to detail the evidence wMississippi Power lf fiuclear Station, contention".

26 (1973).

Units I and 2), ALAB-130, 6 AEC 423, 4a licensing board is not to re h

f il the contentiors and bases there ore, Duke Power Comoany (Am i

merits of the contentions.

t Fuel from Oconee fluclear Stat on l

License Siit -01773 -Transportation of Spen ALAB-528, 9 fiRC 146, 151 for Storage at McGuire i<uclear Station),

This principle was lf, supra at 426.

Peach Bottom, supra at 20; Grant Gu And Power Company ( Allens Creek f

i j

recently reaffirmed in Houston Light noALAB-590,11 NRC 542, 548 (1 i

)

fiuclear Generating Station, Unit 1, ith regard to basis, all that is for the Appeal Board pointed out that, wis that the petitioner state the required at the petition stage etitioner need not establish its contention.

In sun, at the petition stage, although a pd the bases the validity of its contentions an tions and the bases therefor which upon the petitioner to set forth contenfic to demonstrate that the are sufficiently detailed and speci inquiry is warranted, and to put the raised are adnissible and that furtherthey will have to defend ag other parties on notice as to what here, a hearing is not nandatory, This is particularly true where, astion raises an issue clearly oppose.

in order to assure that an asserted contenCi l

(William H.

to adjudication.

8, 12 (1976);

Zimmer Power Station), ALAB-305, 3 tiRC d 2), ALAB-183, 7 AE Company (River Bend Station, Units 1 an n.10(1974).

1

, (

Based on the foregoing, and as set forth below, the Staff believes I

Petitioner's contentions which were subnitted with the Stipulation as Attachment B fail to meet the requirements of 10 CFR 6 2.714(b) and accordingly should not be admitted as issues controversy in this proceed-ing.

For the convenience of the Licensing Board and the parties, each unstipulated contention is reproduced below, followed by the Staff's statement of position.

Contention 1 Accidents I The analysis of the loss of coolant accident (LOCA) and the two design basis accidents (DBAs) within Applicant's Hazard Summary Report (HSR) is faulty in that:

1)

It erroneously concludes that in event of an accident described therein as " Loss of Shielding and Cooling Water",

air convection cooling would be sufficient to prevent cladding failure and significant fission product release.

Petitioner contends that in the event of a rapid loss of coolant while the reactor core is in the pulse mode, there could be a sudden temperature elevation sufficient to cause multiple cladding failures and fission product releases in excess of the limits provided in 10 CFR Part 20; 2)

Both of the DBA analyses in the HSR (" Fuel Element Drop Accident" and " Fuel Elenent Clad Failure Accident")

erroneously consider only those radiation doses to humans that would result from submersion exposure to the noble gases rel ea sed.

Petitioner contends that if such accidents were to occur, individuals would receive additional exposure due to internal emissions of the noble gases, sustaining injuries far greater than those predicted in the HSR.

Staff Position The Staff opposes adnission of part 1 of this contention on the grounds that it lacks adequate basis and fails to alert the parties as to

(

the natters sought to be litigated.

The Petitioner does not indicate the mechanism by which the reactor could achieve pulse mode without the water moderator.

The present wording of the contention states a physical impossibility, since the coolant is required to maintain criticality, and without criticality it is not possible to pulse the reactor.

The Staff is aware of no scenario in which the reactor would not shut down upon loss of coolant, and the Petitioner has done nothing mere than assert, without basis, that these events could occur.

Based on the foregoing, the Staff opposes adnission of part 1 of this contention.

The Staff opposes adnission of part 2 of this contention on the grounds that it lacks adequate basis and constitutes an indirect challenge to the Connission's regulations.

10 CFR Part 20 quite clearly bases the allowable concentrations of the noble gases, Argon, Krypton and Xenon, on subnersion exposures (see 10 CFR Part 20, Appendix B, n.2).

The Petitioner has set forth no "special circumstances" pursuant to 10 CFR 2.758 to demonstrate why the basis for Part 20 limits, submersion exposure, should not be applied in this case.

Based on the foregoing, the Staff opposes adaission of part 2 of this contention.

Contention 2 Accidents II Accidents can be expected to occur at the AFRRI reactor of a different kind and greater severity than those described in the HSR.

Such accidents would result in significant offsite releases and include:

1 1

. Petitioner Failure of the N-16 diffuser system.N-16 bubbles would contends that in the event of such failure, 1) l t cladding accumulate along the surf ace of the fuel e emena) ins t

tion of the coolant resulting in rapid temperature eleva d loss of causing:

elements and possible multiple clad failures, anb) production an water shielding; andradionuclide N-16 with its powerful gamma ray.

h Two maximun credible accidents (MCAs))beyond t e a) power design basis of the reactor (Class 9 accidents :

2) l ladding excursion accident (PEA) resulting in multip e cfa in the thermalizing effect of hydrogen, followeb) LOCA resulting in zirconium-steam interaction; and atu re,

multiple cladding failures at an elevated temperfo tention on the Staff Position The Staff opposes adnission of part 1 of this con n issue which is not grounds that it lacks basis and seeks to raise a h N-16 diffuser Petitioner has misunderstood the purpose of t e lation of li tigable.

The systen was never intended to prevent the accumu On the contrary, the systen retards system.

nitrogen bubbles on the fuel cladding.the decay of N-16, which has a the rise of dissolved nitrogen to permitThe Staff could half-life of 5.7 seconds.

ble, performs an entirely failure of a system, where that system, when opera

~

Petitioner.

different function from that described by the his contention on the The Staff opposes the admission of part 2 of t s an issue which is i

grounds that it lacks an adequate basis and ra seTh neither concrete nor litigable.

rsion accident or a LOCA could way the mechanism by which a power excu the Zirconium More importantly, it is a scientific fact that i ity to both air and water.

occur.

hydride used in the fuel has a very low react v

. It is simply physically impossible to have an " explosive Zirconiun-steam interaction" or an " explosive Zirconium-air interaction".

Contention 3 Testino Facility Petitioner contends that the AFRRI facility is a testing facility within the neaning of 9 31.a(3) and 9104(c) of the Atomic Energy Act of 1954, as amended, and 9 50.21(c) and 9 50.2(r) of 10 CFR Part 50.

[ AFFIDAVIT TO BE SUBillTTED AT THE TIttE OF FILING 0F STATEt1ENTS OF POSITION)

Staff Position

('

The Staff maintains that the AFRRI reactor is not a testing facility

(

within the meaning of 10 CFR 50.2(r).

I, The Trustees of Columbia University, ALAB-3, 4 AEC 349 (1970) the Atomic Safety and licensing Appeal Board reviewed the certified question of whether a TRIGA reactor was a " testing facility" accor ding to the definition I

of 10 CFR 50.2(r)(1). The Appeal Board decided, based o'. the potential for Id. at releases of radioactivity, that it was not a " testing facility".

The Staff follows the long-standing precedent of Columbia 350, 351.

liniversity and opposes the adnission of this contention.

l 1

1 i

9 P

8 Contention 4 in Sitino Applicant has failed to demonstrate that the AFRRI facility satisfies the siting criteria set forth at 10 CFR Part 100.

Petitioner contends the AFRRI reactor falls within the scope of Part 100 siting criteria either as a testing reactor or a research reactor and cites for the latter case the Memorandun from Vollmer (Director, Division of Engineering, NRR), to Eisenhut (Director, Division of Licensing, NRR).

Petitioner contends that because of the density and residential nature of the population in the plume exposure EPZ, the inadequacy and inaccessi-bility of highways, the inadequacy of Applicant's Energency Plan, and meteorological, geological and hydrological conditions of the area surround-ing the facility, Applicant cannot provide reasonable assurance that Part 100 offsite dose limits would not be exceeded in the event of a raximum credible accident.

Staff Position The Staff opposes the admission of this contention on the grounds that it seeks to raise an issue which does not apply to the facility in question and therefore is beyond the scope of this proceeding.

The scope of 10 CFR Part 100 is set forth in 10 CFR 6100.2(a) which states:

This part applies to applications filed under Part 50 of this chapter for stationary power and testing reactors.

Since the AFRRI reactor is a research reactnr, and not a power or testing reactor (See Staff Position on Contention 3, supra), the site criteria of Part 100 clearly do not apply.

In the event the Petitioner seeks an exemption from the regulation, the "special circumstances" of 10 CFR 5 2.758 must be addressed.

Petitioner has failed to do so.

l 4

_ Contention 5 NT Routine Emissions I enissions from routine operations and disposal of so

' maintained within the limits of 10 CFR Part 20 in that act listed below and Applicant's radiation monitoring meth ual and probable actions are inadequate to detect and prevent their recurrence corrective 1)

The data cited in 4) of the stipulated contention (Routine Emissions I) and Applicant's written response to Petiticner's question submitted in the winter of 1979 is the highest total exposure measures over the year at any

"[w] hat one of the reactor environmental nonitoring stations

[ years 1975-1979]",

for the these stations from 1962 throughdemonstrate that releases measure,d a 1965,1978 and 1979 resulted in average annual whole body doses to members of the public in excess of epa's limit of 25 mrem.

2)

Applicant's incineration at NNMC of 160 boxes of contaminated solid waste, cited in NRC Inspection Reports for 1975-1976, Docket No. 50-170, resulted in the release of r

radioactive gases and particulates in excess of the limits set forth at 10 CFR Part 20, Appendix C.

s 3)

(EIA), submitted in conjunction with its license renewalSin application, admits that the highest average unrestricted area exposure rate from airborne releases (set forth in the EIA) extends to residential areas, it is highly probable that such public in excess of 0.5 rem and, violate the principle tha i

emissions from Applicant's operation be kept as low as is reasonably achievable (the ALARA principle).

4)

Applicant's Environmental Release Report, issued 12/14/71, indicate that between 1/1/70 and 7/1/71 exposure rates in several unrestricted areas were as high as 1-5 mrad /hr.

At this rate, any person who lived or worked in these areas 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in a year, or about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> a week, would receive an annual whole body dose in excess of the NRC's linit of 0.5 rem /yr.

Since 50-60% of the area within a one mile radius of the AFRRI stack is residential, it is highly probable that the population dose limit was exceeded during this period.

This is a violation of the ALARA principle.

l

. n:...

f Staff Position' ry.

The Staff opposes admission of part 1 of this contention on the

~

grounds that it is an attack on the Commission's regulations.

In the case of research reactors, the NRC does not apply exposure standards set by EPA.

The applicable NRC regulation is 10 CFR Part 20, which has an annual limit for whole body doses in unrestricted areas of 500 mrea (10 CFR 6 20.105).

The Petitioner has not demonstrated "special circumstances" pursuant to 10 CFR 6 2.758 to show why Part 20 should not be applicable.

The Staff opposes adnission of part 2 of this contention on the grounds that it fails to put the other parties on notice as to what they will have to defend against or oppose.

Neither the Staff nor the Licensee have any record of the reports Petitioner refers to.

The Staff is not aware of any incineration performed under this particular license and has been informed by AFRRI that all wastes are shipped off site.

Unless the Petitioner is able to be specific enough to enable the reports to be identified, the Staff opposes this contention.

The Staff opposes admission of part 3 of this contention on the grounds that it lacks adequate basis and fails to alert the parties as to the matters sought to be litigated.

The fact that an unrestricted area exposure rate extends to residential areas does not raise a litigable issue since, by definition, an unrestricted area can be a residential area (10 CFR 5 20.3(a)(17)).

The test is whether the emissions result in doses to the general public in excess of.5 rem per year.

Petitioner has stated no basis for contending that it is " highly probable" that doses to the general public in excess of.5 rem per year have occurred.

.. V,

~

The Staff opposes part 4 of this contention on the grounds that it lacks adequate basis and seeks to raise an issue beyond the scope of the proceeding.

The Petitioner has misstated the facts in the Enviromnental Release Report.

The Report states quite clearly that a direct radiation exposure rate of 5.0 mR/hr was produced at the ikxitron 250, an x-ray i

facility located in a building not part of the AFRRI complex.

Since this Board is considering the license renewal of the AFRRI reactor, part 4 is beyond the scope of the proceeding.

Contention 6 Routine Emissions II

~

(

10 CFR Part 20 limits are inadequate to protect the health and safety of the population in the vicinity of the AFRRI reactor.

This proceeding presents "special circumstances" within the meaning of 10 CFR i 2.758 that warrant the Board's consideration of whether the offsite air-and waterborne release limits set forth at 10 CFR Part 20 and Appendices B and C thereto are adequate to protect the public health and safety.

[ AFFIDAVIT TO BE SUBMITTED AT tit 1E OF FILING 0F STATEMENT OF POSITION]

Staff Position The Staff opposes the admission of this contention on the grounds that it is an attack on the Conmission's regulations, and that it is so vague it fails to put the other parties sufficiently on notice as to what Petitioner seeks to litigate.

The Petitioner states no basis whatsoever for its bare

I

. W-lg-claim that 10 CFR Part 20 limits are inadequate to protect the health and safety of the population in the vicinity of the AFRRI reactor.

Contention 7 Security Neither the Physical Security Plan for the facility nor Applicant's history of security violations and substandard management and operating procedures demonstrate that the controlled access areas can be protected from sabotage or diversion of special nuclear material according to the standards set forth at 10 CFR Part 73.

The Draft Audit Report of the AFRRI facility prepared by the Defense Audit Service in 1979 cites frequent instances of security and management violations, including:

1)

Eighteen activations of the facility alam system during a 34-day period, caused by personnel leaving work af ter g

nomal duty hours from unauthorized exits.

Auditors were told by AFRRI security personnel and other AFRRI officials that s

investigations were not made of the activations and that not enough security people were on duty to investigate each time the alam went off; 2) unauthorized people entering the facility by following enployees in who used their magnetic cards to unlock the door; 3) failure to escort visitors attending weekly seminars and provide them with dosimeters; 4) failure of employees entering and exiting the building after hours to sign a log showing their time of arrival and departure; 5) violations of Applicant's accounting and dispensing procedures for controlled substances such as narcotics.

Staff Position The Staff opposes admission of this contention on the grounds that it lacks adequate bases and appears to raise issues which do not apply to the

ee37 3 facility involved in this proceeding.

The AFRRI reactor facility possesses

,-.'.i-~~

special nuclear material of low strategic significance.

As such, only i 73.67 of 10 CFR Part 73 applies.

10 CFR 9 73.67(a)(2) requires that the physical protection system shall provide:

~

(i) Early detection and assessment of unauthorized access or activities by an external adversary within the controlled access area containing special nuclear material; (ii)

Early detection of removal of special nuclear material by an external adversary from a controlled access area; (iii) Assure proper placement and transfer of custody of special nuclear material; and (iv)

Respond to indications of an unauthorized removal of special nuclear material and then notify the appropriate response forces of its removal in order to facilitate its recovery.

None of the instances cited by the Petitioner appear to demonstrate a lack

\\

of compliance with 10 CFR 73.67, especially in that there is no showing m

early detection would not be accomplished.

In addition, the Petitioner fails to indicate the connection between the violations and the controlled access area.

No allegation has been made that any of the violations resulted in unauthorized access to the controlled access area without detection.

CONCLUSION For the reasons stated above, the Staff urges that the Licensing Board (a) approve the Stipulation submitted by the Staff, AFRRI and Petitioner

. mg.

and (b) deny admission of all other contentions advanced by Petitioner at this time.

Respectfully submitted, f

Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this 14th day of April,1981 1

UNITED STATES OF kiERICA NUCLEAR REGULATORY CD:i".ISSION P..

BEFORI THE AT0tlIC SAFETY N13 LICENSING BOARD o.e - -

In the fiatter of

)

)

Docket No. 50-170 AR::ED FORCES RADI0 BIOLOGY RESEARCH

)

INSTITUTE

)

(Renewal of Facility

)

License No. R-34)

(TRIGA-Type Research Reactor)

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S STATEMENT OF POSIT 10!1 Oil UNSIIPULATED CONTENTIONS OF PETITIONER CITIZENS FOR NUCLEAR REACTOR SAFETY, l'IC." in the above-captioned proceeding have been served on the following by deposit in the United States nail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal nail system, this 14th day of April,1931:

Louis J. Carter, Esq., Chairaan

!!s. Elizabeth B. Entwisle Administrative Judge 3118 Hartford Avenue Atomic Safety and Licensing Board Silver Spring, MD 20910 23 Wiltshire Road Philadelphia, PA 19151 Atonic Safety and Licensing Board Panel

  • Mr. Ernest E. Hill U.S. Nuclear Regulatory Connission Administrative Judge Washington, DC 20555 Lawrence Livermore Laboratory University of California Atonic Safety and Licensing Appeal P.O. Box 808, L-123 Panel (5)*

Livermore, CA 94550 U.S. Nuclear Regulatory Connission Washington, DC 20555 Dr. David R. Schink Adninistrative Judge Docketing and Service Section (7)*

Departnent of Oceanography Office of the Secretary Texas A&M University U.S. Nuclear Regulatory Concission College Station. TX 77840 Washington, DC 20555 l

Mr. Robert L. Brittigan, Esq.

General Counsel Defense Nuclear Agency Washington, DC 20305 Richard G. Bachmann i

Counsel for NRC Staff

1

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76 03/33/81 liL u '

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UNITED STATES OF' AMERICA NUCLEAR REr,ULATORY COMi'ISSION BEFORE THE AT0f'IC SAFETY AND LICENSING POP D In the Matter of

)

)

Docket No. 50-170 AR'ED FORCED RANI 0 BIOLOGY RESEARCH

)

I!5TITUTE

)

(Renewal of Facility

)

License No. P-32)

(TRIM-Type Research Reactor)

)

_STI PUL ATI0'J The NR: Staff (Staff), Arned Forces Radiobiology Research Institute

( AFPPI or Licensee), and Citizens for Nuclear Reactor Safety, Inc. (CNPS or Petitioner), by their respective attorneys or authorized representatives, hereby stipulate and agree as follows:

1.

Discussions having been held between the Staff, Licensee and Petitionar pursuant to tha Letter from Staff Counsel to Adninistrative Judge Carter dated January 16, 1981, the Petitioner agrees that the sole contentions it is asserting in this proceeding are those set forth in Attachment A (Stipulated Contentions) and Attachnent B (Unstipulated Contentions), subject to the reservation set forth in paragraph 6 bel ow.

The renumbering and wording of the contentions set furth in Attach,1ents A and B supersede that set forth in all filings by the Petitioner prior to this date.

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Except as set forth in Attachments A and B, the Petitioner hereby withdraws all other contentions subnitted by it in all of its previous petitions and filings.

3.

The parties to this Stipulation agree that the contentions set forth in Attachment A meet the requirements of 10 CFR 9 2.714 as to speci-ficity and basis, raise appropriate issues for detemination in this proceeding, and thus constitute admissible contentions herein.

4.

The Petitioner asserts that the unstipulated contentions set forth in Attachment B are also proper contentions which should be admitted as matters in controversy and will file by April 14, 1981, or such other date as is set by the Licensing Board, such statenent of position as it deems necessary and appropriate with respect to these contentions.

5.

The Staff and/or the Licensee do not agree that the contentions set forth in Attachment B are proper contentions to be admitted as matters in controversy.

The Staff and/or the Licensee Applicant will file statements of position with respect to these contentions by April 14, 1981, or such other date as is set by the Licensing Board.

6.

Nothing in this Stipulaticn shall be deemed to prevent the Petitioner from filing new or amended contentions upon a showing of good cause as required by 10 CFR 5 2.714 of the Commission's regulations.

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7 10:qin; contained in this 5tipu!ation:

(a) small se deere an ai-ission by the Sta'f e-the Li:ensee of tne nerits of any contention or t'le va'.idity of any allegat on of fa:t ce l a n-stated in acj i

contention; nv, (b) shall be constrJed as a x31eer by any cart,. t, t*.is stipalation of any rights ith respect to the ed-issibility of e.idence parsuant to 10 CFR @ 2.M3 c' the Com.ission's repJiations.

Ea.7. pacty to this Stipulation exaressly reserves any riptt to me.>e 'c.-

4 sun 13ry disposition parsuant to 10 CFR 6 2.749 of the Comission's regulations in regard to any contention advanced by the Petitioner and ad-litted by the Licensing Board, i

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ldate)

~~~

Elizabeth B. Entwisie, Esc.

Counsel for Citizens for Nuclear Reactor Safety, Inc.

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/

[date)

Richard G. Bachmann, Esc.

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Counsel for NRC Staff M4 3 r (cate)

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RdAAPP&

Robert L. BrittiganM5q.

Counsel for Armed Forces Radiobiology Research Institu*.-

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'd-ATTACHMENT A Mb -

STIPULATED CONTENTIONS 1.

_ Accidents I The analysis of the " Fuel Element Clad Failure Accident", one of the two design basis accidents (DBAs) within Applicant's Hazard Sunnary Report (HSR) is faulty in that:

The analysis of the " Fuel Element Clad Failure Accident" erroneously assu:nes that cladding failure during a pulse operation or inadvertant transient would occur at a peak fuel element temperature of less than 100*C.

Petitioner contends that such cladding failure would be much more likely to occur at elevated fuel temperatures (in excess of 400"C), resulting in far greater gap activity and fission product releases than the HSR postulates.

2.

Accidents II Accidents can be expected to occur at the AFRRI reactor of a different kind and greater severity than those described in the HSR.

Such accidents should be more properly designated DBA's to ensure that such accidents would not result in releases in excess of regulatory linits.

1) Fuel element storage rack failure.

The HSR does not provide reasonable assure 4ce that such an accident cannot occur in that: a) it fails to publish the calculations from which it concludes that a contact configuration of the twelve elements stored in Applicant's pool would not

ATTACHMENT A 4.

,,fresult in a critical mass; b) it does not cite the source for its statement that experience shows it takes approximately 67 closely packed fuel elements to achieve criticality.

2) Failure of an experiment.

Applicant has failed to show that several instances of malfunctions of confinement safeguards at AFRRI could not recur during an experiment failure, resulting in the release of radiation in excess of occupational and offsite linits.

Such malfunctions include:

a) a breach of containment caused by missing rubber gasket sealing naterial on the double doors to the corridor behind the reactor control room, in violation of Applicant's Technical Specification, i I. A.4.

(See, Notice of Violation App. A, NRC Inspection Report Docket No. 50-170,10/13/78);

b) failure of the reactor room ventilation dampers to close on August 26, 1975 when the Continuous Air tionitor was alarmed (see, DNA Abnormal Occurrence Report to Directorate of Reactor Licensing, dated September 3,1975, Docket No. 50-170, 9/10/75.);

c) failure of the lead shielding doors to stop opening at the fully opened position (see DNA Abnormal Occurrence Report, dated July 27, 1976, Docket No. 50-170,8/16/76); d) reactor core position safety interlock nalfunction on February 1,1973 (not recorded in Docket No. 50-170),

petitioner contends that human error coupled with failure of built-in l

safeguards could lead to a series of events resulting in releases of radioactivity in excess of regulatory limits and cites the following past malfunctions at AFRRI as evidence that such failures could occur there in the future: a) malfunction of Safety Channel One on flarch 15, 1980 An NRC inspection on March 17,1980 " revealed that Safety Channel One would l

l l

l

ATTACHMENT A ~w

- r-4L initiate a scram in accordance with [ Applicant's] Technical Specifi-cations"; b) reactor exhaust system malfunction on August 9,1979 caused by an electrical fire in the EF-1 cubicle of the motor control center, in turn caused by a power surge due to a faulty transformer; c) malfunction of the fuel element temperature sensing circuit caused by a " floating signal ground", reported by DNA on August 1,1979; d) malfunction of the pool water level sensing float switch caused by wear on the jacketing around the wires leading to the switch, reported by DNA on July 31, 1979; e) malfunction of Radiation ftonitoring System caused by two loose wires in the control box and resulting in a failure of the reactor roon ventilation dampers to close (on August 26,1975 (referred to in Contention 2h),

AccidentsII, supra);

f) malfunction of the Fuel Temperature - Automatic Scram System.cn January 29, 1974, caused by a build-up of high resistance material on the meaianical contacts of the TZ output meter; g) malfunction of the Reactor Core Position Safety Interlock System on February 1,1973, caused by a faulty de-energizing relay (referred to in Contention 2d),

Accidents II, supra).

Applicant has not shown that the TRIGA reactor's negative tenperature coefficient will automatically shut down the reactor in accident situations with damaged fuel elements, where the moderating effect of the hydrogen nuclei in the U-Zr-Hx alloy may be significantly reduced and the value of the negative temperature coefficient is changed.

4) Multiple fuel element cladding failure accidents have not been considered in the HSR.

Such accider.;s could result from: a) defects in the material filtegrity of the fuel elements themselves; b) an uncontrolled

ATTACHMENT A

  • poghhexcursioninthereactorcore; c) LOCA; d) sabotage, aircraf t collision or natural ("act of God") accident.

3.

Emergency Plan The Energency Plan prepared by Applicant in conjunction with its license renewal application does r.et comply with the standards set forth at 10 CFR Part 50, Appendix E, in that it fails to provide reasonable assurance that appropriate measures will be taken to protect the public health and safety in the event of offsite releases following a major accident such as those described in Accidents I and II, supra.

The following elements required by Appendix E are missing from the Plan:

A.

Organization

1) Description of the normal plant operating organization.
2) Detailed discussion of plant staff emergency assignments and duties of an onsite emergency coordinator in charge of exchanging infor-mation with offsite emergency authorities.
3) Description of Applicant's headquarters personnel who will be sent to the plant to augment the onsite emergency organization.

4)

Identification of and methods used by Applicant's personnel responsible for making offsite dose projections and transmitting the results to State and local authorities, NRC and other appropriate govern-mental entities.

5)

Identification of Applicant's employees and consultants with special qualifications for coping with emergency conditions.

I

ATTACHitENT A..

(

) Description of local offsite emergency support services.

7)

Identification of, and assistance expected from State, local and Federal agencies with emergency responsibilities.

8)

Identification of State and local officials responsible for planning protective actions, including evacuations.

B.

Assessment Actions

1) Description of offsite monitoring methods for determining the magnitude and continually assessing the impact of radioactive releases.

C.

Activation of Emergency Organization 1)

Description of emergency action levels for notifying offsite agencies and notation that a nessage authentication schme exists for such agencies.

D.

Notification Procedures

1) Description of means for notifying and agreements reached with l

local, State and Federal officials and agencies for the prompt notification and evacuation of, and other protective measures for, the public.

2)

Identification of the State and local government agencies within Applicant's Emergency Planning Zone (EPZ).

3)

Description of provisions for yearly dissemination to the public within the plume pathway EPZ of information on emergency planning, nature and effects of radiation, and a listing of local broadcast stations.

4) Demonstration that the State / local officials can make a public notification dbcision promptly on being informed of an emergency.

ATTACHt1ENT A -

~

E.

Emergency Facilities and Equipment

1) Description of arrangements for transporting contaminated indivi-duals to identified treatment facilities outside the site boundary (i.e.,

facilities other than the National Naval itedical Center).

2) Description of arrangenents for treatment of said individuals at said facilities.
3) Description of a near-site emergency operations facility and offsite communications systems with a backup power source.

F.

Training

1) Description of provisions for conducting a radiological orien-tation training program for local Civil Defense, law enforcement, and news nedia personnel.

G.

Recovery 1)

Description of criteria for detennining when Applicant's facility may be re-entered or its operation may be resumed.

4.

Routine Emissions I Applicant has not demonstrated that airborne and waterborne radioactive emissions from routine operations and disposal of solid wastes will be maintained within the limits of 10 CFR Part 20 in that actual and probable violations of these regulatory limits have taken place on the occasions listed below and Applicant's radiation nonitoring methods and corrective actions are inadequate to detect and prevent their recurrence.

I

ATTACHfENT A.

1) Applicant's equipment, methods, and reporting system for measuring I

releases into the Montgomery County sanitary sewerage system and at its perimeter and offsite monitoring stations do not provide reasonable assurance that violations of regulatory limits have in all instances been or will be detected.

Environmental monitoring is inadequate to determine radiation doses to the public due to inhalation or ingestion because:

a) film dosimetry detects only external ganma radiation, b) the particulate radioactivity monitor for airborne effluents (i.e. a pancake-probe C-M counter) is not isokinetic, and therefore cannot be used for meaningful evaluations.

Applicant's only other stack effluent monitoring system, the radioactive gas monitor, is likewise not reliable for particulate sampling.

(See, Environmental Release Report issued 12/14/71, covering period 1/1/70 - 9/30/71, and Inspection Report No. 50-170/77-01-03.)

c)

Applicant was cited by the NRC for a violation of environmental sampling and analysis procedures. The Violation Notice of Gross Beta Effluent Analysis, based on an NRC Inspection conducted January 12-14, 1977, cited Applicant for calculational omissions, methods for preparing and analyzing samples, and instrumentation used.

The gross beta measure-ments were made without the use of a beta self-absorption correction in the l

presence of significant amounts of suspended solid material.

(seeNRC i

l Inspection Reports No. 50-170/77-01-02 and 50-170/77-01-03.) Moreover, l

l Applicant's " Environmental Sampling and Analysis" program does not provide adequate information on how quarterly environmental samples of water, soil i

4

ATTACHMENT A I and vegetatio,3,are prepared and analyzed, nor does it provide the raw data

']

collected over the past ten years.

d) The " concentric cylinder set model" used by Applicant to derive its dose assessnents to the environment, and from which it concludes its effluents are within regulatory linits, is an unrealistic nodel.

2) An NRC inspection conducted January 10-12, 1979 revealed that, contrary to Applicant's Technical Specifications governing discharge of airborne radionuclides, Argon-41 and other radionuclides were discharged at ground level outside the reactor building for several nonths through a leak in the ventilation exhaust stack drain line (see NRC Inspection Report No. 50-170/79-01).

It is highly probable that this resulted in releases in excess of the maximum permissible concentrations set forth at 10 CFR Part 20, Appendix B.

3) Applicant's Airborne Release Reports for 1962, 1963, and 1964 and AEC Inspection Reports for the same years (Docket No. 50-170) reveal that releases of Argon-41 from Applicant's stack exceeded the maximum permissible concentration for unrestricted areas listed at 10 CFR Part 20, Appendix B, during those years.

(Also see letter fran AEC to National Naval Medical Center (NNMC) dated October 6,1961. Docket No. 50-170).

4) Applicant's Environnental Release Data and Perimeter Monitoring Reports, Docket No. 50-170 (5/27/66 report and 9/20/66 report), show that emissions from the AFRRI facility in 1962 and 1963 resulted in annual whole body doses in unrestricted areas in excess of the NRC's regulatory limit of 0.5 rem.

t

ATTACHt!ENT A..

5.a._ NEPA I The NRC Staff has not prepared an environmental impact statement (EIS) addressing the proposed licensing action.

In view of the foregoing contentions which, in their sun, establish that enissions from routine operations and postulated accidents at the AFRRI facility present a significant threat to the public health and safety, Petitioner contends that the proposed licensing action is a major Federal action with significant environmental effects.

As such, NEPA requires preparation of a site-specific EIS.

6.

NEPA II The NRC Staff's environmental impact appraisal does not adequately consider the impacts associated with operating the AFRRI facility for another twenty years, nor does it adequately consider alternatives to re-licensing the facility, including the no-action alternative, relocating the reactor, or doing the research at other reactors as required by 10 CFR Part 51.

}l L

I ATTACHMENT B x-UNSTIPULATED CONTENTIONS 1.

Accidents I The analysis of the loss of coolant accident (LOCA) and the two design basis accidents (DBAs) within Applicant's Hazard Summary Report (HSR) is fa91ty in that:

1)

It erroneously concludra that in event of an accident described therein as " Loss of Shielding and Cooling Water", air convection cooling would be sufficient to prevent cladding failure and significant fission product release.

Petitioner contends that in the event of a rapid loss of coolant while the reactor core is in the pulse mode, there could be a sudden temperature elevation sufficient to cause multiple cladding failures and fission product releases in excess of the limits provided in 10 CFR Part 20;

2) Both of the DBA analyses in the HSR (" Fuel Element Drop Accident" and " Fuel Element Clad Failure Accident") erroneously consider only those radiation doses to humans that would result from submersion exposure to the noble gases released.

Petitioner contends that if such accidents were to occur, indivudals would receive additional exposure due to internal emissions of the noble gases, sustaining injuries far greater than those predicted in the HSR; i

f

ATTACHMENT B 2.

Accidents II Accidents can be expected to occur at the AFRRI reactor of a different kind and greater severity than those described in the HSR.

Such accidents would result in significant offsite releases and include:

1)

Failure of the N-16 diffuser system.

Petitioner contends that in the event of such failure, N-16 bubble would accumulate along the surface of the fuel element cladding causing: a) insulation of the fuel elements from the water coolant resulting in rapid temperature elevation of the elements and possible multiple clad failures, and loss of water shielding; and b) production and release of the gaseous radionuclide N-16 with its powerful gamma ray.

2) Two maximum credible accidents (MCAs) beyond the design basis of the reactor (Class 9 accidents):

a) power excursion accident (PEA) resulting in multiple cladding failures at an elevated temperature with reduction in the thermalizing effect of hydrogen, followed by an explosive zirconium-steam interaction; and b) LOCA resulting in multiple cladding failures at an elevated temperature, followed by an explosive zirconium-air interaction.

3.

Testing Facility Petitioner contends that the AFRRI facility is a testing facility l

within the meaning of 6 31.a(3) and 5104(c) of the Atomic Energy Act of 1954, as amended, and } 50.21(c) and 9 50.2(r) of 10 CFR Part 50.

[ AFFIDAVIT TO BE SUBf1ITTED AT THE TIf1E OF FILING 0F STATEftENTS OF POSITION]

ATTACHMENT B 4.

Siting 1

Applicant has failed to demonstrate that the AFRRI facility satisfies the siting criteria set forth at 10 CFR Part 100.

Petitioner contends the AFRRI reactor falls within the scope of Part 100 siting criteria either as a testing reactor or a research reactor and cites for the latter case the Memorandum from Vollmer (Director, Division of Engineering, NRR), to Eisenhut (Director, Division of Licensing, NRR).

Petitioner contends tnat because of the density and residential nature of the population in the plume exposure EPZ, the inadequacy and inaccessi-bility of highways, the inadequacy of Applicant's Emergency Plan, and meteorological, geological and hydrological conditions of the area surrounding the facility, Applicant cannot provide reasonable assurance that Part 100 offsite dose limits would not be exceeded in the event of a maximum credible accident.

5.

Routine Emissions I Applicant has not demonstrated that airborne and waterborne radioactive emissions from routine operations and disposal of solid wastes will be maintained within the limits of 10 CFR Part 20 in that actual and probable l

violations of these regulatory limits have taken place on the occasions l

listed below and Applicant's radiation monitoring methods and corrective 1

l actions are inadequate to detect and prevent their recurrence.

1) The data cited in 4) of the stipulated contention (Routine Emis-i sions I) and Applicant's written response to Petitioner's question submitted i

in the winter of 1979, "[w] hat is the highest total exposure measures over l

l

ATTACHMENT B I the year at any one of the reactor environmental monitoring stations, for l

the[ years 1975-1979]", demonstrate that releases measured at these stations from 1962 through 1965,1978 and 1979 resulted in average annual whole body doses to members of the public in excess of EPA's limit of 25 mrem.

2) Applicant's incineration at NNMC of 160 boxes of contaminated solid waste, cited in NRC Inspection Reports for 1975-1976 Docket flo. 50-170, resulted in the release of radioactive gases and particulates in excess of the limits set forth at 10 CFR Part 20. Appendix C.
3) Since Applicant's Environmental Impact Appraisal (EIA), submitted in conjunction with its license renewal application, admits that the 4

highest average unrestricted area exposure rate from airborne releases (set f

forth in the EIA) extends to residential areas, it is highly probable that such exposures have resulted and continue to result in doses to the public in excess of 0.5 rem and, violate the principle that emissions from Applicant's operation be kept as low as is reasonably achievable (the ALARA principle).

4) Applicant's Environmental Release Report, issued 12/14/71, indicate that between 1/1/70 and 7/1/71 exposure rates in several unrestricted areas

{

were as high as 1-5 mrad /hr.

At this rate, any person who lived or worked in these areas 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in a year, or about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> a week, would receive i

i an annual whole body dose in excess of the NRC's limit of 0.5 rem /yr.

Since 50-60% of the area within a one mile radius of the AFRRI stack is residential, it is highly probable that the population dose limit was exceeded during this period. This is a violation of the ALARA principle.

ATTACHtiENT B !

6.

Routine Emissions II 10 CFR Part 20 limits are inadequate to protect the health and safety of the population in the vicinity of the AFRRI reactor.

This proceeding presents "special circumstances" within the meaning of 10 CFR $ 2.758 that warrant the Board's consideration of whether the offsite air-and waterborne release limits set forth a'.10 CFR Part 20 and Appendices B and C thereto are adequate to protect the public health and sa fe ty.

[ AFFIDAVIT TO BE SUBrilTTED AT TIME OF FILING 0F STATEMENT OF POSITION]

7.

Security Neither the Physical Security Plan for the facility nor Applicant's history of security violations and substandard management and operating procedures demonstrate that the controlled access areas can be protected from sabotage or diversion of special nuclear naterial according to the standards set forth at 10 CFR Part 73.

The Draft Audit Report of the AFRRI facility prepared by the Defense Audit Service in 1979 cites frequent instances of security and management violations, including:

1) Eighteen activations of the facility alarm system during a 34-day period, caused by personnel leaving work after normal duty hours from unauthorized exits.

Auditors were told by AFRRI security personnel and other AFRRI officials that investigations were not made of the activations f

1 ATTACHMENT B and that not enough security people were on duty to investigate each time the alarm went off;

2) unauthorized people entering the facility by following employees in who used their magnetic cards to unlock the door; 1

3) failure to escort visitors attending weekly seminars and provide them with dosimeters; 4) failure of employees entering and exiting the building after hours to sign a log showing their time of arrival and departure; 5) violations of Applicant's accounting and dispensing procedures for controlled substances such as narcotics.

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Document Comments:

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4 AFRRI STIPUL, ATTACH A ANNIEM i

Requestor's.ID:

ANNIEM i

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UNITED ST ATES OF A.MERIC A NUCLEAR REGULATORY COP. MISSION EEFORE THE ATOMIC SAFETY AND LICENSING ECcRD In the Hatter of

)

)

Docket No. 50-170 M!'ED FORCES RAD 10E10 LOGY RESEARCH

)

INSTITUTE

)

(Renewal of facility

)

License No. R-84)

(;RIGt-Type Research Reactor)

)

s CERTIFICATE OF SERV!CE 1 bcreby certify that copies of "ST]PULATION" in the above-captioned proceeding h:,ve bten served on the following by deposit in the United States mail, fit st class, or, as indicated by an asterisk, through dcposit in the I:uclear Regula-tory Co mission's internal mail system, this 1st day of April, 1981:

Lo.,is J. Carter, Esq., Chairman Elizabeth B. Entwisle, Esq.

Ad-inistrative Judge 8118 Hartford Aver.ue Ato-ic Safety and Licer. sing Scard Silver Spring, MD 20910 23 Wiltshire Road Fniladelphia, PA 19151 Atomic Safety and Licensing Board Panel

  • Mr. Ernest E. Hill U.S. Nuclear Regulatory Ccm ission Ad-ir.istrative Judge L'ashington, DC 20555 Law ence Lisemore Laboratory Ur.isersity of California Atomic Safety and Licensing Appeal P.O. Sex SOS, L-123 Panel (5)*

Lis emore, CA 945E0 U.S. Nuclear Regulatory Co cission 1.'ashington, DC 20555 Pr. David R. Schink Ad:-inistrath e Judge Docketing and Service Section (7)*

Departrent of Oceanography Office of the Secretary Texas A&M University U.S. Nuclear Regulatory Cox.issior.

College Station, TX 77840 Washington, DC 20555 Robert L. Brittigan, Esg.

General Counsel Ocfense Nuc1' ear Agency 1sshington, DC 20305 u

Richard G. Bachmann

-~

Counsel for NRC Staff

-

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