ML20077C117
| ML20077C117 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 10/26/1994 |
| From: | Carroll G GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20077C101 | List: |
| References | |
| REN, NUDOCS 9411300335 | |
| Download: ML20077C117 (8) | |
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l Docket No. 50-160 '94 !10V'-2 M 21
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GEORGIANS AGAINST NUCLEAR ENERGY PETITION FOR LEA O INTERVENE IN CONSIDERATION OF APPLICATION FOR RENEWAL OF FACILIT LICENSE Georgians Against Nuclear Energy (GANE) respectfully petitions the Nuclear Regulatory Commission for intervenor status in the consideration of Georgia Institute of Technology's request to renew Facility License No..R-97 to operate the Neely Research Reactor on Georgia Tech campus in downtown Atlanta. We request that a public hearing be held concerning the license renewal. (Docket No. 50-160 License Renewal Application dated April 19, 1994, Federal Register Notice September 26, 1994, page 49088.)
GANE feels that the Neely Research Reactor on Georgia Tech campus has a history of poor management and lack of utility. We state that the continued operation of this unnecessary reactor in the heart of Atlanta (population 2,000,000) is impermissible by Commission standards. The Commission's mission is to protect human health, life and property by enforced regulation of its licensees. To allow this 5Mw reactor to continue to operate violates your mission.
We state that the needs of humanity and the nuclear industry at this time are not to educate another generation of nuclear operators, but to take up the task of finishing nuclear technology. It has been fifty years since nuclear energy exploded upon this planet at Hiroshima -
GANE feels that it is time to face our nuclear waste dilemma. We encourage Georgia Tech to provide leadership by closing the Neely Reactor and focusing its efforts in the areas of nuclear waste research and decommissioning of nuclear facilities. He envision the research reactor on Georgia Tech campus being used for the good of 1 humanity to help solve the decommissioning dilemma.
Our concerns that the Neely Reactor is unsafe are myriad:
SINKHOLES In June 1993 a major, 100-year-old Atlanta sewer line that runs under Georgia Tech campus 1/4-mile from the reactor building suffered a catastrophic collapse, swallowing two people to their death along with two automobiles. This Orme Street Line has persistently caused flooding of many structures on Georgia Tech campus. The 1993 incident made national headlines and prompted the Commission to request a long-
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overdue site characterization study of the reactor site. A publicly available geologic survey shcws the reactor to be sited atop the Wahoo Creek Formation, a slabby, viscous and muddy medium-grained muscovite plagioclase gneiss which tends to break across oblique planes. This is not the aolid bedrock formation that the reactor's management assumes.
INSTABILITY OF FOUNDATION The stability of the foundation of the reactor building is in question because of an underground water flume directly below the reactor.
Witnesses remember a sinkhole swallowing a man adjacent to the reactor building 20 years ago. The fact that Georgia Tech has no documentation of this event is negligent.
PHYS., AL PIANT DEGRADATION A very large crack caused by water damage is visible in the viewing room to the reactor room. The reactor, a few yards from the damaged wall suffers the same structural stresses from foundation shifting due to underground hydrologic activity.
INSUFFICIENT MONITORING Georgia's Environmental Protection Division is charged with monitoring the facility. This data is used, presumably, by the Commission to establish whether operations at the Georgia Tech reactor are in compliance with regulations. The EPD reports are inadequate in several respects. No air monitoring has been performed around the facility.
Some isotopes are monitored for effluent discharge to city sewers and deposition around the site. Many isotopes are unmonitored altogether. )
Among the isotopes that are monitored, levels above the legal limits have been recorded to have been released to the environment throughout the years. It appears that neither Georgia EPD or the Commission have enforced either state or federal regulations for the Georgia Tech research reactor. Further, over the years EPD has shown a consistent pattern of diminishing oversight, dropping whole categories from monitoring. The weak monitoring and reporting effort culminates in EPD's not even publishing the annual reports since 1989. Apparently, i the Commission has not noticed the lack of availability of this important safety data.
CONTAMINATED SEWERS Several large U.S. cities, notably Albuquerque, New Mexico, have discovered extensive radioactive contamination to their sewer systems L
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. following their use by licensed handlers of radioactive materials.
Since waste water is treated and returned to the environment for re-use in our city, this is a problem that cannot be ignored. The unforeseen expense to affected cities has been tremendous and burdensome, and GANE seeks to prevent such contamination here, if it is not too late already as EPD has allowed excessive contamination to pass unregarded.
. CRITICALITY ACCIDENT There is enough fissionable material present in the reactor core that a criticality accident may occur. The reactor has no containment structure. The steam explosion that would follow a partial fuel melt would distribute the reactor core's fission-product inventory, several million curies of highly radioactive isotopes, over a six-mile radius of the reactor. This poses a grave health threat to residents and visitors in Atlanta, threatens the lives of emergency personnel and campus residents and would ruin billions of dollars wortii of real estate in the surrounding crowded business district of Atlanta.
Obvious scenarios that may lead to a criticality accident include the control rods being removed too fast or hanging-up and flow blockage from debris (or inadequate coolant for any reason).
YHLNERABLA WATER SUPPLY The Hemphill Reservoir, which supplie s drinking water for the greater Atla ' area, is within a mile of the facility. Rapidly growing popt 2 tion und deteriorating infrastructure have combined to cause a chronic watnr shortage in the Atlanta. region. The contamination of the Hemphill Reservoir following an accidintal release from the Georgia Tech researct reactor would greatly enacerbate the problem.
COBALT-60 Adjacent to tLe reactor, 400,000 curies of cobalt-60 is stored, shielded by 30 feet of water. A breach to the shielding pool, caused by a steam exp?osion in the reactor, leaving this highly active i
material completely unshielded would yield 480 million roentgen per i
hour exposure to emergency personnel attempting to deal with the l catastrophe. The highest count registered in the containment building (
following the meltdown at Three Mile Islanc in 1978 was 30,000 roentgen per hour.
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THREAT OF TERRORISM The. presence of the Olympics in Atlanta in 1996 creates a specific situation which has historically attracted terrorist activity and threats. The reactor uses highly enriched uranium as fuel. During refueling this bomb-grade uranium fuel is a tempting target for terrorists. The presence of fissionable and highly radioactive fission byproducts at the reactor, make the reactor not only a tempting target for theft of bomb-grade or hazardous materials, but a target for a World Trade Center-type bombing which would noc only injure residents and visitors to Atlanta, but create an international diplomatic disaster for the United States.
LACK OF SECURITY Reactor security is grossly inadequate. The reactor building may be accessed directly from the outside, no personnel are assigned to the building outside of normal business hours. Essentially, the entire security system consists of a chain-line fence with some barbed wire on top. Wire-cutters would be sufficient to breach the fence.
INADEOUATE EMERGENCY RESPONSE PLAN The emergency response plan for the Neely reactor is uncoordinated and unknown to local and state authorities. Georgia Tech considers an accident scenario not credible and has plans only to evacuate the reactor building in the event of an accident. A campus-wide evacuation drill has never been held. There are no provisions to alert City of Atlanta or State of Georgia authorities and these authorities have no plans of their own concerning an emergency at the reactor.
FIRE HAZARD Georgia Tech's Fire Safety Department has no jurisdiction over the reactor. They have no knowledge of the nature of materials and operations of the facility, or of evacuation plans or emergency response plans. The department is of the opinion that the Commission is responsible.
MANAGEMENT PRO BTIMS
- Safety concerns at the Georgia Tech reactor are the sole responsibility of Dr. R.A. Karam. Since he has been quoted publicly as not believing an accident is possible, the entire operation has an obvious cultural bias against emergency preparedness.
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- The reactor was shut by the Commission for several years in the late 1980s for safety reasons resulting from poor management. The same management is presently in place.
GEORGIA TECH UNWILLING TO PAY LICENSE FEE Georgia Tech claims it cannot afford its yearly $60,000 fee to sustain a license from the Commission and has asked for a waiver. This underscores the fact that the reactor is a financial burden to the university. We do not see the right in shifting the financial responsibility for a risky activity that demands regulation from the entity petitioning to continue operations.
Respectfully submitted,
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)/fA/V) lenn Carroll Representative for GANE Dated and signed October 26, 1994 in Decatur, Georgia Copies to:
Secretary of the Commission U.S. Nuclear Regulatory Commission Docketing and Service Branch Washington, DC 20555 Ofiice of the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Randy A. Nordin Manager - Legal Division Office of Contract Administration Georgia Tech Atlanta, GA 30332-0420 GANE Addresses:
Georgians Against Nuclear Energy P.O. Box 8574 Atlanta, GA 30306 )
Glenn Carroll J GANE 139 Kings flighway Decatur, GA 30930 l I
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4 Federal Ragister / Vol. 50, No.185 / Monday, September 26, 1994 / Nodoas
_9068 2:00 PM-J 00PM:E2actlan ofNew the time to be sat aside far this purpose
. integrity. Representatives of the industry will partidpate,as appmpdate ACRS Members fCpen/ Closed) may be oblatned by mniading the 2:30 PM-5:00 P.M : Meeting With the The Comahtee will dum AM Mtive MwQo dna
- PosenbGity die Duvctor,Qfficefor Analysisand' qnsillicatir.as of canA1Am nominated [ law **0*0* **1 Evaluation of OperutionalIkta(AEOD) for appotatment to the ACRS. adjusted by the Chamnaa as ==nasaary (Open) A portion of this session will be to facilitale the enaarf o(the meeting, closed to discuss matters the release of Persons planning to arsand al-Id chedt The Committee will rnest with the which would c astitute a clcarJy Diredor of AEOD to discuss items of g
"" warranted invasion of personal mutualinte est, including the NRC TechnicalTraining Peegram. Pdvacy.
3:15 PM-4:15 PM: Stmtgic Planning . I have delanmined in acoonianos with Friday, October 7,1994 (Open) Subsection 10(d) P.L.32-483 that it is
. 8:30 AM-8:35 4M.:Open1rg Remm*s %e Committee will hold strategm necassary to does pations of this bythe ACBS Charimon (Open) planning discussions related to its meeti g noted above to discuss
%e Acts Chairunan wiH make future activities. hdormation that involves the internal opening vernarks mgarding moduct of personnel rules and practices of this 4:15 P.M.-6:30 P.M.: Prepomtion of advisory Committee per 5 U.S.C.
the meeting ACRS Reports (Open) 552(c)(2); and to discuss information the gf y f [ O enjP
%e Committee will discuss proposed release of which would constitute a ACRS reports on matters considered deeriy unwarranted invasion of
%e Committee will hear during this meeting. personal privacy per 5 U.S.C. 552b(c)(6).
presentations by and hold discussions Further infonnetion reganiing topics with representatives of the NRC staff Saturday, October 8,1994 to be discussed, whether the meeting regarding the rod mntred system single 8:30 A.M.-11:00 A.M.:Prepamflon of has been canceled or rescheduled, the failure event at Salem Unit 2, the ACRS Reports (Open) Chairman's ruling on requests for the findings of the Augmented Inspection resent oral statements
%e Committee will continue .ts i opportunity and the time to al fotted therefor can be Team (AIT), liconese responses to Generic Letter 93-04, and the staffs discussion o posed ACRS reports m obtained by enatadirig the ACRS actions. ReprHSentatives of the industry matters cousi ernd during this meeting. Executhre IXredor, Dr. John T. Larkins will participate,as appmpriata. 11:25 A.M.-11:45 A.M.:New Research (telephone 301-415-7361), between Needs (Open) 7:30 A.M. and 4:15 PM EST.
10:00 AM-11:30 AM:IPEInsights Pmgram (Open) The Cornmittee will discuss new Dated: September 20,1994. ,
remrch needs,if any, identified during Andrew 1 Batu, (
he Committee will hear presentations by and hold discussions this metmg. Advisory comminee Monog-ment oyicer. I (FR Doc. 94-23755 l'Hed 9-2344; BM5 aml with mpnysentatives of the NRC staff 11:45 A.M.-12:00 Noon: Miscellaneous regarding the IPE Insights Program. (Open) auseo caos me-eus 11:30 AM-12:15 FMiReport of the The rammittee will discuss P&PSubcommittee (Open/ Closed) miscellaneous mattars related to the [ Docket No. 60-14Gl c nduct of Commutee activitis and The Committee willbear a report of the Planning and Procedures c mplete discussions of topics that wem Consideration of WTh%*-
Applicatfort for Subconsmittee on mattens related to the n t c mpleted during previous meetings gg ,
conduct of ACRS Imsiness and intamal as time end availability of information a,4ond and eS matters Permit. The United States N=ria=r Regulatory r Eing to the A mmbars. Procedures for the conduct of and Commission (the Commission)'is A portfon of this session may be participation in ACRS meetings were considering renewal of Fadlity License closed to discuss matters that relate Publisbod in the Federal Register on No. R-07, issued to the Coorgia Institute solely to infernal pemounel rules and 1993 (58 FR Sit tB). In of Technology (Goorgia Tech or the practices of this Advisory Committee, Septembw andance wi30;th these procedures, oral for operstkm of the Georgia licensee) and matters tim nAmese of which would a wrinen statents may be pmented Tech Rasasch n an,nocated on the constitute a clearly unwarranted my members,of the public, electronic Georgia Tech campus (a (he city of invasion of personal privacy. recordings will be penmtted only Atlanta FuhonCounty, Georgia, during the open portions of the meeting, The renewal would extend the 1:15 PM-1:45 P.M.: Future ACRS and estions may be asked only my expiration date of Facility Urma No.
Activities (Opent met of the Committee,its R47 for twenty yests froan date of
%e Cormnittee will discuss topics consultants, and staff.1%rsons desiring issuana.in accordance with the proposed for consideration during to make oral statemente should notify licensee's timely application for mnewal future ACRS meetings. the ACRS Executive Directar, Dr. John dated April 19,1994.
. T. Larkins, at least frve days before the Prior to a duisinn to renew the 1:45 P.M.-2:00 P.M.: Reconciliation of meeting if possible, so that appropriate license, the Cn-W will hava made ACBS Comtnents and arrangements can be made to allow the fmdings required by the Atamic Energy Recommendations (OpenJ necessary tinw during the meeting for Act of 1954, as amandad (the Act), and The Committee will discuss responses such statements. Use of still, roothm the Comm1cann's regulations.
from the NRC Executive Director for picture, and television cameras during Within thirty d,ays of publication of Operations to ACRS comments and this meeting may be limited to selected this notice, the licensee may file a -
recommendations included in recent portions of the meeting as determined request for a hearing with respect to ACRS reports. by the Chairman. Information regarding renewal of the subject facility license l
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' Federal Register / Vol. 59, No.185 / Monday, September 26, 1994 / Notices 49089
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. and any person whose interest may be fact to be raised or controverted. In Nontiruely filings of petitions for i affected by this proceeding and who addition, the petitioner shall provide a leave to intervene, amended petitions, wishes to participate as a party in the brief explanation of the bases of the supplemental petitions and/or re. quests proceeding must file a written request contention and a concise statement of for hearing will not be entertained for a hearing and a petition for leave to the alleged facts or expert opinion absent a determination by the intervene. Requests for a hearing and a which support the contention and on Commission, the presiding officer or the petition for leave to intervene shall be which the petitioner intends to rely in presiding Atomic Safety and Licensing filed in accordance with the proving the contention at the hearing. Board that the petition and/or request Commission's " Rules of Practice for The petitioner must also provide should be granted based upon a Damestic Licensing Proceedings" in 10 references to those specific sources and balancing of factors specified in 10 CFR CFR Pan 2. Interosted persons should documents of which the petitioner is consult a current copy of10 CFR 2.714 2.714(a)(1) (i)-(v) and 2.714(d).
awaro and on which the petitioner For further details with respect to this which is available at the Commission's intends to rely to establish those facts or action, see the application for renewal Public Document room, the Gelman expen opinion and the petitioner must 1
Building,2120 L Street NW., dated April 19,1994, which is available l provide sufficient information to show for public inspection at the Washington, DC 20037. If a request for that a genuine dispute exists with the Commission's Public Document Room j a hearing or petition for leave to applicant on a material issue oflaw or at 2120 L Street NW., Washington, DC intervene is filed within the time fact. Contentions shall be limited to 20555.
prescribed above, the Commission or an matters within the scope of the j Atomic Safety and Licensing Board, Dated at Rockville, Maryland, this 19th day amendment under consideration. The of September 1994.
designated by the Commission or by the contention must be one which, if Chairman of the Atomic Safet and For the Nuclear Reguiatory Commission.
proven, would entitle the petitioner to L,icensing Board Panel, will le on the relief. A petitioner who fails to file such S'7 " *"# E * '.88*
n*]uest and/or petition and the a supplement which satisfies these Director, Non-Power Reactors and j
t Secretary or the designated Atomic requirements with respect to at least one "
Safety and Licensing Board willissue a contention will not be permitted t 0 tu cr S ppoIt, Office notice of hearing or an appropriate participato as a party. ofNuclear Reactornegulation.
order. Those permitted to m. tervene become ( R Doc. 94-23756 Filed 9-23-94; 8:45 am]
As ronired by 10 CFR 2.7 t 4, a parties to the proceeding, subject to any suo coos 7ses-os-a petition for leave to intervene shallset limitations in the order granting leave to forth with particularity the interest of intervene, and have the pportunity to the petitioner in the proceeding, and [ Docket Nos. 50-352 and 50,353]
participate fully in the conduct of the how that interest may be affected by the hearing, including the opportunity to Philadelphia Electric Company; ,
results of the proceeding. The petition present evidence and cross-examine Consideration of lasuance of '
should specifically explain the reasons witnesses. Amendment to Facility Operating wh intervention should be permitted A request for a hearing or a petition License and Opportunity for a Headng wit i particular refemnce to the for leave to intervene must be filed with following factors: Secretary of the Commission, U.S. The U.S. Nuclear Regulatory !'
(1) The nature of the petitioner's right Nuclear Regulatory Commission, Commission (the Commission)is l undee the Act to be made a party to the Washington, D.C. 20555, Attention: considming issuance of amendments to proceeding; Facility Operating License Nos. NFP-39
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Docketing and Service Branch, or may !
(2) *Ite nature and extent of the be delivered to the Commission's Public and NPF-65, issued to Philadelphia !
petitioner's property, financial, or other Document Room, the Gelman Building. Electric Company (the licensee), for '
interest in the proceeding; and 2120 L Street NW., Washington, DC operation of the Limerick Cenerating (3) The possible effect of any order within the time prescribed above. Station, Units 1 and 2, located in which may be entered in the proceeding Where petitions are flied during the last Montgomery County, Pennsylvania.
on the petitioner's interest. The petition ten (10) days of the notice period,it is The proposed amendment would j should also identify the specific requested that the petitioner promptly revise the Technical Specifications to aspectts)of the matter of the j so inform the Commission by a toll free Permit an increase in the allowable !eak 1 promeding as to w ich petitioner telephone call to Western Union at 1- rate for the main steam isolation vah'es !
wisha6 to intervene. Any person who (MSIVs), and delete the MSIV Leakage (800) 325- 6000 (in Missouri 1.-@00) !
has filed a petition for leave to intervene 342-6700). The Western Union operator Control System (ILS). The main steam I or who has been admitted as a party ' should be given Daiagram Identification drain lines and the main condenser may amend the petition without Number 3737 and the following message would be utilized as an altemate MSIV requesting leave of the Board up to addressed to Seymour H. Weiss: leakage truatment system.
fifteen (15) days prior to the first petitioner's name and telephone Before issuance of the proposed ;
prehering conference scheduled in the number; date petition was mailed; license amendment, the Commission i proceding, but such an amended Georgia Institute of Technology; and will have made findings required by the j petition must satisfy the specificity publication date and page number of Atomic Fnergy Act of 1954, as amended requirements described above. this Federal Register notice. A copy of l (the Act) and the Commission's i Not later than fifteen (15) days prior the petition should also be sent to the regulations.
to the first prehearing conference Office of the General Counsel, U.S. By October 26,1994, the licensee may scheduled in the proceeding, a Nuclear Regulatory Commission, file a request for a hearing with respect petitioner shall file a supplement to the Washington, DC 20555, and to Mr. to issuance of the amendment to the petition to intervene which must Randy A. Nordin, Manager Legal subject facility operating license and include a list of the contentions which Division Office of Contract any person whose interest may be are sought to be litigated in the matter. Administration, Georgia Tech, Atlanta, affected by this proceeding and who Each contention must consist of a CA 30332-0420, attorney for the wishes to participate as a party in the specific statement of the issue of law or licensee.
proceeding must file a written mquest
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