ML20080G790
| ML20080G790 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 01/25/1995 |
| From: | Nordin R Neely Research Reactor, ATLANTA, GA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#195-16302 95-704-01-REN, 95-704-1-REN, REN, NUDOCS 9502090066 | |
| Download: ML20080G790 (34) | |
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.e UNITED STATE 9 OF AMERICA - -
NUCLEAR REGULATOhY COMMISSION 55 FE9 ^ PJ 1 4 ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: g[t 00 %
Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam f
In the Matter of ) Docket No. 50-160-Ren
)
GEORGIA IMSTITUTE OF )
TECutiOLOGY, )
Atlanta, Georgia ) ASLBP No. 95-704-01-Ren
)
Georgia Tech Research Reactor )
)
(Renewal of Facility License ) ,
No. R-97) ) January 25, 1995 i 3EORGIA INSTITUTE OF TECH 57 LOGY'S OPPOSITION TO PETI'fION FOR LEAVE TO INTERVENE
' i F.7 LED BY_ GEORGIANS AGAINST NUCLEAR ENERGY Procedural History The Georgia Institutic of Technology (Applicant or Georgia Tech) submite T,his Opposition to the Petition to Intervene 3 origina?.ly filed by Georgians Against Nuclear Energy (GANE) on October 26, 1994. l This is a proceeding to renew Facility License No. R-97 for the Georgia Tech Resecrch Reactor (GTRR or Reactor) , which ;
r is located on th. campus of Georgia Tech in Atlanta, Georgia. :
i Georgia fech timely filed its renewal application dated April !
19, 1994, and the Commission published notice of the r
application at 59 Fed. Reg. 49088 (Sept. 26, 1994).
9502090066 950125 PDR ADOCK 05000160 0 PDR
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i On November 1J, 1994, the Chief Administrative Judge escablished this Board pursuant to GANE's request for a hearing. The Board entered a Memorandum & Order on November !
I 23,'1994, in which it found that GANE had failed to show !
standing and noted that a research reactor (such as GTRR) f might be subject to different standing criteria than a power j reactor. The Board allowed GANE until December 30, 1994 in which to amend its petition "to enhance its statement of standing, as well as file a supplement... setting forth the i
contentions it wishes to assert in this proceeding." ;
Memorandum & Order at 6 (Nov. 23, 1994). !
l GANE timely filed an Amended Petition. Following a
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telephone conference on January 10, 1995, the Board entered a [
Memorandum & Order on January 11, 1995, in which the Board i i i permitted GANE to once again attempt to show that it has ;
standing, and allowed it until January 13 to do so. In response, GANE filed a supplemental affidavit of Mr. Robert Johnson. .
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Summary of Arcument ;
i-GANE lacks standing in this proceeding because the Safety !
t Analysis Report (SAR) demonstrates that even the worst credible accident in this small, heavy water research reactor ,
would have n2 effects beyond a small radius on the campus of l Georgia Tech. The SAR demonstrates that the e would be no I
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health or safety effects off the Ceorgia Tech campus. GANE's single affidavit of membership, from Mr. Robert Johnson, shows that he resides several miles from the Georgia Tech campus, and his place of work is also outside the campus. Mr.
Johnson's asserted interests in this proceeding are his health and safety; he asserts no other form of interest.
GANE has made ng contention that Georgia Tech's assumptions in the SAR concerning the worst credible reactor accident are incorrect, and it has made ng contention that the calculations of the radiation effects of that hypothetical accident -- all of which are carefully set out in the SAR --
are incorrect. Given the entire absence of such contentions, ,
Mr. Johnson's health and safety interests are simply not implicated by this proceeding.
Georgia Tech will discuss each of GANE's contentions ,
below in appropriate detail, but twc features of those contentions stand out: First, GANE appears to be unaware that GTRR is a very small, heavy water react.or that operates at low temperatures and pressures. Although Georgia Tech has ,
carefully analyzed the ' worst credible reactor accident' for the GTRR, the plain tact is that this type of heavy water research reactor is inherently safe. In particular, a steam -
bubble within the GTRR containment building, to which GANE repeatedly refers, is not possible with a small, heavy water reactor.
. l Second, GANE repeatedly refers to the lack of monitoring at the GTRR. Since the Commission obviously requires careful monitoring, and tne results of that monitoring are matters of public record, GANE's contentions on this point can be explained only by a failure to consult the relevant public records before filing its petition. .
Thus. Ge:xcla Tech submits that GANE has failed to demonstrato chat it has organizational standing in this proceeding. It also appears that GANE is not in a position to contribute in a meaningful way to the Board's consideration of the renewal application. For these reasons, Georgia Tech requests the Board to deny GANE intervention.
DISCUSSION :
- 1. GANE's Petition and Amended Petition Should Be Denied for Lack of Standing.
The Applicant requests that GANE's Petition for Leave to Intervene and Amended Petitica for Leave to Intervene be denied for lack of standing. Section 18ca (1) of the Atomic Energy Act, 42 U.S.C. Sectior 2239 (a) provides that a hearing shall be granted "upon the request of any person whose interest may be affected by the proceeding..." GANE has
<: .ed to establish that it has any interest that may be affected by the re '. censing of the GTRR. Under 10 CFR
- 2. '14 (d) (1) the Board is to consider the following in ruling
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4 on a petition for leave to intervene:
i) The nature of the petitioner's rights under the Act to be made a party to the proceeding.
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ii) The nature and extent of the petitioner's property, financial or other interest in the proceeding. ,
iii) The possible effect of any order that may be entered in the proceeding on the petitioner's interest.
GANE, in effect, relies on the affidavit of a single member, Robert Johnson, to establish its organizational standing. Mr. Johnson claims that he has a health and safety interest in this license renewal because of the location of his of fice, not his res~idence. While Mr. Johnson's office is approximately one half mile from the GTRR, his residence on Waddell Street (as shown on his GANE membership form) is more ;
than four miles from the GTRR. Even if an office location !
could establish standing -- which Georgia Tech denies --
neither Mr. Johnson's home nor his residence is within the radius that could be affected by the worst credible reactor accident at the GTRR. Thus, GANE cannot have standing in this proceeding based on Mr. Johnson's affidavit, and it has produced no other member as a candidate. l The failure of Mr. Johnson's Affidavits to establish standing results in a failure of GANE to establish standing, i since GANE has not met the requirement that a petitioner show that the proposed action will cause " injury-in-fact" to the
petitioner's interest. e.g. Georcia Power Co. (Vogtle Electric Generating Plant, Units 1 and 2), CLI-93-16, 38 NRC 25, 32 (1993). GANE has failed to meet either requirement ,
under the injury-in-fact test because it has not shown that ,
one of its members would suffer injury as a result of the re-licensing, so that GANE would have " representational" standing, nor has GANE stated in any of its filings any effect up'a n its organizational interests. Houston Lichtina and Power h (South Texas Project Units 1 and 2), ALAB-549, 9 NRC 644, 646-47 (1979), aff'g LDP- 79-10, o NRC 439, 447-48 (A979).
For these reasons, Applicant respectfully requests that GANE's Petitions be denied for lack of standing.
- 2. GANE'S Petition and Amended Petition Should Be Denied
' Because the Contentions Raised by GANE Fail to Meet the Recuirements of 10 CFR 2.714 (b) (2) and 10 CFR 2.714 (d) (2)
The Applicant requests that GANE's Petition for Leave to Intervene and Amended Petition for Leave to Intervene, be ;
i denied for failure to meet NRC requirements relating.to the l t
L contentions raised in the Petitions. GANE f ailed te provide, j as required by 10 CFR 2.714 (b) (2) (ii) , "a concise statement of the alleged facts or expert opinion which support the contention and can which the petitioner intends to rely in ;
proving the contention at the hearing, together with i
references to those specific sources and documents of which the petitioner is aware and on which the petitioner intends to rely to establish those facts or expert opinion." Further, GANE f ailed to provide "suf ficient information. . .to show that a genuine dispute exists with the applicant on a material issue of law or fact...", as required under 10 CFR 2.714 (b) (2) (iii) . I Each of the contentions raised by GANE is addressed by Applicant in more detail below. ,
a) GANE Contends that the GTRR ie Generally Unsafe i Although Georgia Tech's application to renew License #R-97 contains exhaustive information about safety, GANE raises many questions, all of which are addressed in the SAR. Thus, !
the following summary highlights some of the points raised by GANE.
The GTRR is a small research facility licensed by the U.S. Nuclear Regulatory Commission (NRC) to operate at a maximum power level of five (5) megawatts. The GTRR is not a reactor for the generation of electricity. It operates at almost room temperature (maximum temperature at maximum power r
_ 135 F). Most of the time the reactor is operated at a power of one megawatt or less. At this power, the coolant temperature is approximately 80 F. In power reactors, the coolant temperature is greater than 500 F and the pressure in pressurized water reactors is 2200 pounds per square inch.
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'For comparison, the pressure in the GTRR is only 14.7 pounds per square inch. Operating conditions at the GTRR are such that wide margins exist between operating conditions and safety limit boundaries. Instabilities that could initiate transiert conditions cannot occur unless the safety limit ,
boundaries are approached.
In its SAR Applicant has analyzed all credible situations that could drive operating conditions toward safety limit boundaries and initiate instabilities resulting in transients.
The analyses showed that the GTRR design is good enough to (
handle all credible scenarios with no danger to workers or the public. Applicant also performed an analysis beginning with ,
the assumption that the reactor is critical and, without P i
regard to the credibility of such an assumption, Applicant .
then added 1.5% k/k reactivity in one step. This is equivalent to making the reactor prompt critical by a wide margin in order to induce a good size transient. Again, Applicant's analysis .showed that the GTRR can handle this l transient with no danger to the wor):ers or the public. !
Finally, Applicant analyzed a situation that Applicant considers to be incredible and to have an extremely low probability of ever occurring: Applicant assumed that the entire core melted af ter continuous operation at maximum power for a long time; assumed maximum leak rate from the containment building under several adverse weather conditions; i
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l further assumed that noble gas releases are 10nt and iodine l
l releases are 50% when releases from similar type fuel were l
l l measured to be 10% for noble gases a.nd 2% for iodine (see SAR). The results of these analyses are summarized in Appendices B and C of the SAR.
Applicant was extremely conservative in methods used to calculate the results found in Appendices B and C of the SAR.
It should be noted that these extremely conservative methods ignore the reality that the fission product inventory that is currently in the core is approximately 5000 Ci, rather than the more than 60,000 Ci assumed in the calculations. Despite the conservative methods used in the calculations, the consequences of such a scenario, while serious within the 100 meter Emergency Planning Zone (which is contained entirely on the Georgia Tech campus) is not catastrophic for the public nor for the City of Atlanta.
l GANE addresses the population figures for the City of Atlanta in its Petitions. Although the SAR addresses the population figures on page 21 and 26, as taken from the 1990 Census, the actual population figure of the City of Atlanta is irrelevant to these contentions, since any criticality accident would only have implications within a 100 meter i radius of the GTRR. Nevertheless, Applicant's statement that 1
"Approximately 30,000 live within one mile of site", p.2 (SAR), is justified based on 1990 Census data.
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The population of Atlanta that was reported in the SAR on page 17 was in error. A revised SAR, dated Jan. 10, 1995, corrected this and other typographical errors.
As an example of safety problems under this contention, GANE relates a 1972 incident related to the recontainerization ,
of Co . The 1972 incident was not in any way connected with the reactor or its operation. The Co' was brought in by a vendor for reincapsulation under state license. This incident occurred under the watch of staff members who no longer work at the Neely Nuclear Research Center. The discharges of pool water into the sewer system did not at any time exceed the (
limits set under NRC regulations. On the contrary, those discharges, although mistakes, were well within NRC limits by a factor of 100 or more. The table shown in Exhibit 1 to this Response shows some of the results.
There was no evidence whatsoever that a worker contaminated his home and a MARTA bus, as alleged by GANE.
Testin.ony by fellow workers shows that the worker surveyed his home with a Geiger counter and found no contamination.
The charge that the director of the GTRR failed to report the incident to the NRC implies that the incident was of a nature that was required to be reported. The incident, in Applicant's opinion and in the opinion of Paul Fredrickson of the NRC, was not of a level that required reporting under the applicable regulations.
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The reactor was shut down for eight months, not two years, by the then new president of Georgia Tech, not by the NRC, to allow enough time to sort out the issues. The NRC agreed with that decision. These are matters of public ret ord, which GANE could have ascertained, had it attempted to do so.
The charge that there is insufficient monitoring of the ,
GTRR is without merit. The monitoring program is reviewed by the NRC and by state agencies. All releases are well within regulations. The comprehensive radiation monitoring program, which is currently in place at the GTRR, is fully described in the SAR (pp.97-102) and c. overs air and liquid effluents, as well as personnel and environmental monitoring. The existence of and results of the monitoring are matters of public record, which GANE could have ascertained, had it attempted to do so.
GANE charges that the SAR ir grossly deficient by stating that GTRR provides no data on the amount of radiation in curies that is contained within t.he facility. Applicant feels compelled to point out that tha amount of fission products that exists in the core depends on the history of reactor ,
r operation. Currently, the fission product inventory in the core is approximately 5000 curies. This estimate is based on the total dose rate measured at one foot from each fuel element.
As for the remaining information extracted from the SAR, I
l which GANE contends is in error, Applicant states the i
following. The half life of I 222 is indeed 193 hours0.00223 days <br />0.0536 hours <br />3.191138e-4 weeks <br />7.34365e-5 months <br /> and not. l the 1.93 hours0.00108 days <br />0.0258 hours <br />1.537698e-4 weeks <br />3.53865e-5 months <br /> reported on p. 204 of. SAR. This and other typographical errors were corrected in the revised SAR.
Xenon- 137 decays into Cs 227 and not Ce227 The dose exposures were correctly calculated. Daughter products of volarile fission products are included in the calculation, e.g. Sr.90 (SAR, p.196).
b) GANE Contends That the GTRR is Unable to Contain Radiatfgn From the Environment bil issues raised by GANE under this contention have been comprehensively addressed in the SAR. The only exceptions are the 700 mrem / year found near the site boundary and the i scenario of a steam explosion. The scenario of a criticality accident was also analyzed (SAR, pp. 139-144). The probability of a core meltdown was analyzed in Appendices B !
i and C of the SAR. The current fission product inventory is l approximately 5000 Ci. The consequences from this fission product inventory are at least an order of magnitude less than the analysis reported in Appendices B and C.
A steam explosion is not considered credible. The GTRR is operated at low temperatures and pressure. The fuel cannot melt as long as it is covered with heavy water. If the heavy water is lost by some means, and emergency core cooling is not i
available (although two independent redundant sources of emergency coolant are available), the fuel may melt, but it will not produce steam explosions. .
The issue raised by GANE involving the 700 mrem / year present at the site boundary represents a campus-wide radioactive material storage " barn" under state license. It e is not connected with GTRR or its operation in any way. The materials stored at this site are under the auspices of the State of Georgia Environmental Protection Division. The NRC has no regulatory authority over this storage arrangement, and ,
thus, the storage of these materials are irrelevant to this f proceeding. However, it should be noted that measures have :
been instituted such that radioactive waste in the storage
" barn" near the fence is now frequently shipped out to ,
Barnwell, S.C. for disposal . The yearly dose at this location is now normal background. l The charge that a breach to the shielding pool for the Co'" would cause the 400,000 Ci of Co' to yield 480 million Roentgen per hour is not correct. The amount of Co'" at the l
GTRR under state license is only 250,000 Ci. The dose rate from this quantity of Co'" at one foot and with no shield in between is 3.75 million Roentgen per hour. The dose rate at 20 feet, which is the distance to the top of the pool with no water in it, is 9375 Roentgen per hour or 156 Roentgen per minute. Emergency procedures are in place to allow complete 1
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l recovery without harm to personnel or the public. This cobalt-60 is stored at Georgia Tech under license from the State of Georgia and is not part of reactor operations.
c) GANE Contends That the GTRR is Contaminatina the City of Atlanta Sewer System Most of GANE's comments under this contention are directed at the NRC, not at the Applicant. The one comment directed at the Applicant is false. All releases from the GTRR are at least a factor of 100 lower than the limits established by NRC. Furthermore, all radioactive relaases to the sewer by the GTRR are filtered to assure that only soluble radionuclides are released. GANE's remaining comments relating to sewer contamination in places outside of Atlanta are irrelevant to this proceeding.
d) GANE Contends That the GTRR Site is Unsafe Because It Suffers From Unstable Geolooic Conditions t
GANE makes the charge that twenty (20) years ago, a sinkhole swallowed a man adjacent to the GTRR, yet provides no information or facts to support such a charge. Without any indication of the basis of this charge, Applicant is compelled to state that such charge is false and without merit whatsoever, since Applicant is aware of no indication in the public record of any such incident. Applicant has been unable t to locate anyone, who has been at Georgia Tech for more than
twenty (20) years, who claims to know anything about such an incident.
The June, 1993 collapse of the Orme Street sewer line, which is referred to by GANE in its Petition, was more than one-half (1/2) mile f rom the GTRR. The GTRR has been in place for more than thirty (30) years. No evidence of any kind has surfaced that the foundation is unstable or that the structure has moved or shifted in any direction. It is true that the :
collapse of the Orme Street sewer line caused the storm sewer !
to back up in the parking lot of the GTRR. The sewer collapse did not damage the reactor, its structure, or its foundation in any way, shape or form. Mr. Donald P. Alexander, P.E. and Manager, Facilities Engineering, at Georgia Tech recently inspected the GTRR for any cracks due to structural shifting ;
4 over the last thirty (30) years. He concluded that the i building does not have any visible exterior wall cracks or visible wall cracks due to the building shifting or settling.
(See Exhibit 2 attached hereto).
I e) GANE Contends That the GTRR is Unsafe to the Public Because of Inadecuate Security Systems The charge that reactor security is grossly inadequate is without merit. The security system in place is approved by the NRC. Preventing terrorism, during the 1996 Summer Olympic Games or at any other time, is the responsibility of the
United States Government, working with the appropriate local authorities. (Indeed, Congress has already appropriated substantial sums to provide for security during the Olympic Games, and security is a top priority for the 1996 Games.)
Both the regulations, and the relevant case law, show that terrorism is not an admissible contention in a licensing proceeding. 10 C.F.R.S50.13; In re: Northern States Power Co., 5 N.R.C. 11F7 (1977) (consideration need not be given in a licensing ovoceeding to protection of the facility against terroris-a, because applicant may rely on government assistance); In re: Consolidated Edison Co. of New York, Inc. ,
7 A.E.C. 825 (1974) (same) . Georgia Tech submits that no contention relatiing to security or terrorism should be ,
considered in this proceeding. It would be grossly inappropriate to disclose the security plan for the GTRR to the public in this proceeding. Applicant contends that GANE should not be allowed to litigate the security issues and that this contention should not be admitted for any consideration by the Board.
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f) GANE Contends that the GTRR is Unsafe to the Public Because It Has Not Been and Is Not Now Beina Monitored Adecuately The monitoring program at the GTRR is in accordance with NRC's regulations and requirements under the terms of the GTRR
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license. The monitoring program also meets all state regulations. All releases are well within the legal limits.
The SAR describes fully the monitoring program. Annual reports to the NRC document that all releases are I
significantly below technical specifications limits. The charge that "no air monitoring has been performed around the facility" is false. The air that is exhausted through the stack is monitored continuously for any radioactivity before it is discharged. The monitoring covers any gas such as argon-41 or tritium, or vapor such as iodine or tritium oxide, or particulates such as powder or fine particles. All liquid releases are monitored before release.
Any concerns that GANE has with the state monitoring program should be addressed directly to the state and are not i
relevant to this proceeding. Notwithstanding their irrelevancy, Applicant feels compelled to point out that contrary to GANE's allegation, the Department of Natural Resources of the State of Georgia does not use the GTRR and, thus, there is no " hint of conflict of interest" in the State's monitoring of the GTRR.
g) GANE Contends That the GTRR is Not Safe Because It Does Not Have An Adecuate Emercency Response Plan The charge that the emergency response plan is uncoordinated and unknown to local and state authorities is I
also without merit. 4 The emergency plan was approved by the NRC and state and local officials. Regular drills are performed annually with participation from state, local authorities and the NRC.
It is true that a campus wide evacuation drill has never been held. No need for such evacuation is envisioned. The total fission products inventory is low ~5000 Ci.
h) GANE Contends That a Maior City of Atlanta Reservoir is Vulnerable to Extensive Contamination From the GTRR No credible accident has been postulated that would jeopardize Atlanta's water supply. Furthermore, "he reservoir is located upwind from the prevailing winds at the GTRR.
i) GANE Contends That Manacement Problems At the GTRR Arc So Great That Safety for the Public Cannot Be Assured The charge that safety concerns are the sole responsibility of R.A. Karam is without merit. There is an emergency organization in place and there is a Nuclear Safeguards Committee comprised of twelve independent safety experts who review and approve all safety matters. GANE makes reference to the 1987 incident relating to cadmium-115 and states that information relating to the incident was withheld from the NRC. The 1987 incident has been investigated by the F
NRC, considered thoroughly in Federal Court, and is a closed matter. The current organizational structure for the GTRR has been approved by the NRC.
j) GANE Contends That the GTRR is a Financial Liability to Taxcavers of the State of Georaia and to Georaia Tecil Applicant finds no merit in this contention. The GTRR is being used for education, research and public service (See Exhibit 3).
None of the contentions raised by GANE in its Petitions provide " sufficient information...to show that a genuine dispute exists with the applicant on a material issue of law or f act . . . " , nor has GANE provided any reference to " specific i
sources and documents of which the petitioner is aware and on which the petitioner intends to rely to establish those facts or expert opinion," as required under 10 CFR 2 . 714 (b) ( 2 ) .
GANE's Petitions consist almost entirely of stated disagreement with Applicant's SAR, but contains practically no reference to any expert opinions or documentary sources to support those statements of disagreement. Applicant requests that GANE's Petition for Leave to Intervene and Amended Petition for Leave to Intervene, be denied for f ailure to meet NRC requirements relating to the contentions raised in the Petit!ons.
b Under 10 CFR 2.714 (d) (2) the Board shall refuse to admit a contention for the following reasons:
(i) the contention and suppgrting material fail to satisfy the requirements of paragraph (b) (2) of this section; or (ii) the contention, if proven, would be of no consequence in the proceeding because it would not entitle petitioner to relief.
Applicant contends that GANE has failed to meet the requirements of (b) (2) , as outlined more specifically above.
Additionally, GANE has failed to show that any of the conte.ations raised by GANE would entitle GANE to relief, if proven, thus requiring the Board to refuse to admit GANE's contentions under 10 CFR 2.714 (d) (2) .
CONCLUSION For all the above reasons, Georgia Tech believes that GANE does not qualify for intervener's status and that its Petitions should be denied.
Resp- ully Submitted, R nd A. Nordin Chief Legal Advisor Georgia Institute of Technology E. Gail Gunnells Deputy Chief Legal Advisor Georgia Institute of Technology Dated at Atlanta, Georgia this 25th day of January, 1995 00D ERD 1 j' "' ; ;
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 95 F -2 P ,; h.i ATOMIC SAFETY AND LICENSING BOARD q; .
Before Administrative Judges: b0 -
Charles Bechhoefer, Chairman !
Dr. Jerry R. Kline Dr. Peter S. Lam ;
In the Matter of ) Docket No. 50-160-Ren
)
GEORGIA INSTITUTE OF )
'ISCHNOLOGY, )
Atlanta, Georgia ) ASLBP No. 95-704-01-Ren
)
Georgia Tech Research Reactor )
)
(Renewal of Facility License )
No. R-97) ) January 25, 1995 CERTIFICATE OF SERVICE :
I hereby certify that copies of the foregoing Response ,
has been served upon the following persons by U.S. mail, first class, except as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.
Office of Commission U.S. Nuclear Regulatory Appellate Adjudication Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Glenn Carroll l Georgians Against Nuclear Administrative Judge Energy Jerry R. Kline P.O. Box 8574 i Atomic Safety and Licensing Atlanta, Georgia 30306 Board U.S. Nuclear Regulatory Administrative Judge i Commission Charles Bechhoefer, Chairman Washington, D.C. 20555 Atomic Safety and Licensing Board ;
Sherwin E. Turk, Esq. U.S. Nuclear Regulatory l Susan S. Chidakel, Esq. Commission j Office of the General Washington, D.C. 20555 Counsel 1
Administrative Judge Peter S. Lam Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dated at Atlanta, GA this 25th day of January, 1995 Res .c 1 Sub 'ted, ndy' 3 . Nordin Chidf Jsegal Advisor Gecr~ia Institute of Technology E. Gail Gunnells Deputy Chief Legal Advisor Georgi 3 Institute of Technology Exhibit 1 t
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Typical Storage Pool Water Analysis Co-60 Date Activity pCi/cc Date Activity pCi/cc 12-1-94 < 3 . 9 8 5
- 10-7 12-7-92 <5.54*10" 11-4-94 <4.415*10 4 11-5-92 <5.21*10 4 !
10-4-94 <3.77 *10 4 10-8-92 <5.85*10 4 ,
9-6-94 3.01*10" 9-3-92 <5.27*10" 8-12-94 2.31*10 4 8-10-92 2.41*10 4 6-28-94 2.63*10 4 7-8-92 <5.37*10" :
5-31-94 2.31*10 4 6-4-92 5.60*10 4 5-4-94 2.69*10 4 5-5-92 <5.79*10" 3-31-94 3.915*10 4 4-6-92 <5.57*10" !
3-2-94 4.045*10" 3-9-92 3.21*10 4 2-2-94 <3.81*10 4 2-6-92 3.91*10 4 1-7-94 <3.875*104 1-6-92 4.01*10 d 12-3-93 2.05*10 4 12-11-91 3.53*10 4 11-9-93 2.34*10 4 11-11-91 2.93*10 4 10-6-93 2.34*10 4 10-3-91 4.10*10" 9-7-93 2.26*10 4 9-6-91 3.31*10 4 8-16-93 1.81*10 4 8-2-91 3.74*10" 7-7-93 <4.24*10 4 7-9-91 4.27*10" 6-9-93 <4.39*10 4 6-6-91 4.13*10 4 5-7-93 3.28*10 4 5-1-91 2.98*10 4 4-7-93 2.82*10-7 4-5-91 3.09*10 4 3-8-93 2.44*10 4 3-7-91 3.09*10" 2-8-93 <5.45*10 4 2-5-91 2.55*10 4 1-6-93 <4.43*104 1-7-91 2.54*10" Allowed (10CFR20, App.B)Co-60 release to the sewer, monthly average concentration is 3*10 4 pCi/cc. (Note 1)
NOTES:
- 1. If sewer water were the only source of water ingested by man during a year this concentration would give a dose of 500 mrem.
- 2. Above data is pool water, per se, and does not show NNRC water 2
use dilution, (2x102 ml/qtr)
- 3. Our analysis above is often at Lower Limits of Detection (LLO) thus actual Co-60 is less than (<) that indicated.
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Exhibit 2 s
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Pbnt Operations Geoqr,ia Institute of Tecimology 915 Athnric Dnve. NI
\tbnt1 Geswta 3041HaWi USA FAX eM3eW2M 4GieH94 March 4, 1994 MEMORANDUM TO: Dr. R.A. Karam Director, NNRC FROM: Donald P. Alexander, P.E. O*.M R ) 4 A Manager, Facilities Engineering RE: NNRC Building Stability At your request, we have reviewed the available data concerning the possibility that the office building would shift should a washout of the earth occur.
We have examined the following construction documents and records:
earth bore testing reports, foundation details, construction specifications, and visited the building to inspect for any cracks due to structural shifting over the last 30 years of life. The building does not have any "isible exterior wall cracks or visible interior wall cracks due to the building shif ting or settling. The bore testing reports (site B-5, B-6, B-7, B-8, B-9) indicate a mean
- 'I weathered rock elevation of 888 ft. elv. The foundation drawings and specifications direct the contractor to construct the foundation footings on firm undisturbed soil with a measured bearing pressure of 10,000 lbs. per sq. ft. at an elevation as noted on the drawings which also have a mean elevation of 888 ft.
elv. This indicates the building footings were placed on the weathered rock. The west structural / foundation elevations illustrate that the building foundations are to be placed below the existing sewer line. The boring test reports and the site survey indicate that the sewer line is supported by weathered rock, therefore the footings would be sitting on the same rock shelf to support the building. The foundation structure forms a bridge to support the building over the existing sewer line.
Based on the above information, we conclude that if the earth was oroded from under the building, it would be supported by the weathered rock formations.
c: James L. Priest
Exhibit 3 i
19
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/c. . i Georgia Institute of Technology I
NEELY NUCLEAR RESEARCH CENTER fi -
- .. y4 .' 900 ATLANTIC ORIVE ATLANTA, GEORGIA 30332-0425
',,' a " e' (4o4)894-360o USA October 12, 1993 SECRETARY U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention; Docketing and Service Branch Gentlems..:
The Georgia Institute of Technology appreciates the opportunity to comment on externalized benefits of research reactors at U. S. universities. At Georgia Tech, the mission of the Neely Nuclear Research Center (NNRC), where the Georgia Tech Research Reactor (GTRR) is located, is to contribute to the fulfillment of the scientific and technical nuclear needs of the State of Georgia and the United States of America through:
o the education of those who will pioneer the advancement of knowledge in the nuclear field and be future leaders; o the conduct of research of basic and applied nature in nuclear engineering and health physics; o service to the profession, to the State of Georgia, to the U.S., and to the further development of nuclear applications i for the benefit of mankind and the environment. l Records obtained from the Of fice of the Registrar show that to ,
date the Georgia Institute of Technology granted 92 PhD's, 646 MS !
degrees, and 288 Bachelor degrees in Nuclear Engineering and Health Physics.
Nuclear Engineering and Health Physics graduates from Georgia Tech have found productive and rewarding careers in a range of areas including:
Transport of neutrons and photons; Dosimetry; Fission energy systems; Applicationof radioisotopes in medicine, Radiation protection; Risk management; Safety analyses Fusion energy systemsiplasma [
research; Energy needs; Materialscience, Thermalhydraulics and multiphase fluidflow, Computer applications: Environmentalcontrol; Ecology; Transport of radionuclides in the environment; Atmospheric science; Instrumentation; Sensors and detectors.
. l SECRETARY U. S. Nuclear Regulatory Commission October 12, 1993 !
Page 2 No attempt will be made here to trace the careers of all of j our graduates. We do know, however, that they occupy important i positions in the nuclear industry, in academic institutions, in s federal and local government agencies, and in business.
l In tha greater Atlanta area, we made a survey of those who ;
either graduated from or worked at Georgia Tech in endeavors !
related to nuclear science and engineering and who later started !
businesses " spawned" in many cases, at the Neely Nuclear Research j Center. The following is a partial list Company Name Address Annual Sales l Digital Communication 1000 Alderman Drive !
Associates Alpharetta, GA 30302 $292,900,000 Applied Radiological 500 Chastain Cntr. Blvd. ,
Kennesaw, GA 30144-5559 25,000,000 ;
Control i
, Analytics 1380 Seaboard Ind. Blvd. 2,500,000 Atlanta, GA 30318 Theragenics 5325 Oakbrook Pkwy. NW 5,000,000 Norcross, GA 30093 Consort Technologies, 6201 Powers Ferry Rd.NW. 9,000,000 i Inc. Atlanta, GA 30339 Phoenix Corp. 1431-A McLendon Dr. 1,000,000 Decatur, GA 30030 Nuclear Assurance 6251 Crooked Crk.Rd.NW 10.000.000 Norcross, GA 30092 Total Direct Sales Contribution to Atlanta's Economy $345,400,000' Additionally, Georgia Tech graduates in Nuclear Engineering and Health Physics make a substantial contribution to personnel operating Region II of NRC, operating nuclear power plants Vogtle, Hatch, and Farley; operating nuclear fuel services, the Savannah River site, and Oak Ridge National Laboratory.
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SECRETARY U. S. Nuclear Regulatory Commission October 12, 1993 Page 3 Twenty-five Doctorial dissertations (out of a total of 92) in Nuclear Engineering and Health Physics were based on research conducted at the GTRR. Faculty / Graduate students at Georgia Tech over the years produced numerous scientific publications based on work conducted at the GTRR. A partial list of publications is available upon request.
The Georgia Tech Research Reactor is used, free of charge, in support of faculty and student investigations covering a wide spectrum of scientific research by more than 20 universities spread all over the U.S. These universities include the following:
Arizona State University; University of Arizona; Oklahoma State University; University of Oklahoma; Southern Methodist University; University of Texas, El Paso; Mississippi State University; University of Alabama; Tuskegee Institute; Medical College of Georgia; University of Georgia; Emory University; Georgia State University; Armstrong College; University of Tennessee; University of Miami; University of Wisconsin; Clemson University; University of South Carolina; University of California at Berkeley; Georgia Southern University.
The type of research conducted by these universities include:
- 1. Neutron Activation Georgia Tech; University of Georgia; Analysis Emory University; Mississippi State University; I
- 3. Food Preservation Unive sity of Georgia; Tuskegee Institute; Clemson University;
- 4. Geologic Formation University of Oklahoma; Oklahoma State University; Arizona State University; University of Arizona; University of Texas-El Paso; Southern Methodist University; University of Miami; University of Alabama; University of Georgia; Georgia Southern; University of California-Berkeley;
f t
SECRETARY .
U. S. Nuclear Regulatory Commission l October 12, 1993 Page 4 .
i
- 6. Boron Capture Therapy Georgia Tech; Emory; University of i Georgia; Medical College of Georgia; ,
Medical University of South !
Carolina; other universities in the BNCT University Consortium; ;
i
- 7. Agricultural Research University of Georgia; Clemson >
University; Tuskegee Institute;
- 10. Neutron Diffractometry Georgic Tech; s ;
i The above areas of research are described in the nuclear In this letter, we briefly describe i industry literature at length.
our activities in the Boron Neutron Capture Therapy application, training, and tours for High School students and Boy / Girl Scouts.
- 1. Boron Neutron Capture Therapy Our objective is to estuu ch a BNCT Test and Measurements !
Laboratory which would be capaole of both basic and applied l preclinical and clinical research in support of BNCT Technology. ,
The BNCT project will be interuniversity, interdisciplinary in l scope with active participation by the Georgia Institute of Technology, the Emory University School of Medicine and the BNCT i University Consortium comprising nine other universities.
The boron neutron capture reaction in radiotherapy, i "B(n,a)7Li, has recently received renewed attention due to the ,
clinical studies in Japan by Dr. Hatanaka. In these studies patients with tumors of the brain who had been administered a boronated compound, which hei some degree of preference for the !
tumor tissue, were treated with a thermal neutron beam. These treatments resulted in a median survival rate for these patients that was higher than that obtained with conventional radiotherapy techniques or chemotherapy.
SECRETARY U. S. Nuclear Regulatory Commission October 12, 1993 Page 5 These brain tumors, i.e., glioblastomas, are nearly always fatal. The extreme malignancy of glioblastomas is att ibutable to the numerous tiny unencapsulated "fingerlets" of actively growing cells that protrude from a central tumor mass into the surrounding healthy brain tissue. These "fingerlets" severely limit the success of surgical removal. Because of these factors, conventional radiotherapy has been the treatment of choice, its effectiveness being limited by the amount of radiation dose that can be delivered to normal tissue surrounding the tumor. This limitation can be minimized with BNCT. If tumor cells can be loaded with boron while maintaining the concentrations of boron in surrounding healthy tise- : a minimum, the boron neutron capture reaction will deliver an intense radiation dose to the tumor cell thus sparing the normal tissue. The result is that cells in which the reaction occurs are killed, i.e., tumor cells, while other cells, i.e., normal tissue, will survive.
Because of the characteristics of this reaction, identification of boronated compounds, which preferentially accumulate in tumor cells, will provide a powerful tool for treatment of these tumors which historically have been intractable.
Pri~e tumor candidates for BNCT are glioblastomas, ocular and i cutaneous melanomas.
For BNCT therapy to achieve the status as a recognized treatment option for gliomas or other tumor types, considerable work in the areas of dosimetry, neutron beam characterization, and compound development and testing are needed.
, The goal is to produce . thermal neutron beam and an epithermal neutron beam of ademiate flux which contain minimal contaminating radiations, e.g. , gamma rays and fast neutrons. This requires that the physical parameters of the beam (s) be characterized. The physical parameters that are being evaluated are described in the following paragraphs.
The design and construction of the idealized neutron beam will be utilized using filtration to eliminate unwanted radiation components from the beam. Various beam filters are being evaluated. Emphasis is placed on the epithermal neutron beam since the use of higher energy neutrons offers the features of greater i depth of penetration into brain tissue than with thermal neutron l beams and the advantage of sparing the skin. Current work includes (1) measurement of the neutron spectrum; (2) determination of the fast and thermal neutron contaminants; (3) mapping the dimensions l
l
SECRETARY U. S. Nuclear Regulatory Commission October 12, 1993 Page 6 and accompanying fall off of the beam and accompanying gamma rays and (4) optimization of the beam configuration and shielding to achieve a maximum epithermal flux-to-gamma-ray ratio.
It is necessary to perform measurements of dose from the tailored beam (s). Calculations based on reacto- are configuration, fuel enrichment, attenuation, relative bic 11 effectiveness, etc. have been performed. These calculatio- All be verified by measurements utilizing a humanoid p. .itom.
Simultaneously, studies with animal and cell culture models will be initiated so that the effects of the neutron beam (s) on biological systems can be ascertained.
It is our goal to establish a credible and sustained basic research effort in BNCT therapy involving Georgia Tech, Emory, and other universities. The end result of this collaboration will be to bring healing to thousands suffering from incurable brain and other cancers.
- 2. Training 4
NNRC is very active in training students at Georgia Tech in reactor engineering and radiation detection and protection. The reactor experiments involve the following: approach to criticality, checkouts and operation of the GTRR, control rod calibration by various methods, flux mapping, material reactivity coefficients, temperature coefficient, power calibration, activation analysis, and cross section measurement using a single energy neutrons from a neutron dif fractometer. Radiation detection experiments involve scintillation, semiconductor, and gas-filled detectors.
In addition to student training in nuclear science and engineering, NNRC sponsors short courses for training reactor operators and health physicists for nuclear power plants. More than 200 trainees from Georgia Power and TVA have taken such short courses.
NNRC also sponsors short courses in health physics. The topics covered include the following: basic radiation technology; radiation safety officer duties; federal, state and local regulations; licenses; biological ef fects of ionizing radiation; portable instruments frequently used to detect and measure radiation; fixed laboratory instruments used to detect and measure radiation; laboratory techniques to control radiation; radioactive material shipment; practical radiation safety practices; and hands-on control and actual startup of the 5 MW Georgia Tech Research Reactor.
SECRETARY U. S. Nuclear Regulatory Commission October 12, 1993 1 Page 7
- 3. High School / Scout Tours and Projects More than 100 tours for high school students and scouts i ranging in size from 10-30 students per tour are conducted by the Neely Nuclear Research Center staff per year. One institution, the Fernbank Science Center, an arm of the DeKalb County School Board, brings on a regular basis, groups of bright ninth grade students to '
visit the center as part of its scientific tools and techniques ;
program. l r
The Neely Nuclear Research Center also helps many high school / i scoute students with science projects. One example is that of l young Jenni Rausch. She studied the effects of Co" radiation on !
Escherichia Coli, Micrococcus Luteus, and Rhodospirillum Rubrum l bacteria. Miss Rausch received the first place award in the i microbiology classification in Fulton County and third on a j statewide competition involving more than 500 entries. Boy and Girl Scouts earn their nuclear merit badge with NNRC projects.
In summary, the Neely Nuclear Research Center and its !
facilities are widely used to strengthen nuclear science ;
instruction in the curricula of non-reactor owning colleges and ;
universities as well as research opportunities and application of l nuclear analytical techniques for faculty and students in the l sciences. We also have a significant program for high school j students' tours which is very valuable for scientific education, career choices and public information.
In short, the Nuclear Research Center is vigorously involving other universities as well as Georgia Tech faculty in research utilizing the GTRR and associated facilities.
t Finally, the externalized benefits of the GTRR are significant '
and emcompass a wide spectrum of human endeavors. We appreciate the willingness of NRC to reconsider the license fees issue .and '
l trust that the exemption of university research reactor will .be reinstituted. ,
Sincerely, i l
l l
R.A. Karam, Ph.D., Director l Heely Nuclear Research Center RAK/ccg 4
Enclosures:
Attachments A & B
_ . _