ML20096D015

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Discusses P Blockey-O'Brien 10CFR2.206 Petition & Ltrs Written to NRC & ASLB Judges Re Petition & Georgia Tech Neely Nuclear Research Reactor,Radioactive Contamination, Violations & ALARA Issue
ML20096D015
Person / Time
Site: Neely Research Reactor
Issue date: 01/10/1996
From: Blockeyobrien
AFFILIATION NOT ASSIGNED
To:
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
2.206, NUDOCS 9601180420
Download: ML20096D015 (3)


Text

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, , _ Action: Russell, NRR -T PAMELA Bi CCKEY-O'BRIEN r Cy: OGC  % D23 colden valley *~

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U.S. Nuclear Regulatory C&Msefdd0N :. DRPM Washington, D.C. 20555 cys to: Russel1, Mi ra91ia , Thadani Zimmerman, Jan.10th, 1996 Bohrer

Dear Director,

[ /h This letter is in regard to my "2.206 Petition under 10 CFR" and all the letters I have written NRC and The Atomic Safety and Li Licensing Board Judges in connection with the Petition and the Georgia Tech Neely Nuclear Research Reactor, and the radioactive contamination there, and violations, and the ALARA issue.

The NRC and myself and anyone with any detailed knowledge of the global nuclear mess we are in, knows that under NRC Rules, Part 2o, Standards for Protection against Radiation" that all phases of the nuclear cycle from transportation of radioactive materials to nuclear reactors, including the Tech dump of a reactor, operate under ALARA, which allows releases of radioactivirty to air, soil and water on a continuous basis. " Planned deaths" in docDoctor Gofman's words. We know there is no " safe level" of ionizing radiation. There is vast documentation to that effect. We know the so-called

" acceptable levels" and " standards" were set to help the industry -

a political decision, public health be damned. Mr. Mendonga summed it up best, when I was so upset I got into that huge argument with him/NRC when the Justices were last in Atlanta (and I here I want to say I am sorry I yelled at him and I think parb of the problem is that women and men DO communicate and interpret things differently gr and that is a fact that has basis in science and psychology and is not a casual or anti-feminist comment) and and what Mr. Mendonga said at some point, in response to my outrage,was:"It's legal". And there You have it. Many of the terrible problems, are either legal, or not NRC jurisdiction, or not the States problem and on and on. The con 50gubACG is that no one will ACT. No one will stand up and say "this is a p'otentially catastrophic situation and we have to act to stop it."

However, a lot people should be ashamed at what has gone on and still goes on with regard to the Tech reactor situation, whether it is legal or not. Consider these FACTS:

NRC Inspection Reports, State of Georgia documents, and Nuclear Safety Committee Minutes show that beyond a shadow of a doubt the radioactive eq contamination, lack of monitoring, failures to perform radiation level 03 and contamination sutrveys, lea)G of radioactive materials, $ gligence, yf radioactive waste leafs), and a litany of appalling problems not just in the past year, but for years on end.

v4 Specifically, I ask NRC to READ all inspection reports and notices of violation from 1987 up until this present date concerning this awful place. and to make note of the fact that in Inspection Report Number 50-160/95-01 dated June 21st, 1995, for example, when all those tests 9601180420 960110 j PDR ADOCK 05000160 ,a H PDR g0

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were run for the City of Atlanta at the sewage treatment plant, tests for tritium and cobdit-6o were not run -two prime contaminants in the tanMD. released to the sewers - despite the fact that tritium was found in the tanks at the reactor site. Furthermore, it is no wondeT that NRC and Tech do not seem to want to do the tests of the lines and groundwater and ground etc. under the reactor areasas the basement is having a little problem, the basement floor is contaminated.due to (or partly due to ) the bismuth shield leaking since ages (see inspection report 50-160/93-02, Nov. 1, 1993) Nuclear Safety Committee minutes say it's giving off 5 Rem an hour. Oh joy! Oh bliss!

Why "Oh Joy! Oh bliss!" ? Because that is the fuzzy state of mind going on there if the report I got that when it first abafbad years back ,

is correct, Mamely that they used airplane glue to fix it.

I gave GANE quite a few of the inspection reports so GANE too could see what an awful state of affairs exists. I hopd they use them in the l GANE action against the liscense. I'm not going to go into more detail hare as I am asking you all at NRC to read them yourselves and take action to grant my 2.206 petition in it's entirety as I have asked befores By the way, with regard to the tests NRC had run concerning the City of (onAtlanta

p. 20 in the aforementioned inspection report, NRC states that of the report) "The minute qqantities of Sr-90 detected in sludge samples should be expected since its presence is most likely due to atmospheric fa2'out.".

Give me a break. The State of Georgias Environmental 1980 Radiation Surveillance Report of Summer-1979 to Summer

, on page 245 goes into all the contaminants found in the samples  ;

dumped to the sewers noting they are primarily " low-level corrosion l l

and activation products including Co and Cs, with small quantities of sole beta emitters such as Sr-90, and other undetermined sole-beta emitters (probably-C-14) and higher levels of H-3" As the half-life of the Sr-90 is nearly 30 years ,

it came from Tech reactors operations,and likewise for the Cs-137 in the feed cakef due to its half-life.

NRC's partial response to me (p.5) says the radium-226 dnd radium 228 were not from the Tech reaccor, but of course the inventory (in documents signed by the Assistant Attorney General for the State of Georgia) show that there is Ra-226 dnd RA-228 there, and NRC knows what the inventory is, and what was found outside must have also come from inside. as well as from the decay of the u-238 Mhich they also have inside at the reactor Uranium, xhinhxixxxhich is 99.75% listed as AU-DEPL, which is Depleted u-238 half-life of 4.6 Billion years. DU'(Depleted uranium)has a the Gulf War The thousands of tons of it lefttank theatre - it is used in armour piercing bullets and in Ghielding -

hundreds of by all sides, as all sides use it, is estimated to kill emits. thousands of civilians over time due to the ra,dioactivity it It is another reason for Gulf War Syndrome in the Veterans.

NRC 2.206isPetition wrong. should The place is contaminated, outside is contaminated. My be granted and all the documents,I have prove it.

Pamela Blockey-O'Brien. p e,c, w ye m  % h k M s

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' Atomic Safety and Licensing Domed, Hon. Justica Dochhoet'er, Chairman, {gh in: "": E"'

U S Nuclear Regulatory Comission, Washington, DC 20555 T dcsub ,

Sept. 30th, 1995 Regarding Justica Bechheefer's Hencrandus and Order of Sept. 26th 1995 in the matwar of Docket 50-160 Georgia Tech Rcsearch Roactor and GANE Contantion 9 (and my concerns under nzy 2.206) and Whether the organizational change has any effect upon Contention 9 and whether it may moot some or all of the contention.

Dear Justice Esch%efer,

Justice Kline and Justice Lam, Thank you for the opportunity to rompraf . I da not believe that this change renders anything moot. Cne of the,problemo had been that contrary to NRC policy, according to newspaper reports, (Und the former radiological safety officer) all of a sudden, the staff re-organization in the late-1980's toolc away a direct line of comunication on safety issues with high officials at Tech as you are aware end the Radiological Safety Office was put under the Director (Dr. Karam). After all these years of acting centrary to NRC policy (allowed by Tech and the PSC) whiah I would consider to be a serious nanagement defficiency by Georgia Tuch itself as well as the Directoe and a violation by NRC of its own policy, Georgia Tech (with a little help frts NRC perhaps ?) seems to be doing a quick smoke and mirrors job of re-shuffling the dedt back again now the pressure is on, in the hope of avoiding criticism. All this proves, is that there are management problems , this being only one of the problems, which and mysoif would not have been addressed if there wasn't a huge fuss being created by GANE.

Had tho various Committoes and Offices at Tech meant to be involved with the reactor and staff and oversight dono a good job all these years, there would not be, or have been all the problems noted in'the files.

For example, on July 30th,1993, I called to ask what type of research was being done at the reactor. I was put through to a Dr. Larson, who I was told was Assistant Director (I believe of Nuclear Engineering but I am not 100% sure, that can be checked)

He informed me quotetthat he was "not up to date with What they do there" and told me to " talk to Dr. Karana. I remember being very surprised that he did not know what went on there. The Tech lisconse %=nts sutraitted under the Re-licensing 6.2 Nuclear Safeguards connittee , shows there is nothing on healt_h that they look at.

Furthermore, March 9th,1987, Inspection Report of Inspection conducted Feb.17-23 showed HMOR violations on releases to the sewers and a lot more besides which was absolutely appa111 nag, and probicas continued ose way or the other over the years.

Inspection conducted July 31- Aug 3 1989 and Aug.9 -10 1989 and Aug 29 - Sept 9 and Nc miltXIB Nov 1-10 1988 show continuous problems even though NRC had obviously gottan on ths Nuclear Safeguards Committee to get its act together and the Safeguards Corsnittee had been trying. However, as problems re-appear subsequently , or do not seem to have been addressed properly, it looks as if there is not sufficient oversight and monitoring of the facility unless half the known voeld is breathing down 'Dech's neck . That in itself shows a problem at all levels. The June 21st 1995 Inspection Report showed there was no calibration or operating procedure approved by the Nuclear Safeguards COnnittee for the Tennelec Proportional Counter and there were still, in my opinion, serious questions regarding recirculation time with the tanks whicfh discharge to the eswers, as-veil as the problems with no analysis of the particulate filter.

I am also concerned that with this persi.stant pattern of problems which show a certain negligence to say the least, that NUMEDK3 to my kncviedge has been removed from the facility yet prior to tho Olympics and that Tech even has the gall to want to keep the cobalt-60 and bring in the LEU, keep the red-waste and the sealed source etc. In my 2.206 I had asked that ths materials be taken to a secure 95 /o/ 9WD 2- 3 4

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covernment facility to bu kept safo. Dr. Karam told m he had put the cesium-137 up for bids. I prosum that mans what it usustly does, namely that whoever bids lowest gota to haul it off. However, I believe it would be very dangerous for that to go to a non-governmnt site, or heaven forbid wind up on the open market. Barnwc11 10 not only NOT a goversant eito, for example, but according to the report Waste Manags-mnt Inc. An Encyclopaedia of Environmental Crims and Other Misdeeds" (1991)

In 1982 a U.S. Geological Survey report found that radioactivo vaste was icaking fran the Barnwell dump (tritium) and that there was also contaminated water bancath the buried waste (tritium and cobalt-60) andthat in 1986 Chanucicar Trancportation was identified as a potentially responsible party at the Maxey Flats Kentucky Super-fund sito. Further, that Chco-Nuclear Transportation paid a $12,000 fine to settle charges that truck drivera vero permitted to mko improper entries on their record-of-duty status. Chem-Nuclear Servicce and Chem Hacicar Transportation are subsidiaries of the infamous Waste Manage m nt Inc. (aka NMX Technologies) according to the report, the campany and its subsidiarios have paid at least $ 28 million in penalties and settlements in anti-trust cases ( p.128) and has bocn fined millions also for environman D crims . For some obscuro reason, the federal governmnt still gives those awful companies - and thair allies in som cases, such as EFI- contracts. (I suppose it helps that Howard Baker, Reagans former Chia! of Staff is with Waste Managemnt Inc., and that William Ruckelshaus want and joined BFI (formr EPA and FBI) and former high ranking Dept of Energy officials lika Earl Gjelde and Michael I.awronce want and joinod Chcsa Wasto Manag m ant also part of tha Waste Manage m nt Inc. happy family. I do not feel any of thso cogunics (and som not listed with fines against tham) should be allowed to novo this stuff, nor should it go to a privata dump.

Again, with regard to tho question of coatn ss, with which I disagree : with all the concerns regardin] REALTH, as well as s.nett, I do not feel that the Daan/ office of t' the College of Engineering can address any M tha h2alth/ safety issues. Thosas should be addressed by biologists and medical staff who specialize in the terribio hoalth offect of radiation. I would draw your attention to the recent report (over 600 pages) by Nobel Peace Prize Winning Physicians for Social Responsibility entitled " Nuclear Wasteland. A Global Guide to Nuclear Waspons Production and its Health and Environ-mental Effects.7 in which they chargo that on a global scalo the health offects from radiation exposure as a result of decados of nucicar weapons production hava boon widely underestiented and workers often given falso assurances that they wero not over-

, exposed to radiation based on incomplete and sometimes fabricated records. The Tech

-' reactor was/is part of the global weapons cyclo and has recieved military monies.

The inspection reports show concarns with measurto2nts of radiaiton . In my opinion, health of workers and of the public should have been uppermost and it saems it was not.

Even though under "6.2 Nuc1 car Safeguards 00==itteo " 't says they are responsible for mintaining health and saf6ty standards .he entire section, I through 12 NEVER addresses health.Tha Insp ction Report of July lith, 1990, cono Juna 12-14, shows an individual was not pdeforming propiir pdrsonal surveys prior to leaving a controlled area c shoes the individual had only recieved some trainin2 back in 1976 and that tha lisconsco had no formal retraining program How mny tims have worters at Tech failed to monitor themselves for contamination or tho instrumentua they work with (as in this case) the difference being that there was no inspector who happened to be around to notice ? Wo know that it happanod when the follow got on the bus and wont ham in the late 80's, it la anyona guess what has REALLY boca going on there. This is but another small examplo of lack of ovarcight/ management defficiencies.

As noted in the Insp 'ctiori Report of Juna 1995, for 1999,19891989 wit' # bt to gross radioactivity, there was no averago concentration listed for the tutal amount released and no total amount listed in curies for chose years, plus, thoro was no maximum concentration of gross radioativity released to tho unrestricted area or san-ikary sewer listed for the years 1988 throuch 1993 Not only was this a violation, but again showed a lac 4 of oversight and/or mnagemnt on all lovels (and negligenco.)

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,- 3 Tech has had ample tim to otsirate correctly, instead it has been a lihany of problems and a lack of management and oversight.Right up until now.

With this sort of record, there are no guarantees at all that anything will change in the future, and just doing a bit of ro-shuffling now that the heat is on  ;

, is far too little much too lato. That dump should be shutdown. l I would also liko to take this opportunity to raise something on tho l safety / terrorism issue with tho Olympica coming and absant tha Olympics.I stron21y '

sukggest that all parties read the reports from 1972 published in the German news mgazine "Dar Spiegel" .' bout the Munich disaster at the Munich Olympics. and tha )

advance warnings a polico psychologist gave which went virtually unheoded , as I i sometimos get tho impresaion, whether or not it is a true impression, that perhaps '

Tsch wants to keep stalling and than maintain that there 10 not enough tim to get everything out - 4espite their assurances to the contrary) - and then say that they will be able to safeguard anything and everything and not to worry. If this is the case, it vould be disgraceful. Whhie some in the comunity of people vbo are mant to supply all the security for the Olympics may fact that playing Mr. Nacho will take caro of everything, I would remind everyono that we are talking an influx of approx. one million poople into a city that can't even repair its sewers on tim about to be sued for the pollution it causes by people at West Point lake further down the CHattahoocheo River.We are also talking nuclear materials. Macho just won't be enough. Absent the Olympics, the sam security issues remain. At tho Munich Olympi a spdelal, unarmed, police force of two thousand one hundred police men and women patro11od inside the Olympic Village alone , but no one could forsee or prevent young can who climbed tho fence and started the chain of tradgedy. by the time observed going over the fence it was too lata. He didn't look like a stereotypi terrorist either, in his white hat, safari suit and sunglasses - until one saw granade ho carried......My point is, that everything at the reactor MUST go, it should be allowed to wind up on the opdn market for sale either, and that i the cobalt-60. gven absent the Olymoics, the placo is a sitting duck for terrori We are running out of tim. I believe that Tech and the NRC should stop with the dalaying tactics . I consider the mnagement change issues just that.

I bo1Mve they should face up to the fact that everything must go, that the place always was and is likely to rammin a badly managed and op ' rated unsato dump of a  ;

facility and that it poses a real threat to the haalth, safety and well being of the city and stato, and of course that it must bo shut down and cicaned up too.

Wo aro just getting (%'s now Oct. 3rd) .he first effects from Hurricano Opal.

Poachtree Creek has risen 10 foot since last night and will go over flood stago. )

Flood warnin2s are out for Northwest Goorgia and Pulton County where the reactor sits.  !

I hope that basament doesn't flood again.

Thank you for your patience. Sincerely, O -

'3- ,

Pamla Diockey-O'Brien. l

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