ML20097D818
| ML20097D818 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 01/27/1996 |
| From: | Blockeyobrien AFFILIATION NOT ASSIGNED |
| To: | Bechoefer, Kline, Lam Atomic Safety and Licensing Board Panel, NRC COMMISSION (OCM) |
| Shared Package | |
| ML20097D779 | List: |
| References | |
| 2.206, REN, NUDOCS 9602130192 | |
| Download: ML20097D818 (7) | |
Text
1 "b . 6 q1eop $9y The Executive Director, PAM Y RIEN ,
Nuclear Regulatory Commission Douglasville GA 30134 USA and Atomic Safety and Licensing 46%
Board Judges, The Honorable Messrs: ,o Bechoefer, Kline and Lam, Nuclear Regulatory Commission, Washington, D.C. 20555 s
This is in regard to my"2.206 Petition under l'O CFR" against the Georgia Tech Rea on the campus of Geo'rgia Tech in Atlanta, possible license problems and possiSle contam-ination problems. '
When one compares the original license application and the safety and environmental information , a few things stand out?
The" Xenon buildup after shutdown 4 illustration seems to have i vanished, as well as detailed sections on wind roses, streamflow l and such. ALso things like experimental information on stuff like
" irradiation tunnels" ? Does this tunnel refere to "Crenshaws Mountain" ? It seems the. boys had a lot of fun torturing creatures 3
by zapping them with a 5 Curie co-60 source s encased in lead in an underground maze /adivert system they constructed under the campus. 3 I believe it still exists. If water has infiltrated, you could have a problem with lead contamination as well as cobalt-60 contamination.
It would be in an area that suffers from water problems. Besides, some hapless student, or Olympic visitor, might crash through the
" roof" if it has become unstable over time. I can see the headlines now if that happened, the tabloid press would love it :" Olympic athlete descends into atomic underworld, emerges with mutant monster resembling IZZY ". (Izzy is the mascot for the Olympics - ugly and a shade of blue, though not cobalt blue- yet.) Or something equally tacky. As all this went on as a connected " side-line" to the reactorj I don't want to hear the sorry excuse that the State licenses the cobalt-60 from the NRC, and therefore no one has control over it.
The federal government /AEC ultimately owns all things radioactive if I'm not mistaken, so it should be taken back along with the other co-60 in the pool, and the heavy water.
I think it is deceptive and shows poor judgement, that the current license renewal does not include all the information from the original license process too.I do not think Tech should have issued such a
" revised" application. Many extra buildings have been added to the area around the reactor, this will affect wind patterns at low level.
There are far more people in the area than there were in 1964 by day.
Both State and NRC documents make light of the fact that there were very high readings off an area to the south, the State (in the first
" Creative Loafing article) is dismissive of the fact that the stack releases MUST have affected the readings around the reactor, after all, a March 1977 Tech report to NRC says under total gross radioictivity released to air wasl446.87 Curies of Argon-41 for the 9602130192 960205 PDR 0 ADOCK 05000160 PDR
2 1976 Calender year and even though they say radioactive iodine was not detected, they also say the minimum detectable release is 400 uCi/yr. So trace amounts could have been going out daily undetect since years.By the way, that year there were thirty-four unscheduled shutdowns. (Reporting of problems and events seems to have been far ,
better in the earlier years. In that year, it is noted that the maximumcumulativeradiation)dosefromdirect) radiation and gaseous effluent (apparently to the outside , but perhaps not) was j 50 m/ rem year and one occupational exposure was 1,330 m/ rem (how is that persons health ? ANy foilow up done on that ?) IHowever, a 1971 report shows that an e.C;ernal monitoring station to the east, !
Station 13, had direct radiation readouts of 60 b 133 mrem year (which they admit is " a t- abnormally high dose rate") :dnd Tech attributes it to the 1 cermittent use of an isotope handling hood 4 located in the southeast corner of the laboratory building. l
- 1. If you read up on the archaic system for hood ventilation you i will be quite shocked, i
- 2. many of the isotopes handled in the lab are also connected to I reactor useand 3 what Tech is allowed to have in its inventory I l believe, in other words, fairies and gnomes c w.'t be blamed. ;
This problem has probably continued to this day r4 ss proof can be found that the problem was fixed. It is no wonds < ua t in the 1995 NRC inspection reports it was established that a . hoses records of l radiation to unrestricted areas hadn't been done. The place is a dangerous dump. Contrary to the attitude of the State ( radiation j surveillance /EPD program, the head of which is Mr. Setzer) Tech docui clearly says that the stack emissions , argon-41 in particular, quote:"was the primary radionuclide responsible for the exposure at eI of the stations " i.e. external monitoring stations. Even worse, thatI 1
THE MINIMUM LEVEL OF SENSITIVITY OF THE MONITORING SYSTEMS IS 5 mrer l'}Q) -g> Li Ep dosime ters 3 and to mrem for the fi'= badges. SO CONSTANT EXP-OSURES OF SAY below 5 mrem on the one, or below 10 mrem on the others back then -
(WOULDNOTEVENBETABULATEDORSHOWUP,Thefilmbadges God knows how often now) were changed every month, and the TLD's every 3 months. Back then there were 912 badgesand 240 TLD's.
There was a reason for that, the place is dancerous. . NOW THERE ARE TLD's monitored by the State in only 14 LOCATIONS and health physics monitors at the reactor perimiter and the SAR (pages related t Environment - Attachment 3 4.7 ) picks up 10 groentgen/ hour at peak reactor operations according to what is written.. In that Attachment, is also written that approx. 10% of the radioactive wastes in the stc barn that gives off those staggering levels of radiation comes from t reactor,, not just from the crud 116enseddbyythbeSthtteo$fGeorg4A,as everyone is trying to make out.
With all the problems noted in the violations in the last 6 years and*1nspection reports, no one real'.y knows what went out the stack dowk the drain or anywhere with certainty in terms of how much went_
.o_9 t and of what i s o t o p_e oy_er a n d a,b_gze whett h a s b_g gn g r u d g i n g l y a d m i t to. Argon-41 is a beta emitter, Over the years, how many thousands of students and nearby residents in the poorer areas have inhaled, ingested or absorbed this beta emitter ? What about students in the nearby fraternity house where some thoughtful soul put a monitor up, but no one had told the students why ?
All this contamination for a lot of military / DOE contracts ? It's called' killing ones own9And that other contamination over gemstones ?
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And the stuff to the sewers, and all the radioactive crud they dump to )
the laboratory sinks ? The shame of it all.And the noble gases that will also have gone out the stackin small amounts? The shame of it.
The original liscense expired inh 980)accordingtothedocuments. The argument being given to me by NRC, is that via an emendment on a 2 construction license when it went to 5 MW on May 2nd 1973, it was allowed to have a license for another 20 years. This is NOT a proper LICENSE RENEWAL PROCESS. NRC cousel in Reg. 2 has repeatedly told me that an amendment is not the same as a relicensing . Even though she is still doing more research and told me that it may be, I that in the context of agency practice NRC may be giving renewals j l without relicensing., and that the agency may have leeway to do that. '
And even though Mr. Mendonca also said they do it all the time, I l believe this is wrong. It does not have a license in the__ proper sense.
l The license expired in 1980. Period. What is the point of having license renewal proceedings lige what is going on now, if they can just tack it on in some amendment ? If this was all correct, why didn't Tech just try and sneak another extension through by amend- l ment this time ? No, there is something very wrong about all this. !
A license renewal and an amendment are two different things. Counsel !
told me that, and I know it myself. A construction permit with an amendment to the license is not the same thing. Even if it was l put in the Federal Register (I don't have the copies yet Mr. Mendonca '
is sending) a) who would look under construction permits for notices of license renewal ? b) who can afford to get the Federal Register anyway, millions of people don't know what is is, have never seen it either.
No, this is all a devious way to let something continue to operate.
The license expired in 1980, Midnight June 13th 1980 to be exact, and that is what it says. and furthermore, _under the terms of the original license it states that:
" Records showing radioactivity released or discharged into air or water beyond the effective control of Georgia Tech AS MEASURED AT THE POINT OF SUCH RELEASE OR DISCHARGE " (emphasis added) are to be kepg and the fact is, that means when it all leaves the facility, e.g.
external to the stack - not inside- and the actual point of release to the sewers. And Dr. Karam said in the Creative Loafing article of Dec. 17, 1994 that there was no monitoring of what comes out the stack in terms of direct monitoring external to it and that the monitors outside (the stuff EPD has ) monitors So that shows that the permit has been violated anyway, and the State needs to stop pretending that nothing comes from the reactof except maybe, just maybe, teensy weensy, itty bitty amounts. Well, it only takes a teensy weensy radioactive zapping of a cell to cause problems, severe health <
problems down the line, if not immediately.The amount of information in the current relicensing application is lousy and there is no environmental or health impact statement or analysis of the type that should be done today. I repeat, the reactor and everything connected with it and the co-60 should go. And_as far as my contentions $under why ALARA should be revoked, apart from Dr. Gofmans testimonieW on ALARA amounting to plannea deaths", what is in the National Academy
., , ,A i of Sciences BEIR V report (1990) is also proof enough on the terrible j effects of radiation even at lower levels, and the detailed reports on the problems with uptake and magnification of effects of radiation in soil and egetation and in water in combination with chlorination as detailed a s o n e e x a m p l e ,) i n t h e s t u d i e s d o n e b y B e r n d F r a n k e o f IFEU Heidelberg, Im Sand 5, 6900 Heidelberg , Germany.Dcean fish and coral J are contaminated with radiation in parts of the ocean.and in rivers ;
that recieve radioactive effluentsch as aquatic species in the' river nr.'
Plant Farley, with cs-137 Hgs \50 pci/kg, and river sediment in the Savannah River due to Savannah River Site operations at 2,500 pei/kg i 1 Cs-137, an d 19,000 pci/kg Cs-137 in aquatic species in the Savannah Riva, and 22,400 pci/kg tritium in aquatic. species in the same river (all 6EE listed under the Savannah River Nuclear site and Georgia Power Co's Plan':
Gdhi -9PVogtle listing (both are on the Savannah River)l.' But NRC knows what Ef D this is all causing, so why should I knock myself out trying to tell NRC bDDEb that the pdople/ companies who pay NRC salaries are part of the problem of the fouling of the world with radiation ? People eat the fish in the i rivers, and wildlife drink from the rivers, and microorganisms are affected. ALARA should be revoked in particular when it concerns release to water and air, anything that contributes to this burden should not be -
allowed. 5Evg a % APTWl5 As to the exposures allowed to the brain and to the ovaries (and gonads) ;
by NRC, the effects of radiation on the reproductive system are vjugc well documented, I refere you to Dr. Berte11s research, to Dr. Alice Stet research, to the BEIR V report, to the recommendations after Chernobyl :
that anyone who even thought they may be pregnant not carry the child to l term if they were, to the fact that whereas men make sperm on an ongoing !
basis, a female child is born with all the eggs present for her lifetime 1
) in the ovaries, exposure to the ovaries is therefore of paramount importil A genetic dose to sperm or ovum may be of no consequence to the stupid ICRP, but I can assure you, to the woman who bears a child with a genetic defect, or other radiation induced problem if she could get her hands on j j
those fat cat scientists with no concience she'd probably strangle them '
with her bare hands. You need to change the law. NO doses to sperm, (gonads) ova ri es , children, the brain, period. Consider that a demand for a change in the rules and stick it in the Federal Register.Then we can all watch how that one goes can't we ? It would of course apply to all workers in industry (the nuclear industry) tooponsider it a 2.206 to change the rules, or a petition to change the rules. I asked NRC Atlanta to find out how its done for me some time ago, but never got the information.Let us see how the nuclear industry wants to continue to damage the offspring of the nation out of greed.lNever!1et all this ever be construed as an anti- US attitude, this is a GLOBAL problem, and the NRC/AEC/ICRP etc. guidelines are more or less followed worldwide, so it affects the entire world. If NRC took a strong stance on the health issues, then the word would get out, and maybe we could get some global cleanup going, or at least attempts at it. There is a direct correlatior between the lack of a strong message going out from NRC and other govern-ment agencies on the terrible effects of radiation to human health and the environment and to nations wanting to develop,or keep, nuclear weapons and/or the likelihood existing ones may be used, as people still do noji understand the consquences of their use. Witness General Powell on TV recently speaking about how the US MIGHT have used nuclear weapons in thE Gulf War had chemical warfare been released., large scale chemical use.
As ghastly as chemical weapons are, that shows the enormous
4 .. . ,
5 difference between chemical and nuclear weapons is still not JGnes g gdIped by military forces. Agencies such as NRC and DOE and EPA an% the CDC bear responsibility for not broadcasting the tru_th loud and clear. That needs to be changed. The nuclear industry can still make a ton of money focusing on clean-up and what to do with radioactive waste and how to render it harmless. :
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In closing, back to my 2.206 and the Tech license. You should grant !
my 2. 206 in it 's entirety, go back over it all, it is the only sensible thing to do, and take back authority over that cobalt-6o '
and for goodness sake, include"Crenshaws Mountain" cleanup in all this.The name, refers to the lo feet of dirt on top of the co-60 source under the ground. By the way, I understand it's within shouting distance of the President of Georgia Institti$of Technology's house, that should really make his day.....
Maybe NRC better ask if there are any more little nuclear surprises hidden on the campus of Georgia Tech.
Its only a few months before the Olympics, so you all better hurry and grant my "2.206", as I've said for ages, time is of the essence.
Pamela Blockey-O'Brien.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of GEORGIA INSTITUTE OF TEG!NOLOGY Docket No.(s) 50-160-REN ATLANTA, GEORGIA CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing MEMO FM COMIEZ TO JULIAN W/ATT have 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.
Administrative Judge Office of Comission Appellate Charles Bechhoefer, Chairman Adjudication Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Mail Stop T-3 F 23 Washington, DC 20555 U.S. Nuclear Regulatory Comission Washington, DC 20555 Administrative Judge Administrative Judge Jerry R. Kline Peter S. Lam Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F 23 Mail Stop T-3 F 23 U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Sherwin E. Turk, Esq.
Office of the General Counsel Glenn Carroll Mail Stop 0-15 B 18 139 Kings Highway U.S. Nuclear Regulatory Comission Decatur, GA 30030 Washington, DC 20555 Randy A. Nordin, Esq. Patricia Guilday, Esq.
E. Gail Gunnells, Esq. Assistant Attorney General Georgia Institute of Technology Georgia Department of Law 400 10th Street, N.W. 40 Capitol Square SW Atlanta, GA 30332 Atlanta, GA 30334
Docket No.(s)50-160-REN MEMO FM COMIEZ TO JULIAN W/ATT Alfred L. Evans, Jr., Esq. Glenn Carroll Senior Assistant Attorney General Georgians Against Nuclear Energy Georgia Department of Law P.O. Box 8574 40 Capitol Square SW Atlanta, GA 30306 Atlanta, GA 30334 Pamela Blockey-O'Brien
! D23 Golden Valley j Douglasville, GA 30134 l
i Dated at Rockville, Md. this '
5 day of February 1996 CL- 1__ L3 DfficeQf the Secretary of the Commission l