ML20100H297

Georgians Against Nuclear Energy Perfected Responses to NRC Interrogatories & Request for Production of Documents & Responses to Ga Tech Discovery Requests.* W/Certificate of Svc.Related Correspondence

ML20100H297
Person / Time
Site:	Neely Research Reactor
Issue date:	02/22/1996
From:	Carroll G AFFILIATION NOT ASSIGNED, GEORGIANS AGAINST NUCLEAR ENERGY
To:	Neely Research Reactor, ATLANTA, GA
References
CON-#196-17487 95-704-01-REN, 95-704-1-REN, REN, NUDOCS 9602270221
Download: ML20100H297 (116)

Text

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{74K7 wusm 00CKETED n 6 UNITED STATES OF AMERICA C) NUCLEAR REGULATORY COMMISSION

% FEB 23 P2:06 ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETARY Before Administrative Judges: DOCKETING & SERVICr BRANCH Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLEP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 U

GEORGI ANS AGAINST NUCLEAR E?T tGY PERFECTEDJESPONSES TO NRC INTERROGATORIES AND REOUEST FOR PRODUCTION OF DOCUMENTS AND RESPONSES TO GEORGIA TECH'S_,IISCOVERY REOUESTS j f' Georgians Against Nuclear Energy (GANE) respectfully submits the following updated responses to NRC discovery requests on GANE's

! management contention. Following the updates to the NRC are updated )

answers to Georgia Tech's interrogatories and discovery requests.

GANE has an outstanding Motion to Compel filed with the NRC seeking to have access to files pertaining to Rebecca Long. We will add to our i discovery answers any pertinent information contained therein when we

'have had the opportunity to review the files.

GANE has become aware of more communication from Dr. Brian Copcutt tc the Director of the Neely Nuclear Research Center than we have thus f ar been able to obtain and which n.ay be germaine to our contention.

We assume we must file a discovery request with Georgia Tech and if that fails, subpoena the documents from Dr. Copeutt.

' 9602270221 960222 PDR ADOCR 05000160 G PDR l

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/"') It has been a big week at the Georgia Tech Research Reactor! Friday, m/ February 16, 1996, the site at 900 Atlantic Drive in downtown Atlanta was swarming with heavy equipment - trucks, cranes, casks, drills and police cars. As of Tuesday, February 20, NRC and Georgia Tech

-statements are that all fuel has been removed. To where - no comment.

Georgia Tech _has contacted GANE concerning our request to enter and inspect in the interest of arranging a time that works for everyone.

GANE.will be accompanied by NRC Inspector Rebecca Long and former reactor operator for-the Georgia Tech Research Reactor, Dave Cox.

Although our request dealt with other fuel sources than the 17 fuel l rods most recently used in the reactor core, it appears that the l timing of our discovery inspection will enable us to verify the fuel removal committed to by Georgia Tech during the appeal process last summer. This upcoming opportunity quiets our previously stated paranoia that Georgia Tech was playing semantic games with the fuel removal.

GANE makes a special request for consideration of the schedule of Georgia. Tech students in establishing a time for the public hearing.

In consultation with Dieter Vandenbusche, Chair of The Environmental l tN Forum, a Georgia Tech student group, we concur that the weeks prior to

\m-) and during exams are weeks when students would be hard-pressed to attend a public hearing. We further agree that the Georgia Tech populstion, student, faculty and staff, are the most affected population and should be given every consideration to facilitate their attendance at'the hearing. The week of May 20-24 was identified as the last possible week prior to the Olympics in which it would be i favorable to the Georgia Tech population to hold a hearing. GANE is l open to the hearing's being held on Georgia Tech campus. We are enthusiastic supporters of limited public appearances, and feel that a session of at least two hours in length must be offered on one evening since so many people have jobs they must attend during business hours.

It was very interesting talking with many previous employees of the Neely Nuclear Research Center in an effort to fulfill our obligation to the NRC and Georgia Tech with complete discovery answers. We feel i compelled to offer some of the anecdotal " evidence" that emerged from l

j the exercise. It seems that hostile factions run through, at least, the history of the past 10 years. There was consensus that the cobalt-l 60 is much more dangerous than the reactor. Another comment that was f made so often that it inspires this otherwise extraneous paragraph is ]

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? before the Georgia Tech V a $20 million price ,

the perception that the only options lying Research Reactor are either continued operation orlike to state for the recoll tag for decommmissioning. GANE would its face and would push to we are opposed to decommissioning on the reactor building and uncover other options. Although carving upor Savannah River Site in South innocuous given sending Carolina, it to Oak Ridge, Tennessee,so-called national sac It the relatively small scale of the GTRR - Vogtle and Hatch.

that approach for Georgia's other nuclear d plants,eful research into l is our position that the GTRR can provi eions. us guardianship and other nuclear waste optimproved discovery resp  !

Herewith, GANE's new, QUESTS l

GANE RESPONSES TO NRC CONTENTION 9ion or within your DIS,3VERY RE 21.

Identify and describe all facts in your possesstion.

ment knowledge

Response

that supports GANE's are socontention great that safetyor asse problems at the Georgia Tech Research Reactor i

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for the public cannot be assured by the follow ng:failure to have 3/9/87 - NRC cites Georgia Tech for violations forid waste tanks and operating procedures for sampling of the liqu ocedures.

failure to follow health physics and surveillance prb lt-60 to be release Methods being used would (NRC allowInspection tritium and co a 87-02)

Report into Atlanta sewer system. onference with 5/4/87 - Georgia Tech Research Reactor Director hascontrols ment c NRC outlining actions being taken to improve managethe facility to as over operations and health physics at safe operation. chair of the Radiation Protection Carter, and previous 6/10/87 - Dr. Melvin W.an international radiation consultantSociety a Committee, president of both the National Health Physics i s "as a matter of International Commission on Radiation Units res gn structure gement conscience and principle" finding changes in mana " The Radiation

" completely contrary to health physics practice. l the Nuclear Protection Committee was abolished leaving 11/20/87) on yATTACHMENT #1 (Techniaue, Safeguards Committee. of Georgia Tech Research Reactor (Dr. Ratib Karam) facility Previously 7/1/87 - Director

/s4 i is placed over Health Physics personnel at thervised HP personnel a

(/ the Office of Radiological Safety had supe I

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had independent status, reporting directly to the Vice President for

() Research of Georgia Tech. This and the abolition of the Radiation Protection Comraittee contribute to the degradation of management control of the safety of the facility and its operations.

8/18/87 - Gemstone irradiation accident, the notorious cadmium-ll5 contamination incident in which a reactor operator (Bill Downs) rode a MARTA bus wearing contaminated clothing and may have contaminated i his apartment. Discovery of the accident led to the reactor being shut-down for nearly one year. The accident happened as a result of  ;

operators ignoring unexpected high dose rates recorded in the initial experiment. Of'-site contamination may have been prevented if exit monitoring for _adiation contamination had been performed.

Reactor Director delayed reporting the incident to the NRC. Operator failed to monitor area where accident occurred "the breathing zone." Experiment conducted improperly in absence of health physics ,

personnel. Further, the Health Physics department was not informed of the accident which was discovered the following day through elevated routine readings of background radiation. The NRC Investigation Report questions whether incomplete, inaccurate and incorrect records of the incident are from laziness, ignorance and

() incompetence or active deceit. Hostilities. escalate between Operations and Health Physics personnel in the. wake of the incident j and management cover-up. HP personnel involved (Steve Millspaugh and Paul Sharpe) were fired, it was generally felt by other reactor personnel, as reprisal for going to the NRC. (Georgia Tech eventually reinstated Millspaugh and Sharpe in other departments at the University. ) (NRC Investigation Report 87-08) 1/20/88 - NRC issues order for immediate suspension of all reactor operations.

2/16/88 - Nuclear Safeguards Committee minutes. In Item #6 a question was raised regarding the lack of any previous intimation of the Health Physics personnel's incompetence over the past many years of reactor operation. It was suggested that NRC slackness made incompetence hard to detect! Item #7 concerned the delay in reporting the cadmium incident to the NRC Director " conceded possible mistakes on parts of all concerned." John Crecine, President of Georgia Tech forwarded a flow chart of the chain of command to attach to the minutes. The text of Dr. Crecine's letter is not consistent with the flow chart. The flow chart gives the Manager of the Office of Radiation Safety no direct access to anyone I

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O except the Director of the Neely Nuclear Research Center or the Nuclear Safeguards Committee. The letter states "For urgent, or unresolved situations of importance, the Office of heir direct dangerous, Radiation Safety has an obligation to report and inform t  !

the Director of the Neely Nuclear Research Center, supervisor, for Research, and/or the President." .

and/or the Vice President ATTACHMENT #2 3/1/88 - Georgia Tech completes decommissioning of the AGN-201 re by shipping U-235 fuel back to Oak Ridge. An element Region IIcontaining approximately 29 grams of U-235 is missing. Ed McAlpine,  ;

NRC Nuclear Materials Chief, informed Glenn (of Carroll of GANE on which GANE can' find 11/15/95 that the conclusion of the matter was the opinion that the material was never no official record) actually delivered to Georgia Tech in the first place.  ;

(Correspondence - Georgia Tech to NRC 3/1/88) 3/1/88 - Nuclear Safeguards Committee minutes. R.M.Boyd letterce safety of hot presents concerns about d recommends that transfer of up to 600,000 curies of cobalt-60. Boy I

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operations should be terminated. h bsence 4/6/88 - Nuclear Safeguards Committee minutes. GANE notes t e a f Pd-103.

R.M, Boyd. Committee informed by Theragenics of spill ohe. absence l t

2 4/22/88 - Nuclear Safeguards Committee minutes. GANE notes t R.M. Boyd. he was 5/88 - R.M. Boyd transfers to Georgia State University down where as RSO.

Radiation Safety Officer until 9/1/95 when he stepped i Mr. Boyd continues to consult part-time to the new RSO at Georg a State. ide NRC cites Georgia Tech for failing to prov ontrol of 7/1/88 - 9/1/88 - i adequate written procedures for radioactive 12/24/88) contaminat on c liquid waste. (NRC Notice of Violation d T.

9/30/88 - Nuclear Safeguards Committee minutes. H. Edward Thomas resign from Committee.

to resign to do so. discusses Nuclear Safeguards Committee minutes. Committee 10/14/88 - drinking, smoking in areas where concerns about people eating, Non-controlled access to radioisotope radioisotopes are kept. i t for

, storage areas is a problem. The ifCommittee the Committee asksfollowed the D rec up or on

- O' recommendations..GANE notes that this issue it was not recorded in the minutes.

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~~ 11/15/88 - NRC cites Georgia Tech for violations related to cadmium-( ,/ 115 accident finding significant deficiencies in management control of operations at the facility. Failures included failure to follow approved procedures, failure to have adequate procedures for conduct and control of experiments and for radiological safety activities, failure to conduct adequate surveys, and failure to evaluate the extent of radiological hazards. The NRC Investigation found perceived harassment by management and retaliation for discussing safety concerns with the NRC but lacked evidence to issue a citation. Georgia Tech was strongly rebuked in the 11/15/88 letter from Malcolm L. Ernst, NRC Acting Regional Administrator, and assessed a penalty that was " escalated 100 percent because of your prior poor performance in adherence to procedures and radiological controls, and because of your failure to take prompt corrective action to deal with management control problems."(NRC Inspection Report 87-08) 11/20/88 - NRC orders Georgia Tech to cease irradiation experiments until further notice.

12/24/88 - NRC cites violations for improper calibration of the Kanne exhaust gas monitor and the GM gas monitor which measure the air

) emissions of the reactor to the environment. As a result of the incorrect calibration of the monitors, Georgia Tech failed to perform quantitative radioisotopic analyses required in order to know the amount of air-borne radiation to which the populations of Georgia Tech and Atlanta have been exposed. (Notice of Violation date 12/24/88) 1989 - NRC cites Georgia Tech Research Reactor for violations: failure to perform proper containment building leak tests and for operating shim blade insertion and withdrawal in a manner that could have led to a uncontrolled criticality. Georgia Tech did not perform the building leak test (essential to record the amount of radiation leaking to the environment and public) correctly because it had no instructions for analyzing data. Specific leak-rate criteria were missing as well and neither the Director nor the Manager of the Office of Radiation Safety were aware they needed them. NRC concluded after reviewing entries in the logbook concerning the shim blade problem that the operator had no understanding of what was happening with the shim blades. (NRC Inspection Report 89-02) p-m 3/30/89 - Nuclear Safeguards Committee minutes. Director requests that

() the Health Physics Procedures Manual be eliminated.

i approves v 4/28/89 - Nuclear Safeguards Committee minutes. Comm l Confuses ttee Celsius l elimination of Health Physics Procedures Manua .

t on l and Fahrenheit.

6/30/89 - Nuclear Safeguards Committee minutes. d access Kahn to theasks to pu next agenda mechanism for revocation of unescorteif this was pursued in reactor security zone. GANE notes that recorded in the minutes.

7 subsequent Committee meetings it was not d Committee. f Memo from the Director to the Nuclear SafeguarRequests s to 10/26/89 -

Bismuth Block is leaking at a rate of 5 rem per hour.i h Savannah River operate the reactor anyway to fulfill contracts w tAlso doesn Nuclear Weapons Plant. 0 contract. States, "This  !

A with contract U.S. Department of Energy for $300,00is d with epoxy. The essentil l similar leak had occurred in 1983 and was repaire effective this time, t reports leak  !

epoxy was notNuclear Safeguards Committee minutes. Direc or 10/27/89 - Committee asked Karam to that has developed in liquid waste tank. f d. GANE has not been weld a patch and if the NRC needs to be in orme b t the leak able to locate any documentation of communication a ou

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between the NRC and Georgia Tech. Committee 12/6/89 - Letter from Director to Nuclear Safeguards k Leak. Not yet concerning continued tests it of the Bismuth Blochas not been reso resolved. (GANE notes that dated 10/26/89 with Attached to this letter is a copy of the memo l (cited above) from substantial material changes from the origina page seven to the end of the letter. l of the 1/26/90 - Cobalt-60 pool overflows into the lower leve sff device is add reactor building. Subsequently an automatic shut-o (NRC Inspection Report 90-02) Petherick to the faucet.

Nuclear Safeguards Committee minutes. Item urces -toL.handle

1. 5 2/15/90 -

asked Committee to look into the availability of reso ssed concern over removal of radioactive material from campus. Expreis presently being s the safety of the site on campus where itHis estimate of the co

[the Butler building). 00/ year. The cleaning of the site was on the order of $100,0 d to the for Committee unanimously passed a motion to recommen"th administration that f_ shipment of radioactive waste."

( ,j g- 3/22/90 - Nuclear Safeguards ~ Committee minutes. Item #3 - Re: Waste "It is expected that the FY ' 91 budget will satisfactorily address )

the issue." Item #4 - Position of Manager, Office of Radiation Safety needs to be filled. Discussion over Associate Director of NNRC serving as acting manager (GANE notes that that concept smacks of the " fox guarding the henhouse") until replacement found.

Committee passes a motion to " expeditiously find a new Manager."

4/26/90 - Nuclear Safeguards Committee minutes. Item #4. Committee approves <peration of reactor with leaking Bismuth Block per October 26 (which version?) submittal. NNRC staff " confident" that resolution of waste disposal' issue will become effective after 7/1/90-(see 3/22/90 NSC minutes). GANE notes that if the Bismuth {

Block leak ever came up for discussion again with the Nuclear Safeguards Committee it was not noted in the minutes.

5/24/90 - Nuclear Safeguards Committee minutes. Item #2 "Karam informed Committee that a U.S. Department of Energy team from EG&G (Idaho) had favorably reviewed NNRC operation and had recommended to DOE to fund the facility to the tune of about $500,000/ year to bring it up to speed. As a minimum, the cooling tower will be replaced.

DOE has taken the recommendation under further advisement."

- s) 6/13/90 - Georgia Tech Research Reactor cited by NRC for failure to restrict access to high radiation level area where two graphite stringers had been stored for a week, delivering 200 millirem per hour. During the same inspection that the unprotected stringers were found, the NRC inspectors observed a maintenance worker finish mopping in a controlled area and then cross to the uncontrolled side of the monitoring station without performing a personal survey or having the mop surveyed. The worker proceeded to mop the floor in the uncontrolled area. The worker then came back into the controlled area and proceeded out through a door into the Reactor Control Zone and continued to work. The worker had not received special training to work in the Reactor Control Zone. The Director indicated that it was difficult to get maintenance people to work in the facility and that, although this individual made an occasional mistake, he was one of the few willing to work in the reactor building. The saga was not cited as a violation by the NRC! (NRC Inspection Report 90-02) 7/1/90 - Brian Copcutt takes position of Manager of Office of Radiation Safety. ATTACHMENT #3 O

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(N 7/19/90 - Nuclear Safeguards Committee minutes. Changed Committee l \- structure such that the Radiation Safety Officer no longer serves as Chair. Item #5 - Director of Neely Nuclear Research Facility assures Nuclear Safeguards Committee members that they are not liable for decisions or recommendations they make as they are rendered based on l information given to them by Neely Nuclear Research Center personnel. Two non-Institute Committee members request letter from

! the Institute guaranteeing them indemnity against any liability charges brought against them for decisions or recommendations made.

11/15/90 - Nuclear Safeguards Committee ..; 3. Item #2 - Brian Copcutt resigns as Manager of Office of Radiation Safety. In his resignation letter to the Director of Neely Nuclear Research Center (October 8, 1990), Dr. Copeutt states: "I believe that the Manager,

! Office of Radidation Safety lacks sufficient operational freedom to adequately conduct the radiation safety program. Specifically, health physics staff appear to be under the dual control of the MORS

( and the facility Associate Director (Dr. Betty Revsin}. . . . I also object to suggestions from yourself and Dr. Revsin that I should

! not, in the future, document observed regulatory violations or

/"'S proposed program improvements." ATTACHMENT #4 k)

%- 1/31/91 - Nuclear Safeguards Committee minutes. The Committee discussed the status of security precautions during these times of international tension. It was recommended that a motion detector be l installed at the main entrance to announce the arrival of a person.

GANE notes that this apparently still has not been done judging by the recent adventures of FOX Network's "A Current Affair."

3/21/91 - Nuclear Safeguards Committee minutes. Item #6 "The Committee was informed of Dr. Chapman's death. It was reported that l his lab, which was temporarily shut off due to contamination problems, has now been unsealed and declared safe. It was learned that decision on cobalt source has not yet been made." l S/9/91 - Nuclear Safeguards Committee minutes. The committee approved the minutes of the previous meeting subject to rewriting item #6 I

into two separate items #6 and #7. #6 would remain the same with the l l

removal of the last sentence. Item #7 will read as: "It was learned i

that no decision had been made concerning a move to decommission Crenshaw's Mountain." GANE notes that Crenshaw's Mountain has not been decommissioned to this day. It is a 10-foot pile of dirt near

the practice football field and Alexander Memorial Coliseum. The s- l l

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() dirt is piled over an 8-foot culvert and-accessed by an underground network. Crenshaw's Mountain contains a five-curie cobalt-60 source.

Item #4 - The Committee discussed a request to allow setting of lower limits on secondary water flow rate in the GTRR. It was decided that more data were needed to perform detailed power calculations and that the request be denied. However, a 90-day trial approval was given with the proviso that the flow rate be adjusted back to 960 gpm at the end of the trial period. GANE notes that the Safety Analysis Report at 4.4.8.2. states that 1200 gpm are intended for the secondary water flow rate.

6/27/91 - Nuclear Safeguards Committee minutes. EG&G (Idaho) interested in making NNRC major Boron / Neutron Capture Therapy ,

facility. Interest in support of research and activity of $500,000 to $1,000,000, provided Tech continues to support functioning of center. Some changes will be made in configuration of facility. Will take 6 months to 1 year to get NRC approval. " Eventually t'he facility will be used to treat patients also." GANE notes that the new cooling tower's great, but what are you going to do about that pesky bismuth block leak between the reactor and the biomedical

() irradiation chamber? Item #2.111 - The Manager of the Office of Radiation Safety is named the equivalent of Radiation Safety Officer.

8/1/91 - Nuclear Safeguards Committee minutea. Another 90-day  ;

extension on the secondary water flow is granted.

9/17-19/91 - NRC inspection finds Neely Nuclear Research Center Emergency Procedures do not require emergency notification to the  ;

State of Georgia (Department of Natural Resources) and-Atlanta /Fulton County Emergency Management Agency as is required.

Georgia Tech is told to amend procedures. (NRC Inspection Report 91-04) 9/26/91 - Nuclear Safeguards Committee minutes. Commitgee approves permanent reduction of secondary water flow from 960 gallons per minute to 900 gpm. This is not consistent with Section 4.4.8.2 in j the Safety Analysis Report which asserts the flow to be 1200 gpm. I 11/14/91 - Nuclear Safeguards Committee minutes. These minutes are missing.

1/29/92 - Nuclear Safeguards Committee minutes. Gamma Irradiation experiment for EG&G described in great detail. GANE has not been able to find any record of it ever receiving Committee approval.

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1/92 - Director fails to get required approval of Nuclear Safeguards Committee for Facility Modification 92-001 Picoammeter Monitor.

ATTACHMENT #5.

3/12/92 - Nuclear Safeguards Committee minutes. Jim O'Hara appointed Acting Radiation Safety Manager after Betty Revsin resigns suddenly for personal' reasons.

4/30/92 - Nuclear Safeguards Committee minutes. Committee, failing to satisfy the question of how James Powers was able to obtain radioactive materials without going through channels, approves Form A allowing his experiment anyway!

6/25/92 - Nuclear Safeguards Committee minutes. Item #6 states that the previous concern regarding James Powers was resolved satisfactorily. No details. Item #7 - the Director requests to replace committee members Gordon, Barefield and Mshaffey with Braga, Tornabene, and Ghiassiaan. GANE notes that the three new members are listed present as committee members at the next meeting. GANE has not seen paperwork that the committee members were appointed by the  :)

President according to Georgia Tech's stated procedures.

10/29/92 - Nuclear Safeguards Committee minutes. Rodney Ice is new Manager of the Office of Radiation Safety. Item #4 - Roger Wartell

) request was tabled due to lack of clarity in the proposal. Item #5 -

Director informs the committee that he has sent a report on the fuel element weld failure to the NRC. GANE has been unable to find a record of Georgia Tech reporting either the fuel element weld failure or, for that matter, the Bismuth Block leak; to the NRC.

12/10/92 - NRC. cites Neely Nuclear Research Center'for a. violation for failure to require proper notification in Emergency Procedures. The State of Georgia (Department of Natural Resources) and Atlanta /Fulton County Emergency Management Agency are supposed to be notified in an emergency. Director had failed to understand discussion in exit interview during 9/91 inspection'. (NRC Inspection Report 92-04) 12/17/92 - Nuclear Safeguards Committee minutes. Motion approved to change Item #4 (Roger Wartell proposal) in 10/29/92 NSC minutes to read " monitoring equipment to be provided on a regular basis (once a month) by Dr. B. Kahn" (instead of MORS). GANE notes that R.

Wartell's request was approved although nothing is said about how his proposal had been clarified.

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s 2/5/93 - Georgia Tech is cited with NRC violation for operating reactor without required safety system scrams. (NRC Violation 50-62/94-04-01) 2/25/93 - Nuclear Safeguards Committee minutes. Form A request by R.

Wartell was approved subject to (i) clarification by the Principal Investigator on the radio chemical form, and (ii) a resubmission of the Form A request with the revision.

5/13/93 - Nuclear Safeguards Committee minutes. "The Committee granted Form A requests . . . (i) Robert Nerem: Conditions - (a) monitoring must include the incubator (b) comment: Item 11. A ' Geiger counter' is inappropriate to use with tritium. Must use wipe tests using liquid scintillation counter, not Geiger counter."

9/93 - NRC cites violations for Nuclear Safeguards Committee failure to conduct required audits. Also, Georgia Tech was cited for failure to perform biweekly contamination surveys and neutron radiation surveys. Yet another violation was cited for wrong descriptions of material, inadequate emergency notification information and the omission of survey data for the Radioactive Materials Shipments showing radiation levels of the packages. NRC Inspection Report 93-

/~N 02 notes that the procedure for reactor start-up contains " unclear" Y- guidance for monitoring period meters or recorder during approach to criticality. Also, an unnamed individual received a dose of 150 millirem in 1992. Another individual that was mopping up the Bismuth Block leak had an intake of 1.8 microcuries of tritium. After the exposure the management assigned .3 MPC hours to the individual. MPC hours, however, are not tracked. The indicator needle for primary cooling water pressure needs repair. It was bent - apparently from over ranging and was untagged for repair work. Flooded mess in emergency lighting generator room. Director says the leak will be repaired after approval of a plan to modify the Bismuth Shield (is facility management still looking for a new, improved brand of glue?). Firehoses in sections laying in the water, old leaking batteries sitting in sater. A thermoluminescent dosimeter (one of 30 surrounding the facility) near the nuclear waste barn had registered significantly higher than background in 1992. Georgia Tech had concluded the high levels recorded by the TLD to be attributable to environmental damage; i.e. rain and excess heat. The NRC establishes the high readings were coming from the extremely active Radium-226 sources stored in the building. (NRC Inspection Report 93-02) l l

(~'s 9/23/93 - Nuclear Safeguards Committee minutes, "R. Karam presented

\~ I for the Committee's general information a memo from Dr. Ice explaining the Bismuth Block cooling water leak accident. He pointed l out that the memo did not need Committee's approval."

11/1/93 - Georgia Tech's methodology to determine Shim Safety Blade reactivity worth still a safety concern with NRC. (Cover letter to Notice of Violation for NRC Inspection Report 93-02) 12/27/93) - Newspaper reports concerning Rebecca Long, NRC Inspector suing NRC for sex discrimination because her superiors ignored and changed her reports on the Georgia Tech Research Reactor. The sex discrimination related also to disparity in pay-scale between her l and her male counterparts. She cited the good-old boy network as protecting Georgia Tech from an honest assessment and blocking her from raising and addressing the real issues. ATTACHMENT #6 2/10/94 - Nuclear Safeguards Committee minutes. Item #4 "R. Ice reported to the committee an event leading to the contamination of Robert Nerem's laboratory. He informed further that the hallway to the lab has since been decontaminated." (By an untrained custodian i

and a mop?) Item #5 "R. Ice reported to the Commi" 3e the tN chronology of events prior to and since leaking of Ni-63 sealed 5-s source that apparently occurred during shipment to Antarctica. The PI involved was F. Eisele. The source was in the Antarctica [ sic) on an approved NRC reciprocity agreement. The report was accepted."

2/15/94 - Jumpers left in place while reactor taken to criticality.

Operators failed to turn on TR-2 recorder prior to start-up. When the recorder is off the following scrams are inoperative: Shield Coolant High Temperature Scram, Bismuth Coolant High Temperature Scram. If the temperature had become excessive, the automatic scram signal would have failed. (NRC Notice of Violation 8/20/94) I 1994 - Labels on the D2 0 outlet valve and the D20 inlet valve (D20 is heavy tradioactive) water) are transposed. Discrepancy in pressure gauge range found, and the fire extinguisher is expired. No violations were noted! (NRC Inspection Report 94-05) 3/17/94 - Nuclear Safeguards Committee minutes. Item #7 "The Committee was informed about R. Nerem's letter to R. Karam. R. Karam reported an occurrence (without safety implications) (see 2/15/94) involving a violation of procedure for reactor operation. The operator [ Bill Downs) in question has since been restricted to a

(~~N limited access." (Bill Downs is the same operator that caused the

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notorious cadmium-115 accident 6 weeks after the pivotal management

(,_s) change at Neely Nuclear Research Center.)

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4/1/94 - NRC violation cited for failing to retrain operators for l 1

proper procedures to empty pond. (Violation 50-62/I.R.94-04-01) 4/15/94 - Downs resigns.

5/19/94 - Nuclear Safeguards Committee minutes. Item #6: "Dr. Karam i felt that a sufficient number were present [to make a quorum at the 3/17/94 NSC meeting), therefore, all members not present will be  :

contacted to see if they were left off the attendance lists of the l minutes of 3/17/94."

5/24/94 - Letter from E.F. Cobb, Chair of the Nuclear Safeguards Committee, to the NSC informing that no quorum was reached at the l 3/17/94 meeting. ATTACHMENT #7 l 8/11/94 - Nuclear Safeguards Committee minutes. Item #2 " Minutes of ,

the meeting of March 17, 1994, were distributed, but it was decided l that a quorum did not exist at that meeting. All items addressed at that meeting were brought up for consideration and approval." GANE notes that Item #7 concerning R. Nerem's letter about an occurrence was not addressed.

p_ 8/94 - Georgia Tech commits math error on neutron radiation survey (j causing them to be off in their calculations by a factor of 100 times - they divided when they should have multiplied. In addition, certain thermoluminescent dosimeters register extremely high levels.

Georgia Tech and NRC conclude the high readings are caused by exposure to sunshine and rain in the environment. No violation i cited. GANE does not understand why a monitoring system which is not regarded as reliable by Georgia Tech and the NRC is used to document 1 the amount of radiation released to the environment and surrounding populations, (NRC Inspection Report 94-02) j 10/27/94 - Nuclear Safeguards Committee minutes. Item #6 "In another l inspection, NRC cited a violation which has resulted in a slight change in the forms. There was a reported spill in Dr. Kahn's lab (an ampule containing a small amount of tritium used as a standard broke in the liquid scintillation counter). It has been cleaned out."

12/8/94 - Nuclear Safeguards Committee minutes. Item #4 "R. Karam l discussed the failure of an older x-ray diffraction equipment where the shutter malfunctioned and a student may have been exposed on December 6, 1994. . . . Although the dosage was well below

(,__) permissible limit, (GANE asks, how is the dose known if it isn't l

/m\ certain if the student was exposed?) R. Ice and S. Stock asked (GAME N-) asks why R. Ice has to ask) and received an authorization to research the issue further. . . . an interim subcommittee was appointed consisting of S. Ewald, B. Livesay, and B. Kahn to keep up further developments." ATTACHMENT #8 2/9/95 - Nuclear Safeguards Committee minutes. V. Incident reports -

S. Stock: "The Committee discussed the report by S. Stock on the causes of the accident (see minutes 12/9/94 [concerning the radiation exposure of a student by faulty x-ray equipment]) and 4 means taken to prevent its recurrence. This was followed by a discussion of Form A request by S. Stock . . . The Committee imposed the Form A request with the following conditions for a continued operation, and appointed a subcommittee to oversee the same and issue an interim approval.

1. A detailed review of all procedures before any continued operation.

2. An investigation for a long-term solution to the problem; i.e. it may include alternatives such as retrofitting.

3. A satisfactory assessment of the unit by the Manager of the Office of Radiation Safety after all safety modifications have

( been installed.

4. Obtaining of a circuit diagram that specifies the operation of the shutter, with such modification as necessary to assure shutter safety.

J. Choi: . . . The Committee imposed the following conditions for a continued operation of Dr. Choi's research.

1. A pr minate (sic) sign shall be posted by the door indicating that all persons leaving the room must monitor themselves for contamination before leaving the room. A logbook of monitoring is to be maintained.

2. Specific safety procedures for the use of radioisotopes are to be posted. In addition, the posting is required to contain the warning that no procedural variance is allowed without the P . I . 's specific approval."

Item VI. "Dr. Karam discussed the NRC hearing on complaints by two citizens regarding safe operation of the NNRC. He pointed out that the NRC is satisfied with the safety of the entire reactor operation." GANE notes that the license renewal is still under

[h V

question by the Atomic Safety & Licensing Board of the NRC one year m . ._ . _ _ - _ _ _ _ _ _ _ . . _ _ - . _ _ _ . _ _ _ _ _ _ _ _ _

d f

later implying that th'e NRC is NOT satisfied with the safety of the entire reactor operation. Further, if the NRC intervention is discussed in subsequent NSC meetings it is not included in the minutes. Neither do the minutes of the NSC meetings reflect any Committee discussion of the shutdown of the reactor during the Olympics and the removal of the fuel from downtown Atlanta.

3/23/95 - Nuclear Safeguards Committee minutes. Item I - Revision of last meeting's minutes. Item V.1 (S. Stock) strike conditions 3 & 4.

GANE asks, WHY7 Item V.2 (Dr. Choi) remove the word "prominate" (sic). (GANE asks, does Georgia Tech specifically prefer an obscure sign?) "R. Karam discussed and walked the committee through the final report from Dr. Choi on the contamination incident (the student radiation exposure from faulty x-ray equipment]. The Committee was of the opinion that Dr. Choi has fulfilled the conditions (see revised minutes 2/9/95) for a continued operation j

[of the x-ray equipment]. It is expected that there will be at least-one additional audit visit by Dr. Ice to Dr. Chol's lab before 6/1/95." Item IV - Form A approvals: "J.M. Wampler: the x-ray unit is old and of outdated design in the context of safety issues.

However, the way it is being operated by the P.I. and his associates

( under his supervision is deemed safe, provided that no undergraduates '!] are allowed to operate it. The Committee gave its approval."

3/95 - Accidental release of water from the cobalt-60 shielding pool due to a valve that was improperly left open. Not only was the technical error committed, but the accident was improperly reported to the NRC instead'of the State of Georgia, regulatory authority for the cobalt-60. GANE found no record of any discussion with the Nuclear Safeguards Committee in the minutes.

6/21/95 - NRC cites violation for wrong and missing data of environmental emissions of radioactivity from Georgia Tech Research Reactor for the years 1983, 1986, and 1988-1993. The data errors appear to arise out of calculation mistakes, not an effort to falsify environmental data. Management was also cited for making a material false statement in the 1994 Safety Analysis Report submitted as part of its relicensing application where it stated falsely that equipment for continuous, automatic measurement and recording of wind speed and direction was installed. In the absence of actual data Georgia Tech had submitted the same windrose diagram (Oj year after year! NRC cites Nuclear Safeguards Committee for failure

(since 1993) to provide oversight for operation and calibration of a

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\s low background alpha / beta proportional counter used for contamination control and effluent measurements. Comments are recorded about continued extremely high readings from the TLD on the fence by the nuclear waste hut. (NRC Inspection Report 95-01) 7/95 - Georgia Tech response to Notice of Violation cites human error and that the Director takes it for granted that the Manager of the Office of Radiation Safety does not need supervision.

9/21/95 - Nuclear Safeguards Committee minutes. Item #3. Change in management structure approved over opposition of a committee member, 10/13/95 - Memo from E.F. Cobb, Chair of the Nuclear Safeguards Committee strongly recommending that out-dated, unsafe x-ray units be removed from service. A student has narrowly missed a significant radiation burn. The accident would not have occurred if the unit met current x-ray equipment safety requirements. The Committee recommends these units be replaced with new units before they cause more harmful radiation exposure. ATTACRMENT #9 11/95 - Glenn Carroll from GANE sees classified documents at two separate times contained in the same file while reviewing documents

(~T at the Neely Nuclear Facility. The second time was after the file

\~ l had been sent back to the Director with the assumption that the file would be purged of any sensitive documents before returning it for further review.

11/15/95 - Fox Network airs "A Current Affair" program which documents the intrusion of a TV-crew into the building, over the barbed-wire fence and onto the roof over the fresh (weapons-grade uranium) fut1 storage vault.

11/16/95 - Nuclear Safeguards Committee minutes. Item #4.4.1 - Dixon Parker takes over for Taylor as PI on Co-60 irradiation sources.

(Taylor retired). Item #5.2 - Karam informed the Committee that security at the NNRC has been increased since the " Current Affirs" (sic) incident. GANE notes that the front door is now locked. Can we :

get some surveillance equipment and armed guards until you get all the radioactive material removed?

11/29/95 - NRC issues inspection report in which the NRC minimizes the problem of the TV crew security breach by concluding that since the TV crew didn't pick any locks to any secure areas or pack any bombs or grenades into the facility, that all is well and safe. (NRC

/"'N Inspection Report 95-04)

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,_s 12/1/95 - Georgia Tech Response to GANE's Discovery Request,

( ) Interrogatory #14: "Where is the spent fuel?" Response: "GTRR has no spent fuel. All fuel is used in the reactor." #15: "Is there a load of fresh fuel on the premises, and if so, where is it?" Response:

l "GTRR does not have a load of' fresh fuel on the premises."

1/5/96 - Georgia Tech does not produce shipping documents of the spent and fresh (weapons grade uranium) fuel in response to a specific request from GANE. GANE can find no NRC records containing l l

documentation of shipment of nuclear fuel, irradiated or otherwise,  ;

away from Atlanta, j

22. Identify all persons with knowledge of the facts underlying GANE's contention or assertion.

Dr. Melvin Carter, Rebecca Long, R.M. Boyd, Dr. Brian Copcutt, Glenn Carroll, Pamela Blockey-O'Erien, John Galloway, Rob Johnson, Joan O.

King.

23. Identify any person GAHE presently intends to call as a witness in this proceeding to testify regarding the contention or assertion. If GANE expects to call any such person as an expert witness, state the O) v subject matter on which the person is expected to testify, state the substance of the facts and opinions as to which the person is expected to testify, and provide a summary of the grounds for each opinion.

Dr. Melvin Carter was Chair of the abolished oversight committee and is expected to reiterate the concerns he stated publicly when he l resigned - that the management changes consolidating responsibility under the Director were detrimental to health physics principles and fostered an unhealthy and unsafe working environment. (See attachment #1). Dr. Carter is out of the country until the first part of March 1996 and GANE has not yet been able to establish l

contact with him. Until we are able to speak with Dr. Carter, we j will not know if he will testify.

Rebecca Long is an NRC Inspector who brought a sex discrimination suit against the Region II NRC for chilling her investigation of the Georgia Tech Research Reactor, complaining of a good old boy network j that was covering up Georgia Tech's mistakes. (See attachment #6).

GANE has established contact with Ms. Long who is currently an i

inspector with the NRC Region II office and has ascertained that she still has some questions about oversight of Georgia Tech. She is a O hostile witness, i.e., she will not testify unless served with a (sj i l

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(N subpoena. GANE has an outstanding Motion to Compel against the NRC

\- to provide documents pertaining to Ms. Long. When these documents are produced we expect to be able to embellich the information concerning the expected substance of Ms. Long's testimony.

R.M. Boyd is the former Radiation Safety Officer for Georgia Tech and Georgia State University. He left Georgia Tech in 1988 because of his concerns that restructuring of the management and putting the safety office under the director of the Neely Nuclear Research Center amounted to the fox guarding the henhouse. GANE expects him to testify not only to his first-hand experience with the facility, but to the climate and attitude of Georgia Tech surrounding radiation safety and public health. Since Mr. Boyd was Radiation Safety Officer and Manager of the Office of Radiation Safety at Georgia Tech for many years, GANE believes he is qualified to provide expert opinions on safety management. Mr. Boyd will only l testify as a hostile witness, i.e., following being called through

! subpoena.

Dr. Brian Copcutt is currently a Radiation Safety Officer with a Los l

Angeles Hospital. Prior to his short time in the position of

(N Manager, Office of Radiation Safety with Georgia Tech, he had served

'\--) as Radiation Safety Officer for University of Virginia. As he has had a career managing radiation programs, GANE believes he qualifies as an expert witness. His concerns about safety with Georgia Tech's radiation program are strongly stated in attachment #4. We have established contact with Dr. Copcutt, and he is still concerned l about the situation at Georgia Tech, however, he will only testify I under subpoena. GANE will have to decide whether we can afford to bring Dr. Copeutt from California to testify, but we name him as an individual whose testimony would be pertinent and vital to the case and who we would desire to provide testimony if possible. Dr.

Copeutt indicated that there were many more letters than the one we l obtained, written by him to, GANE understands, Director of the Neely Nuclear Research Center. GANE intends to obtain these letters and f

I may be able to embellish the information concerning the expected l

testimony of Dr. Copeutt.

Glenn Carroll is an environmentalist who has worked on nuclear issues since the Chernobyl accident in April 1986. This document contains the substance of the facts and opinions to which she is expected to O)

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s testify.

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Pamela Blockey-O'Brien is an environmentalist who has been studying D} and gathering information on the Georgia Tech Research Reactor for 15 years. The substance of her expected testimony is contained within the 2.206 petition to shut the Georgia Tech Research Reactor which she has filed and added to since 1994. It may be obtained from the Public Document Room. Her investigation is ongoing and may be expected to be added to continuously up until the public hearing.

John Galloway, Rob Johnson and Joan O. King helped GANE research the Nuclear Safeguards Committee Minutes. If there is any cross-examination concerning them, they will need to take the stand. They are volunteer activists and GANE members.

24. With respect to any person listed in response to the interrogatory, state the details of that person's education, employment history and asserted area of expertise.

Dr. Melvin Carter is currently an international radiation consultant.

Dr. Carter was Chair of the Radiation Protection Committee for Georgia Tech. He has served as president of both the National Health Physics Society and International Commission on Radiation Units. Dr.

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Carter held the Neely Professorship in the Nuclear Engineering and Health Physics Department. Dr. Carter is currently in Africa conducting international radiation business and we will have to wait until his return to gather more complete information concerning his education and professional credentials.

Rebecca Long is an inspector with Region II NRC. She has a masters degree in nuclear engineering and has been employed with the NRC for over 10 years. She previously inspected the Georgia Tech Research Reactor (see attachment #6).

R.M. Boyd held the position of Radiation Safety Officer at Georgia State University from 1988 through 1995. He retired from the RSO position in September 1995 and currently works there part-time assisting the new RSO. Mr. Boyd has a bachelors degree in mathematics and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> towards a masters degree in meteorology (see attachment #10). He was employed at Georgia Tech in the radiation protection program from 1964 through 1988, 1974 through 1987 as Radiation Safety Officer and from 1987 to 1988 was downgraded to Manager, Office of Radiation Safety. In these positions he was responsible for radiation safety programs at both

[~'h Georgia Tech and Georgia State University. i

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b Dr. Brian Copeutt has a bachelors degree in Bioengineering and masters

() degree in Biomedical Engineering from the University of Virgina. Dr.

Copeutt's Ph.D. is in Bioengineering and Biomedical Engineering from Texas A&M. Prior to working at Georgia Tech in the position of Manager, Office of Radiation Safety he was Radiation Safety Officer at University of. Virginia for a number of years. Currently he is Radiation' Safety Officer at a hospital in Los Angeles, California.

Glenn Carroll holds a Bachelor of Visual Arts from Georgia State University (cum laude). She has her own business Glenn Carroll Graphics which is so successful that she has time to devote to strenuous volunteer activities such as this one. She has produced two solo exhibits of paintings about nuclear issues, "Show for the End of Time" in 1993 and " Time Distance Shielding in 1994 (at l Georgia Tech!). She has work in many collections throughout the U.S.

I and looks forward to resolving these safety issues stated herein as 1 1

she is newly inspired to begin work on another exhibition -- l

" DEMOCRACY - Respectfully' Submitted, Glenn Carroll." )

-Pamela Blockey-O'Brien is an advocate of the truth and brings a particular breadth of perspective to the issues of management and public safety surrounding the Neely Nuclear Research Center. She

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l feels her participation as a non-governmental organization delegate  !

to the United Nations 2nd Special Session on Disarmament in 1982, l representing over one million people from across the south, is a ]

notable high-light of her interesting life.

John Galloway is a student at Georgia Tech and an active member of.The Environmental Forum, a Georgia Tech student group, and GANE. He has been involved with GANE's intervention on the relicensing of the l I

Georgia Tech Research Reactor since the beginning. He read a large portion of the minutes of the Nuclear Safeguards Committee.

Rob Johnson is an active GANE member and recently served as Director of the Atlanta Greenpeace canvas office. He is currently Canvas Director for the Atlanta office of Public Citizen. He has a bachelor's degree and has been involved with GANE's intervention since the beginning. He has read a large portion of the minutes of the Nuclear Safeguards Committee.

Joan O. King is Georgia Chair of 20/20 Vision and serves on the national board of directors for 20/20 Vision. She is president of the White County League of Women Voters. She has been a volunteer activist with emphasis on nuclear issues for many years. She has

( read minutes of the Nuclear Safeguards Committee.

_ _ . - - _ _ - __m. . . - _ _ _ _ . . _ _ _ _ _ . _ - - _ _ __.- - _ ._ . _ _ . _ _.

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i (~h 25. Identify any persons who have knowledge of the relevancy of the

l. "'A contention or assertion to the security plan and the safeguards used

) and'in place at the Georgia Institute of Technology Research Reactor j (GTRR).

l Mike Salort and Wendy Sax from Fox Network's "A Current Affair" have j the most intimate knowledge of anyone we know with the lack of +

j security at the Neely Nuclear Research Center. The second time Glenn  !

l- Carroll from GANE was shown a classified document at Neely Nuclear [

Research Center (see 11/95) she gave herself permission to read it. It f I described the location of surveillance cameras and the practice of f 4

campus police concerning the facility. The document was dated 1994 as I i near as she can remember and was consistent with what R.M. Boyd has

j. recalled to GANE about security measures in place when he was last j employed there in 1988.

', 26. Identify all documents GANE intends to rely upon in support of its

• t contention or assertion, or which are otherwise relevant to the ,

contention or assertion.

All Minutes from Nuclear Safeguards Committee (Attachments #8 and #11 e % produce an assortment of notes and copies but are not a complete j

set)  !

i Documents relating to criteria for Nuclear Safeguards Committee  ;

Resumes of Nuclear Safeguards Committee members Authorizations for Nuclear Safeguards Committee members List of all persons who formerly served on the Nuclear Safeguards Committee, including, for each person listed, the dates of service, last known telephone number and address NRC Inspection Report 87-02 5/4/87 Conference Report with Georgia Tech Technioue, 11/20/87 (Attachment #1) ,

NRC Investigation Report 87-08 NRC Investigation Report 2-88-003 Chain of Command for Nuclear Safety - Georgia Tech (Attachment #2) 2/18/88 Memo from President Crecine (Attachment #2)

Correspondence - Georgia Tech to NRC 3/1/88 NRC Notice of Violation 12/24/88 NRC Order dated 11/20/88 Notice of Violation dated 12/24/88 NRC Inspection Report 89-02

10/26/89

() Memo from Dr. Karam to Nuclear Safeguards Committee dated Letter from Karam to Nuclear Safeguards Committee dated 12/6/89 w/ attachment

• Brian Copeutt correspondence (some provided as Attachment #3)

Brian Ccpcutt resignation (Attachment #4)

NRC Inspection Report 90-02 NRC Inspection Report 91-04 Facility Modification 92-001 Picoammeter Monitor (Attachment #5)

NRC Inspection Report 92-04 NRC Violation 50-62/94-04-01 NRC Inspection Report 93-02 NRC Notice of Violation 8/20/94

'NRC Inspection Report 94-05 NRC Violation 50-62/ Inspection Report 94-04-01 Letter from E.F. Cobb to Nuclear Safeguards Committee dated 5/24/94 (Attachment #7)

NRC Inspection Report 94-02 Letter from Karam to State of Georgia dated 4/24/95 NRC Inspection Report 95-01

() Georgia Tech Response to NRC Notice of Violation dated 7/95 Memo from E.F. Cobb to G. Wayne Clough, et al. dated 10/13/95 (Attachment #9)

State of Georgia Criteria for a Broad License (Attachment #10)

Affair 11/15/95 (previously

" Nuclear Nightmare in Atlanta" - A current submitted)

NRC Inspection Report 95-04 Georgia Tech Response to GANE Discovery particularly Interrogatory #14 and Interrogatory #15 Correspondence concerning JC O'Hara resignation

• • Documents related to Rebecca Long 12/27/93 Atlanta Journal / Constitution concerning Rebecca Long thttachment #6) 12/26/93 Houston Chronicle concerning Rebecca Long (Attachment #6) l PNO-II-83-009 on 1/31/83 re cobalt-60 shielding pool leak Pamela Blockey-O'Brien 2.206 Petition Docket #50-160 i

• Documents to be discovered from Georgia Tech

• • Documents to be compelled from the NRC iO

, 27. Provide copies of the documents you have identified in response to the interrogatory. .

GANE does not possess copies of many of these documents for financial reasons. We believe that the other parties have the resources and connections to easily obtain the documents which GANE has identified.

We have attached newspaper reports, certain correspondence and notes taken by GANE volunteers relating to the Nuclear Safeguards Committee minutes.

28. As to each document identified in response to the interrogatory, state whether or not GANE intends to seek to move each such document into the record as evidence in this proceeding.

Yes.

29. As to each document identified in response to the interrogatory, state what fact or opinion GANE intends to establish if the document is entered into evidence.

See answer to #21. Also, the Minutes are notable for what they do not contain: rare discussion of NRC Violations, no discussion of State regulations, no discussion of environmental contamination, rare N challenges to the Director - the quorum question and dissent on a management change, no references to communication up the chain of command to the Vice President and President, no meaningful discussion of the interventions conducted by GANE and Pamela Blockey-O'Brien and in particular no mention of shutting the reactor for the Olympics or shipping fuel out.of Atlanta. Certain of the most recent minutes were not available, perhaps the Nuclear Safeguards Committee discussed those issues in those meetings.

30. Identify the specific NRC regulation which would be violated if the contention or assertion were shown to be true. Explain your 1

answer. l GANE's Assertions (Contention #9): l a) " Management problems at the GTRR are so great that safety for the public cannot be assured."

b) " Safety concerns at the Georgia Tech reactor are the sole j responsibility of Dr. R.A. Karam."

c) "Dr. Karam is the director who withheld information about a serious accident from the NRC (1987 cadmium-115 accident) . "

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() d) "The NRC was advised of the 1987 cadmium-115 accident by the safety officer at that time, who was later demoted, and left the GTRR operation claiming harassment. "

3) "Since the incident, management has been restructured giving the director-(Dr. Karam) increased authority, including increased authority over the Manager of the Office of Radiation Safety."

(f) "Although the safety officer has a line to higher-ups than.

the director, since he/she works for the director on a day-to-day basis, the threat of reprisal would be a huge disincentive to defying the director." 1 (g) "The Nuclear Safeguards Committee which has theoretical oversight of the GTRR operations has a distinct flaw in having no concern with health issues."

(h) "The Office of Radiation Safety Manager is sought for its knowledge of law more than its knowledge of health physics. "

.10 CFR Subpart B. 51.11 (b) states: "These responsibilities include protecting the public health and safety, protecting the= environment, protecting and safeguarding nuclear materials and nuclear power plants in the interest of national security, and assuring conformity with

)- antitrust laws."

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31. Provide any and all information, produce copies of all documents in your possession, and respond fully as requested in Interrogatories 21-30 above, regarding any incidents or' problems involving the GTRR which have occurred from 1988 to the present, which GANE contends demonstrate significant, serious or continuing management problems at GTRR.

See #21, #26 and #27.

32. State whether GANE contends that the corrective actions taken by the Licensee following the events in 1987 failed to adequately resolve -

any management problems which may have existed at the GTRR prior to the taking of such actions. Explain your answer in detail, and provide any and all bases for this contention. Provide all information, i identify all persons, and provide copies of all documents which relate to this contention, as requested in Interrogatories 21-30 above.

See #21, #23, #26 and #27. GANE has noted that prior to Dr. Karam becoming director there were only two Radiation Safety Officers (Bob f-~ Zimmerman and R.M. Boyd) over a 22 year period. Zimmerman retired to

( ,) start his own consulting firm. R.M. Boyd transferred to Georgia State to get away from the situation at Georgia Tech. Since Karam's entry into the position of Director 12 years ago, there have been at least six safety managers in two positions Radiation Safety Officer and Manager, Office of Radiation Safety (Bernd Kahn, John Puckett, Betty Revsin, Brian Copeutt, J.C. O'Hara, Rodney Ice).

33. State whether GANE contends that the enforcement actions taken by the NRC following the events in 1987 failed to adequately resolve any management problems which may have existed at the GTRR prior to the taking of such actions. Explain your answer in detail, and provide any and all bases for this contention. Provide all information, identify all persons, and provide copies of all documents which relate to this contention, as requested in Interrogatories 21-30 above.

See #21, #23, #26 and #27 In particular GANE makes note of the apparent failure of management to report the fuel element weld failure and the bismuth block leak to the NRC.

,, 34. State whether GANE contends that any employees or personnel Q) associated with the GTRR (a ) have been intimidated from raising safety concerns by the facility's Director, or (b) have feared reprisals by the facility's Director, at any time from 1988 to the present. Explain your answer'in detail, and provide any and all bases for this contention. Provide all information, identify all persons and provide copies of all documents which relate to this contention, as requested in Interrogatories 21-30 above.

(a) Yes. See Brian Copeutt's resignation letter. (b) Yes. R.M. Boyd will not cooperate with us for fear of reprisal still.

35. State whether GANE contends (a) that any employees or personnel associated with the GTRR have failed to properly raise safety concerns at the GTRR, or (b) that safety problems have not been reported at the GTRR, at any time from 1988 to the present. Explain your answer in detail, and provide any and all bases for this contention. Provide all information, identify all persons, and provide copies of all documents which relate to this contention, as requested in Interrogatories 21-30 above.

1

,-s (a) Karam has not to GANE's knowledge fixed the fuel element weld j (s_/ ) failure or the bismuth block leak and has apparently exposed students l 1

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to-possible irradiation by faulty x-ray equipment. (b) Karam has not

( to GANE's knowledge reported the fuel element weld failure or the bismuth block leak to the NRC. In addition, see #21. Brian Copcutt's resignation letter stating that Betty Revsin discouraged him from documenting regulatory violations implies that Dr. Revsir. may not have documented safety concerns during her tenure as Manager, Office of Radiation Safety. It further implies to GANE that'any Manager, Office of Radiation Safety that co-exists with the current Director may subscribe to that practice.

36. State whether GANE contends that the Nuclear Safeguards Committee (NSC) , the Office of Radiation Safety (ORS), or the Manager of ORS have failed to properly perform their respective roles, at any time 1

from 1988 to the present. Explain your answer in detail, and provide any and all bases for this contention. Provide all information, identify all persons, and provide copies of all documents which relate to this contention, as requested in Interrogatories 21-30 above. .7 GANE believes the NSC is unable to truly oversee the Director and pretty much takes his word for everything (see July 19, 1990, NSC minutes). A notable exception is their slow in coming, but eventual, pressure to take the faulty x-ray equipment out of service. See #21.

The NSC minutes show meaty issues being raised but not followed up on:

The issue of unrestricted access to areas where radioisotopes are stored, smoking and eating in areas where radioisotopes are stored, the leak in the waste tank, the fuel element weld failure. It really stood out to GANE in the case of the x-ray irradiation of a student when the Manager of ORS had to ask permission to investigate further.

Brian Copcutt's complaint about being discouraged by the Director and Associate Director (who later became Manager, Office of Radiation Safety) from documenting regulatory violations implicates both the Director and the person who was MORS from 1991-1993. See #27.

37. State whether GANE contends that the structure and/or allocation of responsibilities of the NSC or the ORS provide a basis for finding that continued operation of the GTRR falls to provide reasonable assurance that the public health and safety will be adequately protected. Identify each and every such regulation, requirement or guidance document. Explain your answer in detail, and provide any and all bases for this contention. Provide all information, identify all

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, persons, and provide copies of all documents which relate to this contention, as requested in Interrogatories 21-30 above.

Previously the Office of Radiological Safety had supervised Health I Physics personnel and had independent status, reporting directly to I the Vice President for Research of Georgia Tech. This and the abolition of the Radiation Protection Committee contribute to the degradation of management control of the safety of the facility and its operations. A sad example of how disempowered the health physics side of the management equation has become is illustrated by Rodney Ice, current Manager of the Office of Radiation Safety, asking for permission to investigate the student's radiation exposure from faulty, out-dated x-ray equipment. See #30 for the regulation. See

1. 21, #26, and #27.

38. State whether GANE contends that the structure and/or allocation of responsibilities of the NSC or the ORS fails to comply with any applicable NRC guidance document. Identify each and every such regulation, requirement or guidance document. Explain your answer in detail, and provide any and all bases for this contention. Provide all information, identify all persons, and provide copies of all documents f\

\~/

which relate to this contention, as requested in Interrogatories 21-30 above.

Please see the answer to your interrogatory #30, as well as, #21, #23 and #27.

39. State whether GANE contends that the events in 1987-88 demonstrate 1 a reason to believe that current or future operation of the GTRR falls or will fall to provide adequate protection of the public health and' safety. Explain your answer in detail, and provide any and all bases for this contention. Provide all information, identify all persons, and provide copies of all documents which relate to this contention, as requested in Interrogatories 21-30 above.

See #21, #23 and #27 GANE finds the change to a one-committee safety program and consolidation of responsibility under Dr. Karam l incongruous with the gravity of the situation as the NRC responded in l its citations and reports to Georgia Tech following the 1987 incidents and violations. In the time following NRC oversight has grown weaker in GANE's opinion (see Rebecca Long documents). GANE believes the Nuclear Safeguards Committee is unable to conduct independent r.\ inspections (see minutes July 19, 1990). The minutes describe guided

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tours where Committee members are shown what they are told is worth seeing. The minutes that GANE has seen do not show where the NSC has been told about the chut-down of the reactor and the removal of the fuel. The TV crew broke into the reactor facility the first week of October. GANE has developed the impression that the NRC and Georgia Tech believe the walk-in occurred the day Bob Lang, head of security at Georgia Tech was shown the tape. They did not know about the excursion onto the roof until they saw it along with the rest of America on national television. GANE concludes they have little actual investigative power. GANE concludes from various references in NRC inspection reports that the system of radiation monitoring which is being used outside the facility by grown-up scientists is a sham. If they don't like the readings, the data is blamed on the weather!

There's no meteorological monitoring device. GANE wants to know, doesn't an NRC inspector climb the stack once a decade to see if everything is in order up there? The impression GANE and the public is getting is that no one's in charge, and that the technology, even on a small scale as at Georgia Tech, is too complicated to handle. The Inspection Reports are rife with the NRC educating Georgia Tech as to the math that has to be done to calculate the emissions. GANE knows O~ this is an educational institution, but we really hoped that the professors were knowledgeable teachers, not students of the NRC. In our answer to #21 GANE cites numerous examples of GTRR management failure to have, understand, and follow procedures. GANE believes l management continues to conceal problems from the NRC, oversight committee and the President of Georgia Tech.

40. State whether GANE contends that the current management of the j GTRR fails or (sic] [will fail ?] to provide adequate protection of the public health and safety. Explain your answer in detail, and provide any and all bases for this contention. Provide all information, identify all persons, and provide copies of all documents which relate to this contention, as requested in Interrogatories 21-30 above.

NRC Inspection Report 95-01 describes a 14 uany of calculation errors ccncerning the emissions from the reactor. There has been no monitoring of wind direction and speed for many years, and management made material false statements about that. Neutron radiation surveys and contamination surveys were not performed and they don't believe the readings on the TLDs (NRC Inspection Report 93-02). They let the O

7-~ maintenance workers who are foolhardy enough to work for them without

(, special training possibly harm themselves (NRC Inspection Report 90-02). Students used faulty x-ray equipment for almost one year at the risk of being hurt (see the Nuclear Safeguards Committee Minutes 12/8/94 - E.F. Cobb's memo 10/13/95). They mailed a leaking package to Antartica (NSC Minutes 2/10/94) and packages that are falsely labeled as to their contents with incorrect emergency contact information (NRC Inspection Report 93-02). They failed their building leak rate test (NRC Inspection Report 89-02), they lost (or diverted) U-235 (Correspondence 3/1/88). #21,#22 and #27.

GEORGIA INSTITUTE OF TECHNOLOGY'S INTERROGATORIES REQUEST REQUEST FOR PRODUCTION OF DOCUMENTS TO GANE

1. Please identify each aspect of the management organization or structure, operations, supervision, budgetary functions, or otherwise which you contend serves as a basis for the denial of renewal by the NRC of Georgia Tech's license.

The organization is basically under the control of one man, the Director, who GANE believes is not being meaningfully supervised by es any entity. GANE believes the Committee is weak and made up of largely

( ,) by representatives of customers of the reactor. GANE believes the Vice-President and President are uninvolved. GANE believes the NRC is sometimes teacher, sometimes apologist, and sometimes gives a $1,000 fine which doesn't mean much to a business with an annual budget of

$700,000.

2. Please identify and describe all facts in your possession or control or within your knowledge which supports each of the aspects of management listed in response to Interrogatory no. 1.

Please see the answer to #21 in the NRC interrogatories.

3. Please identify and describe all documents in your possession or control or within your knowledge which supports each of the aspects of management listed in response to Interrogatory no. 1. j Please see the list provided to answer #26 of the NRC interrogatories.

4. Please identify, giving name, address, and business and home telephone numbers, each person having knowledge of the aspects of

,~

management identified by you in response to Interrogatory no. 1 above.

'd

) Dr. Melvin Carter

['

4621 Ellisburg Drive NE, Atlanta, GA 30338, 770-458-9474 Rebecca Long NRC Region II, 101 Marietta Tower, Atlanta, GA, 404-331-4503 l R.M. Boyd l Safety Dept., Georgia State University, 158 Edgewood Avenue, Atlanta, GA 30303, 404-651-2282 Dr. Brian Copcutt 8720 W. Knoll Drive, Los Angeles, CA 90069-4118, (w)213-977-2920, (h)310-657-8442 Glenn Carroll 139 Kings Highway, Decatur, GA 30030, 404-378-9542 Pamela Blockey-O'Brien D23 Golden Valley, Douglasville, GA 30134, 770-949-9342 John Galloway 25865 Georgia Tech Station, Atlanta, GA 30332, 404-206-9678 Rob Johnson 125 Estoria Street, Atlanta, GA 30316, 404-223-5605 Joan O. King j

/~'T Route 1, Box 1037, Sautee, GA 30571, 706-878-3459 I

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)

5. Identify any person GANE presently intends to call as a witness in this proceeding to testify regarding this contention. For each such person, please state:

a. name, address, business and home telephone number

b. place of employment, title; and education

c. whether such individual was at any time an employee of Georgia Tech See information listed in your #4 and in NRC Interrogatory #23.

6. If GANE expects to call an expert witness to testify on its behalf, please provide the following information:

a. name, address, business and home telephone number

b. place of employment, title, and education

c. professional experience I

d. the subject matter on which the expert will testify

e. the substance of the facts and opinions as to which the expert l is expected to testify j

f. a summary of the grounds for each opinion s_-  ;

. - _ _ _ _ _ _ _ . . _ . _ - _ _ _ _ _ _ _ _ _ _ _ _ . = . _ . _ - . _ - - _ . _ . __

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( R.M. Boyd, Safety Dept., Georgia State University, 158 Edgewood Avenue, Atlanta, GA 30303, 404-651-2282. Mr. Boyd is Radiation Safety Officer at Georgia State University. He worked at Georgia Tech for several years with the current Director, and ended up

leaving voluntarily as a result of the management changes implemented prior to the notorious cadmium-115 incident of 1987. His standing in the Georgia radiation community is good and he has kept up with affairs at Georgia Tech even after leaving in 1988 because of friends and colleagues who have been involved with or employed at Georgia Tech and have come to share his sense that management -

problems at GTRR are profoundly grave. Because of his fear of reprisal from Georgia Tech he is not a friendly witness to us and GANE believes the full story will only come out on the witness stand where he is forced to honor the court.

Dr. - Brian Copeutt, 8720 W. Knoll Drive, Los Angeles, CA 90069-4118, (w)213-977-2920, (h)310-657-8442. Dr. Copcutt has had a career of managing radiation safety in a variety of situations. That and his experience working with the current management structure and Director of the GTRR qualify his opinion as expert.

7. Identify all documents which GANE intends to admit into evidence at the hearing of this case.

Please see item #26 of the NRC Interrogatories, t

8. Identify the specific NRC regulation which you contend has been violated or is currently being violated by Georgia Tech.

Please see #30 of the NRC Interrogatories.

9. Provide all information and produce copies of all documents in your p possession which document or describe in any manner any incidents or l problems involving the GTRR which have occurred from 1998 [ sic] to the present, which GANE contends demonstrate significant, serious, or continuing management problems at Georgia Tech.

Please see the answer to #21 of the NRC Interrogatories.

10. State whether GANE contends that the corrective actions taken by the Licensee following the events in 1987 failed to adequately resolve any management problems which might have existed at the GTRR prior to the taking of such actions. If the answer to this interrogatory is 32 -

-- - - , - ,, - - - - - - - - c-- .m , - . - - - -, -r... , - - - . - - - - - - + , . , ,

1 yes, please explain fully why such corrective actions did not resolve 1

()

any such problems.

Please refer to the answers to #36 and #37 in the NRC Interrogatories.

GANE believes the " corrective" actions of consolidating all authority in the Director has made things worse.

11. State whether GANE contends that the Nuclear Safeguards Committee (NSC) , the Office of Radiation Safety (ORS), or the Ma nager of ORS have failed to properly perform their respective roles, at any time from 1988 to the present. If the answer to this interrogatory is yes, please explain fully all examples of improper or inadequate performance of these entities since 1988.

Please refer to #36, #21 of the NRC Interrogatories.

12. Does GANE have a management plan that it contends should be instituted at GTRR? If the answer to this interrogatory is yes, please state the following:

a. the identity of the person (s) who developed such plan

b. describe such plan, giving specific details as to organization, safety assurance, and operation

() c. describe all differences between the organizational structure and management currently in place at GTRR and the plan suggested by GANE Yes. We would be delighted to iterate GANE's vision for the GTRR. The 30-year license has expired for the Georgia Tech Research Reactor. The current management has not kept accurate recor of the environmental damage it has caused because it cannot perform its math calculations correctly and does not trust the readings from the TLD system of radiological monitoring. The Bismuth Block Shield is leaking and the  !

basement is contaminated by a constant flood of water from that leak coupled with the radioactive metal grindings of the shutter which fall every time the shutter is used and are carried down with the water. j There is or was spent and fresh fuel stashed all over the building (although as of midnight February 20, 1996, we hear it is all gone) and 250,000 curies of cobalt-60 to contend with. If the facility were '

in better shape it might be a worthwhile activity to devise a management plan that would work safely. With honest, hard-working, talented management, and a robust, empowered health physics program, a concern about safety of workers, the public and environment, there (m) might be a mix that would be reasonable. At this point, given the l

a

degradation of the facility, the damage to the environment and the unsafe culture which has become endemic, GANE suggests it's time to change the question. The management structure that is needed now is one to perform closure and clean-up of the facility. We've been reluctant to come right out and say this, but given the material false statements about the air monitoring equipment and possible material false statement concerning the presence of fuel, apparent failure to report serious safety concerns (fuel weld failure and bismuth block leak), inability to perform too many procedures correctly and too many errors in calculations, too many analyses of environmental contamination not performed - in short, the current Director is not up to the task. To perform the clean-up, GANE recommends that you use j outside contractors for fuel removal and to assess the contamination of the buildings and lend expertise on avcilable methods for clean-up, or more precisely stated, containment. GANE believes the nuclear I program would be wise (and on the leading edge of a new market) to reorient its goals to a nuclear waste mission. The Health Physics program needs to be reinstated to equal power with operations. Make-up l of the oversight committee needs to be half health physics people and

(~' half technical people. Another worthy goal for the nuclear program is.

\ to gather more knowledge of the health effects of radiation exposure.

This is a discipline that, alongside nuclear waste, has received a short. supply of energy in the 50 years of the nuclear industry. GANE would like to see Rebecca Long reinstated to the GTRR project as NRC investigator since we have gotten the impression that she la an earnest and intelligent NRC investigator. If she took her job too seriously to please the good-old-boy network, GANE puts that on the plus side of her resume.

The differences between our vision and the current morass are, different director, different mission, use outside expertise, maybe the same radiation safety officer, let's empower him and see how he does. Emphasis on health and safety.instead of production. Restructure management at the facility to equally empower health and safety personnel with operations. Restructure committee to have balanced talents. Give the committee a key to the door, so to speak, the power to fire one of the managers if need be. Let's get some people that are strong in math in there. Maybe Arjun Makhijani would like the job of helping Georgia Tech back out of the nuclear corner - a physicist and environmentalist tackles a real-life nuclear waste and contamination problem. Give one of those big-mouth environmentalists a chance to put

, () their money where their mouth is, eh?

13. Does GANE contend that management at the GTRR should be changed in any respect? If so, please describe all such proposed changes and the purpose of all such changes.

Please see the previous answer.

14. Does GANE contend that the GTRR cannot be managed appropriately and safely under any management plan? If the answer to this interrogatory is yes, please provide the factual basis of such contention.

Yes. The fact, to GANE, is that GTRR's license is expired and it's an old, rundown, leaking piece of equipment which has ended its service life. The fact'according to Dr. John Gofman, Dr. Rosalie Bertel, Dr.

K.Z. Morgan, Dr. Alice Stewart and many others, is that there is no safe level of radiation. The fact is there is plenty, and years' worth, of work to do to shut the Georgia Tech Research Reactor down properly and to deal with the building and contamination legacy. GANE hears humanity crying for options to deal with nuclear waste and spent

() radioactive buildings. The fact is, if we don't learn how to deal with a small operation like the Georgia Tech Research Reac or, how will we ever manage to face the legacy of the large facilities like Nuclear  ;

Power Plant Vogtle? GANE believes there is a lot of risk in the clean-  ;

up and containment activity but that it is a more worthy goal than to push our luck by operating the Georgia Tech Research Reactor further.

She gave a good service life. Let's dignify her service by giving the i students at Georgia Tech an education opportunity to lead us to a  ;

wisdom for which humanity has been waiting 50 years.

Respectfully submitted,

' Y (D)tav&

enn Carroll epresentative for GANE Dated and signed February 22, 1996 in Decatur, Georgia O

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_ , . _ . , ,.,.~,_m. _ - . _ . _ , . ..

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/'N VERIFICATION U)

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Personally appeared before the undersigned attesting officer, Glenn Carroll, who, after being first duly sworn, deposes and states on oath that the facts set forth within and foregoing are true and correct to the best of her knowledge and belief, h VV f G enn Carroll epresentative for GANE Sworn to and subscribed before me this 22nd day of February, 1996.

-X & A A- a NOTARY PUBLIC My commission expires:

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1 ATTACHMENT #1 Melvin Carter Story Technique November 20, 1987 1 page O

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ingwe can doaboutit,but we're try- atite wium uus em ~

,' things in """"~~ ~'*" "'" d $4000 from two agsnts.j - yx; i Jvate te

• ' 'to, iin"1 ? ing very hard to make our guys 'Ihere un- are sorg-dehimacan-[

thing.I knew the time Tech because he accep

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Riccardo'alife ti th/y're in you[p n,'} thefactthatitdidha ',I ire derstand what happened to Ric- . didate for this ki'rkt cardo, (We want them to realize) ari d you also hope that you develop - are people outthere wmrare Ihis - ' howmuchmoneythigiscostinghim thatlong before evenhome ofa these"

,[ t'get bond of trust, ao that they can4 afterpeoplelikeRiccardoen d toprevent things came up.Whenever you've got, ~~

ball,but' in the long run. Ilopefully, by edu- people hke Mr. Abem'athy and Mr.% come to you in a time like this.?.b is nothin we have a I

is much cating others about the rules, they Wilson out there,however,you can't. . 'Ihese things don't get established ,. Ri '

,hewillnot will understand that it will hurt protect your players for the rest of . rightaway,andeventhen,therewill d tion,alcoholabuse.gamb teams them in the fbture, they will not do their lives.'Ihey're people, and they , . always be people - - who do the wrong :, f e ucaand ^~ ofcourse

' that he . it. .

have to become responsible people. ' things.I'm not at all comfortable 'with W . u i' Rosa: Asfar asour pmgram goes, . ~ %,d continued on' ed.: ,y y.

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about "we're not changingwhat we've done ' : You hope that they learn during . .,

.Radlaf/On 6Xpert resigns to pf0 tost.Che

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iri the past at all I think,in fact, that -

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• ang we've made a every effort to pre-forumwith vent thiskind of thing frum happen. ~

thletes on En't at thb Neely Nuclear ReSearch CeNbrW

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program-that( not just lip serv- ' tion and unalterable opposition to has since be'en ah' hed as'part#, o Riccardo the organizationalchanges atNee ice. We have seminars on things of By ROHERT LINZ 213 hf

.er, met the News Staff ,, ,

the proposed changes. , Carter said,that by resigmng,hd this nature that are conducted OrtJune 10 Carter" resigned as a has"done what (I) thought was a ' #1

}'J ' yearly,and we have video tapes for

g, and in response to the orgariir.ational

matter of conscience arilpnneiple" a pm jf eady signings those who can t see the eenunan, changes made atthe Neely Reactor' ' from the chairmanship of the) Radi - . . .g '

on Tech's campus, . Melvin W.

Carter, former chairman of the Ra aQ'rotection_ 'M Committee,which7 struc -

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diation Protection Committee,has j ,

, resigned. Carter said he vigomum . ,

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,l " fly in the face of all generauv recog ;

l r 20* 1987 nized and establised pnnriplea nf ;

1. l radiological safety " . ,

j e 3 --The SGA Credit Union Committee Carter has had over thirty.6ve apply once ogain for a charter for the Georgia f experience in health and. .

, yean .g -

safety programs,and has been con- ,,

nt Credit Union. - .

cerned specifically with radiologi ,

,, pmgrams.g n ,,

lhPage 13 -it's a slow week for news at cam they are completely con-Picayune. Now those guys know how we -

trary to health physica practice."

. . Technique- j Furthennore, he said he believes the changes reflect pmrly on Geori

• p n,

• Page '15 - Tech gets a bowl bid. al- gia Tech, which houses "one of the . j -

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' largest and best llealth Physics this case it is only for the College Bowl, and ,

programa. , , . .i s ,

WhenCarter.uponhearing of the ' j

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e 32 - Tech didn't lose last week, but , , , g, ,.y m p '

n,they didn't play, either.They take on Waka

, MELVIN CARTER resi3ned as chairmart of the Radiation ' aiictor.1 Pg '

Saturday at Grant Field. the then acting president,Ilenry C.;Hourne, expressing - ~.,. his d. ,dissatisfac ' t  ;

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Management Flow Chart Before and After j Crecine Memo + Flow Chart i 4 pages I l

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OFFICE OF Tile I

VICE PRESIDENT FOR RESEARCH I I

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. NNRC DIRECTOR CO:011TTEE (Cl! AIRMAN : RADIATION SAFETY OFFICER)

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MANAGER OF THS. MANAGER OF MANAGER OF COORDINATOR OF OFFICE OF ., REACTOR HOT CELL EXPERIMENTAL

.(RADIATION SAFETYl- OPERATIONS OPERATIONS RESEARCH 19 e a c.s. Ga %ter; /Giu -~

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FIGURE 1 NEELY NUCLEAR RESEARCH CENTER ORGANIZATION CHART 8

Othce of the Em.Jent Georgia Institute of Technology Manta. Georgna MU O

O (404) 894 5051 February 19,1988 To: Interest arue Nucle Safegt ar Corr l

From: John P. Crec '

President - # -

Subject:

Organiz ' nal Arrangements / Radiation Safety cc: H. Bourne, T. Stelson  :

In reviewing the organizadonal aspects of the recent controversy surrounding safety at the Ne Nuclear Research Center, it is apparent that some misunderstandings exist regarding res anc x>nsibilities, supervisory, and reponing relationships surrounding the Radiation Safety group l the Nuclear Safeguards Committee. This memo is intended to clarify two aspects of these  !

organizational arrangements, the relationship of the Nuclear Safeguard Committee to the President  ;

of Georgia Tech, and the reponing and supervisory arrangements for the Radiation Safety Office.

He Nuclear Safeguards Committee repons to the President of Georgia Tech. The Director of the Neely Nuclear Research Centeris an ex-officio member of the Nuclear Safeguards Committee.

l The Chamnan of the Nuclear Safeguards Committee is Georgia Tech's Radiation Safety Officer.

[Stelson to Boume,5/27/87 "The Radiation Safety Officer would have the authority to repon independently to you (as President of Georgia Tech) on any matter of urgent need completely bypassing all organizational structure. This is the same as current practice."]In addition to i

immediate reponing of emergencies to the Office of the President, a monthly summary of safety i related incidents should be forwarded. The Director of the Neely Nuclear Research Center, like all line managers dealing with radioactive materials, repons to the Nuclear Safeguards Committee in the area of safety. J - -

i A distinction exists between the supervisory and reporting relationships of the Office of Radiation Safety. For day-to-day supervision, the Manager of the Office of Radiation Safety reports to the Director of the Neely Nuclear Research Center. Supervision encompasses both financial and  !

l administrative matters and broad program direction. In terms of reporting responsibilities, an l obligation exists for the reponing of all safety violations, dangerous conditions, and potential problems to the Nuclear Safeguards Committee as well as to the appropriate line manager, regardless oflocation in the Georgia Tech organizational structure. The Nuclear Safeguards Committee has a direct reporting relationship to the Office of President of Georgia Tech. For urgent, dangerous, or unresolved situations ofimponance, the Office of Radiation Safety has an obligation to repon and infonn their direct supervisor, the Director of the Neely Nuclear Resean:h Center, and/or the Vice President for Research, and/or the President.

The attached organization chan is intended to represent these points.

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1 Office of the President r ,

Nuclear Office of the Vice Safeguards President for Committee (Chr:

Research Radiation Safety

' ' Officer)  ;

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NNRC Director Safety PoLey) 1 Supervision,

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Reactor Gamma Radiation Experimental Operations of Radiation Operations Research Safety

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v ATTACHMENT #3 Dr. Brian G. Copeutt Georgia Tech Offers Senior Research Scientist Position 4 pages O

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.. Georgia Institute of Technology 9' ,

i NEELY NUCLEAR RESEARCH CENTER Goo ATLANTIC ORIVE ATLANTA GEORGIA Go332-o4P5 nn. (404)094-3600 March 31, 1989 Dr. Brian G. Copcutt P. O. Box 3425 Charlottesville, VA 22903 -

Dear Briant We are pleased to offer you a position as Senior Research Scientist at the Neely Nuclear Research Center effective May 8, 1989, at an annual salary of $50,000 on a twelve month basis.

Georgia Tech staff appointments are subject to confirmation by the Board of Regents; however, full approval is anticipated.

Your assignment will be in the Office of Radiation Safety, helping in the development of adequate health physics procedures and taking the initiative to develop research proposals in the area of health and safety.

e

( NNRC is primarily dependent on sponsored research. All employment and assignments are ultimately contingent upon outside funding. Because of this funding situation, all NNRC staff members  ;

should remain constantly aware of the need for developing and conducting sponsored research. I NNRC staff members participate in the Federal Social Security Program and in the Teacher's Retirement System of Georgia. The latter presently requires a contribution of 6 oercent of gross salary checks. The present State contribution is 13.63 percent.

Your 6 percent contribution to TRS will not be subject to federal income taxes. Your salary for purposes of federal income taxes, will be reduced by the amount of your 6 percent contribution. Upon )

completion of 10 years of creditable service in the System and the attainment of age 60, members have a vested right to benefit. The Institute has several attractive group insurance programs which are ,

optional.

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You will be required to complete a health questionnaire and, j depending on the circumstances, may be required to pass a physical j examination with the expense to be borne by you. Other i r requirements are the signing of a loyalty oath, patent agreement, and completion of a State Security Ques +1onnaire.

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Telex:: 542507 GTRIOCAATL fax: 404-894-3120 (Venfy 404-8944951) a i w. -e i w.,.... , c ,... as n ., , . a o r ..i r,e,,,...a. ned rmni,wmaat Onnortumv inst'uon

O Dr. Brian G. Copcutt March 31, 1989 Page 2 As required by the Immigration Reform and Control Act of 1986, during the first 3 years of your employment, you will need to complete the upper portion of a Federal Form I-9 and, in the presence of an authorized deputy of the Georgia Tech Personnel Division, present proof of your identify and proof of your eligibility to work in the United States. A sample Form I-9 is

• enclosed. This sample shows the document (s) you should have available during your first 3 working days. Our Personnel Division  :

will be happy to answer any questions you have regarding this.

We sincerely hope you will join us. We feel you will have a great opportunity for professional development here and that you will be an asset to the NNRC and Georgia Tech.

Sincerely,

@W R. A. Karam, Director Neely Nuclear Research Center lO i

RAK:dwa i pc Dr. John P. Crecine, President I

Dr. T.E. Stelson i Dr. A.P. Sheppard i

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Georgia Institute of Technology l bl NEELY NUCLEAR RESEARCH CENTER l L,' eOO ATLANTIC DAIVE ATLANTA, GEORGIA 30332-0425 March 15, 1990 Dr. Brian G. Copcutt P. O. Box 3425 Charlottesville, VA 22903

Dear Dr. Copcutt:

We are pleased to offer you a position as Senior Research Scientist at the Neely Nuclear Research Center effective July 2, 1990 at an annual salary of $65,000 on a twelve month basis.

Georgia Tech staff ~ appointments are subject to confirmation by the Board of Regents; however, full approval is anticipated.

Your assignment will be Manager, Office of Radiation Safety (MORS). The MORS is responsible for the radiation protection program for the Georgia Tech ampus.

As you know, Georgia Tech is fast becoming a major graduate research institution. As such, research scientists are encouraged I- to develop research areas with outside sponsors. Such activities help faculty members not only stay current in their knowledge of i their chosen field but also make them and their graduate students contributors to that field.

NNRC staff members participate in the Federal Social Security Program and in the Teacher's Retirement System of Georgia. The latter presently requires a contribution of 6 percent of gross salary checks. The present State contribution is 13.63 percent.  !

Your 6 percent contribution to TRS will not be subject to federal '

income taxes. Your salary for purposes of federal income taxes, will be reduced by the amount of your 6 percent contribution. Upon completion of 10 years of creditable service in the System and the attainment of age 60, members have a vested right to benefit. The Institute has several attractive group insurance programs which are optional.

The Georgia Tech Research Corporation (GTRC) arranges and pays for actual costs of packing and moving household goods and books of new research faculty, excluding firewood, outbuildings, chain link fencing and other fencing, and building materials and the shipment of automobiles and boats. GTRC will reimburse for the l actual cost of storage and special handling charges not to exceed

$1,000. Insurance at the rate of $1.25 per pound will be reimbursed for allowed weight. Mileage allowance at the rate of p 21 cents per mile will be reimbursed based on the standard road l G ,

Tvez:: 542507 GTRIOCAATL Fax: 404 894-3120 (Venfy 404 8944951)

A Unt of the Unversity System of Georgia An Equal Education and Employment Opportunity Institution

Dr. Brian G. Copcutt

& March.15, 1990 h Page 2 distance from Charlottesville, Virginia to Atlanta to move a personal automobile. Personal travel expenses at the rate of $50 for each 700 miles of travel distance, prorates for distances in partial increments ~of 700 miles and based on the standard road distance from Charlottesville, will be reimbursed; or , in lieu of the ' personal car allowance and- personal expense allowance, GTRC >

will provide reimbursement for the actual one-way economy airfare '

for you and your immediate family. Upon notification of your acceptance of this of fer, GTRC will advise their contract household goods mover who in turn will contact you directly to make all the '

necessary arrangements for your move to Atlanta.

You will be required to complete a health questionnaire and, depending on the circumstances, may be required to pass a physical examination with the expense to be borne by you. Other requirements are the signing of a loyalty oath, patent agreement, and completion of a State Security Questionnaire.

As required by the Immigration Reform and Control Act of 1986, during the first 3 years of your employment, you will need to complete the upper portion of a Federal Form I-9 and, in the presence of an authorized deputy of the Georgia Tech Personnel Division, present proof of your identify and proof of your eligibility to work in the United States. A sample Form I-9 is enclosed. This sample shows the document (s) you should have available during your first 3 working days. Our Personnel Division will.be happy to answer any questions you have regarding this.

We sincerely hope you will join us. We feel you will have a great opportunity for professional development here and that you will be an asset to the NNRC and Georgia Tech.

Sincerely, 8 ' &LW~-

R. A. Karam, Director Neely Nuclear Research Center RAK ccg pc: Dr. John P. Crecine, President Dr. Michael Thomas Dr. Gary Poehlein O  !

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ATTACHMENT #4 l

Dr. Brian Copeutt l Resignation Letter !

10/8/90 1 page j i

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Georgia Institute of Technology G

S.nast-NEELY NUCLEAR RESEARCH CENTER Goo ATLANTIC OAIVE m-

.' ATLANTA. GEORGIA 30332-0425 (404) t3se e t oo October 8, 1990 Dr. R. A. Karam, Director Neely Nuclear Research Center Georgia Institute of Technology

Dear Dr. Karam:

I regret that I must offer my resignation from the position of Manager, Office of Radiation Sgfety and Senior Research Scientist effective November 2, 1990.

After carefull consideration I feel that it is impossible for me to work effectively within the structure of the radiation safety program at Georgia Tech. I believe that the Manager, Office of Radiation Safety (M.O.R.S.) lacks sufficient operational freedom to adequately conduct the radiation safety

,e program. Specifically, health physics staff appear to be under

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the dual control of the M.O.R.S. and the facility Associate Director. On a personal basis, I have been discouraged from making even minor decisions without first consulting you and Dr.

Revsin. I also object to suggestions from yourself and Dr.

Revsin that I should not, in the future, document observed regulatory violations or proposed program improvements.

I cannot, in good conscience, take responsibility for a program whose priorities I cannot set and in which I must compromise my professional judgments.

1 Sincerely, d  %.

Brian Copcutt, Ph.D. l l

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l (N cc: Dr. B.K. Revsin

'n Dr. Gary Poehlein Members, Nuclear Safeguards Committee Teias 5.t2507 GTRIOCAATL Fax: 404 894 3120 (venty 404-8944951)

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- 1 l ATTACHMENT #5 '

l' Picoammeter Monitor i Procedure 4200 Form i 1/92 i i page i

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l NEELY NUCLEAR RESEARCH CENTER nor Change Procedure 4200 umber: Revision 00 By: CHANGES IN GTRR DESIGN Approved 04/28/89 Dates / / Page 3 of 4 APPENDIX A d i

10 CFR 50.59 SAFETY EVALUATION QUESTIONNAIRE

, FACILITY MODIFICATION NO: 92-00i TITLE: I c O 4d fA/E72ER od/ rof

1. Will the probability of the occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the nafety analysis report be increased? [yes/no) A2o

2. Will the possibility for an accident or malfunction of a different type than evaluated previously in the safety analysis report be created? [yes/no) Alm O 3. Will the margin of safety as defined in the basis fo,,any r technical specification be reduced? [yes/no) NO

4. Is the prop 9 sed change an unreviewed safety question?

[yes/no) No HQTg: If additional space is needed to justify conclusion (s) please attach extra sheet (s).

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, DATE:

PREPARED BY: / - 2 M2.

J APPROVALS: l Director NNRC: M

• Ntd MSm I c79/9A Nuclear Safeguards Committee:

O ATTACHMENT #6 Rebecca Long Story Atlanta Journal / Constitution 12/27/93 Houston Chronicle 12/26/93 7 pages l

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C4 Monday. December 27.1993 *****  ;;j Although Long's allegations i _ myolve one of the agency s five u Georgia Tecn continued op-

'jG regional offices, reports have efaling the reactor until January

~ cO g3 p t y ,

bb LUI. e previously mdicated a growmg 1998,when the NRC ordered it to cease all experiments because of n 1strust of the NRC among whis- I

, . tttblowers at nuclear power a!." breakdown in management i

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plants.

, Long said some NRC manag-ers delete or " water down seri-co$trols" - the same problem 14118 had previously identified.

• They put something in [the I

i t e reggtor] that got much more ra-ous safety problems documente,d diation than they thought it L

,P' b tfyjnspectors.She added thatitis

,- an agency dommated by " good wpuid and the sample exploded,"

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old; boys" who reward " team contaminating a worker, Long gig pisyers."

g The NRC hired lang m. Feb- Song's discrimination and harassment allegations against hijlanta WOnlan Cites g g , = ,ataae ,hcn g a s;a 1

report onTeCh reactor gagere ,, re3;1ed

, in 1990 by a than male inspectors with com-L. MBut a federal judge who re- l p, arable backgrounds. She holds '

pTED PRESS viewed the ruling decided to re-a; master's degree m, nuclear en- trylhe case, which now includes

,. A Nuclear Regulatory Com- {i gineering. '

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rptAsion inspectorin Atlanta who i additional alle*gations.

1. .tShe said her trouble began af- f-NRC Chairman Ivan Selin re-has sued the agency for sex dis- t(rthe complained about her pay Eriinination and harassment says i fukd to comment on thelawsuit.

to* Region II managers. Named in Inhe past he has vowed to pro-her, work was compromised at her lawsuit are managers Frank potential risk to the public and tecF nuclear industry whistle-  !

Jape, Ken Barr and Bruce Wil- bloGers and weed out harass-nuclear industry workers. soti. Another manager, Bill Lit-3 eRebecca Long,40, said male medt and discrimination within

[O tie,3was the subject of a griev- the agency.

mhnagersin the Atlanta regional afice lAng filed with her union.

of! Ice undermined some of her f, Jape, Barr and Little still l nfety related findings out of gork in the Region II office. Wil-

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Spite.

son left the NRC last year.

'" 'She said the handling of her ,;Little, reached at his home by safety report on a nuclear reac- the Chronicle last week, said "I ,

t6Fht Georgia Tech was an exam-don't know of any retaliation" pjs of what she considers ques- against lAng. Jape declined com-tionable NRC conduct.

"l ?"I'm not anti-NRC," she told m'e pt. Neither Barr nor Wilson re. turned telephone calle.

g the: Houston Chronicle in Sun- .-?/The Georgia Tech :ncident, day's editions. "Some of the fin-estpeople I've ever worked with dtilch resulted in a wor (er's ra- Md diation exposure, was one of sev-are jpti:here, t

andthere It's just that theyaredopock-a hell of a er'ia examples Long offered of what she considers questionable g [.;LM,y eg of problems that need to be NRC conduct, cleaned out." . In 1987, she inspec'ed a re-SIAng works in the NRC's Re-gigp II office in Atlanta, which ogrsees 33 nuclear reactors in search reactoroperated by Geor-gia; Tech. Based on Nr inspec- l2 27 h tsod,the NRC cited the university RSoutheastern states, Puerto f5Fseveral violaticas, including Itico and the Virgin Islands, failure to properly control ex-She said four men in the of- pehments.

ffe,e have tampered with her .CA few months later, she said, work, badgered her with deroga-tory comments and improperly fap:e retracted the citations with-out her knowledge, contrary to denied her promotions and bo- NRC procedures.

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nuses since 1987.

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P. 4E 1 CENGTH 49 INCHES i

HEADLINE ' Clamp down/The Silencing of Nuclear Industry

1. rkprs/URC's ability questioned with worker's claims / Charges by Nesale inspector cite lax safety, harassment f'~ BYLIE JIM MORRIS

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CADIT Staff PAT 2',INE ATLANTA 96b705, CRAPHICS Photo Rebecca Long looks through documenta she has j accumulated in a sexual harassment and diacrimination )

Case, cgainst the agency (p. 30) ,

1 AM CREDIT W. Harewood/Special to the Chronicle WTES Copyright, 1993 Hcusion Chronicle ArtEA -- Inspector Rebecca Long says she's seen the dirty side of the fluclcar Regulatory Cornmission: male managers who crudely harassed and 7

discriminated an*e her becauce of her Acx a6d ustdermined some of her o f .s p i tC .

MS. Long says she's seen enough good -- syrtpathetic NRC managers, dedicated irtspectors -- to raske her want to stay on, despite the loathsome things she j

$nys have been done to her since she joined the agency nearly eight yearc '

Ag o . ."

Dtt, r1 st anbl-f4RC, " .t.. '. . ': g , G, v. has ;il/a a voluminnus; sor, discn:..ination and sexual harassment lawsuit against the agency in federal Court Some et the finent people I've ever worked with are here, and they do

<3 hC1 of a job. It's just that there are pockets of problems that need to be

-m cdc.arted out. "

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's. in her first media interview, Long told the Houston Chronicle laat week that I y,ht.hu been harassed since 1987 by four male manager.3 in the NRC's Region II .

0$C n in Atlanta, which overcees 33 reactors in 10 sout.hoa? tern etato , l

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-moukh het 'in tront of other NRC employees and licensees -- utilitico and universities that operate remotors and are regulated by the agency.

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!aproperly' denying her promotions, overtime and bonuses.

Ed.iieving SSsues- .

her of her technical duties as punishment for pursuinpisafety 2,P.Je. . ., -..c. y> , . ?m,'

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anceofLong'sstorygoesbeyondthe'loutishbehaviorsheclaims t 4 Atlanta me'n displayed.lIt castssnew doubt on the objectivity and effectivenkss'o,f clie NRC, ' formed in 1975 to protect Workers and .the public from the h'afardf.oQuggpower. .

Aldough Long's allegations 'irivolve one of the NRC's five regional offices, the Chrontisltnifydviou' sly has reported a growing mistrust of the agency as a Mole andng whistls-blowers at nuclear power plants, including the South Texa2 5g bnt daty-related near Bay City., allegation Many of these workers believe the NRC has not takon their seriously or done enough to protect them from retaliation. A congressienal hearing wao held on the subject last July.

In har interviw with the Chronicle. Long offered a rare behind-the-scones o look. at a closo-kalt organization. The NRC she describes is an agency in which f, sown managers, for petty rancons,

% protolems documented in incpection reports. delete or water down* serious safety It is an agency dominated by good ol4 boys,

• many of them V6%rans of the Navy's nuclear submarine progre.ra. who r%Wrd shoW tootcam much players' independence, and lash out against workers -- especially women -- who i

i Long said."I'm of ten told I can't amount to anything because I'm not a ' Navy nuke, '

• Long said she knew something was am.iss when she was hired by the NRC at an ent;ry-level salary -- about $20,000 lees than what male inspectors with r.orparable backgrounds were getting -- even though she had 10 years' Optrience an a nuclear en-lneer in the private sector. Once she made pay an i%uA che said, Region II managers began retaliating against her.

T ve raised cafety issues and had a performance appraisal lowered as a (E$ ult,'

Long said. Because I've filed EEO (Equal Employment Opportunity) c,owpla b ale."in t s , they brand me as a traitor AswJl not a team playe,r. I*rn an unwant+ d "Three of the men identified by Long -- Frank Jape, Ken Barr and Bill Little are,still with Region II, Br4cd Wilson, left the NRC last year and is working in privateJape and Barr in manageme industry. Jape, Bhrr and union Wilson che grievarme are namedfiled. in Long's federal suit. Little was the subject of a Reoched at his ho::.e last week, Little said: I don't know of any retaliation

• gbinst Long. Jape declined comment. Barr did not return a telephone call to N 5 office and Wilson did not return a call to his home.

Lo ?sids a mete.r'c dugn it nuclear engincoring and spent a decade wi:.h B .:k & Wilcox, a Virginia-banod engineering firm, beforo joining the IIRC in f t 346ary 1986. When she was hir+d by the agoney, the said, she was considered 3p e.c:ert in roactor physics. I had to givo up worki.ng in ty arna cf

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j-f.4 i* 'rgs bong $ept ( AWou can .imaginei bew +4wah116t'lt.'Is to find a saf liiough urf efforts, a plant has been made safer

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i tbechuseL Z'm good

,'opportunity.to do anat it.enorteous

" service to,tig publio,.

I eould It's an .be. all q, m" ..>.% N owedito,do;j ,.,,

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e k ng has inspected most of the nuclear power plants in Regi

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44thority's t$baliation.against whistle-blowers Watts Bar and Sequoyah plants in Tennessee s Ferry ms right here in niy own agency." ,.'.and

a. m think:

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Well, D-they've done worse to1 s

' Lac,g%J0-year-old father, Frank Iend spent 23 years with th

e NRC and its, t.

predecessor, Y29pped,toher.

A, e the Atomic Energy Cotanission,

. He is as M

before retiring i l

'W7be managasient of the NRC ,

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as lo' ng' a^s I can remember, has protected wrongdoers' within the agency, Frank Long said. Ho said beycan recall onl of government service.or- three employees who were fired all from hic yearsthe NRC or the AEC during two So C of the worst offenders, Se.d away tro college on paid sabbatical.he said, were transferred to other offices or Th6,,NRC io

supposed to look for safety problems .

m d it more like a country club for management.reSalved frer aafety problems, period. *

. **They've and take enforce They're not seriously looking O Said Rebecca Long's attorney, Jon timring:

V permitted be.c.au::e of her tocompeten do her job. There should be a place for her in this agencyDecky's stru;g no place for (managers'ce, ) and they've tried to drive her out. There should be person's work product when doing so has safety manifestations.* labeling someone a Long tolls a chilling tale about a research reactor operat e dy Georgia b Tech he# inspection the NRC cited the university f'a.ilure to properly control experibents. ,

including for several violations

'Theysaid.

'Cong were $ sticking enmples in the reactor without doin g safety analyseo,*

k few months later, she said, Fran5 3a m.s kno#.edy, cont;raff to 194 groce ures.pe retractei the citations without her evprriments because of aeye.eatI"O the reactor until ,.Tongary 1988, v.her. the tc.0 ordered itG 1ohy had identified the year before. breakdown in management controlo' - the same irsue to cease all m cy put

{jnockyht something in (the reactor) it would and the sample explodod,' contaminatine a workthat got much more radiation th er, Loner en ;

6 terr. 'rech tha t down t hL i reactor 6pceraission to restart it for nine months.in FwLloary 19e8 and was not given NRC

• 5Lgr.ificant amount for a research reactor,' Long said.It also paid a $5,000 fine.

Th+t,'s..

3 t ong aid that while r.ho was incpecting the p 6%e m m 6ter Toch officialc that iens to the NRC. The employees weretw., university o@loyces had trade salety reacter, serreo* c in P.mim. !1 U. l d

( tb4 t: learn who in Region II was responuible fired, Long said, but the was naver for breaching their l

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s (n late 1968 she said fshe raised twegsagti [h1Ptitimbhing' the positions of~ about the 'lVA's Browns,. , , ,

kMfplaheeper'atsts worimit- ' ~ k.'" ' h' $'

• Me%@6tWesafety-relsted

. ys1ves4u compcI6 Ant's/M.thaB51eht of ficials were trieving r.uclear. . fuel. without monitoring radiation levels. ' ^ ;s ; ,e< >

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Ner boss'. at. the 61me, Bill Little, disagreed *W1Eihdr 'tNidihbs and told her .

_she was ' 'not, + technically competent. ' she said. '

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• IwasorpEndedfreminspecting,*LongsQd/b technical duties were "',

r%4tr d Q asakept from necessary trait 6nh'.

I h etE11ated aga' inst!Yr f6 Browns. Fur W 92 giving her a bad performanca' appraisal'in 1989, rendering her rsiiing safety issues' at inelig;Lble'.for.d promotion and awards.-Long filed a union grievance and the *

' appiaith1Wideclared nu11 and void,'she said, but the decision came too late

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t;o b6fiefibhirp 4 few months before Little gave her the appraisal, Long received a letter of c mmendation from James Sniezek, a deputy executiv.e director for operations at fDC headquagters, for her Browns Ferry inspection.

Irvi990, Long was wo'rking for Ken Barr, who gave her another poor appraisal.

OEe said I needed to take a hit' for filing union grievances and EEo complaints. Long said. He said he was rocciving pressur's fron his management to lower the appraisal . "

1.o.; said Barr tried to suppress and undermine' findings she made during a '

[(3' l$90 inspection of the TVA's Watte Bar plant, which is still under canstruction, and unnecessarily delayed' the issuance of her inspecticn t'epo rt . ,

Barr also pressured me to close (worker) allegations without investigating them,' Long said.

AS it happened, Long's W2tts Bar inspe= tion findings were a major factor in a yearlong suspension of construction at the plant and won her praise from legion II Administrator Stewart Ebneter.

puring a meeting, Ebneter called it the best inspection he hed ever seen,*

Lo?.g said. One of my findings at Watts Bar resulted in a criminal ,

rrosecution."

(ong said she also nad trouble with Barr'sN- boss at theminer Bruce Wilson.

time,spellina

[Wison repeatedly called her an ' ' i d i ot" making orrors in reports and mictreated hu in other W6% She, said.

l.sA said she asked Ebneter for help on several occasionc but he caid he'd i bee [n told by NRC attorneys to stay out ofRegion it." II spokesman Ken Clark l 5&id Ebneter had no comment on Long's case because of the litigation. l

'b, Len;'s discriminat en and harar.rment allcmticM wrinst Frank ht'e d

taracte act. h r witt - t uu.n ep2r.tet 1: tv.. t othat t:ru.

Lens can. .-

e C :yeec -- were heard by a tederal magistrate in 1990. The following yoar the. magistrate held that Long had f ailed to show she had been a victim of 3 clicparate treatment' or sexual hatassment and rejected her claims. t

\ fue a f ed wrni judge who revicw+d tho r wirtrate'c uling decide ! to totry the "j ta$e. which now includes additional allegations. Zimring +axpects the trial to T.8kA.nlace next year.

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. . ngl sal.d, the NRC has resq;i.to[ Ldeng's',now-lengthy listNf l

1. ctlyg itee k and .it's ,ralf ** 4MkS un de' ting',in' recognition of 1Q'

. g;g,g, .

l Kafion. * % ' spo44b'iUg(^'f.o.protectvaployeesfromhatals

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M "MQ l,Nfyl p' W ,i,

. .c# da ,said she'would not haveistied the' WRC 1 ,hthen the harassmaht 'ahd dis 6rimiristion if[it,had firmly disc i

Q Ie began. Instead, she said, the NRC

! I ~ 1(llegal behavior.h a defended him and other Region,II managers who engaged in inappropriate

. . . .s 1

" ' . . ' ' on.ce, I spoke out against management, I basically became an enemy of'the ld}Qi,%48mt,'sh'esaid. They began circling the wagons.* ,'

gic p A :y jJ 4

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position, spelled . . ~ . "<a "gyciNg: ;NRC'e. i 9e%n Atlanta, is tha,t ^ n letters to Zimring from the, U.S. qittgroey's'

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tp, mediation unless )s $$notc.cotinider settling Long's lawsu'itTor ?

.- igns.

Mat; Long says, is something..sh's, . won't do. ,It's a matter ofE inciple."

MO(f .edfy 30 ,f . ,

• ' /

• kC Chaiman Ivan selin has pdb$cly, vowed to protect nuclear industry workers

';(rbmretaliationforraisingsafetyj. concerns.Andsoonafterhetookthepost '

. "pn July 1991, he distributedTo Nhc employees a videotape in which he outlined M g policy regarding sexual harassment and discrimination.

TWinference Long drew was that Selin at least would listen to her problems and might even intervene on her behalf.

So, in April 1992, ,

his immediate intervention.* Selin never responded to the letter orsho cent selin a lette

.sulsae:;uent telephone messages, Long caid.

.Salin said in a telephone interview last week that be could not comment on V L. ting's case because of the lawsuit.

llom/ever, he said, The NRC, like other federal agencies, has become in::reasingly sensitive to sexual harassment and the many different forms it can take. We have recently issued a new brochure specifically on this topic, '

d ich broadens the range of remedies and opportunities available to the person

% e thinks she has been harassed and to her supervisors."

$glin maintained that the NRC is no worse than other agencies but said: We hWe had a couple of cases in the past of sexual harassmente It's been fairly SWetle h rassment, but when we looked into it the cc: plainants were right. -

We're certainly not immune to this problem. "

Salin said he believes sexual discrimination is otrongly coveredT by 4 Wisting NRC policy. Long rails at such statements.

o Taey don't seem to care about discrimination," she said, and they haven't done.aanything about the harasernent 1 *ve endured. "

l.org's battle aoainst the Region II men, she said, has run up more than hoo,000 in legal expences and Ivined seven years of my life.

"So many days I would erme home frm work and jurt elekt el a3 ta b .o jai frovn th" etre c .

.v e -y'C Cone to me that day," s:he said. '

or my friends and the moral support of inspectors who weren't Ii it weren't.

afraid to do right thing, I never would have survived this."

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.,SPECIALINSTRUCTIONS:

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l ATTACHMENT #7 E.F. Cobb Memo Nuclear Safeguards Committee Quorum 5/24/94 1 page j

Southern Nuclear Opera:ing Company Post Office Box 1295 Birmingham, Alabama 35201.t295 Telepnone 205 868 5000

. Southern Nudear Operating Company the southem electnc system May 24,1994 4

Nuclear Safeguards Committee Re: March 17,1994 Meeting Draft minutes of the March 17,1994 Nuclear Safeguards Committee Meeting show that six members were present. Six were absent. Those present were: R. Braga, P. Desai, S. Ewald (Alternate Chair), S. Ghiassiaan, B. Kahn and J. Vickery.

The charter for the Nuclear Safeguards Committee specifies that, "The quorum shall consist of not less than a majority of the Committee membership and shall include the Chairman or his designated alternate. The operating staff may not constitute a majority of those present." The operating staff are not members of the Committee and the designated (Alternate Chair) was l Steve Ewald.

With regard to a quorum, six members do not make a majority, seven are required.

Consequently, the meeting conducted wi'.hout a quorum of members did not conform to the charter, and therefore, may not be considered a formal Nuclear Safeguards Committee Meeting. The documents reviewed on March 17,1994 will have to be reviewed and approved again in a Nuclear Safeguards Committee Meeting that has a quorum of members present.

We will review the documents from the March 17,1994 meeting at the beginning of our next meeting scheduled for 1:00 p.m., July 14,1994. To facilitate the review, all material from the March 17,1994 meeting and a copy of the draft minutes of the meeting are being distributed by attachment to this letter to the members who were not present during the March 17,1994 meeting. Members receiving this material are requested to review the documents prior to attending the July 14,1994 meeting in order to expedite the review and approval of the -

documents during the meeting.

Please call me at 205-868-5161, if you have any questions.

Sincerely, E. F. Cobb, Chairman EFC/esg Attachments cc: See attached distribution

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1 ATTACHMENT #8 Nuclear Safeguards Committee Minutes j Student Irradiation 12/8/94 l

2 pages 1

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MINUTES OF THE NUCLEAR SAFEGUARDS COMMITTEE MEETING OF p p December 8, 1994 A6 v >

Members Present E.F. Cobb (Chair), R.A. Braga, P.V. Desai, S. R

/l Ewald, S.M. Ghiaasiaan, P. Girard, B. Livesay, j F L. T. Gucwa Otherr, Present: R.A. Karam, R. Ice, S. Stock (MSE), B. Statham The Chair called the meeting to order at 1:00 PM. l

1. Minutes of the Committee meeting of October 27, 1994 were approved.

2. Procedure Modification Minor modifications to procedures 0001, 3500, 4501 and 7246 were approved after discussions.

3. Procedure Deletion  !

It was agreed to delete Procedure 7276.

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4. New and Old Business j R. Karam informed the Committee that the NNRC is currently discussing with NRC the conversion of the GTRR to. a lower i enrichment fuel, as well as a 20 year extension of operations license. The NRC has approved the amendment request to convert to low enrichment fuel. The request to renew the license is being evaluated.

The DOE lacks funds currently to furnish the lower enrichment fuel.

R. Karam also informed the Committee about a hearing held by the NRC in Washington, D.C., in consideration of Ms. Glenn Carroll's request to deny the NNRC a license to continue operation. Ms. Carroll has until the end of December,1994 to come up with supporting documentation. Another est by Ms . ,u Pamela Blockey-O'Brien suggests that there is, nsafe soil under the NNRC. In actuality, the soil und the reactor #JGgi consists of weathered rocks. The NRC has asked the NNRC to inspect the sewer facility at the NNRC.

R. Karam discussed'the failure of an older X-ray diffraction equipment where the shutter malfunctioned and a student may have been exposed on December 6, 1994. The student has been satisfactorily checked out. Further determinations are in j progress. Although the dosage was well below permisalbJe O limit, R. Ice and S. Stock asked and received an authorizat2.c.t 1

I to research the issue further. The machine in question has

)

' l Minutes Nuclear Safeguards Committee December 8,-1994 O

Page Two >

been tagged out. At the suggestion of E. Cobb, the Form A approval of' the PI was temporarily suspended until a final report is made to the Committee by R. Ice. R. Ice was asked to keep the Committee informed on the progress of the student.

It was also suggested that the student be kept informed on the progress of the findings and the monitoring of his health. An interim subcommittee was appointed consisting of S. Ewald, B.

Livesay and B. Kahn to keep up with further developments.

The next meeting of the Committee was scheduled for 19th January, 1995 at 1:00 P.M.

The meeting adjourned at 2:25 P.M.

Respectfully submitted,

\) h Y ' (C Prateen V. Desai, Secretary O f I

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i ATTACHMENT #9 E.F. COBB Memo to Wayne Clough Old X-Ray Producing Devices 10/13/95 l

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' NEELY NUCLEAR RESEARCH CENTER 4

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ATLANTA, GEORG!A 30332-0425 USA (4o4) 894-3 Goo October 13, 1995 4

MEMORANDUM TO: G. Wayne Clough, President Prashant Desai, Textile Engineering Ahmet Erbil, Physics Henry Paris, GTRI/EOEML Byungwoo Park, MSE Stuart Stock, MSE Donald Vanderveer, Chemistry Jesse Wampler, E&AS Roger Wartell, Biology Angus Wilkinson, Chemistry Loren Williams, Chemistry FROM:

Emsley F. Cobb, Chairman, Nuclear Safeguards Committee

SUBJECT:

"Old" X-Ray Producing Devices The Nuclear Safeguards Committee is comprised of twelve technical experts in various fields of science and engineering. This Committee is appointed by the President of Georgia Tech and is charged with the responsibility for maintaining the health and safety standards associated with the use of radioactive materials and x-ray producing devices. Radiological safety and radiation protection are central issues which the evaluates. Instrumentation-control systemsCommittee play a carefully vital role in radiation protection. "Old" x-ray producing devices often lack the appropriate interlocks for high probability of pafe operation.

l Recently, a student inadvertently placed a hand in an x-ray diffraction beam. I A review of the incident indicated that the potential exposure received was just v!. thin legal limits. The student narrowly missed a significant radiation burn. This beam, while small, is an extremely intense source of x-rays.

The accident would not have occurred if the unit had met current x-ray equipment cafety requirements.

The Committee recommends strongly that all unshielded, non-interlocked Currently, x-ray diffraction units be removed from service.

administrative there are neveral of these units in service under controls.

n Administrative controls or controls by procedures are adequate provided users of the x-ray units follow d the procedures verbatim.

Unintentional deviation from the procedures could cause harmful radiation exposure. The Committee recommends that these units be replaced with units that have interlocks for safer operation.

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l ATTACHMENT #10 State of Georgia Criteria for a Broad License (Health Physics) 1983 l

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. I,h CRITERIA:

TORMAL EDUCATION AND CERTIFICATION EXPERIENCE A. sachelor's degree in health physics A.,3hree years of Applied thealth' physics emperience

, in a, program with radia-I tion pe8 stir; problems, simi-t g M GAsestn'the program to be'menaged.

B. Bachelor's degree in radiological health B. (Same as above)

C. Bechelor's dagstesia a physical science ' C. (Same as above) 7with'enei year of graduate work in health physice' D. Comprehensive certication by the American D. (same as above) n Board of Health Physics d -

In cases where the license applicant believes that a person not satisfying the above criteria is qualified to act as the radiation safety of ficer in its program, it may submit a description of the training and experience qualifications of the person in question with supporting justification for utilizing the individual as the radiation safety officer and relating the specific qualifications of the individual to the demande of the position. In doing so, the applicant should consider each of the criteria. listed below and specifically state the qualifi-cations of the candidate radiation safety officer that meet these criteria. In l addition, should the applicant feel that any of the below criteria are not appli-  ;

cable to its program, the basis for its position regarding each such criterion I should be explained. j e RADIATICH 5ATETY OTTICER CRITERIA Gh C 1.

Ability to communicate clearly, both verbally and in writing.

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2. Knowledge of mathematics, physics, chemistzy, and biology sufficient to gj[ understand health protection standards, theories, and practices.

3. Knowledge of current standards, guides, and reports published by organizations jy [4 *3 .

such as the International Comunission on Radiological Protection, the National Council on Radiation Protection and Measurements, the United Nations Scien-tific Committee on the Ef fects of Atomic Radiation, the National Academy of sciences, etc. and the ability to understand, interpret, and apply them effactively, j

4. Knowledge of and ability to operate and interpret the results from radiation measuring devices associated with the- use of the radioactive materials. l

5. Knculedge of and the ability to understand and apply the applicable Georgia, s

. - __ _ _ _ _ . - ..____._m. . . _ . _ _ _ _ - . . ___ .. _ _ _ _ . . _ . _ _._ _ _

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e NRC, or other Agreement or Licensing State' regulations, guides, etc.

6. Knowledge and ability to evaluate the need for shielding and the types

., and amounts of shielding required.

7. Knowledge and ability to calculate radioactive decay, build-up, and se-cular and transient equilibrium.

8. Knowledge and ability to calculate internal and external radiation doses.

9. Knowledge of personnel monitoring devices and ability to select the proper device for a specific application.

10. Knowledge and ability to manage or conduct a radiation protection training program for facility personnel, including both radiation workers and non-radiation workers.

j (pc 11. The knowledge and ability to recognize and. anticipate existing and potentia'l problems and to take appropriate and timely. actions with respect to them.

12., Knowledge and ability to select appropriate radiation and radioactive -

materials measuring devices consistent with their proposed use.

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13. Knowledge and ability to apply effectively current radioactive effluent treatment methods, equipment, and procedures.

14. Knowledge and ability to recognise potential contamination associated with M -

the use of radioactive meterials, control such contamination and decontami-nate equipment, facilities, and personnel as necessary.

15. Knowledge and ability to prepare a facility emergency plan and conduct or manage operations in accordance with the plan. ,

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, 16. Knowledge of and ability to evaluate, select.; maintain, use effectively and

}. . , supervise the use of protective clothing and equipment (respiratory protective

.' equipment if required). .

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17. Knowledge and ability to evaluate, design, test, maintain, and supervise the maintenance of process control and confinement system such as gloveboxes, hoods, etc.

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18. Knowledge and ability to evaluate, select, design, maintain, and test sealed i sources of radiation and devices in which the sources are to be used.

19. Knowledge and ability to evaluate r select, design, use effectively, maintain, and supervise the use and maintenance of waste collection, treatment, packaging and disposal equipment, and the facilities with related radiation safety pro-cedures.

( p' 20. Knowledge, ability and authority to manage, effectively the license applicant's radiation safety program.

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ATTACHMENT #11 Notes of GANE Volunteers

, Nuclear Safeguards Committee Minutes Inspection Reports 47 pages

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The. ConmITne Imposed The Srm A lbyesT k<hh The Gilowly condlrion Ge a cont loved opriruk, and cypoisTed o GubccomlTRe to okrsee The so n and bsve on IoTir!ir1 affroVal, I, A deTal led revlcw< of all (vocedv/es befort any coot lAM qperarlon. l 2, An lnvesTaya7,'en -for a los9 Tean s^oler,k  ! Te % ptbblem; E,e, li~roy incivk alTens7l% 5veh as reTa,fl Tris l 3 o r:s u . , _3ma s -i, i,' thoas ent all safely modiflc.rlons ,O h- s- I~r e l l l i l l s t)  ; e 0* ChTah!ny of a circvlr dlm am ThaT l Specif/es TAe gj:xviith of & 5/ rsrer, whh 5& Rod lficoTim a< necessacy l To assure 54v7Ter sah7y, l T Choi *, The loMl Tree lppsed h Follo43 andlTlons l fv a cont lnved opetalon & &, CM's ferearth i In A f re 6

• n (sic) s,'on shall be posted by %e doer IndicaTln3 ThaTall pehens leaa5 The ham \

evir mantrar hrselas -Por conTominarfon l beFm Ievi3 The roon. A 16 ho d & in i rec lng on Is To be t>>a kralned, 2, qmlAc safey ptscedwes for % vse & l'oalo l,ar. pes att r, be pared, In oakrlon, The p pos lAr S ls (tquired To cooTain The tvsrby %r* no G procedwal variance is allod wirhour de P, z, '.s speelfk 4 proval. " VI, On, (au discvs: sed h NAc hea45 on complainn by l % clTIntnr t%ad'y safe cpunk of The NNAC, He plAted our %T The NRC is saTisfM wha The sdety of The enTlre tractor gearkn, U i e43hs \ T, Gevb!cas of lasT thwTlQ thiscs, l Tre M I y Src,h coedNons 3+4, Tytm V,1-1 Aemw The arr) " prom lnare" l l l 4 O O O R Ilow dhewsa) osa alted k cosmitree Tirv & 74e finol trper En,e k, WI on TJe con %rian IAcident The Comitree uns of k opinion %T Bt, Chol bas fuIClIls] k ccsdiWans [see ByIsgd thkuTes CI9hs) for a conTinved operoTian. Trir expecTid k^r 7heik l will be dr leair oss adalrlenal au dlr v0lr by Dr. %ce To th Chol's job befree f///qg, U TV, f0rm A cpivvals " J; pl. W pter : % X-tsy unir h old and o+ ovTdared l hesl$n En Tl\e ctATexT oF strfeTy issvts, ll0MVt.:q Tfe way lr is he!ny opera,ac) yb TAe P,r, osa Als as5vclaTyr l U/1dt? bl5 SyvIslos, is deened soQ pivvided TlcY to l vndergiudvare are alload To operoTe lr The , ,- & ITee gcw } Ts cg/butsl, 5l Iffy 96 bt Form A tw vest U, Groc)().' Th!s ws bas l ally a progress NporT Inadt by l S.R. sroo in re,ene s to TAe t%vliemesrs inywsed by 7bt NSC En a pitviovs lhecT!n9, TT kats noTed TbW $ Gub~ CoMiITee OVMl% The ffopftsS l100 0lfecc]( opproved 0 Cony!!ved oferbTl# tinh l Sa!r\f resrtlcT!veSfe(!S'lCond/Tl cts, e.. The com,(Tree cytb,,<) T},e subeoMIIre:'S (tcomtendoT!,e ced The G A /kqw:si, S. Te Ol0rlsdAa

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ma s , v a r vi.ws,o+ sr rai.r:co euy v., a:.cu,, a by a. xa " l l One so,'r sTlIl noT ln [Jue in ke) l l $I.2t l95 3, BreadwT To k I?eurors literst, . ... Tn beleF, - & asexaresT vas To ckvge % Ad"!n STruervet hm & 019 To The O{4(ce of The Dean 05 En3 terAny, I All theMbers (blutdQ f yla Tele &ne Cf/Med & Chan3e viTh osly one excepTlon, Ove Ti 7he /16Censp To afvsT To The /het3aaba) E/vch/e of JRA, The feco.verdirlan for The c& tAs frw&rtktl anc) aa v d ," 4, Fom A ; 90et c I/arTo " Aepesr um 4,, mar inTeth gpreni b Trunsk 0f /hdlcacTlye AaTedal [w Room 214 To Acco Sto in k Cheny Enem Gldl9, A/PAdv2D. V S. " RevkJ leirer fear &. T,3, 0ldrlsTlna conceml9 conecTi'a meswe T. he Tak in Tie horeil.'9 ef isotopes in his labonTor a The CetntTln phcedvies' were jv)) acceprble o O 4, Fom A redu llllt/95 4,I- Diven ihr)(er Tbkes c*r br Taylor as Pr on (o-Go irrad,'eTian sovites, (Taylor 1%T!ind) 5,2 " Cuarir AF4 irs (s0 ln'k: A koe lofvu m canttree sr gecaciry or A nRc has been incred sla The lac lkr: lie anfIrmed %Ther %T"is s;ecurity xne us vlalared, Sab $ht >on Svrtt ke/M4I, / W ks ontloscal kT' The (esim Gov /tt tvill be />,oed % Emersn Gs,'Idkg shocTly, \1 l l O O s/de 12/dn k W ~ Q 'J ' c ov7 olny S a re s k'p w 7kr poperaer Is s7arTec] 13lN/9s paprvoir is bily had-Jard e taltdv 6/ttl% paperverr is Cisdly g%pel 8/9/95 safeb cleVs 6/Wl95 Perfmd b Tavdei Re%) y by Ebat  % ey rce els/w? t1/Iulss w dya ks p s e n d by Tobantes STrydom 12lIrl95 heVIeVed by Edg ar Tavdel 10.hl98 95 l Stlan Nrl( Froml Feirt s% yam "To r,5a,Js To % de dieser # 9s9soi I hls T waste cosRist no EPA listed or Cbe*cTer/ 5 7fc # )1c2n d us u sTE Th& GbNedi'S fcpe/ Work thiYieTe') 9/99(q O ) i OCTOBER 19. 1989 MEETING ) The Chairman and several members of the Nuclear Safeguards 1 Committee (NSC) met on October 19, 1989 to consider the problem of the leak associated with the bismuth block. B. Kahn, Members present were 1 1 P. Desai and J. Mahaffey. Non-members present were R. Karam and B. Revsin, j The group was informed of the status of the repair of the block and was presented with the plans for a temporary solution to the leaking problem, i. e., to install a catch system which would collect the leaking water, circulated through a 5p filter and a deionizer column, ultimately returning to the tank of the bismuth circulation system. The reasons for suggesting this temporary fix were several: 1) attempts at repair by application of epoxy to the block had not been totally successful even though a diminution in flow had been achieved; 2) dose rates at the leaking block were approximately 5 R/ hour at the surf ace of the inner block which significantly limited personnel time in the area; 3) the leaking system does not appear to pose a safety question and since there are numerous commitments already made for reactor time, shutting down the reactor for major repairs would impose a great hardship; and 4) the Center is in the process of negotiating contracts with several clients which require the reactor to be operational. This business is essential for the Center's continued existence. s The deliberation of the group resulted in the enumeration of O areas that need to be addressed. These are enumerated below.

1. Radioactivity content of bismuth block cooling water.

2. Water-Bismuth Interaction Needs Review

a. Has shielding of the gamma rays been affected.

b. What is the chemical reaction if any?

c. Epoxy coating over the bismuth.

3. Water-Magnesium Interaction 4

4. Heat Removal with Reduced Flow (15,000 BTUs at 5 MW).

a. What if remaining water does not cool block?

b. Estimate temperature rise

i. without cooling

11. with 3/4 normal flow

5. Test Run (approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />)

+ - - + - We- TJ *am-t+ e--a- y e=r-- -m e -iwe-- +- e- -g - m- e r-- - _ =< _ _ . _ . ._ . . . _ _ . _ _ _ _ _ _ . _ _ . _ _ . _ . . ~ . _ . - . - . . . . _ __ . _ . . . 7 __ . . . . _ _

6. Permanent Correction to Problem

a. Cost

b. Dose Estimate for personnel doing work.

Several of the group viewed the bismuth block at the termination of the meeting. It was agreed that Dr. Desai would perform the BTU calculations at various coolant flow rates by , Monday, October 23, 1989. Karam and Revsin will address the remainder of the items. It is anticipated that the entire package will be ready for presentation the NSC which meets on Friday, October 27, 1989 ~ MINUTES OF THE NUCLEAR SAFEGUARDS COMMITTEE MEETING OF July 19, 1990 Members Present: E. Cobb, P.V. Desai, N. Gordon, L. Gucwa, B. Kahn (Chair), L. Petherick, J. Vickery Others Present: B. Copcutt, R. A. Karam, G. Poehlein Distributions: (1) Agenda for the current meeting (ii) Copy of Lettel from the Georgia Dept. of Human Q1ationf to B. Revsin (iii) Form A apy w val draft from R. A. Braga . R os c a- U s-Chairman B. Kahn called the meeting to order %at 1:07 P.M. The minutes of the previous conunittee meeting of June 28th were not ready, and will be available- at the next Connaittee meeting on August 30th. 07<

1. In response /to the letter from the Georgia Department of Human Sesources] concerning conflicting roles of the Radiation Safety Officer (RSO) and the manager of the Office of Radiation Safety (MORS), the Connaittee decided to do away with the title of RSO for the chair of the O

NSC. It was recomunended to ask the MORS to keep the NSC l informed on issues related to radiation safety. The Connaittee asked R. Karam to send a copy of his response to the Georgia DNR to the members of the NSC.

2. The Conunittee heard from Dr. Poehlein regarding the advisability to limit the period of service on the Conunittee to three consecutive years. It was agreed to divide the members into those serving for three years, those for two years and those for one year. Each year, one-third of the membership will be appointed for three year terms. B. Kahn encouraged the members to suggest possible candidates to serve on the Connaittee.

3. The Committee gave Form A approval to Dr. R. A. Braga.

4. The Conunittee approved a minor change in previously approved Procedure 9155.

The Secretary of the Committee had to leave the meeting at this time (3:05 P.M.). L. Petherick prepared the remaining attautes which follow. O O Nuclear Safeguards Committee Minutes for July 19, 1990 Page 2

5. Dr. Karam briefed the Committee on the responsibility and liability to Committee members. He stated that the Nuclear Safeguards Committee Members rendered their decisions based on the information given them by the Neely Nuclear Research Center personnel with no liability for decisions or recommendations made by the Committee members. However, Institute faculty and staff who are members of the Committee are afforded protection through Board of Regents' insurance policies. Non-Institute members.of the Committee, of which there are two, may not be protected as Institute members are. The two non-Institute Committee members recommended that they be furnished a letter from the Institute guarantoeing them indemnity against any liability charges brought against them for service on the Committee they render free of charge to Georgia Tech, with the exception of their knowingly giving false or misleading information.

The two non-Institute members stated that they would send to Dr. Karam a suggested or recommended wording for a letter of indemnification. Dr. Karam also briefed the Committee on present reactor operations: Mitsubishi contract; Department of Energy considering the reactor as a back up for research and development; and the Savannah River Project is still on go awaiting approval from the NRC. Dr. Karam briefed the Committee on hot cell operations: They have a contract with TVA for radiation qualification testing of cables and circuits. They would be irradiating this material with 80 to 100 mega-rads of radiation. i There were two NRC inspections held at the Neely Nuclear Research Center. One inspection resulted in 0 violations. The other inspection resulted in one violation in which the NRC inspectors discovered a graphite stringer with an excess of 100 milli-rems of radiation per hour that was not locked in a physical space. This violation was abated immediately upon being ' found and response to the NRC is being prepared. l ~ O Nuclear Safeguards Committee Minutes for July 19, 1990 Page 3 Reactor has been in operation up to a power output of 4.5 megawatts. The reactor has been operating mainly during the night time hours because of the high daytime temperatures. Everything appears satisfactory in all reactor operations.

6. The meeting was adjourned at 3:15 P.M.

Respectfully submitted,

• 9 Prateen Desai O

O ( .U w f Georgia Institute of Technology lJ.} J NCE.Y NUCLEAA AE9F.AACH CrNTER \. ca00 A*LANT C De*VE l ATLA *dTA r.FOf40th 3033Soe#S 9 ~ t.b., u. 1, , .  :. .~ b l7. 8 1 *. i. E ...e ,...b A.. .a reb et . Ef . f '} ^ 1 rpe .. . f Oser Patibt m For several seaths we have discussed my desire to leave the ' Huelomr Research Center. After due cessideraties, I have deelded that I should leave et the end of this meeth. As you know, I have been leeking for asether positten at Georote fondn. Tech, bewever, a traesfer ese %en held up by lack of befora October there is a possibility that fuads will beoene available on November 1. J1, and if se, I shall transfer to a new posities Even if funds are set available, it is set in my interoet er coorgia my stetus,Tech's interest to prolens this period of uncertainty is should a traaefer not ooeur, I will resign from Seergia Tech at the end of workday Oeteber'31, 1989, 1g Thank you for your understeading,  ; .ia.orel ,, A M#. MM" metert u. maedeseld { f 5 e . u v. e,a... ., ai....-.,..,c-.. gegg n,eenssaammeseenemisme%mannia 3 i CERTIFICATE OF SERVICE - Docket No. (s) 50-160-REN DOCKETED USNRC O Secretary U.S. Nuclear Regulatory Commission ' Docketing and Service Branch 56 FEB 23 P2 06 Washington,'DC 20555 0FFICE OF SECRETARY Office of Commission Appellate Adjudication 00CKETING & SERVICE U.S. Nuclear Regulatory Commission BRANCH Washington, DC 20555 Administrative Judge ' Charles Bechheefer, Chairman Atomic Safet'j and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 t Administrative Judge Peter S. Lam Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear. Regulatory Commission l O Washington, DC 20555 Sherwin E. Turk, Esq. Susan S. Chikadel, Esq. Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Randy A. Nordin l Manager - Legal Division E. Gail Gunnells Office of Contract Administration ' Georgia Tech Atlanta, GA 30332-0420 Ms. Pamela Blockey O'Brien D23 Golden Valley Douglasville, GA 30134 Alfred L. Evans, Jr. Esq. Senior Assistant Attorney General 40 Capitol Square NW i Room 232 State Judicial Building Atlanta, GA 30334-1300 l l The Honorable Zell-Miller .Governoriof Georgia O State Capitol Atlanta, GA 30334 'The' Honorable John' Lewis . United States Congress 229 Cannon Office Building Washington, DC 20515 Wayne Clough, President-c/o Dr. Daniel S'. Papp Executive Assistant to the President Georgia Institute of Technology Atlanta, GA 30332-0325 John Galloway ~25865 Georgia Tech Station Atlanta, GA 30332 Dieter Vandenbusche, President The Environmental' Forum A Georgia Tech Student-Organization Student Organizations Atlanta, GA 30332-0283 Jeff Favorite Apartment 12H \ 1185 Collier Road NW Atlanta, GA 30318 Rob Johnson 125 Estoria Street Atlanta,-GA 30316 I 1 i

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