ML20112E021

Testimony of P Blockey-O'Brien to Bechhoefer,Kline & Lam of ASLB Re Georgia Inst of Technology Neely Research Reactor & Parts of Associated Bldg Complex Which Fall Under Terms of Original License.Testimony Part of 2.206 Petition

ML20112E021
Person / Time
Site:	Neely Research Reactor
Issue date:	05/22/1996
From:	Blockeyobrien AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20112E009	List: ML20112E021 ML20112E086 ML20112E088 ML20112E096 ML20112E109 ML20112E128 ML20112E146 ML20112E171 ML20112E184
References
2.206, NUDOCS 9606050124
Download: ML20112E021 (41)

Text

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TESTIMONY TO THE HONORABLE JUDGES BECHHOEFER, KLINE AND LAM OF THE ATOMIC SAFETY AND LICENSING BOARD, ON THE MATTER OF THE GEORGIA INSTITUTE OF TECHNOLOGY NEELY NUCLEAR RESEARCH REACTOR AND PARTS OF THE ASSOCIATED BUILDING COMPLEX WHICH FALL UNDER THE TERMS OF THE ORIGINAL LICENSE.

FROM PAMELA BLOCKEY-OjBRIEN. (Member, I.F.O.R.)

(This Testimony is to be considered part of my "2.206 Petition under 10 C.F.R. Chapter 20 before the Executive Director of the '

i NRC and the NRC Commissioners. It is also given in support of the G.A.N.E. proceeding against re-licensing the above.)

Honorable Judges, I offer this testimony to the memory of JANET LOWE,who was working with me many years ago to expose what has been happening at this facility. She was killed in a mysterious hit and run event, a few days prior to her giving testimony against the Georgia Power Company and some weeks before a press conference and investi-gation we were working on was to be announced. About 15 years ago she was the G.A.N.E. representative. Because Janet was a Jewess, I of f er these words f rom the TAMW4b :"Every contoversy which is for the sake of Heaven will in the end endure, But one which is not for the sake of Heaven will not endure in the end."The words "for the sake of Heaven" being defined as "to establish truth" in the Comment-CMries. (The Living Talmud, The Wisdom of the Fathers. p.216, Select'ed and Translated by Judah Goldin.)

So, Janet, "for the sake of Heaven", this one's for you.

In addition to the many letters submitted under my 2.206 bbready I will cover many issues. I was going to start with bd4 overall manag-ement, things like : what took Tech so long to discover scientist Gruen (spdlling ?) had been bdshing holes in the wall of the old Civil Engineering Building and dumping contaminated rags and liquids in the walls (Source, Mr. Lupton and Mr. Boyd) Ehd poor Mr. Boyd had to tear the wall out to try and clean up all the Cesium-137. but I decided to go first with the " good ol' boy / cover up" angle first that NRC Inspector R. Long and G.A.N.E. have referenced.It needs detail-Ung not only to show how this awful situation has existed so long, but to show, as Senator Abraham Ribicoff once said in regard to the NRC's predecessor the Atomic Energy Commission , it becomes " difficult

.n.to:4stermins. inakhetorganinHan schema 14f,hhadiS0t @artsh Commission ends and the industry begins." (p.39 " Meltdown, the Secret Papers of the Atomic Energy Commission" by Daniel Ford,former Exec.

Director of the Union of Concerned Scientists.)

I have made a chart on this : In 1937 the Industrial Development Counc was formed in Georgia, it incorporated in 1946 . Later the so-called EES, Engineering Exp@riment Station the original name for this l program entered the picture at Tech, the sub-critical reactor was brought in to it in the 50's thankd to the AEC, (the forerunner of the NRC)WGeorgia Tech and the Board of Regents and the Georgia Power g( Company,thb purpose being to train reactor opdrators across the South 1 to turn the south into a nuclear bastion from a power and defense

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2 I'dlieve b the sub-critical reactor fueled with uranium slugs is the one you saw stashed near the stairs. That was followed at the Engineering Expdriment Station by the 1 MW reactor i.e. this_

reactor later upgraded to 5 MW. The EES was a research facility loosely tied to. Tech, but NOT a part of TECH. By 1971 it had a budget of $7.2 Million, mainly funded by the DEPARTMENT OF DEFENSE In 1971 Dean Thomas Stelson first shows up helping to push a merger of some typd of the EES with Tech so it can get its money-grubbing little hands on federal funds (Atlanta Costitution 4/1/71 l E'xpdriment Station, Tech Pushes Merger Plan) It didn't seem to bother anyone that it could be illegal under Georgia law according to then State Rep. Clayton Brown Jr. (" Merger at Tech in Peril" Atlanta Constitution 4/21/71) This was the same Stelson who pushed the re-organization plan putting Dr. Karam in charge later,that caused the huge problems,part of the basis for this GANE action.

Admiral Rickover, father of the " nuclear Navy" had already set up a contract between Westinghouse and the A.E.C. a sort of co operative agreement (see " Meltdown") ,

facility had to encapsulate 2,500,000 Curies so when in 1972 the of Cobalt-6o forEESf@Wawl Westinghouse and Nasa that resulted in them contaminating the " heck out of the place" (Robert Boyd former RSO) including the sewers, where they nearly lost Atlanta & Robert Boyd) the NASA / Westing-house / Tech relationship was in full bloomI am not sure if the EES wa =

vas fully merged into Tech, but Ron Bell the CFO of both the Georgia Tech Research Instit'te u and the Georgia Tech Research Corp.

said to me GTRI used to be called the EES (April 8th 96 phone conversation) In any event, in 1984, the Industrial Development Council became both the Georgia Tech "Research Institute (GTRI) and the Georgia Tech Research Corporatid$ NNth are headed by the Preside of Georgia Tech Wayne CLoughBoth have the same CEO,CFO Agent and Secretary , the only difference is the Applicants Attorney on GTRI, who is listed as PS ARKWRIGHT, who I believe was a head of Georgia Power Co years ago, anc a George H. Lanier has that position with GTRC. Both GTRI and GTRC are listed at the Secretary of States Office as PRIVATE CORPORATIONS, and as non-profit corporations. Both have no business license (a requirement of the law) and according to Dun and Bradstreets Million Dollar Directory for 1996 and the Atlanta Reference Library (April 16, 1996 phone call) the GTRC made $136,000,000 in 1994 has 1500 employees and was founded in 1937. The Secretary for both GTRI and GTRC is the former head of NASA, Admiral Richard Truly5Techs PR man told me the reactor is also some kind of sub-unit of the Georgia Research Alliance (formed by former Gov. 2er Harris and others and the Atlanta Business Chronicle 10 9.92 says Georgia Tech is racing into Biotechnology and quotes one Robert Nerem professor and co-chair of the new health science and technology committee (,who contaminated the hell out of his lab, hallw

-way and peoples shoes had The GTRC has a contra with Neutron Technology Corporationto be thrown of away.}

Idaho (where INEL is that 3

has ties to Tech (Dr. Karam) and the reactor, Neutron Tech and GTRC's contracts involve the leaking Bismuth block to then do so-called Boron Neutron Capture Therapy to kill a type of brain tumor called GLIOBLASTOMA. The Dept. of Energy, according to Dr. Ice, rated Techs reactor the best in the country for Boron Neutron Capture Therapy. The Dept. of Energy has huge contracts with the reactor over the years. When the A.E.C. got

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l split up by a disgusted Congress into the Nuclear Regulatory j Commission and the Dept. of Energy, it became the DOE's job to '

push nuclear weapons, nuclear power and so on.Many space shuttles have nuclear " payloads" . Dr. Ice has a distinguished military career and is an ardent proponent of BNCT for the treatment of l glioblastomas. Admiral Truly was an astronaut. A prime cause J of glioblastomas is solar flares in the irradiation of military space crews, other causes of gliob? astomas are mustard gas exposure, l radiation from low energy high dose radiation, electromagnetic l radiation / power lines, petro-chemical and solvent exposure l widely used in engineering, construction and petroleum industry I and vinyl chloride exposure used in the same industries. The backers of Neutron Tech in the BNCT / leaking bismuth block /

venture with GTRC are Morrisson Knudsen Engineering and construction l and Vestar Inc., a pharmaceutical co. . Solar flares can I also cause endometriosis in women. Wouldn't it be better if they all, (4dmiral Truly, GTRC, Dr. Ice, the DOE, Neutron Tech etc.)

just told all the military space crews and high altitude pilots l and so on that that the job related exposures can give them glioblast blastomas down the line, forget the billions they want to spend o constructing space stations and use the money for free national hea:

health care and cleanup of this nations over 40,000 potentially radioactively contaminated dumpsites ? And the other industries can find non-polluting alternatives to what causes glioblastomas.

Tech does not have the permits from the NRC for all this anyway

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according to the NRC's responses to me. and this dump of a reactor is not the place to attempt it anyway.

The State Department of Natural Resources Radiation Protection Division, which, like the Nuclear Regulatory Commission,is also funded by its licensees the nuclear industry, also holds contracts to the tune of up to nearly loo,ooo dollars a year, wit'hrtRe same GTRC. All the GA. EPD Radiation division environmental surveillance seems to do, is go out and collect the samples and do the odd oversight ( I am not speaking of the inspections'here) as under the terms of the contracts, which are attached, the GTRC not only runs all their tests, whcih includes the ones in their own backyard at Tech, , it does it for EPD STATEWIDE at all_

Georgia Powers plants and outside the DOE Savannah River Facility,

-it gets worse - they help write all the Environmental Radiation Monitoring report books and reports for Ga. EPD radiation division, there is a provision too that Ga. EPD can interfere in Tech publishing any data in research papers , presumably on the effects of radiation and pollution, that they don't like, and to top it off.

the internal files have reports that show Tech /GTRC saying the on campus soil contamination is from the facility, that does_not appear in published reports. Internal files show that TLD's have been missing, , that there is contamination all over the place,--

that the contracts specify Dr. Kahn, who contaminated his own lab, that and that he is on the advisory committee for the DOE's Savannah River site (when Tech can't even keep from exposing the students) -that Dr. Stelson signed one GTRC contract with EPD,brC GTA C -, that Leonard Ledbetter the former DNR Commissioner who lef t under a cloud of controversy and then j oined Law Environmental tho CoWFmg

& a) did the ny -site specific earthquake study,the NRC tried to tell s n 4-me showed the reactor was on stabi ,non earthquake prone opwo

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• region the same Law ' compOly tha t did the soil bore tests under the reac6or site and co-60 storage pool that show they hit groundwater a few feet down like I said,and that it is not on the famous rock at all, but on a combination of crumbling rocks and sand and silt ( let alone that the original 1960 Safety Analysis says its on a MUD FLAP which I'll get to later when I tell you how they pollutted the Chattahoochee River and a lot more besides) and the EPD/GTRC contracts do all the state drinking water test'ing too -which may explain why the drinking water radiation analysis part of the tests provided to the City are exactly the same for three years in a row- and the Radiation Surveillance environmental monitoring computers are directly tied into Techs system. EPD's Mr. Hardeman told me all their reports were on computer printouts now, left me a note to that effect even. ,

but I found out files existed, and when I wanted to see them,4 I was told I really didn't need to as I had the printouts, th t they h

were boring, that after all there were about three linear feet of them, real boring, and besides, there was nowhere to sit. I said I was coming anyway and I'd sit on the floor. You would not believe what I found, and I only saw a fraction of the files of Mr. Hardemans. I'll get to it in a minute. I also saw Mr. Hills licensing files done by his ins " which 1 the pool also falls under @ C[pectors on thisthe (ou regulate, complex, pool thab contains l the sp,ent fuel rods as well as the cobalt -60. Mr. Hills inspectors {

tore Techs miserable little program in shreds I'll get to that too. j Mr. Hardeman also raised internally major questions about the j 44M cobalt-60 and the contaminatioed water released to the sewers yb b '

ag6 4,< The co-60 18 encapsulated, it is not meant to be leaking, Dr.

.g.w p%M . Karam told me the pool water was totally clean, though I have my j doubts, but the co-60 is also an activation product produced in  ;

the reactor and gej from the reactor too. NRC reports j keep saying$ k the D D I N the pool, if it is, the j sources are also king, leaking particlesperhaps since the  !

sources are like metal chips and wafers encapsulated. 1 I have different sets of printouts and books from EPD, some things i are not on one printout, but on others, or not in the books,or in i books and not printouts.Mr. William Cline helped write"%arly I reactor safety reports, he then goes to join the NRC one signature ,

shows he's on an oversight section. EPD does not take the waste-water grab samples itself at Tech, it's a" good faith" sample given by Tech according to EPD's technical support person at Tech Mr.

Blackmon. Mr. Cline set it up like that according to Mr. Blackmon.  ;

Mr. Blackmon led me to believe he'd take tests round the reactor for nearly two years, then I was told he wasn't allowed to by his j superiors. Mr. Hardeman said his boss, Mr. Setzer who sits in a j downtown office and attends conferences (as opposed to the rest of his staff who are at the airport) wouldn't allow it and his job was at stake if he pushed it. EPD refused my phone calls so many times the secretary asked me how it made me feel. These are all the tests the NRC did not look at 42o help them deny the '

Y tNA first part of my 2.206.T Betty Revsin was an NRC inspector who gdgb b q went to join Tech.Her campus surveys list a background of counts i e r minute as being betwqeen 40 and 400. 200 was the cpm in the gD i ?mium contamination incident in one area.

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i' Onearoninths'Bungar-HonryBuildinghad2000cpk'(Revsins, notes) c' Nuclear Safeguards committee memb'ers have included / include a form

{,. reactor RSO, Mr. O',Hara, Mr. Ewald of Georgia P wer, E.M. Cobb

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of Georgia Power, Dr. Kahn who consults for DOE Savannah 4 River Nuclear Site and is involved with the GTR Contracts with Ga. EPD Radiation Division (also signed by Mr. Hardeman of i that Division, and Mr.

4 and Mr. Len Gueva of EbascoReheisnowcurrentDNR/EPDDirector)

Services and Westinghouse on

' documents. There was a huge scandal involving Ebasco and a compMny called Moreland Altobelli in Gwinnett County detailed in the now defunctaDaily News'of April 6th and April 7th 1992.

' Moreland-Altobelli is headed by the former head of the Ga.

Dept. of Transportation (D.O.T.) Tom Moreland. The DOT held radioactive work connected with the reactor,Mr. Boyd told me there is some source buried next to a highway, and in the files at EPD,I sm) it listed Radiation tests done for the highway Dept and they were leaving e'"

contaminationinplace(Oct.20th1977lettertoMr.Simamis.)

Moreland-Altobelli is part of WSGI (Williams Service Group Inc) It is a V,irgil Williams company,(one of many) his copp-antes also do nuclear plant work, coatings {pr the TVAg Dr. Karam told me back in 1995 that they a so do testing for TVA, Duke Power + Georgia Power.Mr. Williams is a member of the powerful. Georgia Tech Foundation (see Atlanta Journal Constitution excerpt). He is a confidant,and financial sup-porter of the Governor (widely. reported by AJ & C.over the years) I first appealed to the Governors office about this situation by phone a letterwhich wasn't,May lith 1995,as answered, After 5I had sent the attempts,'

Governor enduring verbal abuse (likB I have to endure from some EPD staff who don't understand the issues)tbeing cut off, they told me they had sent the letter to Reheis (who signed the GTRC contacts) and I found out from Hardeman it was put in his, file. . Approx.

late July 1995 I called the governors office to try and get a meeting with the governor about this whole situation which was basically useless as the proceedure would have been enormous and they couldn't guarantee it anyway. I also left a message for Tech President Wayne CLough to call me. He never did. I said in the message what it was about. March 14th 1996 at about 4.30 or so I got through to a Jeff McCord in the Governors Office and told h,ip about the problems,+that the former medical doctor at Grady Dr. Holmes had told me he would have to be evacuating the hospital if there was an accident there after I told him what was there (Dr. Holmes was a prominant well respectedAfricanAmericanphysician)healsosaiditsounded like downtown would have to evacuated. He was the radiation doctor who would have recieved patients in case of accidents etc at Tech, listed on n the Revised SAR. I spoke to him Nov.9th, y wg73 q g qg 1994.After this ap red in my 2.2067 news reports said he was 4g gg ousted and then I heard he died. Months afterwards NRC contacted the hospital about this but it was too late)I told McCord about my 2.206 and I had the documents to prove it and wanted a meeting with the governor if need be. I told him I had written to the Governor etc. and that the state attorney generals office was

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being used to fight something contrary to the public good. He said the governor had to rely on what he was told by his State people but would talk to the governor and get back with me, a)

" he never got back with me, b) Later, in the State files, I found the attached memo dated 3/19/96 from Mr. Hardeman to TRMcC

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't of the Dept. of Defense Nuclear Emergency search Team (NEST) which shows that 1) they were not going to do anything about analyzing the Georgia Tech situation unless someone quotet" started yelling .

about it" 'someone' meaning someone they all did noc ridicule obviously, b) it shows that there is some type of terrorist threat.

c) They do not understand the health consequences (as in instant death) l or slightly delayed death depending on what sources got stolen.ft l is not just the 300,000 curies in the pool alone of co-60, there are two inventories the second is attached as you have the first,GRYYnTPER.

The State of Georgia and Savannah River Site uses the term mci to ,

mean millicuries, this is important when reading the inventories. You l Will note differences between inventories.The NRC Commissioners have i the power to order the cobalt 60 out. The pool is also used for spent I fuel storage which is about the most radioactive stuff on earth as I you know. l The problems in the late 1980's concerned gemstone irradiations which l went wrong. Due to the " Creative Loafing" article of Dec. 1994,GANE '

got a call f rom a j eweler, an older lady called Ms. Ackerly.(AND, for the record, nothing better happen to her) she was concerndd,as she deals with stone dealers, and she had overheard a conversation in her shop approximately in 1990/1989 . I spoke to her about it. she said ston !

dealers rented space in there, one had said thatothey'd spilled all his topazessanother that* they'd burned up his t,ourmalines." She was con-cerned as she had recently read a notification that only one place IRT, San Diego, was allowed to do this. She was concerned about the exposure to women and children from this,and indeed at first NRC was concerned and stopped it then re-allowed it under dubious circumstances noted in the attached news article from " Common Cause" Magazine March April of 1990. Ms. Ackerly thought the stone dealer would want to talk to Ms. Carrol. To cut a long story short, when Ms. Carrol tried to talk to him about it, she was basically told to back off. I called NRC about it (who months later informed me Tmo$ Mfys allowed to irradiate them in experiments gif they were not sold to the public.) At the time 3Mr.

Bassett and Mr. DiMiranda got very concerned and called me back and said they'd had a meeting on it and were moving on it, and I assured NRC that Ms. Ackerley had told me she would meet with them and help any way she could.There is more to the story in that I also contacted a customs officer and an agent with bbe DNR/EPD Environmental ($ rimes taskforce who I thought, from what I had been led to believei was also with the GBI ( I only recently found out their offices are at the GBI, but they worked for DNR) to get more help. I gave them all each others phone numbers. To this day, NRC, no one, ever contacted Ms.

Ackerly. But I did some checking. The one fellows name was Tim Rourke.

The phone books also said his name and that it was TRI/ Tim Rourke Imports. I checked with the Secretary of States of fice and found out l that an officer of the company was one Felker Ward. Mr. Ward enjoys a certain level of publicity as the attached news articles show.

First, he sits on the Board of the Department of Natural Resources (DNR)

2) He was a recipient of a Georgia Power lot lease at Lake Burton about which there was controversy. 3) He was among loan guarantors for Mr.

Andrew Young who of course is with Law mentioned earlier and Law also got Olympic Contracts. In addition, according to Mr. Boyd, when he was there, gems would be sunk down the pipe at the pool and the proximity to the co-60 irradiates them. Further, according t'o a @erman journalist,

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a former reactor staff person, gemstones would be put in the pool, hundreds of pounds, in special containers with holes in and the cobalt-60 put on top and they let them be there two weeks. That it was done until at least 1991, and that NRC knew .By calling IRT in California, the reporter found out that if topazes are previously irradiated with neutrons ,normally hh a reactor, the price is very expensive, and one has to wait half a year before marketing.

The use of cobalb is a bit cheaper. In arguments with NRC's Mr. Collir on what I believe is a disgraceful process,he maintained that only neutron irradiation would be dangerous (i.e. for the public when irradiating gems) . As the co-60 pool is also used to store the spent fuel rods, and as they would give off neutron irradiation Ithe amrug concerned about all this and ~ feel it was all shoved under

/or the pooll If there is time I will get back to things like NRc sending me (i.e. Mr.M4%GrktQ sending me the cartial denial c of about Vnj2.206 which was over 600 pages short. When I found out tnat months later, and raised hell about it, at first NRC did not<

want to send it to me maintaining it was just footnotes, I was i demanding to sp@ak to Russell about it (the executive director who l vas responsible for$ too, finally Mr. Mendonca tracked it down and sent it all to me as he had thought I'd been sent the complete i decision and that it was only the forty odd pages. The 600 plus extra pages were very interesting. for one thing they partly l

proved what Mr. Bassett had agreed,with me on, namely,that f.

k. l he knew there were items or issues I had under my 2.206 which ]w)ere I not addressed and that anyone could see thatgand when I asked him if he would tell that to a judge in a court of law, he said he would ht he had to, so you can ask him. (Conversation Aug. 4th 1995) and I can tell you details about Mr. Collins and and I think a lawyer or Glenn some other NRC fellow and Oscar Di Miranda calling after , L- "l toldq)o%at the first testimony that Mr. DiMiranda j had told me his s

g pe ple had told him there vould be contamination of the sewer lines etc. at Tech (wh' ice they have refused to test these three years now) l and Mr. Collins backtracking on telling Oscar there would be contam-ination, and we had a huge argument, but as I didn't wan't Mr.

Dimiranda to into trouble I let it all goglet them have it their way. And on"%get eing told I couldn't speak to Mr. DiMiranda anymore and on and on. But I want to get to the massive contamination and pollution of the Chattahoochee and the campus etc. What I have told you so far should show.you that there IS a good ol boy network. Oh, I know how Ms. Long must feel, NRC and EPD the Governors office staff,tTech have caused me great emotional distress that has made my health problems worse , like her, all I have been trying to do is protect the public. She must suffer greatly. I also know that there are official and unofficial reports. For example, things were left out of the repcmrt on the fuel removal . I questioned Mr.

Bassett on some aspects and found it out. It leads into the campus contamination issue : Mr. Bassett and another inspector also crawled around under the pool area, Vhat is not in the report is that they made quick measurements and scooped up some surface dirt.

I had been asking for procer* core samples from beneath the reactor itself as well as the pool etc. After a lot of "ba and him not wanting to admit things, he said h%$%%yggypnd forth"had not easurements gone over 1 Millirem an hour using a n XETEX monitor in the crawl space the water washie48 the soil out from under which of course goes g

further onto the campus and sinks into the groundwater and affects micro-organisms and insects etc. If it was always 1 mrem an hour thats

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B 8,760 mrem a year. If'we cut'that'in.ka~1fevenit is still over 4,000 mrem a year going out from,under the crawl space to 3

the campus environment 3 in some manner.

The 1960 original Safeguards report for building the reactor is incredible. Which is why I believe the current SAR was revised. leaving out absolutely vital information. NRC knew this

-Mr. Mendonca told me they had read the original and gone over it when I asked him if they'd looked at the one that wasn't revised and he was mocking me that I wasn't a geologist and NRC geologists had looked at all associated documents - not understandi that because of the issues I. work on I have had to do vast geological research. - and the EPD has a copy of it in their filed and the EPD Radiation Division lied and were misleading in th the partial response to my 2.206, what is on this chart I drew,

. . . states that the large scale topographyof the region is such that the reactor site lies near the head of drainage of a LARGE PART OF THE SOUTHEAST (pages 23 and 24) that the Ocmulgee River basin at its nearest point is 1.9 miles from the reactor --

the Flinth nearest point is 8 miles j the Etowah-Coosa-Alabama basin is 17 miles northwest and the Chattahoochee River basin is 10 to 20 miles wide in the vicinity of Atlanta. But guess what, i they didn't care.Later in 1969, Georgia Tech (and the DNR and AEC l who allowed it) weep dumb enough to stick 2.5 curies of Kr 85 and i 5 curies of tritium in the headwaters in the CHattahoochee l and to also do similar in the headwaters of the Flint and '

South Rivers (EPD files and attached documents from the AEC, Tech and the State) when they must have.known that the poor fished  ;

all down the river, and animals did drink from it having little  !

other sources. and that it would have affected La Granged drinking water intake. and pollutted the river even further.

Page 28 shows how the water pooled under the reactor itself.

Page 24 details site spMcific topography showing the surface drainage at the site would concentrate in the depression west of Atlantic drive and the runoff would come from 10 acres. It details overflow could go east and west of Atlantic drive roughly 20 acre feet could be temporarily paded in the depression the equivalent of 16 inches of rainfall on 15 acres draining to overflowing catch basinsy EXCLUSIVE OP of the 10 acres . It states how waste carried by surface runoff (for example radioactive crud that's deposited on the

" faked containment dome,or on the roof of the lab area and on vegetation from air borness, deposited - my addition) may be deposited on the ground in these depressions , or may infiltrate with water into the ground, or it may be carried into.the STORM sewer . EPD test of 2/20/80 in the runoff ditch showed vegetation / grass with 8800 i/kg of Be-7 and 61pci/kg Cs-137 The water itself contained l -ants includingtritium(not(pe2/29/79 contained)asetofconta listed in one of the printouts)

these are in pages 154,153 b(nd 156 of the 1979/80 report book EPD gave out After I raised questions on what was dumped to the sewers and about surface sunoff,uihey did not list them in the other books e.g. 85-87,88-89 but Tech took samples of water in 1985.I found in EPD files for waste water (6/20/85) cobalt 60 cesium 137 (22 pci/1) and alpha and beta emitterse .Jsamples of water taken and referred to cryptically, gin March 1985 at GT 176

Tech says-are in monthlv r in printouts.

Not in three printcuts they sent fne, eports are notand are not in the booke

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Please remember tests of what vsc9 dumpWd to sewers are all messed up ,. dot in some printouts etc. I could go on, but as they bold me, it gets boring....(documentation of tests attached)

What is dumpMd to sewers /is of vital importance. As yo u know it is well documented that there-is no safe level of ionizing radiatior.

furthermore, ionizing radiation the health effects of exposure to low levels of have been detailed in the most recent report of the National Academy of Sciences National Research Council entitled the BEIR V report governmentoftheUnitedStates.)Despitethefactthat(1990 Thisthe is in effect way it a rep calculates so-called background radiation- which the government has inflated over the years-are ridiculousi in that,for example it averages everything out and divides it by the entire US population when we know infants in utero, children women the old and the frail and then men, in that approximate order,are diferently affected by exposure ,with infants in utero the most affected, and despite the fact they try and say a massive part of exposure is due to radon in water, when in fact vast areas of the united states contain less tha-than 1 pei/galmost' half the nation, found they are often suspisciously close to andgwhere higher levels are mill tailings piles or nuclear facilities,: horbo8 iq reg <gl f ranium igures were provided by the DOE,and help was given by DOE a; aciated univer-sities and St484 y-the 400 odd page report contains some ghastly information. I draw your attention to pages 12,13 and 14 and 15 on effects to DNA , both direct and indirect, an_d energy absorbtion taking place in water, since cells are made up of 7o% water, and I i

vould add that tritium (d-3) in water, subsequently enters every cell in the body . - the natural human body burden of tritium a being only one billionth of a curie - hence, the dumping of tritium i indeed any radioactivity to water is serious. Cobait -60, is not l readily soluble in water either, however can give off deadly doses,  !

Atlanta has a massive problem with so-called " combined sewer over-flows" indeed huge daily fines are being given because this problem has not been addressed, after even moderate rains the sewers overflow,

. This problem existed back in the 1950's and 1960 when the original Safety report was written, hence page 29 shows that in dry weather l all of the flow in the trunk sewer the waters from this reactor and hot cell ,

pool etc. NRC licensed goes to;normally, would be diverted into an interceptor to the north and go to the Chattahoochee via the f

Clayton Sewage Treatment Plant, from whence the radioactivity can't h be removed, though some is trapped in the sludges, which are then [

burned,at the present and then the ash is incorporated into bricks ,

and other building materials. Back then, the sludges got routinely dumped to the CHattahoochee anyway. BUT, in wet weather the flow in the sewers is too much, so it bypasses the interceptor, flows instead via what is now called Tanyard Creek, but back then was an open ditch, DIRECTLY INTO PEACHTREE CREEK, AND FROM THERE DIRECTLY INTO THE

> CHATTAHOOCHEE RIVER. this was expected to happen back'"ph40 5 to 7

{ times a month, now it is more frequent. IT GETS WORSE The 3 drinking y water intake for the City of Atlanta the cities of Marietta,Smyrna A Hapeville, Forest Park and military installations li_ke Dobbins is i

only 150 yards upstream from the mouth of Peachtree Creek. Page fi3 ' 31 states " THERE IS THE POSSIBILITY OF A FLOOD IN PEACHTREE CREEK WHEN THE STAGE IN THE CHATTAHOOCHEE IS LOW. THIS C4UMb RESULT IN h UPSTREAM MOVEMENT OF THE FLOODWATERS pag @ THE CITY WATER INT 8046E hg. -

w

I9 When the pool for the highly radioactive' spent fuel rods and the cobalt-6o siphoned down three feet the night'of January 31st 1983 l and quote "since no water was found under! the concrete flooring and it had not gone to the holdup tank they. surmised that the water had gone to the sewer system although that valve was found CLOSED on the morning of Feb. 1st 1983" They calculated a release of 2700 gallons. . Two things are noteworthy, one is that Bob Boyd l told me that under certain circumstances they found that the valves could backflow into the city drinking water system (ask him about it) and it had to be corrected . . If it went to the sewers,and they do believe it did, not only did they go down the wrong manholes to sample (EPD) they sampled in a blinding ainstorm Mr. Hardeman told me he would never forget,HE{he requ{est$d Ya$p$$s were picked up two days later from RM Clayton (from the constant sampling) i requested by Mr. Hardeman to start at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on 1/31/83 through to o800 hrs on 2/1/83(The obvious point is that 1) they were surprised,according to Mr. Hardeman,that the samples did not appdar to be as high as they thought they might beiand 27 6Mth the heavy rain, the contamination in the lines that would have existed would have been thoroughly washed into Peachtree Creek bypassing the interceptor,and little reached the treatment planot. The interceptor

( is 7000 feet north, and even back then p. 29 states that Since the interceptor flows nearly at its capacity in DRY weather it is likely that s44rface run-off from any appreciable rainfall vauld 0d50 be diverted to the ditch." I.e. Tanyard creek. They assume a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rainfall of only 0.1 inch would fill the interceptor to capacity.

How many times has Tech dumped to the sewers and it has bypassed and gone to Peachtree Creek and directly to the CHattahoochee ?

How many times did it hit the drinking water intake ? They are meant according to the original specifications to hold up the water they dump half way through for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, do more sampling and then continue to dump. . But Betty Revsin in a letter to EPD, in the attachment part, dated Aug. 3rd 1990 says : "Over the past several years , the only radionuclidee determined to be present in the liquid waste were tritium (dt a very low level) and trace quantities of cobalt-60....due to the typMs of radionuclides observed in the liquid waste , no holdup time for the liquid waste is routinely planned, instead, discharge occurs when the tank is full." She not only is stretching the~ truth from here to Mt. Everest and back accordin to the reports I have enclosed , she thinks in another sentence the two tanks that hold 1500 gallons each are termed " low level" l

because of their low volume. This is pathetic.

I also refere you to inspMction Report and allegations of March 9th, 1987 on this issue done by NRC. It's appalling.

The NRC and Dr. Karam give out the guff that the high TLD readings at one location are due to the weather (GAME) also referenced this,

! e.g. heat or cold. This is ridiculous. The original Safety Report l details how the size of raindrops; wind speed, wind direction stability or instability of the atmosphere, and so on will affect the pollution from the reactor over pages and pages and pages. how large raindrops will wash out particulate and gaseous matter and deposit it on the ground f aster, . The high readings kytdue to the crud they release.

John Richards'of EPA /ERAMS (whose* COMPLY code *NRC threw at me in my 2.206,-which is computer modelling bearing little resemblance to the real world) told me)before he knew I was dahing a 2.206;

( -[i .' . , .

l ~

H. ,,

(kens $s } E9RqNE) thatwhenhewasastudentatTech,ftheArgonwasgoingout the stack i on a daily basis at two and a half times background. I put this in i the 2.206 but didn't name him. I'm naming a lot of people as I am sick of what they are doing. ,

I asked him to monitor air during fuel removal, but he didn't do it.

Just like I asked Mr. Bassett to be sure the roof plenum that vents everything out the hot cell areas would be monitored during fuel removal i Not only was it not done, (and I reminded him I'd asked for it l and he agreed I had (apr% 1st conversations) the famous particulate l sampler on the line was evaluated (they've geen evaluating for ages) i and not at all checkecWhe reason given 8W4Nsting up on the C

l roof was that they had a monitoring device in the line, so I asked well j what was the set point for that alarm 7 and he said he hadn't written it down, and I asked who all my requests go through as i I know they seem to cut him off at the passiand he said it is usually someone from ,

Mr. Uryck's office or a, division director or alternate and named 1 Mr. MalletandMr.CX1111nsandalawyer(whylawyers$Ialso  ;

asked who climbed the stack to read the monitors.He said usually the i HP technicians, but I know from a prior T eport they are not doing it, I He said they report it in the annual reports. That's the problem, l the Neely Center could write in their reports that they are in reality l

)

1 all Martians and the NRC would believe it.

i Here is a chart of DIRECT RADIATION WHICH THE CAMPUS AND THE STUDENT GET EXPOSED TOi In transit doses for students are higher than at the l huge Trident Nuclear Submarine base at St. Marys. l THE SAVANNAH RIVER NUCLEAR SITE, A D.O.E. SITE HAS 96 TLD's ONSITE in the worst areas. You know that the SRS site is about the most contami ;

inated 300 square miles in the nation (outside of the Western Shoshone i Indian land AKA the Nevada Nuclear Test site). Of those 96 TLD's O S% !

l 14 were over 100 mrem a year, 3 over 200 mrem / year one over 300 mrem /yr j i

At the SRS site perimeter there are 179 TLD's (allowed DOE site j l perimeter exposure must not go above 100 Mrem /yr) 3 were over 90m/ rem l year but-below 100 m/ rem year. 58 vere below 60 mr/ year, all the rest l were between 60 and 90 mrem / year.  !

! You know what's coming, missing TLD's and all, of the 631 TLD measuremen l fordirectrtdiationexposurereportedlytakenbyGaEPD(AKATech/GTRCl) between 1/24/78 and 3/4/96,at between eight and 14 TLD locations I

i there were two low measurements in 1982 of 49 m/ rem year plus/minus l a few points (which should probably be used as site background) I 138 measurements were between 100 and 200 mremfyear  ;

three between 200 and 300, seven between 300 hnd 400, 7 between j l

400 and 500 , 2 between 500 and 600, 1 of 726 Mrem /yr plus minus 73 l on 12/20/88 and one of 997 Mrem year plus minus 36 on 3/18/85 '

The majority of the remainders were in the 70's 80's and 90's. j

'MERr a tWe TLD 's a t th e former Lockheed Nuclear Aircraft Lab, which l contained nuclear reactor and hot cells and lab like here, and which is l now euphemistically called the Dawson Forest Wildlife Management area. When it was decommissioned, some of the liquid radwaste got i poured into a hole in the ground and they put a rock on top, (ask Mr. l Boyd about it too) they fenced the highly contaminated cooling off area 1 etc. back in the late 60's the people who lived in the nearby houses were on wells that were contaminated in state reports. You can bet

[ the people were assured it was OK, it doesn't matter, they're dead now.

By 1993 the area of TLD 's 1,2,3, and 8 had readings between 84 mrem

U - c!

93y 11 .

o V) b h oa m year and 293 mrem / year. THIS AREA IS CLOSED TO THE PUBLIC DUE TO E$# 3HIGH CONTAMINATION. YET GEORGIA TECH COULD EXPLODE A NUCLEAR DEVICE ON o o,$ @ CAMPUS AND NEITHER THE NRC OR THE GA. EPD WOULD PROBABLY DO ANYTHING o o e u cMORE THAN SAY "WE"VE ANALYZED THE SCENARIO AND FOUND IT NOT CREDIBLE"

@' O T$ s which is their favorite phrase.

u j;Gg 8Another chart I made shows a lot of things you can read later, but j m s u uthe H-Area at Savannah river had highest Cesium-137 contamination 5

$ j i

• ein soil at 1.o1 pei/ gram or 1010 pci/kgbut Tech gets to have f 0 " gm g1500 pei/kg 3/18/85 and 1400 pei/kg on 4/24/86 1n the soil and 3 3 g c a e o the Tech /GTRC documents attribute it to the reactor, but NOTHING "Op$o is said on that fact in the GA. Rad. surveillance report bookfor 85-87 g et5:~ mCo-60 is a man made activation product produced as a result of the d $$r $ violence of the chain reaction. It's a beta and gamma emitter. Safe Drin]

• jy$y ing water Act allows a maximum of 100 pci/1 which is actually a v m c outrageous - New EPA regs may change this, anyway, Tech levels in water

.35 $ M to sewers which becomes everyone elses drinking water downstream,

1. y M @ reached 520 pci/1 5/22/91 EPA's federal so-called " allowable" limit Nw m (allowable to them, but not to anyone in their right mind) for

$ o,$d,3 BETA in water is 50 pci/1 so Techs BETA in water ranges from 1,950 pcil

>E@eto to 1,ioo pci/1 in 1991 to 800 pei/1 3/4/92_.>

xea- c_ )b

$ 3 d d $Before I get to contamination of people as a result of this dump and g U y ydeaths due to what has gone on, I wish to state that Dr. Berte11 was or. Osent a great deal of documentation on this mess, She is, as you know E.3 $$ Man expert on the effects of low levels of radiation and is not affiliate <

'4jggvith any government or military that can influence her work.

e p%2Without knowing that there was transport of radioactive sources (un-

@o U -@ escorted I may add according to Dr. Ice) across the campus, she did g g g g an analysis pinpointing exactly how they would be transported, she ec salso did an estimate based on what we thought at the time was an accurate

• f d j $ inventory of the co-6o, but in fact it is higher. The analysis was qmN mj 3for the catastrophic effects of dispersal / exposure to co-6o in the s um pool and it was terrifying. As one has to go out of state to get 4 j * .C " "anyone to make a proper judgement on the effect of the co-6o, I would

. z m x s E m tell you what two Radiation Safety Officers in other States with 3 c)'$ $ $ great experience in this matter have said, given a scenario of an >

" {# @ gattack or similar on this pool resulting in the cobalt-60 being disp- [

so versed

$8.do mRadiation Control, Alabaida Department of Public Health *,"It would be a ("

m into the environment Kirk Whatley, Director of the Division of ymifg gvery serious problem, no one could dispute it, in my opinion anyone (MyphoneconversationwithhimMarch14th1996)3i

- av -would agree to that "

C e Qu Larry Addis in a phone interview with German Journalist Irene Hell M % ,

N r g CI heard a recording of, said dispersal outside would be catastrophic d i o+ estabilization, cleanup, personell exposure would be catastrophic" E $ @ S $The bottom line is one would have to immediately evacuate about a half

, gg E mile radius. Any particle sized pieces that got into the water or c.- mo esewer system would have to retrieved. Mr. Addis who I quoted earlier j F# *# is the Radiation Health specialist at Clemson University who has ,

managed 250 radiation safety people and has vast experience. I do not l 1

o, a want to hear that any of these people are interferred with or demoted, j i

J 1 jThere seems to be a history in the nuclear industry of ruining peoples i

' -s o m iives if they speak out. Even Dr. Karam agreed April 18th that 4 e c1 e.ecobalt doesn't disolve in water . It would be really nice if NRC Region 2 4"4-II could stop trying to convince me it's soluble .

7 I also want to enter a recent letter to me from Dr. Berte11 in 4i a V1 ,

13 -

in which she says quote: U"Thank you for forwarding more information on the very risky Atlanta housing situation for the Olympic Athletes, I cannot understand the recklessness of this choice, or of the continued housing of students so close to the nuclear reactor and cobalt -60 storage." She then goes on to tell me about the International Atomic Energy Agency's attempts to cover up Chernobyl disaster and mentions that these so-called radiation " protection" experts find all the suffering of the children and the liquidators at Chernobyl Is quote

" recoverable and therefore not a detriment" She concludes with the observation that quote" It may take upT hany more years to finally bring the nuclear industry into line with occupational and public health standards for other hazards, but it will have~to come. This will undoubtably force the closure of such polluting installations as that at Georgia Tech. Please know that I support your efforts to close down this facility and have the Cobalt-60 removed prior to the Olympic Games this summer. A terrorist attack would produce a disaster worse than Chernobyl and the prime victims would be our finest young athletes. I believe that we have established credible documents that provided timely warning to the Olympic organizers of the danger.

They will have to answere to severe international condemnation if the worst happens. However, they may also be found responsible for direct damage to athletes exposed even in the best case scenario."

By the way, Dr. Berte11 agrees with me that the campus is severely contaminated.

pp,gks)

Now we get to contamination of people : attached documents, one of whicli

, has the first page missing show that workers have been seriously contaminated. Mr. Lupton, Mr. Pemberton, an unamed person, and p og W@mtW1 @vi i )N M' in another incident a Mr. Shannongthe documents from EPD files are attached. The first incident shows then NNRC director Dr. Russell was told, also Mr. Carter. There remains a serious question noted in the documents if federal people were told. State obviously was as it was in l l

their files. I spoke to Mr. Lupton (April'9th'96) He said when in- I cidents occur they do an hour and a half of washing before the State gets there and it should be changed. He suffers many skin cancers. His first wife died of breast cancer and had no X-rays in her life (of the breast  ;

prior to diagnosis. It is possible contamination tracked home could have had something to do v.ith it. We shall never know. He also said there had been someone who taught at Tech a brilliant graduate student working with radiation called Joe de Lavalle ? spelling) who"took a lot of radiation and was dead in two days." is wife had worked at the library, I tried to locate her, but she is dead. He also worked with Mtrium-90.

They worked with Sr-90 boo at the area Qqt licensew They manufactured Mtrium microspheres to be implanted in patients. .Acc. to State files, (Sept. 6 80) Dr. Mantravadi of the University of Ill. got them and 3

implanted them in a patient. then saw unexpected radiation levels around the patient. He went nuts, his patient and others died, word had to go out to wherever they had been sent. 50% had leaked from the microspheres. Mr. Lupton told me that " it was done by a graduate student who didn't know what he was doing". Which sort of makes my point about students involved in dangerous work.

As The ORIGINAL 1960 Safety report shows that They put this entire reactor a hot cell, pool and lab En the middle of peoples homes, the nearest being 200 feet and within 400 yds and 600 yds of Home Park School bNbn..<

JM ,

J. j

~Mg s.

O'Keefe respectively and within about 300 to 500 yards of*he Calloway apartments v4hich houses 156 families of students and faculty and and many small businesses equally close, I did some i tracking, which was almost impossible. However, I tracked the former owner of Southern Oxygen Supply which was at 801 State St. about 330 yards to the south /se of the reactor , hot cell and strontium 90 glove box /ytrium 90 location. the owner had had no idea what it really was, or what was done there at the time (not surprising as)a) on the original liscence only three people got a copy one being then Governor Carl Sanders, and b opportunity for comment was published in the federal sgister in Washin)gton that most people, specially back then, had never even heard of or wouldn't know how to get, 3 The owner told me (April 15th'96) it was a s' mall business less.than 10 people. He himself had.had heart problems and a stroke (which Dr. Gofmans many papers have linked to radiation) His wife who visited often had many operations on her thyroid. Theco-ownerdted ago 50 in ;Paf ter much suf fering from bone cancer a cause of which is Strontium-90 tha snventigljich if inhaled or ingested seeks out bone (see the BEIR report and Dr. Helen Caldicotts works) such as " Nuclear Madness, What you can do" published 1978)but what upset him the most was the bone cancer of an employee he had first hired at the age of 18 who died about 1980.

He said by the time he died his bones had so deteriorated he had lost about eight inches in h.ight too. He siad he would just let him cor.

and sit at work and try arid d.o odd things at first, he said quote" He was one of the sweete'st, nicest people, It was tragic.He'd be just a-sittin' there tears ~cominout of his eyes he hurt so bad" at this point t f e of less W aE $qrerown'r,Mr. old met theifew-female Smith, himself began employees did to notcry. So , -

discuss their health problems with him - you have two bone cancers, thyroid ops, stroke and heart problems . A former, highly controversial Governor of Georgia, Lester Maddox, had a restaurant about 370 yards from the reactor complex. His rare cancer and struggle with it was highly publicised down here due to his notoriety.

I could go on, the studentgin the frat housing nearby who recently was getting over non-Hodgkins lymphoma. The TLD badge on the side of the Frat. houseino one told them what ib was for. No one had. told them what to do in an emergency. The dead birds and animals that were not road kill in that area of the campus (Janet had told me of that also years ago) I could go on for days EwMMhn The twelve places on. campus with fixed radioactive contamination including room 167 in the NNRC that had SR-90 contamination on the floor and they put epoxy over the contamination and a new floor down and stuffed waste in the basement.

The cesium-137 separation being done in the shock out back venting benzene, a known carcinogen too (Mr. Collins and NSC Minutes)

The leaking tritium container being stored in the hoods of a lab in 1993 that contaminated the lab and although it was meant to be sealed someone came in and stole a tritium pump.

The contamination in the cobalt-60 pool.the failure of alarms at the hot cell doorsx, the having to hand-crank each cobalt source up into J the hot cell that can take five minutes (Mr. Boyd) .

(

Dr. Mahaffeys report (Feb. 19th 87 Radiation protection Committee 1 minutes) of the failure of equipment in the reactor control room

! causing the reactor power level to rise undetected by the operator

l

/ 6Ii The radiin needle the notorious " Union Miniere" of Belgium certified -

that same Union Miniere that has helped rape what used to be called the Br.lgian Congo to help provide uranium fod% the US Nuclear bombs searching inder a pilegot

- and how it lost, and how Bob Boyd found it after hours of of LEAVES I

. The fact that Boyd and g at a meeting in the early seventies ,when asked by Dr. Spooner ifWright) they should approve the co-60 coming in told the University NO, t Some and of the clean should stuff came up, it'sfrom onthe theLockheed banks of sitethe Lockheed contaminated Etowah River.

I l

Mr. Boyd did the best he could with a program that was often very l difficult, and the documents show that no one wanted to spend the needed money on upgrading and safetye ,

A couple of years ago, Mr. Blackman, the EPD Technical support person over at Techs labs, told me the State was going to put air monitoring samplers around them. on April 17th he that dump of a reactor facility. -I'd been asking for told me it was net put in place like I had asked for and added "

I'm not going to deny it's not a reasonable thing to do". He told me they don't go up onto the roof of the building l

(i.e. to monitor the plenum the hot cells and glove box ybat NRC licenses under the original license) l He said their health physics (Techs) program is responsible for on campus monitoring. I had called (April 1st) the reactor had asked the health physics technicians even though one Mr.ofBassett his had told me climb the stack to monitor it -

reports said they were not doing it. I spoke to Mr. Jawdeh and asked how often they read for contamination and how often the filters were changed from the hot cell areas and the fume hoods 3and he got very confused and told me to speak to Dr. Ice who told me the filters were usually just contaminated with " dust and dirt" which I find highly improbabbe, and he did not seem to understand how the air flow goes at all from the hot cells and asking what reference I had, I said the drawings or documents or something like that. He said they didn't check up on the roof, He also said they don't sample for tritium. He told me samples were taken when the fuel rods were cut, but there wasn't any monitoring done up on the roof. I had told him there was meant to be a TLD etc in the plenum on the roof and it was meant to be monitored for tritium up there.

He was a bit confused and had said that when the TLD's were changed out they would include the one on the roof, but seemed unsure. I asked when they'd be read, and he said quoteuthe badge that read for the FUEL EXCHANGE was read this week".

I found the words " fuel exchange very interesting, as you had ordered no fuel to come in before the Olympics, etc. . Mr. Collins told me about early March, that some of the it hadfuel there been leftwas not irradiated there. (i.e. it was fresh fuel) and that If so, it must be HEU.

all the fuel, period, fresh and irradiated spent fuel I thought was meantall the toHEU) be out prior to the Olympics. I also urge you to pay special attention to the damning inspection done by Mr. Hills staff because it shows his

!, division has serious concerns over the way things are run, and the State license is up for renewal in a few days.

l position, he can only go by the truly awful StateMr. laws Hill is in a difficul:

and he has to rely on what Tech tells his division , except when his staff do their inspections, and even then , given Techs track record,what can be relied on ?

Feb.

29th 1996 NRC issued a notice on the spent fuel shipment from Tec

q I

l lb which says the unirradiated fuel was shipped out. Mr. Collins said it was left. .

NRC InspMction Report 50-160/96-01 is very inter-esting, ,

documente prior to the not event just because the pdople and a fuel were element wasgiven leftnoinforma the hot{bellgtggigigg training overnight instead of being put back in the pool after the saw blade broke (to vent out the plenum all night).and that another vaste tank must have developMd a leak as it was also patched - but it says nothing about unirradiated fuel being shipped out. l A Georgia Tech News advisory of March 1st,1996 says "The transfer i removes all of the highly enriched uranium from the Georgia Tech Campus, and boasts that it was carried out by NAC International, i one of the leading spent fuel transporters in the world. If I l were Tech, I wouldn't boast about using a compMay the Gwinnet Co. I business license division said had no business license, a legal  !

requirement.

There is so much more, but the bottom line is this : the reason Tech was initially pleading that it would cause undue hardship,  ;

blah blah fori them to go back and produce all the files GANE requested or something to that effect, may have had something to do with  !

the documents that show for years the place seems to have been run,- {

the entire program , everything about it,--like a medieval pig-pen. )

Mr. Boyd told mei that because every time they run it at over 1MW the containment (sils up with Argon, khRXxRXRRxhRdxkR and it leaks, they had to put a separate air conditioning system in so the ,

reactor operator wouldn't have to breathe the Argon Actually, I just l checked my notes, he said"the whole building fills up with Augx l radioactive Argon.."  !

I would urge you to read every single NRC inspection report from 1985 onwards, and you will be appalled. Although I have most )

1 copies, we don't have the money to copy them and you could get them l from NRC. Tech is rich enough to pay for their own copies. l There is no real license, it expired in 1980. All they got was an amendment to a construction permit. NRC's own counsel told me it was not the same thing. In the revised SAR the lousy one that they submitted they said decommissioning would cost 10 million and wanted to get the Georgia taxpayers to pay for it. It will probably cost far more to cart every last bit of contaminated crud offsite.

I believe , since priva'te corporations etc. were also involved that Georgia taxpayers should not have to pay perhaps those who benefitted from the vast amount of military contracts done there should. ,

and all the companies and out of state people who have used it.

kTKKXXXXXXXXImaAAAiAAAmmF Am Ain AAIXX KAK KAX ARAF I R X 5 E K AR AAA KAR AM AAAAAA XXXXXXXXKKRXNAR AARERAAKXAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA l In Techs opposition to the GANE pdtition of Jan 25th,1995they do not appMar to adderstand the ef fects of radiation [Eheremarkonpage7

'6 hat it is small. As you know, there can be a huge amount of radio-activity in a small quantity of waste for example with high deadly activity. It is not the size, it's what's there, what is released etc. I bMlieve what is in my 2.206 makes a mockery of both Tech and the

NRC's positions against GANE and my pMtion NRC even told me May loth,5 l 95 , when the fuel rods were still in there, that it would not be over for the city if there was an attack on it, say by a mortar or worse, when I protested this and said it would also cause a massive fire and cobalt would be exposed etc. , disagrand NRC bs Mr.

^

F.

l%d h}. I i y

}

L.

Mendonca disagreed, he said they'd analyzed it. I got so q_pset about this statement I called Mr. DiMiranda (this was before I was told I couldn't speak to him) I was crying, . Mr. DiMiranda l seemed worried and said he'd look int.o it, to try and put it out of my mind. I said I couldn't, I dream about it. May lith I called Mr. DiMiranda again and he said he had spoken to Mr. Mendonca and advised him to call me , and asked if he should try and get him for me. I said yes. No one called. Also on May lith 95, I got hold of Dr. Warte11 in biology at Tech (listed on the second iventory as using radioisotopes I believ) and tried to get him to do something about getting the Cesium -137 irradiator out from the

! biology building as it was a danger to the students. He said he had more things to worry about on a daily basis and it was not his pervue, that he would h ang up on me (i.e. if I didn't stop urging it) and anyway he had to go to a meeting. By July 20th when I called 1 Nrc's Mr. Dimiranda to ask for the umteenth time for the sewers and lines at the reactor to be tested, Oscar said he'd been ordered to.

tell me to talk to Craig. So I called Craig Bassett and told him, also about the need to X-Ray the . Late July I had a huge conver-sation with Mr. Bassett who was insisting on NRC's position that the reactor was on solid rock. as he had indicated NRC was getting l ready to send me some type of response to my 2.206 I told him they better read my letters and the 2.206 better not come back saying it was i

on solid rock. He said hn'd E-mail Marvin Mendonca and t' ell Mr. Mallet

! who was the Division Director.over this. I was'getting so cross I told him he could tell Mr. Mallett ,.who Mr. Bassett had said also would not get/do the bests' , that he could go tell Mallett to

~

go put a-zoot suit on and get down the sewers and test them himself.

Arouond this time I spoke to Mr. Shapiro, a State Geologist, and told him how the reactor was on the Wahoo Creek formation and over the old creek drainage area on fill. and about the sinkhole. He said if the fill contained saprolite, or limestone might have washed out and also have caused the sinkhole problem, he said he thought a main problem would be from the old creek / drainage bed. I asked if NRC had contacted them, he said NRC had not spoken to.him or his staff, and.he doubted they would come to him. He did if they had spoken to his boss (McLemore I think)$ a@ ot knogN m

hMWbELL*pdata showing very few Georgia counties had uranium bearing deposits at all of course,'and that in Fulton Co. there was only one undis-closed location (and ib probably wan't under the reactor !) By the val a favorite argument of the DNR/EPD is that the on campus levels are high due to'the granite buildings.

a) their own measurements taken at Stone Mountain, one of the worlds biggest granite monoliths period, shows along the creek below the carving 14 uR/Hr, on top of it 18 teR/Hr. measured with a'Ludlim survey meter (p171 ,1979/80 book report) across the state of the 25 other measurements done excluding Stone Mt., 16 were much lower with an average or around 8 i'R/hr. (P.170-171) b) from 1960 Report photos, you can see how little granite l there was in the area, all trees and little houses and its on the Wahoo Creek formation. Mr. Boyd said he remembered that back then

( surveys showed very little, practically nothing. They had even done tests, that they must be recorded in early documents.

A c) In endlosed documents you will see maapings that are higher than 14uR/Hr, missing TLDs and all. There is no way that all the granite buildings on the Tech campus are equivalent to the mass 7 of Stone Mountain.

g

I Y sv-h0 'h.ne l There is a lengthy Saga concerning my trying to track down pe these early Dept. of Human Recources Records I won't go into?';

now, but you can have my notes if you decide you want them '

(i.e. copies) With one state official getting very scared l'1 after making enquiries for me , very very disturbing, and involving movemen't of files contrary to state proceedures according to two people. I was also trying to check any early health exposures to radiation in those files.

I bM11 eve the Commission should take back control over the c0-6o sources at Tech. I bM11 eve there is ample evidence that very serious health and safety problems exist surrepunding all the years of op'd ration of this f acilitypthat careful reading of inspection reports and my own experiences concerning l Techs nuclear reactor program with State and #6th NRC show the problems run deep, and that the main reason for Tech wanting'to keep the facility going, is major contracts, also with DOE and perhaps the military, and out of sheer greed ,

a city could wind up being sacrificed.There.is also basically no insurance of note to spdak of and there is an indemnity agreement mentioned in the attached documents. When I asked l i Techs legal counsel Mr. Nordin and Mr. Freddy Everett of j i Techs Risk Assessment division March 4thi ko tell me the amount i of insurance carriesd on the reactor Everett was very uptight and angry and he did not want to tell me and neither did Nordin, refusing to look it up and saying one would have to I go thrbugh the state open records ACT. I asked both Ken Clark,

'he PR man at NRC and NRc's Mr. Mendonca to send me'information on the amount of insurance and indemnification. I have not recieved it. I realize I could have gone through the hassle l of the Open Records Act, but, the bottom line is, as Tech stated in its Feb. 1st 1960 Application to the Atomic Energy Commission, enclosed, page 2, "As an Agency of the State of Georgia the Georgia Institute of Technology is legally immune from public liability ". But who really owns the reactor ? The most frequent answer I got from Tech Officials revolved around the Board of Regents. They are individuals.

It doesn't really matter, no money in the world could compMn-sate for the death of a city.

In the light,of current medical / health standards and knowledge, I find it appalling that in order to try and get a renewed license the so-called Revised SAR submitted used standards set back in the 1950's. It's in SAR footnotes.

The BEIR V Report goes into the details of effects of radiation at low doses, on everything from causing increases in all typMs of cancers, to serious genetic. defects, mutations, damage to subsequent generations, effects on schblastic apptitude in children and so forth. Tech shows a complete

disregard for the sanctity of life, for future generations L, and for environmental consequences by using documents of the

[ tydl submitted in order to get relicensed. 'By todays medical and EPA standardo this facility cannot be relicensed. This

! ?[, facility is in the heart of a major city. It is old,in an earthquake zone, one unsuitable soils, at the headwater regions qi of major rivergconstantly exposing young people to its daily v,

emissions under ALARA. It was not built to current safety G.

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and it is doubtful Tech would have succeeded back

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in the sixties in loc'ating it where it is particular those in'the medical and enviro;had more people nmental known, community, as in I i

we have known the effects of-ionizing radiation for over 100 years.  !

Both Madame Curie and her daughter died of its effects. Native  !

-Indigenous peoples have realized its effects without understanding I what it was for centuries,. Avodding areas that we later realized l had uranium deposits in large quantities. (Australian Aborigines,  !

certain Native American Nations). I I would like to 'say that I find it cruel and objectionable that NRC staff and Tech Council pushed to EXCLUDE MS. CARROLLS TESTIMONY. and, for the most part succeeded perhaps due to canstee constr91nsts of how the ASLB must interpret the existing laws.

Ms. Carroll may not be an l@xpert" in the sense of being a rudistaginatxknuttkxphyxizzxxx Tech scientist torturing animals to death by radiation in Techs underground maze' called .

Crenshaws Mountain witn cobalt -60 to establish what we already know, namely that radiation kills, but she has more of a mehtal and in depth understanding of the consequences of the nuclear nightmaregand compassion for living things than)the army of high priced lawyers ranged against her have n }' their desire to win at all costs over the common good, they committed an act of me.ntal cruelty against her by making sure she could not participate the way she had hoped. I urge you to fully' explore everything she raised in writing - and in any of her statements-to the fullest.

I beg you to consider all letters I have sent under my 2.206 pdtion and this portion also, as well as all inspection reports and documents referred to and supplied. I believe there is overwhelming evidence to support my 2.206 o ntentions and Ms. Carro11s contentions. .

I therefore plead, that in the interests of the effects to future generations , and the current well being of the city and the state that you grant us a favorable judgement.

Dr. Berte11 was shocked 1 Rat e%posure levels at this facility . Since 1980 NRC has recommended that ionizing radiation exposure to the general public from a local nuclear power or nuclear weapons complex not exceed 25 mrem year. Mr.

Collins said nuclear research reactors got exempted If that is true, it is indeed a disgrace. The office of Mr. Hardeman, if I remember correctly was recently sent a notification via Senator Glenn's committees ,again if I remember correctly, concerning the fact that Dawson Forest was contaminated. We discussed it, but I did not take notes. The need for cleanup was at issue. How much more then is the need for this campus, this reactor site to be cleaned up which is far more contaminated according to their own documents ?

NRC should abide by EPA standards at the least. And under those terms, this dump of a facility could not be relicensed.

In closing, I would quote from the last page of former executive director of the Union of Concerned Scientists book : Melt-down - the Secret Papers of the Atomic Energy Commission" which has a forward by former ASLB Judge Samuel Jdsch3 1amenting that had g he known what Ford's ten years of research uncovered, a number of

[g facilities would not have.been built in this country. Ford's

'( closing book statement says : "

One can only hope that before the h

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b next meltdown accident, the authorities will finally recognize that when one is at the edge of a precipice, the only progressive move is to step backward."

Everything about this facility shows we are at the edge i

/' of a precipice. I am aware, as Judge Bechhofer told me, 'lhat due {

1 to my detailing and raising the terrorism issue, and GANE raising 1 it, the fuel rods were removed prior to the Olympics, and I thank you for understanding this grave concern. However, even absent the Olympics this facility poses the same threat in the heart of the city The LEU (Low Enriched Uranium) they wish to bring in afterwards to refuel it with is even higher in plutonium. The Emergency Planning Zone NRC allows around this reactor is only 300ft,beyond that, the students, the city itself can go to hell, which it will; in case of accident or terrorist attack. Please help us step bdck from the precipice , because if you don't, bMsed on the evidence I have put before the Commission these last two years, I believe one day a lot of people are going to look up and see the Angel of Death . Please, shut it down, forever.

A Thank You, Pamela Blockey-O'Brien.

PAMELA BLOCKEY-OBRIEN D23 Golden VaDey, Douglasville, Georgia 30134 USA.

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Rcsalie B:rtell, PhD,-GNSH 710-264 Queens Quay West, Toronto ON M5J IB5 Canada Tel: 1416-260-0575 / Fax: 1-416-260-3404 emall: 103062.1200@compuserve.com l

May 6,1996 Pamela Blockey-O'Brien D23 Golden Valley Douglasville, Georgia 30134 USA l

Dear Pamela,

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Thank you for forwarding more information on the very risky Atlanta housing situation for the  !

Olympic athletes. I cannot understand the recklessness of this choice, or of the continued housing of students so close to the nuclear reactor and cobalt 60 storage. I have been slow to respond to i

! .you because I have been in Europe for a month trying to deal with the International Atomic l Energy Agency attempts to cover up the Chernobyl disaster. Their conference in Vienna ended

j. without a consensus of the damage from the disaster, with the officials insisting that only 31 ' l

- people died, and there were no other problems except for thyroid cancers, most of which were not fatal. The Ukrainian Minister of Health was maintaining that 125,000 had died and there were

- many children and adults suffering immune depression, stomach ailments, autoimmune diseases, congenital malformations and other problems.

Not only do the radiation " protection" experts consider 10,000 more cancer deaths than would be

! permitted to chemical polluters, acceptable to the public, but they fmd that all of the suffering over the past ten years of children and the liquidators at Chernobyl is " recoverable and therefore l

L not a detriment". This is very strange thinking from an occupational or public health point of view. However, with such a strange concept, they encourage recklessness in exposing women,

- children and men to this hazard, o

It may take us many more years to final y bring the nuclear industry into line with occupational and public health standards for other hazards, but it will have to come. This will undoubtedly force the closure of such polluting installations as that at Georgia Tech. Please know that I support your efforts to close down this facility and have the Cobalt removed prior to the Olympic games this summer. A terrorist attack would produce a disaster worse than Chernobyl, and the prime victims would be our finest young athletes. I believe that we have established credible documents that provided timely warning to the Olympic organizers of the danger. They will have 1

to answer to severe international condemnation if the worse happens. However, they may also be j found responsible for direct damage to athletes exposed even in the best case scenario.

i Sincerel bu U$

Scientific andHuman Rights Consultant to the International Institute of Concern for Public Health d

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i Probable Health Effects resulting frorn Exposure to lonising + probable skin bums. hearth prior to j Apparent

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immediate death. None i

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1,000 or more Frying of the brain .

FoetM or @k hMWw death if pregnant. recovers to somewhat 600-1,000 Weakness, nausea, Deathin about 10 i normal healthin abc ut vormting and days. Autopsy shows

, three months.He or diarrhoea followed by destruction of she may have apparent hematopoietic

{ permanent health improvement. After tissues, including

! damage,may develop severaldays: fever, bone marrow, lymph diarrhoea, blood nodes and spleen; cancerorW tumours,and win discharge from the swetting and

{ probably have a bowels, haemorrhage degenerat'on of shortened lifespan.

of thelarynx, trachea, epithelialce!!sof the Genetic and bronchiorlungs, intestines, genital teratogeruc effects, vomiting of blood and organs and endocn,ne 50-150 Acute radiation Tissue damage blood in the urine. gfands. sickness and bums effects areless 250-600 Nausea, vomiting, Radiatioranduced areless severe than severe. Reduction in diarrhoea, epilation atrophyof the -

at the higher lymphocytes and (lossof hair), endocnne glands exposure dose. neutrophilsleaves the weakness, malaise, including the pituitary, Spontaneous abortion individual temporarify vomiting of blood, tnyroid and adrenal or sti!! birth. very vulnerable to bloodydischarge from glands. Infection.There may the bowels or kidneys, From the third to be genetic damage to nose bleeding, fifth week aner offspring, benign or bleeding from gums exposure,deathis malignant tumours, and genitats, closely correlated with premature ageing and subcutaneous degree of shortened Wespan.

bleeding, fever, leukocytopem.a. More 1 Genetic and inflammationof the than 50% diein this teratogenic effects.

pharynx and stomach, time period.  ;

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causes decreasein 0-10 blood cells especiatiy psyddarological None Premature ageing, granulocytes and disturbances. mild mutationsin

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-ti Symptoms of mataise i er st I 150-250 Nausea and vomiting

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' * ' .ff.- 1 2-  ?, F led to the Mannattan Project."

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. hundreds of times greater than the National 7 '. Academy was told or than we had calculated J

ll% in the earlier years of nuclear optimism. .i ,

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in it...and afterwards, suddenly, for no other -

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g3 explainable reason that has yet been

}/ advanced by anyone in the industry or the fk j Atomic Energy Commission, or the NRC,  ;

t- there was a sudden and unexplained rise in i infant deaths, in leukemia, and many years

'd later in various types of cancers."

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i Introduction The late Congressman Clifford Allen of Tennessee spent his

,f, lastThanksgiving Day composing a press release about the severe underestimates of radiation released into the biosphere from the nuclear fuel cycle. He had just received some alarming informa-tion, a copy of the memo written by Dr. Walter Jordan, a member of the Atomic Safety and Licensing Board and a former Assistant Director of Oak Ridge National Laboratories. In 1977, in what has come to be known as the " Jordan Memorandum," Dr. Jordan disclosed that the estimates of the releases of radon gas from the nuclear fuel cycle had been 100,000 times too low. Dr. Jordan's figures showed that as many as one hundred deaths could eventually resultfrom each day that the nuclear power industry continued in operation.

With Congressman Allen as he composed his press release was Jeannine Honicker, a Nashville businesswoman. Jeannine's daughter, Linda, had contracted leukemia at age nineteen, but recovered after a difficult and complicated bone marrow trans-plant Jeannine's husband, Dolph, News Editor for the Nashville Tennessean, had written Linda's story for the Reader's Digest.

In the process of learning about leukemia, Jeannine discovered something else. Leukemia is one disease which has been shown to f be caused by radiation. According to health physicists, a doubling of the spontaneous rate of leukemias might be part of the price we would pay if we used nuclear generated electricity.

Jeannine was among more than thirty intervenors in the licensing process for the world's largest nuclear plant at Hartsville, Tennessee. Joining with nuclear opponents in ten southern states, she helped to found Catfish Alliance. Following Clifford si Allen's death, she ran for his seat in Congress, unsuccessfully.

In early 1977 Jeannine met Stephen Gaskin, founder of The Farm, a religious community in Summertown, Tennessee, and Albert Bates, a paralegal associated with Farm legal. They s agreed to help prepare a case against the Nuclear Regulatory y  ; Commission.

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Biography of John W. Gofman, M.D., Ph.D.

Education A.B. Chemistry, Oberlin College,1939 Ph.D. NuclearChemistry, Univ of Calif., Berkeley,1943 M.D., Schoolof Medicine, Univ, of Calif., San Francisco,1946 Internship in Internal Med., Univ. of Calif. Hosp., San Francisco, 1946-47 Positions Academic appointment, Div. of Medical Physics, Dept. of Physics, U.C. -

Berkeley,1947; advancement to Full Professor,1954; Emeritus.1973.

Concurrent appointment (1947 on), instructor or Lecturer in Medicine, Dept. of Medicine, Univ. of Calif., San Francisco.

Medical Director, Lawrence Livermore Laboratory,19541957; Associate Director,1963-1969.

Founder and First Director, Biomedical Research Division, Lawrence Livermore Laboratory,1963-1965.

Chairman, Committee for Nuclear Responsibility (current).

Honors and Awards Gold-Headed Cane A ward,1946, to graduating senior for qualities as a physician, U.C. Medical School Modern Med/ cine A ward,1954, for outstanding contributions to heart disease research Lyman Duff Lectureship A ward (Amer. Heart Assoc.), for research in atherosclerosis and coronary heart disease Stouffer Prize,1972, for outstanding research contributions in arteriosclerosis One of the 25 Leading Cardiologist Researchers of the Past Quarter.

Century, American College of Cardiology,1974 Patents

• Discovery of Fissionability of Uranium 233

• Two Processes forIsolation of Plutonium Books Published .

What We Do Know About Heart A ttacks Dietary Prevention and Treatment of Heart Disease (with A.V. Nichols and V. Dobbin)

Coronary Heart Disease Population Control through Nuclear Pollution (with A. Tamplin)

Poisoned Power: The Case Against NuclearPower(with A. Tampi;a)

Other Publications Approximately 150 scientific articles encompassing the following fields:

• Lipoproteins, atherosclerosis, coronary heart disease

• Trace elements by X-ray spectroscopy

• Chromosomes and cancer

• Medical eflects of lonizing radiation

• Nuclear power, the hazards of plutonium and other sources of ionizing radiation

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,5 e Bl' Tile COURT: Those rules provide '

.. hation)s one form of energy. We have

.j that you willgive a summary of all of this background ? '.T ~ Ta'diation ranging in wave length all the way

-l information and ask one question and ask the witnessi [n very long wave length to very short wave length, l ifthat's correct. Do you have all that information that : a$d the types of radiation we are concerned about here you can recite? 5e those of very short wave length in the form of l

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'Xkrays and gamma rays; and in addition these can be l Bl' AIR. KACIIINSK1": l'es, I do, and 3 gknerated by machines, for example, X. ray Exhibit No. 5 is a biographicalsketch.- 1 " generators, or they can come from natural and

7 man.made substances.

l B1' TIIE COURT: Let Exhibit No. 5 be [ In addition to that form of radiation, we have

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filed as an exhibit and go on to a pertinent question '

' particles that can be emitted by radioactive sul5 stances,

' l, then. Let Exhibit No. 5-do you have it over there? such as electrons, which we call either beta rays or s

Let it befiled. I will read that. l'cu don't have to f positrons.

go into that. Exhibit No. 5 is a vitae, allright. 5 We have alpha particles which are charged nuclei of

[ Alarhed andfiled Exhibit No. 5 in erddence] [ helium.

These are all forms of radiation; either waves in

1. . nature or particles. Actually the waves are also Bl' TllE COURT: Go ahead, sir. R regarded as particulate for some purposes.

l B Y AIR. KACIIINSK1': [ Continuing] ,l Q. Okay. II_ow does radiation affect living il

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e organisms?

x. Okay, as a result of your education and *

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i experience in relevant areas, do you feel qualified to answer questsons on radiation physics

• A. in generai, ionizing raaiation affects iiving organisms in a destructive manner. It causes, and biology?

as it goes through the cells of living organisms, the

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in which they are present and thus altering those atoms and molecules to some other form.

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, . Could you tell us briefly what is radiation? and molecules, it can often displace ciectrons from g;,. one energy state in the molecule to another. All of t {'l t hese have the effect of altering the naturally

., occurring substances in a biological organism.

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f the BEIR Committee in testimony before the Congress I in February has stated that the BEIR Committee is

going to raise their estimates, because the hazard now

. appears to be worse than he thought, which is in the

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right direction.

And we understand that there will be a report from e the BEIR Committee this fall sometime revising their t previous estimates.

l 1 Q. Could you tell us what AbtRA, A-L-A *

, R.A, refers to? l 8

A. ALARA, A L A R-A means as low .as [

reasonably achievable. It has nothing to do i

! with safety or freedom from cancer and genetic injury. [.

It just means that for the amount of money you are willing to spend, try to do what you can to keep people from getting too much of a dose and hence too many q cancers and leukemias and genetic injuries. Il p

Q. Does AbtRA essentially plan in human deaths?

A. so ieng as you have. ...

. B Y THE COURT: What is that again?

BY MR. KACHINSKY [ continuing]  :

s s ., Does AIstRA plan in, is it included?

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11. The effect of radiation in producing cancer N B Y AfR. KACHINSKY: ALARA.. .. is that for a period and after the person is

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v- f an irreversible m, jury.

b B Y AIR. KA CIIINSKY: Plan, p-l-a-n, plan. ll"' ' h'" * ' '* * 'i ' l ' "' I i"Oi' O b'f*

f 4 you begin to be able to perceive an excess of cancer.

Now, in the human, the studies that have been going B Y Tile COURT: All right.

, have not been going long enough so that we know for

{ sure whether once you start seeing, say, a thirty A. rian in human deathse i per cent increase in cancer per year, whether it will last for twenty years or thirty years or for the whole l g B Y AfR. KACHINSKY: [ Continuing] [ rest of the life of the persons expesed. We call this

~

} region where the number of cases of cancer deaths i  ; each year caused by the radiation, where that number i . What-does A LdRA..... f. stays fairly constant, we call that a plateau region.

f And the question asked in your question about a A. It permits deaths. i

[

'if "8 P'^'e " i' 'h* '"di"'i " *ffec' ' "'i""*d throughout the rest of the life or do you go back to the

& normal risk after thirty years or so?

[; Q. Permits human deathst j Everyone in the radiation community of protection 3 knows that we don't know the answer, and the only j- $ reasonable prudent public health posture is to assume A. ves. because AtAaA does not say-see. the a a iifeiong piateau uniess you have proved that it isn t

, . .. only way you could avoid deaths from the 3 lifelong.

l nuclear fuel cycle is to have zero releases. $ 11ut the number of cancer deaths is much higher

' }[ ALARA says keep the releases as low as you can f if the plateau lasts for the lifetime than if it only lasts

, I reasonably achieve with the economics that you want to for twenty or thirty years. i spend on it and the equipment you have available {g h"$  ? and so forth. P So it is a planned emission of radioactivity and . IVhat uns the Tri-State Ienhemia Study?

$ h f t,. that in effect means planned deaths. g

$ A. That was a study or the association er such

'j Q. IVhatisalifelongplateau?  % diseases as leukemia with the amount of G

k X-rays that have been received by people in their past e f

. 58- j k 59 -

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T UMTED STATES ' /T g g NUCLEAR REGULATORY COMMisstON N a : Dr. John W. Gofman SEP 111970  ;

g "AsmacTom. o. c. asss ,

% ... . . /j .

j SEP 111978 h There are a few points in the article that we would like to  :

Q coment on. \;

r 1 (1) The most serious flaw in the article is that it does ]

-t -3 not seem to properly catch the extent of our concern j

% with the growth in total worker exposure, that is the a Dr. John W. Gofman i U collective dose, as compared to the exposure of *

, Comittee for Nuclear 3 E' ' individuals where the picture is generally better. Also. [

Responsibility. Inc. i v in discussing the growth in the collective dose, we are c P. O. Box 11207 1 9 =ure that we discussed this as being of concern not just i San Francisco, California 94101 . because of genetic effects as the article says, but also [

7 somatic ef fects.

Dear Dr. Gofman:

. 4  :

q i (2) ' The article coments on planned pmposals to the Comission. [

Thank you for sending us a copy of the rtici YW can mfer to Oe staU paper for the specWes of what ~

The Day. from June 30. We were not aware of h appreciate your calling it to our attention" *8" J lJ We proposed to the Comission. One point we discussed was the importance of an infomed decision by radiation workers

([

) d T to accept exposure, and this is undoubtedly the basis for M The interview with us on which the artici -y -

the somewhat paraphrased quote attributed to Goller. The time ago. We have recently gone to the Com 1 evidence mounts that, within the range of exposure levels "

h a staff g Paper on the topic of occupational exposure. th k y- encountered by radiation workers, there is no threshold, will find this staff paper a current and m deta Hed a p. i.e., a level which can be assumed as safe in an absolute e picture of our views. A copy is enclosed

• M R. sense. We have found in discussions with people both in 2 4

$?a the power industry and.in the nuclear medicine field that Your letter questioned the context of the quotati ns 1n the article. The interyfew covemd the broad s .

~8 N many people in these fields honestly believe that the low levels of exposure pemitted are without risk. which j n

exposure to ionizing radiation. only part o whic reflects that somehow the wrong message has been delivered.

or activities licensed by NRC. There was particul 7p Y in spite of the fact that our regulatory program has been

{  ?

on occupational exposures in the ins ti 7 based on the prudent policy assumption that any amount modification of nuclear power plants and n th " ~1 . of radiation has a finite probability of inducing a i nuclear medicine. Presumably because of limit t f health effect, e.g., cancer. We brought out in the ,,

and in recognition of the particular intemsts f 8 1Mi d intenlew wr concern that in the past the way the the article deals mostly with exposure of worke t 1

g- regulations were written and regulatory programs were -

1 reactors and thus applies the quotations 1 - e established may be responsible for creating the impression

" c '

among many w rkers that the levels of exposum permitted context than the interview. HNever* we fee th thors .w are completely without risk. We felt that it should be have made a fair and generally successful effor main thrust of what we said. Although ch f he maten al in

"

• 1 -il '

made clear to workers that there is some risk. The third I quotation marts is in fact a suma of t -

explicit point in the article is just one way of doing that.

9 '#"*8 U" we don't feel that what was said i P d.mcognizing'EhL

?

that a writer must have some latit d n ' N (3) We discussed with the reporter two epidemiological studies g

to an article of reasonable length. "9 * ' "9 I"*'I'" QI j.T started by the AEC. one being the Health and Mortality Study.  ;,

j Q of which the Hanford study was part, and the other the j j r Transuranium Registry. The article somehow seems to confuse g and lug these together.

} k u

. i a A A y e

• =

\ _

c il[ - 62 T " [

I i

Dr. John W. Gofman I

(4)

The ' ducted remarks about the problems of ingested or industry, but rather exposure ofinhaled activity were no atmospheric bo:"b testing pecgram,peronnel a subject during the with which we believe you are mucn more familiar than we.As effect that the very high level of uncertainty wit respect to both " body burden * &nd neutron exposure had

' been recognized early and a number of effective measures

, taken to keep this type cf exposure to extremely low levels.

and in particular needed to be taken into account expanded epidemiological programs since much cf the We have been told that the total number of pe in the weapons program ever the years is quite large .

( We could discw just nit-picking.

H The article is fundamentally a good job of

-f

, 3 to improve public understanding of some of the have to be faced in dealing with nonthreshold pollutants there is a growing awareness that radiation is only we think one o;f these This certainly is an area which r.eeds public attention and great .

awareness of the difficult public health judgments that must be made in balancing the needs of society against the adverse imp of activities taken to meet those needs.

Sincerely, ht d. kW 4, Robert B. Minogue. Of rector Office of Standards Development, i'

Karl R. Goller '

Office of Standards Development

Enclosure:

SECY-78-415 f

j cc: Mr. Lance Johnson G The New Lcndon Day 47 Eugene O'Neal Drive b

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New London, Connecticut 06320 I' F $

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A. i heiieve the standards now in effect, the per.

j( mitted doses would permit people to die, yes.

y;

,[

Q. What standards, in your view, would not

• permit people to die with regard to releases

@ from the nuclear fuel cycle?

's <

A. zero reiease. l

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Q. Zero radiation.

standard . . .

And that is the only ]

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, A. That would keep people from dying, yes, sir.

, .e

~ $h Q. In your view, is there anything, any

}! activity, that canjustify releasing radiation j f; to the general environment where people may be j ft f g)  ?.

exposed to it? i]\

y

, A. I think that that is a very fundamental lf gy question for society.

h (v The Constitution tells me that it's not permitted to .j$

&k do something that takes life away without due process, pf

(- jl, and releasing radiation c'oes that.

gQ So, I can't justify a way if it justifies releasing fj f, radiation and killing people unless we change the L;p c!i {g &

f Constitution. l tj 0

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f; e\ Q. Is it your testimony that no dose however (,Q

{y i small, as long as it is not zero-the F r 6 Y 3}4d

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{ HEALTH EFFECTS OF EXPOSURE TO LOW LEVELS OF

                                              !              IONIZING RADIATION:BEIR V i                                                           This volume reevaluates the health risks of ionizing radiation in light of i                                        ,

new, much more reliable dose estimates for the A-bomb survivors and 11 more years of follow-up of the survivors for cancer mortality, follow-up

    =                -
                                               .             studies of persons irradiated for medical purposes, and relevant experiments with laboratory animals and cultured cells. The committee presents risk               ..

estimates for specific organs in relation to dose and time after exposure, and compares radiation effects between Japanese and Western populations. They apply their risk estimates to the 1980 U.S. population to project the risk of 3 cancer mortality at low levels of continuous exposure and for acute exposures, and give confidence intervals for these results. BEIR V also examines heritable effects due to parental exposure and the l effects of irradiation on the developing fetus; presents risk estimates for heritable effects, which are based primarily on studies with laboratory animals; discusses the role of somatic mutations in the development of radiogenic cancer; and examines studies of those exposed in utero at

           ~

Hiroshima and Nagasaki, which show significant effects on brain [. development and intelligence. _ Also ofinterest . . . HEALTH EFFECTS OF RADON AND OTHEliINTERNALLY DEPOSITED ALPHA-EMITTERS:BEIRIV BEIR IV describes hazards from radon progeny and other alpha-emitters that humans may inhale or ingest from their environment. The authors analyze and summarize clinical and epidemiological evidence, the results of s animal studies, research on alpha-particle damage at the cellular level,

                                            *l               metabolic pathways for internal alpha-emitters, dosimetry and micro-dosimetry of radionuclides deposited in specific tissues, and the chemical l-     toxicity of some low specific activity alpha-emitters. Techniques for estimating the risks to humans posed by radon and other internally deposited alpha-3 emitters are offered, along with a discussion of formulas, models, methods, and the level of uncertainty inherent in the risk estimates.
                                                       ;      ISBN 0-309-03789-1;1988,624 pages,6 x 9, index, paperbound l,  .

ISBN 0-309-03797-2;lurdbound NAl~lON Ali ACAI)l31Y PRFM ihe National Academy Prew was created by the National Academy of Sciences to publish the reports iwued by the Academ3 and by the National Trademy of I ngineering, the Institute of Niedicine, and the  ! y National Research ('ouncil, all operating under the  ; charter granted to the. National Academy of Sciences  ; h I b3the Congrew of tige t 'nited States 4 A

BACKGROUND INYORMAl'lON AND SCIENilt/C PRINCIPLES ^ L$ L 12 EFFEC 15 OF EXPOSURE 10 LO V LEWL5 OF IONIZING RADIATION' , filled with tissue-equivalent gas at pressure levels appropriate for simul ting ' sphercs of tissue with diameters on the order of 1 pm.! The principles of '

                                                                                                                           - H2 O+ + H2 O - OH' + H 3O+

microdosimetry are extensively discussed in the BEIR IV report (NRC88) and ICRU report 36 (ICRU83).-

                                                                                                  . The free radical OH* has an unpaired electron and is therefore highly; e    : reactive as it seeks to pair its electron to reach stability. At the high Energy Nansfer-Kerma and Absorbed Dose                                              ;     initial concentrations, certain back reactions occur produr.ing hydrogen
                                                                                                   . m lecules, hydr gen per xide and water.             e initial species produced in The transfer of energy from photons to tissue takes place in two stagesi      ,

(1) the interaction of the photon with an atom, causing an electron to be set j ' water md@ can men k wnuen an

        ' in motion, and then (2) the subsequent absorption by the medium of kinetic .       (                              HO radia6m

e.,, H', H2O2 , H2.

2 energy from the high energy electron through excitation and ionization. . The first stage can be identified with the quantity called kerma, K, l

• which stands for kinetic energy released in the material. Instead of being ionized, the water molecule may simply be excited accmdng to & reactbn:

' - K - dSr/dm, witcre dE r is the kinetic energy transferred from pho. - i tom tr actrons in a volume element of mass dm. (2 HO radiation

H,0*

                                                                                                                                                     ~
                                                                                                                                    ~

The second stage, energy absorption, is more important for under- [ . standing radiobiological effects. The absorbed dose, the energy absorbed - t where H2 0'. is the excited motecule. But H 2O? soon breaks up into the per unit mass, differs from kerma in that the dose may be smaller due  ; H radical and the OH* radical accmding to: to lack of charged particle equilibrium, bremsstrahlung escaping from the { ' medium, etc. Another difference is that the kerma refers to energy trans-fer at a point, whereas the energy is absorbed over a distance equal to H2Oi - H* + OH'. the electron range. Of the two quantities, absorbed dose'is the easier - As a result of the above processes, three important reactive species are one to approach experimentally and can be determined by a number of { produced:' the aqueous electron, OH', and H', with initial relative yields well-defined techniques, including gas ionization methods, calorimetry, and h thermoluminescent techniques. On the other hand, kerma is often more  ; f about g%,45%, and 10%, respectively. These reactive species attack j molecules in the cell leading to the production of biological damage. The casily calculated.  ! OH* radical is believed to be the most efTective of the three species in ji . causing damage. Because it ifan oxidizing agent, it can abstract a hydrogen Radiation Chemical Effects Following Energy Absorption h. atom from the deoxyribose moiety of DNA, for example, yielding a highly p reactive site on DNA in the form of a DNA radical. Since this process After the electron produced by a photon interaction passes through . anses from the irradiation of a water molecule rather than the DNA itself, y tissue, exciting and ionizing atoms and molecules, a number of important s . the process is known as the indirect effect. Electrons set in~ motion by chemical events that precede the biological effects take place. Most of i photons can, of course, directly excite or ionize cell macromolecules by the energy absorption takes place in water, since cells are made up of more then 70% water. When an ionizing particle passes through a water j direct interaction with the critical molecule. His is called the' direct efrect.- ( Both mechanisms can produce cellular damage. There is strong evidence molecule, it may ionize it to yiekt an ionized water molecule, H2O+, and that the DNA is the most critical site for lethal damage, but other sites an electron by the reaction: such as the nuclear membrane or the DNA-membrane complex may also H2O H2O++e ' [ be impmtant. Ward (M88)' has derived an approximation of the damage yields {, The electron can be trapped, polarizing water molecules to produce the y expected in various moieties of DNA within an irradiated cell, in which; consideration is given to the direct deposition of energy in DNA and other - so-called hydrated ciectron, c.,. On the other hand,- the ionized water: $ molecule, H2O+, reacts at the first collision with another water molecule j molecules. Table 1-1 shows the amount of energy deposited per Gray in . each moiety of DNA within a cell that is assumed to contain 6 pg of DNA. to produce an hydroxyl radical, OH* according to the reaction:

                                                                                             ~

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J TABLEl-1 Amount of Encrgy Deposited in DNA TABLE 1-2 Yields of DNA Damage Necessary to Kill 63% of the per Cell per Gray Cells Exposed Mass per Celt eV Number of - Number of Lesions Constituent (pg) Deposited 60-eV Events Agent DNA ksh per M per Dn* Deoxyribose 2.3 14#U 235 Ionizing radiation ssB I,000 Bases 2.4 14,7(U 245 dsB 40 Phosphate 1.2 7,3(0 120 Total LMDS* 440 Bound water 3.1 19,tX10 315 150 Inner hydration 4.2 25#U 415 Bleomycin A2 ssB 150 dsB 30 SOURCE: J. F. Ward. C. L Limoli. P. Calabro-Jones, and J. W. Evans UV light T<>T dimer 400,010 (WARM). ssB 100 flydrogen peroxide 0" ssH <2.600,00 37*C  ? Benzo [alpyrene 4,5-oxide Adduct 100.000 Calculated from this is the number of events since 60 eV is the average Anatoxin Adduce 10,0 0 amount of energy deposited per event. 1-Nitropyrene Adduct 400,00 The yields of DNA damage necessary to kill 63% of mammalian Methylnitrosourea 7 fethy uanine cells (63% of cells killed means that, on average, each cell has sustained 3.Methytadenine 30,000# one lethal ewnt) can be assessed for various lethal agents (M88), as 2-(N-Acetoxy.N-acetyl) amino-fluorene Adduct 700,000 shown in "Ihble 1-2. The high efliciency witit which ionizing radiation (and bleomycin) kill cells is not simply due to individual OH radical-induced Other similar aromatic amides produce about the same number of adducts per lethal event lesions, as witnessed by the large-scale production of single-strand breaks "Dn = dose of agent required to reduce survival of cells to 37% cf the number exposed. with hydrogen peroxide. Mrd et al. (WA87) suggest that the efficiency of s a inu tiply darnaged sues. iate[gft , cell killing by ionizmg radiation at relatively low levels of DNA damage is dog calculated from individual exposures; no survival curves available. due to the production of damage in more than one moiety in a localized region, i.e., lesions resultmg from multiply damaged sites m_ a smgle location OURCE J. F. Ward

• C. L Limoli, P. Calabro-Jones, and J. W. Evans (Wa88).

or locally multiply damaged sites (LMDS). Recent studies (Wi85, Gr85, Ei81), as analyzed by Mrd (Wa88), sup- . . port the importance of indirect effects of ionizing radiation in producing DNA; these result from a high local energy deposition m the DNA (m. damage to intracellular DNA. This is of particular significance in view of such a volume, multiple radicals cause multiple lesions locally); (5) the the suggestion that most intracellular DNA damage is caused by direct individual lesions making up an LMDS can be widely separated on the ionization and that radicals produced in water cannot access the macro- opposite strands of the DNA; if they are separated too much, they could molecule. It appears from the above analysis (Wa88) that the volume of be repaired as individuallesions. water in the DNA-histone complex (nucleosome) is at least equal to the DNA volume and that radiation-produced OH radicals in the water volume have ready access to the DNA molecule. Physics and Dosimetry of IIigh-LET Radiation (Neutrons) Some of the current assessments of DNA damage caused by ionizing Inscractions ofNeutrons with 7 Issue Elements radiation in mammalian cells (Wa88) are as follows: (1) direct and indirect efIccts are both important; (2) the quantity of damage produced by ionizing When neutrons impic3e on a tissue medium, they will either penetrate radiation is orders of magnitude lower than for most other agents for equal it without interacting with its constituent atoms or they will interact with cell, killing efficiency; (3) mdividual damage moieties are not biologically its atoms in one or more of the following ways: (1) clastically, (2) inelasti-sigmficant since they can be repaired readily by using the undamaged DNA cally, (3) nonclastically, (4) by capture reactions, or (5) through spallation strand as a template; (4) LMDS are more likely the lethal lesion in cellular E' **

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Q 4?n' Genetic Effects of Radiation j.,4 5 qh 1 if.ii. - g4  ; IY  !

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 ,          fi. .      INTRODUCTION e   '

P .. y tjs lonizing radiation damages the genetic material in reproductive cells 3' d

            }k' and           resultseffects in mutations          that firstare   transmitted        from generation
                                                                                                           .@f to generation.

The mutagenic of radiation were recognized in the 1920s, ([(@;qE j and since that time radiation has been used in genetic research as an important means of obtaining new mutations in experimental organisms. G 4 ' y }j . ' Although occupational exposure to high levels of radiation has always been , e of concern, not until during and after World War II was there a concerted 1 5 effort to evaluate the genetic effects of radiation on entire populations. N These efforts were motivated by concern over the effects of extremely large 1(l .[ 8 sources of radiation that were being developed in the nuclear industry, of radioactive fallout from the atmospheric testing of atomic weapons and of

                                                                                                                      ]f
              .        the rapidly increasing use of radiation in medical diagnosis and therapy. In                    ;
    .,dP    h           1956 the National Academy of Sciences-National Research Council (NAS-NRC) established the Committee on the Biological Effects of Atomic J$               Radiation (denoted the BEAR Committee), which was the forerunner of                      +d      1

[ the subsequent NAS-NRC committees on the Biological Effects of Ionizing { ):, ' Radiation (BEIR committees; of which this BEIR V report $j is one). A 1 gy c 'Wj.. series of reports from the U.N. Scientific Committee on the Effects of

    } {@f Atomic Radiation (UNSCEAR) has also addressed the genetic efIects of
                                                                                                                    ]i;  .

51 f: radiation exposure on populations. :l,

                 .           Although there is a continuing need to assess the genetic effects                               'j rf <f& of radiation exposure, for several reasons the perspective has changed                                  "k,
               ,                                                                                                        W             i
     ' S$p somewhat from that in the 1950s. First, it is now clear that the risk                                       .) of cancer   !

hc; 65 . !$ a Yl h i 1.-) l

m b l , s 66 EFFECTS OF EXPOSURE TO LOW LEVELS OF IONIZING RADIATION in individuals exposed to radiation is significant and that limiting exposure to radiation to reduce the risk of cancer also limits the genetically significant [!} 3 e f exposuse. Cecond, the instruments and techniques used in medical radiation have improved significantly, so that the overall doses used in medice.1

                                                                                                         ! p'e [
 ;}                    diagnoses are reduced and patient exposure in all but the targeted organs               ,

t g is lessened. Third, in regard to the induction of mutations, the greater . current risk seems to result from exposure to chemical mutagens in the g a i environment rather than from the exposure of populations to radiation. g $[y;v

  ]                     Despite changed conditions, estimating the genetic effects of radiation              .g si-remains important for setting exposure standards, both for the general              ~

population and for those exposed in their occupations. :r There are many dilliculties in measuring the genetic effects of exposure of the human population to radiation and other mutagens. This is why, J more than 20 years after the BEAR Committee first addressed the issues of . D iH radiation exposure, there is still uncertainty and controversy. He following j ji f, are some of the difliculties and considerations that must be kept in mind, f I_ The genetic effects of radiation are expressed, not in irradiatedb; indi 3 f viduals, but in their immediate or remote offspring. The time lag is great Ql 3-l because of the duration of the human life cycle, and massive epidemiologic e f studies with long-term follow-up are needed to accumulate sufficient data for statistical analysis. Moreover, for risk estimation of exposures that are ,

    ?

not uniformly or randomly delivered to the entire population, the age and Ii sex distribution of the exposed population and the different probabilities of s having children for members of the population of each age and sex must

              !            be taken into account.

The mutations induced by radiation can also occur spontaneously. When humans are exposed to low doses of radiation, it is difficult to 9 estimate what small increment of mutations is induced by radiation above that from spontaneous background radiation. However, radiation has been found to be mutagenic in all organisms studied so far, and there is no reason to suppose that humans are exempt from radiation's mutagenic effects. These mutagenic effecta are expected to be harmful to future generations [ because, in experimental organisms, the majority of new mutations with detectable effects are harmful, and it is assumed that humans are affected f; similarly. Indeed, the harmful effects of mutations that occur spontaneously { in humans are well documented, because many of them result in genetic 1 I disease. The genetic efIects of radiation must be detected through the study of certain endpoints, for example, visible chromosome abnormalities, proteins with altered conformations or charges, spontaneous abortions, congenital

           !                malformations, or premature death. In addition, radiation induced muta-tions may affect different endpoints to different degrees. For example, the f    ,

dose of radiation required to double the incidence of one endpoint need n  ! l h

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