ML20204G770
| ML20204G770 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 02/28/1999 |
| From: | Blockeyobrien AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20204G762 | List: |
| References | |
| NUDOCS 9903260270 | |
| Download: ML20204G770 (17) | |
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%f [ l'anwla IMey O'ikien
!, '1he Executive Director for Operations, .
S V D3 c*n vaney t . 7631 Dallas liwy
- j. U.S. N.R.C. , .
%wn,, c3 3 mms, Washington, D.C. 20555 1
I Re: Comments Solicited Persuant to-10 CFR.20.1405 and 10 CFR.50.82(b) (5) j concerning NRC approval of '1he Georgia Feb. 28th,1999 l
Institute of Technology decommissioning j
- plan for their Neely Nuclear Research )
Reactor (License.R-97) on the campus ;
of Georgia Tech near student housing !
t inl downtown Atlanta.~bontT n-gn l l ' Here follow my connents on the above referenced plan:
'1his plan should NCTP be approved as written. . It's grossly inadequate. i The NRC never answered a question I posed in connection with additional correspondance
- I sent regarding my 2.206 Petition, and the question has a bearing on the. current C+x-dssioning plan also. It concerned Tech snManly deciding it didn't need this ,
radioactive dump of_a reactor,after fighting to keep it open tooth and nail,using oodles of lawyers and the State Attorney Generals Office, and them basically infering I
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.it would be the end of western civilizatic as we know it if they couldn't keep this l
~ awful facility open. The' question was, more or less, :Were they lying then (in saying i "howtheyneededit)oraretheylyingnow(insayingtheydon't?)Iaskitagainin
( connection with this application "Are they lying now ?" Do they really want to do a I real im'==nissioning job 7 It doesn't look like it.
I ask it, because in the original Tech documents, the original estimate for such a dawrmnissioning was $10,000,000. ter $6,820,000. Furthermore, where are the details showing how much of the money will be spent on ACIUAL cleanup etc. and how much for wages, and how much to waste management companies, shipping, equipment purchase (you can't rentLit as they seem to want to, then return it,it will be contaminated)and ;
who exactly will these entities be ? Furthermore, they want to Mt up the Georgia General Assembly for the' money. I don't think so. hs noted in my 2.206, as far as I could establish, the reactor seemed to owned by a conglomerate of GTRI,The' Board l of Regents .and others,possibly includi brought it here to begin with, namely
't Georgia Power etc. (see my 2.206) As I have stated in the past, those who own it and those companies + universities, who used it can pay for the cleanup of the mess they made - not- forgetting the Department of Defense who helped subsidize it and the agencies and entities who used it,such as the NRC itself and the EPA. IUr GEORGIA ,
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TAXPAYERS.
At first I read what NRC sent me (i.e. the "short form") casually, and I got that old sinking feeling one gets concerning Tech,and this radioactive dump and how ~
t o they've handled the affair, then I began to get tho distinct impression that Tech was L $$ up to it's old tricks perhaps,. because, although Tech's letter states the d tv'= ant L QL .was prepared by NES., it says iLwas in conjunction with GrRR staff and they'd re- j l g viewed it, and yet it.seemed to be partly just a regurgitation and recopying of the
- i. o same old stuff - including the "mischaracterizations" and floor plans directly out of j g that terrible:re-licensing application they originally put in for. So, I began to j q read it: carefully.. By the time I.got to Line $ in the introduction,in the very first a
33 paragraph I knew Tech's old habits were alive and kicking - they are a bit like M a certain historical personage in Washington, only Tech's addiction appears to be f' trying to continue.to' irradiate asl much W humanly possible,as they intend to leave b the highly radioactive building in place , as they say in Lire 81they want to be ,
g " able to get US NRC to. release this radioactive junkpile for " unrestricted use by J
Georgia' Tech".- and continue 'other" licensed activities" (i.e. with radiation) at the s
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c) l site. Considering that their activities have included torturing animals to death by radiation, blowing up gemstones while irradiating gems for jewelers and cx>ntaminating l 6 ^ hell out of the place, and also contaminating hallways, parts of the campus and on ard on, - including releasing airborne radiactive contamination that blew onto the campus, the frat house and the fomer housing for the poor nearby AND NUT TELLING THEM .(I won't even get into the dumping of the radioactive wastewater to the sewers with no permit from the City of Atlanta for almost 30 years) just as now, you can bet your bottom dollar that they have not sent a letter to the parents of every student I on the campus, inferming them that they currently hold almost 200,000 Curies of radio
! -active Cobalt 60 (it turned out, that at the time of the Olympics, Dr. Bertell and I l originally had a lower figure, and it was far higher, and now its just under 200,000 C1) in the office building next to the reactor, separated from the outside world with cement wall, and still vulnerable to accident and terrorism, the consequences of which would be a disaster as both I, Dr. Bertell and Others have told NRC,the fomer Governor g
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ard even the President (ramamhar the telegram to Clinton I sent,did that cause a stid) I and Tech still won't get it out (and neither will anyone else order it out, including the NRC Commissioners to their eternal shame) considering all this, Tech is unfit to have any program dealing with radiation on campus, other than teaching it out of books.
The co-60 in the poo go back to DOE Savannah River site from whence it came, and i l as the pool, and the hot cell (where they have now stuffed the other cobalt 60 irrad- l iator encased in 4,000 lbs of lead - they told me recently, to do materials testirg fov- ]
forgoodoldGeorgiaPower(SouthernCo. owned)fortheirlousy,decrepitnuclearplants) i falls under the reactor license ( and as the reactor is being decomissioned, l then all that goes with it must NRC's questions to Tech speak of the l Ynterface between the co 60 stora pool and the reactor" and of the"Co 60 irradiator". ;
So where is the decommissioning plan for all cf that ? 1 The entire reactor, contaminated containment dame, contaminated floor, basement, cement ,
on which it stands on the famous " mud flap" , the contaminated cement that " protects I it (the reactor) from the buoyant forces of the groundwater" (remember ?) the contamin-ated soil beneath it, the adjacent building with all its contamination, even the cont
-aminated groundwater beneath it, everything must go, and the groundwater be v uped.
Please note: they make a difference between " direct radioactivity" and "rmovable radioactivity". It looks as if they only intend to try and remove what they can;because ;
the place 4.s so radioactive, the walls, the elevators, the duct space,the decontamin-ation roms, radiochemistry room hoods, chemical additive tanks, air conditioners, cat-walk, the control rom, even the control roam console etc. ad nauseum, that unless j that whole pile of radioactive junk is hauled offsite in its entirety, it's going to j l sit there, with young people all around it and coming and going inside the fake contain-l ment dome and adjacent building giving off alpha, beta, and gama radiation until l
dmmay- which may be sooner, rather than later considering Y2K and the Co 60 sitting l
there in the spent fuel pool - and that is totally unacceptable.
l Their " Reactor Facility Description" is understated to say the least. How it actually
, started and the details on Tech, Georgia Power, Atomic Energy Comission and Defense
! Department boys and their toy, is in my testimony of May 1996 before Atmic Safety
! and Licensing Board Judges Bechhoefer, Kline and Lam. Tech's " exploring the frontiers of biology nnd material sciences " included causing excruciatin pain pain and death to animals and humans alike.
Under CONTAINMENT Description : they say "leaktight barrier" it never was, frm day one, 'mch knows it, and so does NRC. .
Re: the water filled fuel storage hole. It'll be highly contaminated, they also put spent fuel in it if I reember correctly, and one was giving off a n enormous cbse,it was in an inspection report.
Under " operating histor; ": While they were running around saying how underutilized it was, in the meanwhile they were running it almost daily - as I surmised.
Under Dammmissioning 1.6, t all they want to do is their usual, tidy the place up a bit, clean it up a hit, remove the reactor vessel and a few odds and ends and keep right on going. it s una ceptable.
3 Under 1.7i Program Quality Assurance It says Georgia Tech will conduct its own overcheck of the Decomissioning Contractors programs, to ensure that the work is performed in a safe and controlled manner. What a lark! Thisjfrom the same outfit that had everyone and their brother running around looking for a lost radium needle, l
until poor unappreciated Radiation Safety Officer Boyd found it outside under some I leaves. This;from an institute that would not even listen to their own Radiation l Safety Officer when he and another staff person told Tech NOT to bring the cobalt-60 I in as it was too dangerous. This,from an Institute that even succ&ded in contaminating the AtCS on the campus, that Dr. Copcutt fcund. This,from an institute that could not even keep its sources under proper control and sent a leaking source to Antartica.
This,from an Institute that allowed dangerous experiments with benzene as well in the l shack next to the reactor,where they would scxnetimes store radioactive waste. No way I should that happen. NRC should mandate that Quality Assurance have a citizen selectedg totally independant scientist do that, such as a team from RPHP, and Public )
Citizen,and Marvin Resnikoffs Radioactive Waste Management, and Dr. Bertell too,56 M. Maybe Tech will learn scnething in the process.
Under 1.8) They say there'll be an Executive Engineer to be used by Tech , who will, among other thin Contractor documents."gs,Sounds" coordinate revi%
a little like and approval running of the interference Decomissioning
- besides, there should be two people, one of them a biologist who specializes in the medical effects l of radiation exposure. Again, independant. 1 I
Under 2.1i Not only has Georgia Tech not , repeat NOT, included ini.ts decommissioning plan the followina , quote : "In addition to the reactor, the facility also contains laboratories, offices, classrooms and a hot cell, which are g included in this de-comissioning project. Therefore, during the dimantlement program, precautions will be taken to preclude unauthorized access to controlled areas, to prevent the spread of airborne contamination to prevent any direct radiation hazards to personel."Further, they say they want to use AIARA principles "as set forth by Tech". Let us take a very close look at this. 1. I have enclosed a copy of two of their drawings under this plan, one of the groun floor, one of the first floor (pages 12 and 13 of their plan) and three pages from their relicensing application, showing the first floor, the ground floor and the second floor also. This is to show how totally interconnected
.the buildings _are that house the. reactor, hot cell, labs, offices,etc. and I have added the notation as to where the cobalt 60 is stored.This building is full of staff and students. And it seems, they sti11 allow visitors. I point out, probably for the millionth time, the vulnerability of the cobalt-60 to terrorism. Anyone could climb on the roof (as Fox news did in broad daylight, remember ?) and drop explosives down the hot cell ventilation duct , end needless to say the consequences would be horrific.
I will not elaborate again on the " rocket launcher through the wall from half a mile or more away" scenario I went over with NRC and the Judges prior to the Olympics,and the rest of the scenarios (which caused Tech to move the Highly Enriched Uranium out and the esteemed Judges to forbid the Iow Enriched Uranium to come in ) again, exc?pt to say that obviously Tech doesn' t care diddly-squat about the safety of the students staff and anyone else there, and nesther did the former Governor,the President of the United States, or the NRC's own Comissioners,all of whom could have ordered it out, indeed are the only people who can under the law, and who did not. We all know the consequences of such a disaster, and no one will act responsibly and get it out of there. Now, this irresponsible Institution wants to bring in all sorts of heavy equignent, including abrasive saws, drills, blow torches, shot blasting equipnent, robotic arm, jackhamer etc. (the vessel part itself weights 2,000 lbs -by the way, was the crane they'll have to use ever certified after I raised the issue ? It was left as an "open" item) and they intend to do all this work with radicactive dust all over the place and they'll need people with self contained noon suits, and the vibrations could crack (remember they've patched it before if I remember correctly) the aged,MDIATION DEGRADED CEMENTT POOL CONTAINING 'IEE COBALT,WE'O LOOSE THE SHIEIDING WATER, AND WE'D ALL BE IDOKING AT" APOCALYPSE NOW" IN DOWNIUdN ATLANTAs and they are going to be conducting business as usual,and have staff and students richt next to it
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all the time. ND,ED, ND, and again NO ! M is me6L not be allowed by IWC. %e l entire building adjacent to the reactor and the batrhgs amund the site itself I cn the campus aust be evacuated, as well as the dormitories while all this is going !
an, and the Co 60 must be ru oved first too. An enclosed " bubble" with HEPA filters I must also completely enclose the OUTSIDE of the reactor building and the building 1 part with the offices, cobalt-60 pool, hot cells too, during the entire cleanup and i removal, and that office building with the pool and everything in it must be removed I too. They contaminated labs and hallways in it, one room with Strontium 90 and put l epoxy over the floor. I keep telling you all to go back over aLL THE FILES,ALL THE NUCLEAR SAFEGUARDS COMMITTEE MEETINGS, EVERYTHING. Back to day one, plus all the State files (not just the computer printouts) and force them to clean up all the areas )
on campus with fixed contamination.(Former RSO provided a list also to Jerry Taylor of l that. Rooms in different campus buildings.) j g As'to Tech and the AIARA issue. Ict us not forget that the Atcaic Energy Agency had l a star scientist, the man who co-discovered Uranium 233 ,the man who holds degrees ;
in chemistry, nuclear chemistry (PH.d.) and is also a medical doctor, the first medical i director of Ocrence Livermore Nuclear Labs, the founder and first director of the !
Bicmedical Research Divisicn at 87rence Livermore for the US Government. The man who holds patents on the discovery of the fissionability of U-233 and on two processes for isolation of*. plutonium. The man named one of the 25 leading cardiclogist researchers of the past quarter century by the American College of Cardiology in 1974, the expert on the medical effects of Jonizing radiation. Remeber him ? The man the NRC wrote to in 1978 because '
The man your pred;as they ecessor, mted,he tne Atomic was more familiarwent Energ,Comission with nuts scxne of the over whenissues than he told they.
them, l and a Congressional Comittee,how the allSle radiation levels were killing people.
The man that powerfull friend of the nuclear industry ,Hollingsworth, told they7d "get',' because he disclosed the effects on the people of the US. That eminent scientist Dr. Gofman, who ruddenly didn't get funding. Remember what he called ALARA ? Planned deaths . Planned deaths, gentlemen. ALARA meaning of course "As Iow As Reasonably Ach l 1evable - i.e. dependin@ on how much money you want to spend,you keep radioactive l contamination"a- low as reasonably gehievable! Yet Tech wants to set its own ALARA l
levels . NO. When I called Tech not too long ago to ask where they were storing l the co-60 irradiator now that they had moved it (violating every regulation in the g
j book in the process) prior to the Olympics - after I was the person that had to j tell h che own Head of Government Secured Installations. that it was stuffed in an i
underground maze near the presidents house - which just about gave him a heart attack -
(ask him), I mentioned Dr. Gofman in the course of the conversation, and the fellow at Neely informed me that Gofman was " discredited" so, a) that eminent scientist who was with the early team that did some of the work that led to the Manhattan Project (in which he declined to take part) highly regarded worldwide, is considered discredited by some fellow down at a contaminated research reactor and facility, and b) looks like the campaign to "get" him has worked to sczne extent, and c) such persons as the fellow at Tech who made the rude and blatantly untrue remark about a person with Gofmans stature will have input on setting Techs AIARA system. No.
-S meone like Dr. Ernest Sternglass, Prof. Emeritus of Radiological Physics at the School of Medicine should be brought in from RPHP. Someone independant who knows what they are doing. Ievels must be set as low as _ humanly _ possible.
Under 2.2 A little truth in advertising would have been nice. After all the issues G.A.N.E. raised,and All the issues I raised under my 2.206 and testimony to the judges, there was no way this side of eternity that Tech could have dared to continue to operated that du.np considering the contamination and problems. Fur-ther, they have 90lY. listed two of the almost countless problems and major events that occurred during the operating history, furthermore, the Argon-41 release rate went out the stack at 2i times background (see my 2.206 testianony to the judges) into the 90's., and the place leaked like a sieve every time they operated over
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a megawatt. Ask Poyd. He knows what went on despite efforts to prevent it. Pity they left out how the bismuth block leaked for years and they kept trying to fix it with aitplane glue. Since the sump is also contaminated and considering that it leah d for years, all over the floor, the entire floor needs removing as it is saturated.. There is no mention of the contaminated basement, the fact that it would flood too and when the water receeded it will have transported radioactive contamination to the outside with it into soil and groundwater the thing virtually rests on,being is that sometimes the carcasses asitisonlyafewfee)tbelow.Notto7orgotten,hebasement,youknowallthat of the poor dead IRRADIATED ANIMALS wefe put in t
" exploring the frontiers of biology" stuff....I also find it amazing that the issue l of the plutonium contamination is not really discussed at all. Should be. And the leaking Yttrium microspheres they manufactured using grad students that wound up killing patients.
Under Current Rad. Status; ThefactthatintgeBASICchare.cterizationsurvey contamination ranges up to 1,400,000 dpm/100 an were found for a y direct were i found is disgusting, but not surprising. However I believe when they really start work, they will find even higher coni: amination. To try and downplay it by saying '
the background obtained in certain areas was high and could have led to higher readings; has nothing to do with it, the inside of the containment dome was so contaminated from the constant trouble over the laears . Before they started it up, there was no " background" to speak of anyway.
Under 2.2.3 Release Criteria l They should not be allwed to use limits specified in a 1974 (i.e. 25 years old) Guide on radioactive materials unrestricted release criteria limits for surface contamination. They are also obviously trying to get NRC to approve their plan before Aug. 20th 1999 to avoid the new criteria set out in Title 10,ch.1. Part 20 July 31,1997 edition. They must be held to the strictest standards under that July 31st 1977 edition and not earlier. It must never be released for unrestricted use,ever. The background levels of naturally occuring radiation l at the site prior to it's being built were next to nothing according to Boyd who was there,and who dug up samples that were meant to be kept to prove it,and another man helped. Average background radiation across Georgia,even after contamination from nuclear fallout from weapons tests and Chernobyl (Chernobyl is no longer being l
picked up here according if any measurement of backgroundto isthe usestate,(d, gsfoY$1 be - none of the DOE and othe inflated background or EPA's famous TENR (Technically Enhanced Natural Background Radiation) doublespeak should be used. ;
With regard to methods of cleanup : The abrasive saws will release airborne radiation, e.g. activation products when cutting stainless steel, and if they cut underwater, the etntaminated water would have to be disposed of as radioactive waste and not poured to the sewers. If they do it using oil, the same would apply. They could also have major problems with the rubotic arm , and test runs should be practised elsewhere first.
If any radioactive so-called Depleted Uranium is involved as metal that requires cutting, I would reming the NRC that this is estremely hazardous, only those u th experience l should do it, it has to be done in a special way and the airborne fines can ignite..
l No workers should be employed who have not had extensive prior training and experience i in trying to decontaminate radioactive sites. .
Under 2.3 Lwmmissioning Activitiest Since the reactor " fake" containment building is so highly contaminated and can never be released for unrestricted use, obviously it has to be reitoved off-site, and the same applies tothe " associated facilities".
It says that all procedures will be reviewed by Tech for completeness and compliancce with all US NRC, State of Georgia and Georgia Tech rules and regs. Now Tech is the i outfit that had so many violations of NRC Rules we could do an en clodaedia on them.
The State of Georgia has extremely bad and lax rules, and they .v managed to run N 8N iN egtatgg g g g , g g g g g g g b aM sgtg tg used Tech radiation I
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Also the State contracts with Tech for radiation work. However, despite that, since we appear to have to deal with the awful situation we have, there should
- be State oversight by both Mr. Hardanans Division and Mr. Hills Division (Mr.
, Setcer sits in a different office a fdmiles from his staff, and when I spoke to him a few years ago, he told me he had never read the Tech files, so unless he has ploughed through them since, he protnbly is not as aware of what has gone on.)
as well as the Department of Human Resources of the State of Georgia and their j
Division of Public Health, as well as Mr. Jim MCNamara's Hazardous Waste Division and the States Superfund program (this qualifies as a State Superfund site) , as well as both the E.P.A.'s Office of grourc1 water and surface water, and the Fulton County Health Department (Atlanta is in Fulton County) Medical officers. This should be mandated by the NRC. Everyone involved must bear the following in mind:
" It is possible to elimirnte certain hazards by suitable physical or chemical treatments. Hamful bacteria can be destroyed by heat or by suitable chemicals.
An acid can be neutralized by a base.A capacitor can be discharged. In contrast to this, there is nothing that .;an be done to aradioac tive material that will cMngu .tM cbaractarutics of its radiationJts t==rature may be raised or low- ,
ered and it rey be subjected to severe mehanimi treatment or tvwNned denically with other elements, but it will still continue to radiate as before. 'Ikre is no swit& available which can turn the radiation on and off. No matter what treatment they recieve, rMimetim materials will continue to emit radiation in auuutuarmw: -
g with definite natural laws." (From: Radiation and Radiation Hazards, by W.W. Schutz y of the General Engineering Laboratory of the General Electric Company written in 1951)
T All " dilution" in water does, for example, is spread it around. Further:
"Ienizing radiation aunmy* the genetic material in Maudactive cells and resulth '
in mutations that are transmitted from generation to generation........it is now clear that the risk of cancer in indivithala --M to radiation is significant and that limiting er.wusure to radiation to raam the risk of cancer also also limits the genetically significant ev m mre.." This from Health Effects of Exposure to low Levels of Ionizing Radiaticn. Biological Effects of Ionizing Radiaiton V."by the National Academy of Sciences National Research Council The report was done at the request of various govern.nent entitiesand associated entities, and although it contains the usual inflation of " background" , it very clearly states ,page after horrible page, the ghastly effects of low levels of radiation on the unsuspecting public, so, when Techs application and documents refere to " low" levels, these levels have devastating consequences M Because all the young people who are, and will be, exposed to low levels (if anything is left on site)will suffer damage to the reproductive organs, everychildtheywillbear(andinwomentotheovariescontainingalltheeggsfor everything must be removed offsite, and a)ll the above mentioned hazards should b provided by Tech to all staff and students on campus and all potential workers and State Agencies., contractors and sub-contractors.
Under 2.3.12!- the 'one day" site-specific training class i.erformed by a Georgia Tech representative is totally inadequate and cannot be trusted due to Techs history.
Both it, and the Decomissioning Contractor worker training program cited,should have independant oversight and should last a minimum of three nonths in order for them aE to go over all files, learn about radiation and medical effects etc.- $1us3contain
- classes taught by the State Division of Public Health and an expert such as health a
administrator aM ra7 arch epedemiologist Joseph Mangano of RPHP. (Radiation and f Public Health Project.) and Dr. Sternglass. All Georgia 'Ibch staff and staff from the Nuclear Research Center should be invited to attend. LGtfA should also attend.
During all work, a physican specializing in radiation contamination should be on site at all times,along with a specially equipped ambulance and medics, as of course ambulance, medics and equipnent can be contaminated by contaminated persons and
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their clothing. The plan should also specify which area,of which hospital has been 3
sealed off to deal with any radiologically contaminated / injured persons, (as far as I know, thera is not one in Georgia) or whether military doctors who have dealt with radiological:.y contaminated persons will be brought in and such a person be flown to a militar/ facility for treatment if they are contaminated.
Concerning the site survey - as I said before, original " background" of the site was extremely Jow. It was a residential area with large shade trees,some people had domes-tic animals, and a little water course ran across the site and a lot nore besides.
The information on the sewer etc. under the reactor is in my letters connected to my 2.206 and can be retrieved. The massive amount of radioactively contaminated lead that is on site (over 133,000_ pounds) should NOT be disposed of as " mixed waste" but as RADIOACTIVE WASTE, because that is what it is, notwithstanding possible regulatotory J gobledegook over definitions. It should not be recycled either (although I am aware <
how badly NRC and EPA'wants radioactive metal recycling to help out the nuclear boys) l
$ as it will contaminate the recyclers, the recycling facility, the workers, and the end
} product. To the States knowledge, there is no " mixed waste" facility in Georgia any way - and since Techs plan only referes to some unnamed " disposal site",where and_what 2g is that ? Or had they intended to dump it in a landfill smewhere ? All the lead paaint s and the lead on the reactor top will also be , radioactive,aM the same would apply.
E Both EPA and State of Georgia Specialists in lead, as well as Osha reps, should also 3 7,be brought in , including frce the State Superfund Division for consultation and over-sight, as well as the State Division of Public Health and a paediatric toxicologist M@ 5 specializes in the effects of lead in children, from an independant source.
who
~n The highly irradiated shim safety rods, regulating rod and drive and drive motors likewise b $ are got " mixed waste" but RADIOACTIVE WASTE.also the beryllium source, and must go to d3 a radioactive waste site. They are so obviously trying to cut costs it's a disgrace.
yg Where are the remaining fission chambers /u-235 going ? They should be sent to Savannah g# River or Oak Ridge since those are already National Sacrifice Areas to the governments pg eternal shame, and so highly contaminated that is not going to make much difference.
eg The activated concrete must also go to a radioactive waste site, or next thing you know, gg someone will be grinding it up to help resurface roads, or the US Anny Corps of Engineers 2" may allow it to be dumped offshore to created one of their artificial reefs - after N all, if railcars and aircraft can be used, ....
$ d. Under " Outdoor characterization":- as I have stated, the vast amount of documentation on ap this site that actually exists, shows the yard, runoff area, shack-out-back, water, groundwater, vegetation and areas of the cam p are contaminated. The contamination f{4 n as shown in various reports and documents included Tritium,Cesiu:n 137, Strontium 90, N Beryllium 7. The Liquid waste system and sewer is likewise contambated, including 3 all that,is a must. Why are new retention tanks going to be installed ? inere is no need of them as everything must go, including the cobalt 60. The Entire reactor ventilation system, including the stack (why does that gay."ss heede8 buls?) is like-wise severely contaminated , and also the hot cell ventilation duct. For example, during fuel removal prior to the olympics, when cutting a fuel rod, the saw blade s(tuck and broke and they left both the fuel element and broken saw in there overnight to vent.
out side. To top it off, it turned out they had not even properly trained people. This was a viMation in an inspection report. Under 2.3.8'. - The Draft Copy of the final project report, and the Final Report should be provided to the publict for review The Radiation Safety Officer is I believe Dr. Ice. On a project like this, he should be assisted by a radiation biologist, as a health physicist is not a doctor, as well as the aforementioned doctor who whould be on site at all times,the reason being that this is a University Campus, not somewhere remote from a population center.
The tadiation Safety Officer and his staff and he additional stat f as nentioned, should be allowed to go over everyones head at. .ach if needed . The Technical Safety Review,Cbemitee should tot be appointed by President Clough of Tech. This is a po-L
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tential conflict of interest as he is the head of GTRI (see p.1) r tractor will be an experienced Under 2.4.5 - it and decontamination says the Decomissighge decomissioning . 3 lic is entitled to know whe they are, and what their track record is. Furthermore, if it is any cmpany to do with, or a subsidiary of The Southern Cmpany/ Southern Nuclear Operating Co/ Georgia Power, or WMX Technologies / Waste Management Inc/ Chem-waste / Chem Nuclear fervices in particular,They should be obli(ged to put all Atheir NRC and/or EPA and State of Georgia Violations and/or fines on the record first.
They mention further on, that Barnwell (Chem-Nuclear) and Envirocare are possible waste disposal sites. Envirocare WHERE ? As of today, March 1,1999 (this ccmnent is taking a while to write up) according to the Georgia Secretary of State, Envirocare Inc. doesn't exist as far as they are concerned because it was disolved by their office , administratively disolved for non-payment,on 8/6/96.
Under 3.1.2.: Looks as if the unnamed Decommissioning Contractor will be responsible for the Health Physics Program during the project. This is not acceptable, they should be working with Dr. Ice and his staff and the extra _ staff I said should l be hired on the previous page. Dr. Ice knows this facility now and the Decomissioning Contractor doesn't. Dr. Ice has distinguished career experience prior to RSO at Tech.
Under 3.1.2.2.4 Environmt.ntal Program Plan'- This document (to be prepared) should also have input frm , and be reviewed by the following : State of Georgia Mr.
Hardemans Radiation Surveillance and Mr. Hills staff and Mr. James McNamara of the i States Hazardous Wacte Division and the State Superfund Program, E.P.A. Air, Water l (ground and surface water Programs and Radiation and also State Dept. of Human Re- ,
sources , Division of Public Health, Fulton County Health Dept. Medical Officer, 1 State Non-Point Source Pollution Division and NPDES Permit section, US Dept. of Fish and Wildlife biologists (due to water and aquatic species impact if the pol-lution winds up in the Chattahoochee and both Tanyard and Peachtree Creeks prior to that) the Citizan Group Representative for Save Atlantas Fragile Environment Vivian Steadman Ph.d., and Dr. Ice.
There should be absolutely no releases to the sewer system, as it flows ultimately to the Chattahoochee River, and due to Atlanta's terrible Combined Sewer Overflow problems each tin.e there is heavier rain, as shown in my "2.206" Petition, the water bypasses the interceptor, does NOT go through the treatment plant (from which something that is radioactive can't be removed anyhow, but it may trap radioactive particle size contamhants, which are turn going tro wind up in the sludge, which is incinerated and sanfs the radioactive airbornas out the stack, and some will be trapped in the flyash which get made into bricks -along with other additives-next door,or goes to be incorporated into cement) but goes into Tanyard and Peachtree Creeks and into the river that way.
Under 3.1.2.2.5. Emergency Plan i . 'Inere is basically no Neely Nuclear Research Reactor Center one at present, except sme sort of tablatop one. They have NEVER had a campuswide evacuation drill (probably so as not to draw attention to the facility anyway - I mean most parents would not be thrilled to find out what their children are going to college next to) the plan they used to bave was the sorriest m anyone could imagine, and the nearest fire station for example, that would t apond has, absolutely no protective gear for anything concerning radiation -they would be wise if they headed in the opposite direction to be honest, specially aayth h1 involving the cobalt-60. I established just prior to the Olympics, that neither Georgia Emergency Management Agency or the NRC had a single full " moon suit" of the type worn in radiological disasters, and the Federal Emergency Management Agency had thought they had one in a warehcuse somewhere in Forest Park.... .I &xtbt the situation has changed.
Under 3.1.2.4 Radiation Protection Equignent'.- 1) dosimetiers 'cy the t1m they
- how, the person is already contaminated. 2) the contamination cont al egelp e nt (barricade rope, sheets of plastic plastic bags, plastic containers) is taur #mble.
9 i
Since when can we control radiation with plastic sheets ? Hw about some portable movable lead lined cement screens , with the lead encased in the cement (i.e.cenent on both sides ) and lidded storage containers , that could be moved by forklifts ?
Under 3.1.2.5. ThJadiation e Exposure limits: these are particularily appalling.
- 1) is it going to Wade clear to all involved in the cleanup, including workers hired on, that as soon as they are involved as workers in a nuclear facility type situation that they are m longer considered, by law, a " member of the public" and during any period in which the individual recieves an occupational dose (NRC Regs.)
and since they basically no longer exist,not only are the exposure levels mind-boggling , but if anything happens and the poor suckers try and sue as an injured
" member of the public" it would become very interesting ? 2) The exposure levels say they will use an w mire level of 100 mrem a day, and weekly 25cmRem - first of all if they allow 10e . lay with a five day work week, that cames out to SoomRem a week. EPA guidelinea as bad an they are, say 100 mrem from ALL SOURCES a YEAR.
e Regulations are set to allow the nuclear industry (military or commercial) to operate-this is historical f.act,. Furthernore, to quote the NRC's definitions of Part 20 .
Standards for the Protection Against Radiation, the purpose of these regulatior among other things, as to make sure individuals are not exposed to a total (ca exceeding quote :"the standards for protection against radiation prescribed ir, .
regulations in this part." So, all these regulations have little to do with W health anyway. However, for the plan to be prepared to allow the sorts of expos cited is a disgrace. As NRC well knows, the embryo / fetus / pregnant woman is the most sensitive to the effects of radialton (it can cause spontaneus abortion or foetal 4
death or mental retardation etc) after which comes children,then women ard last, men -
3 we have been over this before. In view of the latest (non-military,. on-nuclear industry) ;
findings on the biological effects of low-levels of radiai;an, and of the fact that i this facility is on a university campus with thousands of young people as " ell as staff and students,who may be, or are pregnant,amongst the population on campus,and because NEC CAN take action to further reduce exposures (see last sentence under 20.1001 "However, nothing in this , ft shall be construed as limiting actions that may be necessary to protect health and safety") not only must the most receng findings on the biological effects be applied to lower exposures to the public, % t"$6 D have eaid, a sizabla part of the campus should be evacuted during this deccamissioning, in particular the buildires and dormitories all around the reactor / office build 5g.
The A3LB Judges know how close all the buildings are to this facility. They also know hcw stidents go back and forth all the time, and staff likewise, as well as visitors and people driving by .I feel sure they would agree that considering all the other sources used at the center (e.g. Strontium 90) and that blasted cobalt-6o in the pool that falls under the reactor license (even if the State will not order the cobalt out,and theylicense the cobalt), that evacuatiort is the way to go.
Last but not least, I cal kd the company listed on the documents, NES Inc. and found out they had not been told the half of what the history of the site was,didn't even krow the area floods, or about the Nuclear Safeguards comtittee meeting minutes stuff cnd on and on, or the tritium contaminated soil. They maintained they had not known about either my "2.206" or the GANC petition. Plus, a student frcxn Tech came out to see m sane time back, trying to gather sane information for a sort of historical history, .nd informed me that the files at Tech were in great disarray und that no one seemed to have much knowledge of what had gone on there, in the past. So, NRC should insist that every Pred of paper in the files be read and put in order, plus all the historical records etc. be found and gone over, and theentire docket, including
- s. ,ts in the archives be gone over by all concerned, inclucing the contractors.
oted that the NES document did not seem to contain any reference to contamination
& Sr.90 or Be 7 to name just a few. Also, NRC questions them about the sources of the many alba radiaition readings. Could be frcan the plutonium sources, or just frun t
I 10
_ae plutonium in the irradiated spent fuel rods, or both, amng other things. 4 I would remind the NRC to look at their entire radicartive inventory, it's enough to l make ones hair stand on end. They also use radioactive sources still in different parts {
of the campus. But hey, no one seetra to care.
This plan is inadequate,in that it also shows they seem to think they can leave the rest of this radioactive dump stzding after Sauling out the reactor. They have not even done soil borings below the reactor as just one example. There is a massive radiological history to this dump, so why is everyone acting as if no one knows about it ? There is vast infortretion in the NRC's Violation Reports for starters. They should read them all. They obviously have not even gone over State of Georgia documents. If they had, they would know that 1995 waste water sample from Tech had a tritium level ;
of 186,000 pCi/1. !
As for the famous bismuth block, it leaked at 5 Rem an hour, remember.
On p.65 they say all decommissioning activities will be performed under s 10CFR Part 30 " Rules of General Applicability to Domestic Licensing of Eyproduct Material". This site used Special Nuclear Materials, indeed it was able to have up to 66 Kgs of HEu on site if I reme%er the documenat correctly. It was far more than used to be mentioned. They did experiments and cesium separation in the shack next to the reactor. This reactor etc.
and all the military and commercial related " playing around" that went on dates back, as you know , decades, there is no way it will cost the price (
stated to cler' the mess up, it will cost far more than the $1o Million ther said rea u r decommissioning wouN cost a few years ago. The reactor el . is also connected with the Georgia Aetsearch Alliance, and the Board f$ Regents that oversees the Georgia college system and there are all t%se political ties - they are appointed by the governor of Ga. and rubberstamped by him too - all this according to Tec.i - they discuss allocations for ,
whatever is needed at Regents meetings then go to the legislature -again according to Tech. It would appear that everyone is trying to spend the Icast possible amount on the decommissioning. That is totally unnaceptable, in particular since Tech gets millions and millions of dollars in military money yearly, and stinkingly rich Universities like Emory also work with Tech /the reactor (Dr. Karea told me). I said beforehand who can help pay for all of this, 11RC better get that one straight because the people 4 of Georgia are not going to be too pleured to find out they are meant to ,
be paying to clesnup a radioactively contaminated site they sent their kids j I
to.
On top of everything else, under the Rules, NRC is meant to also publicize the notice and solicitation of comments in local newspapers , the only 3 such listed forum readily accessable to all is the Atlanta qournal and 4 Constitution, Sunday Edition, Hundreds of thousands of a'r'I Dass the site on i
theadjacentinterstateandsideroadsdaily.Wedonot[wantarepeatofwhat I happened when this reactor came in, namely that only a handful of people l knew (although Tech may wish that !) It should b e immediately plas !( I in the Atlanta Journal and Constitution , in a prominent section such as the " Sunday 'huder" sect ion, and the comment period should be extended. ;
If this has not been done already. If it has, when was it published in j the newspaper ? Also the Office of NRC in this Region in Atlanta,should g
have a copy of the application and the entire public Document Room files on Tech /Neely placed there too. It is absolutely ridiculous, not to mention outrageous, that NRC expects people to go to Washington to look at the files and application. It should also be prominently displayed in the i Atlanta Intown newspaper " Creative Loating".Both papers are also widely 1
/
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- 9 11.
read by the rest of the Tech faculty and by all the students,and they are meant to be given an opportunity to comment and'see the application and the entire' Docket. During the GANE case, where NRC located the Public Document Room, Las in another town's library, when it should have been at the Atlanta Public Library downtown. NRC should either set it up there, or at their office in the-Federal Building. (The files for those other dumps,' Plant Vogtle and Hatch should also be placed there so people can see what's going on). .
This plan, as proposed, is contrary .o the safety and health of the public, for all the aforementioned reasons,it shou'.d not be approved as written. As far as the Cobalt-60 ic, concerned - just what is the NRC (and NRC Comissioners) basis for leaving it there ? Is it because it's stuck ? Explain why NRw' Comissioners are not ordering it out . I know they have the authority to do so, regardiess of who licenses it. Justify how such a Curie quantity of Cobalt 60 can be left in the middle of a highly populated campus vulnerable to terrorism or accident, separated fran -
the outsido by a cement wall, and please provide the medical consequences of someone l
standingnexttoOnlya20Curiefragment,(,assuminganexplosionthatblewitall overtheplace,)andwhatwouldhappentothatpersonin8 minutes,sothepublicknows l
what to expect in case of such a tradgedy. I know the consequences,as do others.
I want NRC to admit it knows, because if NRC doesn't know , then the agency doesn't know what it's doing. If NRC does know, then it must agree that the cobalt-60 cust be moved., and the question is,why is NRC doing nothing ? Forget the legalese, just tell the public how they can expect to die if somethire happens concerning the co-6J j
They have a right to know how little anyone cares atout their lives at the NRC,0R Treu, d ~
l Pamela Blockey-O'Brien.
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