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Georgians Against Nuclear Energy Amended Petition for Leave to Intervene in Consideration of Application for Renewal of Facility License.* W/Certificate of Svc
	ML20078D002
Person / Time
Site:	Neely Research Reactor
Issue date:	12/30/1994
From:	Carroll G; GEORGIANS AGAINST NUCLEAR ENERGY
To:	; Atomic Safety and Licensing Board Panel
References
	CON-#195-16218 95-704-01-REN, 95-704-1-REN, REN, NUDOCS 9501270208
	Download: ML20078D002 (103)
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UNITED STATES OF AMERICA DOCKETED i US!1RC i i t N ATOMIC SAFETY AND LICENSING BOARD j

'95 JAN 13 P2 :20 i Before Administrative Judges:

0FFICE OF SECRETARY !

Charles Bechhoefer, Chairman DOCKETmG & SERVICE l BRANCH .

Dr. Jerry R. Kline [

Dr. Peter S. Lam i

l Docket No. 50-160-Ren 1 In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTvR ,

Atlanta, Georgia Facility License No, R-97 l

I GEORGI ANS AGAINST NUCTRAR ENERGY :

AMENDED PETITION FOR LEAVE TO INTERVENE ,

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IN CONSIDERATION OF APPLICATION FOR RENEWAL OF FACILITY LICENSE I

Georgians Against Nuclear Energy (GANE) respectfully petitions the '

Nuclear Regulatory Commission for intervenor status in the consideration of Georgia Institute of Technology's. request to renew Facility License No. R-97 to operate the Georgia Tech Research Reactor on Georgia Tech campus in downtown Atlanta. We request that a public l

hearing be held concerning the license renewal.,(Docket No. 50-160 License Renewal Application dated April 19, 1994, Federal Register l Notice September 26, 1994, page 49088.)

GANE feels that the Georgia Tech Research. Reactor on Georgia Tech campus has a history of poor management and lack of utility. The reactor is located in the heart of an extremely densely populated area. The reactor is at the heart of Georgia Tech campus which has a population of 13,000 students and 5,000 faculty and staff. Within a one-mile radius, Georgia Tech acknowledges a residential and business population of 30,000 (Safety Analysis Report for the SMW Georgia Tech Research Reactor, April 1994, p. 2) although actual 1990 census figures are 60,000. The City of Atlanta population is 394,000 9501270200 941230

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l according to the actual census. Georgia Tech acknowledges 360,478 people (S AR, p.17). The 20-county metro area had a population of 2.8 million people in 1990. The Commission's mission is to protect human health, life and property by enforced regulation of its licensees. To l allow this SMw reactor to continue to operate violates your mission. i GANE attaches the affidavits of 44 people who live and work within a five-mile radius of the GTRR. Their names in alphabetical order are:

Chuck Alexander, Kishi Animashaun, Victor R. Bolet, William D. Boring, Angela Brown, Scott Brown, Matthew M. Butler, Ira Camp, Jennifer L.

Carr, Megan Carmody, Daniel Cawlfield, Eric S. Crane, James Wright Crane, John Paul Davis III, Jon-Paul Devore, Ginger Dollar, Dean Driscoll, Case Edwards, Sondra Farley, Robert Friedman, Daniel John Galloway, John Galloway, David Loujs Glatzer, Adam J. Goldberg, Jennifer Goodwin, Christopher Hubbell, Jim Jendzurski, Anna Jordan, Robert Johnson, Stephen Taehee Lee, Alvin Lenoir, John Paul Leonard, Bailey McGee, Lynda Patterson, Chip Ramsey, Suresh Randawa, Daniel Salmond, Susan E. Saxon, David M. Shackleford, Margaret Smith, Helen Scott Swain, John Tingley, Steve Weisz, Tamara K. Wright. These people have asked GANE to represent their lives and well-being before the NRC on the issue of the permanent shutdown of the GTRR. Many of the people before you are students. Many of them are only 20 years old and hope to live long, healthy lives and to bear children. The most affected population nearest the reactor is extremely youthful and therefore more vulnerable to the effects of radiation exposure. Several of them havc expressed that many of their friends who will wish to stand with GANE are out-of-town for the holidays, so, we ask you to accept more atfidavits up to the pre-hearing conference. We believe we have standing to intervene by the affidavits presented today, and feel certain you will want to grant the population around the GTRR their full rights to enjoyment of the democractic process.

GANE has also attached the affidavits of her officers, F. Kaf Vontillius, Coordinator and Patricia M. Richardson, Treasurer, attesting the fact that GANE wishes Glenn Carroll to act as her voice in this proceeding.

We re-state that the needs of humanity and the nuclear industry at this time are not to educate another generation of nuclear operators, but to take up the task of finishing nuclear technology. It has been fifty years since nuclear energy exploded upon this planet at Hiroshima - GANE feels that it is time to face our nuclear waste dilemma. We encourage Georgia Tech to provide leadership by closing ,

the research reactor and focusing its efforts in the areas of nuclear f

i waste research and decommissioning of nuclear facilities. We envision the research reactor on Georgia Tech campus being used for the good of humanity to help solve the decommissioning dilemma.

Following are our contentions proving that the Georgia Tech Research Reactor request for license renewal must be denied:

1. GANE contends that the GTRR is generally unsafe. On page 1 of the SAR Georgia Tech claims that no safety problems have been encountered.

In stark contrast is the actual history: in 1972 there was an accident during the recontainerization of cobalt-60 which resulted in serious contamination; in 1983 2,700 gallons of cobalt-60 contaminated water was accidentally and illegally spilled into the City of Atlanta sewer system; in 1984 the cobalt-60 shielding pool overflowed; and in 1987 a worker contaminated with cadmium-115 also contaminated his home and a MARTA bus following a spill. The director of the reactor failed to report the incident to the NRC which resulted in severe reprisals when the NRC found out. The reactor was shut down for two years, received 25 violations and a nominal $5,000 fine, which although small is unusually high for a research reactor (NRC reports, Atlanta Journal / Constitution, Creative Loafina).

As will be shown in a separate contention, insufficient monitoring is performed on the facility, so we don't really know the extent of environmental contamination from releases from the GTRR.

The SAR is grossly deficient in its basic information. Table 2.1 on page 7 gives no data to describe the amount of radiation in curies that is contained within the facility. In this piece of information lies the basis of the risk level to which the large affected ,

population is exposed. The SAR fails to discuss anywhere core melt scenarios which involve a breach of the reactor building (referred to by Tech as a containment buildi ng).

Other information in the SAR is deficient and lacks credibility. We spot-checked Table C.1 on page 204 and found I-131 listed as having a i half-life of 1.93 hrs, when the actual half-life is 8 days. We did not check all the data in the table, but point out other obvious errors of pertinent isotopes which are unanalyzed. Xe-137 is listed with a half- !

life of 3.9 minutes. The daughter isotope, Ce-137 which follows the Xe-137 decay, is omitted. So too is the Sr-90 which results from Kr-90 decay ignored.

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2. GANE co nt ends , .t hat the GTRR is unable to contain radiation from the environment. The containment shell is designed to leak 1/2% of its volume per 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period (SAR, p.5). The reactor containment building ;

is described as a "relatively leak-tight barrier" (S AR, Sec. 4.3, p.

43). Georgia Tech admits that people will be exposed to radiation [

releases and that all the krypton and xenon will escape as well as i one-half the inventory of iodine (SAR, p.187). GANE urges you to find i this risk unacceptable and deny the license renewal request.

State'of Georgia Environmental Protection Division (EPD) TLD's show 700 mrem / year around the reactor site. Georgia average background is i 49 mrem / year and Atlanta's average background is73-130 + or - 130 mrem / year (Georgia Department of Natural Resources, EPD Radiation Surveillance Report). ;

There is enough fissionable material present in the reactor core i that a criticality accident may occur. The steam explosion that would f follow a partial fuel melt would distribute the-reactor core's [

fission-product inventory, several million curies of highly L radioactive isotopes. If the containment were breached, over a six-mile radius of the reactor could be exposed to dangerous levels of [

radiation. This poses a grave health threat to residents and visitors l in Atlanta, threatens the lives of emergency personnel and campus f residents and would ruin billions of dollars worth of real estate in i the surrounding crowded business district of Atlanta. 3 Even if the containment holds, the building would leak in the !

I neighborhood of 10,000 curies of radiation per day which would spread i rapidly and chaotically once released into the environment (SAR, p.5). [

The students, faculty and staff of Georgia Tech would suffer the most {

immediate and severe harm. F The concrete shield which is supposed to enhance the containment [

I ability of the sheetmetal containment wall is only used on the sides of the building. The top is left unshielded except by the 7/16" steel roof (SAR, p.44, Fig. 4-8). The Chernobyl accident breached a 1,000-ton steel roof. GANE thinks that a loss-of-coolant accident which l leads to a steam explosion could breach the containment. At any rate, . ;

a rocket-launcher or grenade could easily breach the building from the j outside. ;

Other weaknesses in the containment are from the several penetrations in the containment buildinJ: truck doors, air lock doors, 19 electrical penetrations, ventilators, smoke stack (S AR, p.51, 93).

l There is a pipe tunnel underneath the reactor which is unshielded and j provides a pathway for radiation to escape (SAR, p.67). Another

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deficiency is noted, that the secondary emergency cooling supply hook-up is in the pipe under the reactor. Emergency personnel entering to hookup the emergency water would likely receive an extreme radiation exposure.

The failure of Georgia Tecn to acknowledge and analyze the possibility of core melt and subsequent release of millions of curies to the environment through a breach in the containment building shows a serious deficiency in Georgia Tech's understanding of the operation they claim is safe. Other inaccurate scenarios are presented in the SAR: a discussion about how the radiation cloud will spread (SAR, p.

195) is unconcerned with thunderstorms or tornados. A discussion about skin exposure to beta emitters (SAR, p. 197) similarly fails to register that an organism receiving skin exposure is likely inhaling the same contaminants.

Scenarios that may lead to a criticality accident include the control rods being removed too fast or hanging-up and flow blockage from debris (or inadequate coolant for any reason). Fuel temperatures under normal operating conditions range as high as 211*F (SAR, p. 8) and during one accident scenario described (SAR, p. 139) can range as high as 277 F. Following a loss-of-coolant, this environment would promote the steam flashing that would lead to a steam explosion.

Georgia Tech acknowledges that the dynamic of water and steam is difficult to evaluate theoretically (S AR, p.178) yet assumes that an explosion breaching the reactor building is not credible.

Adjacent to the reactor, 400,000 curies of cobalt-60 is stored in a 5' x20' pool, shielded by 18 feet of water (S AR, p. 37). A breach to the shielding pool, caused by a steam explosion in the reactor, leaving this highly active material completely unshielded would yield 480 million roentgen per hour exposure to emergency personnel attempting to deal with the catastrophe. The highest count registered in the containment building following the meltdown at Three Mile Island in 1978 was 30,000 roentgen per hour. Several National Institute of Occupational Safety and Health (NIOSH) studies are available to help Georgia Tech appreciate the gamma radiation toxicity of cobalt-60. A 1992 study by Grahn, Lombard, and Carnes proved that cobalt-60 exposure is linked to tumors of the lymph, vascular and pulmonary systems. They also found high incidence of ovarian, adrenal and pituitary cancers. In 1967, Lesher found that 300 roentgen exposures in mice moved cells in and out from S-phase to M-phase and impaired ability to synthesize DNA. Chambers, Biles, Bodenlos, and Dowling found in 1964, that 700 roentgen exposures in swine caused 100% death from hemorrhagic syndrome.

3. GANE contends that the GTRR is contaminating the City of Atlanta sewer system. Several large U.S. cities, notably Albuquerque, New Mexico, have discovered extensive radioactive contamination to their sewer systems following their use by licensed handlers of radioactive materials. Albuquerque's radiation laws are the strictest in the nation, and yet this still-unremediated contamination problem occurred (Voces Unidas, 4/93, 8/94).

Cobalt-60 was found in ash from incinerated sewer sludge in Southerly Sewage Treatment Plant in Cleveland, Ohio. A subsequent investigation found the lines to be contaminated which prompted Ohio Senator John Glenn and Representative Stokes to commission a General Accounting Office investigation. The May 1994 GAO report expressed findings that neither the NRC or the EPA had ever monitored for sewer contamination (Science News, Oct. 1, 1994, Vol. 146). This sort of regulatory void allows the public to be exposed to great harm with no knowledge or consent. The presence of the GTRR in such a large population center poses an unacceptable risk.

In 1991, the NRC discovered that isotopes which had been expected to disperse in the sewers were accumulating to dangerous and illegal levels and revised its regulations concerning sewer releases.

Subsequently in July 1993, the NRC required a study be conducted by Georgia Tech of radiation levels in 300-feet of sewer extending from the reactor outlet (Alternatives, 9/93). The NRC is investigating Georgia Tech's findings and has alleged that Georgia Tech did not actually perform the study at all. Oscar DiMiranda, Senior Allegation Coordinator for Region II NRC said, "NRC experts told me there will be contamination." (12/21/94 phone conversation with Pamela Blockey O' Brien. )

Since waste water is treated and returned to the environment for re-use in our city, this is a problem that cannot be ignored. The unforeseen expense to affected cities has been tremendous and burdensome, and GANE seeks to prevent such contamination here, if it is not too late already as EPD has allowed excessive contamination to pass unregarded.

And again, in the absence of real monitoring, Georgia Tech's claims that it can operate GTRR safely have no basis. ,

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4. CANE contends that the reactor site is unsafe because it suffers {

from unntable geologic conditions. The stability of the foundation of the reactor building is in question because of an underground water flume directly below the-reactor-(City of Atlanta Sewer Map, CH2MHill, i 1988). Witnesses remember a sinkhole swallowing a man adjacent to the reactor building 20 years ago. The fact that Georgia Tech has no l documentation of this event is negligent.

In June 1993 a major, 100-year-old Atlanta sewer line that runs ,

under Georgia Tech campus 1/4-mile from the reactor building suffered a catastrophic collapse, swallowing two people to their death along with two automobiles. This Orme Street Line has persistently caused i flooding of many structures on Georgia Tech campus. There is an aging, 6' pipe tunnel directly under-the reactor (SAR, map, p.30). The 1993 ;

incident made national headlines and prompted the Commission to request a long-overdue sewer line study (Alternatives, 9/93). This is the same study previously cited which is under question now by the NRC. f The reactor is sited atop the Wahoo Creek Formation, a slabby, '

viscous and muddy medium-grained muscovite plagioclase gneiss which

tends to break across oblique planes (Georgia Geologic Survey Bulletin

96). This is not the solid bedrock formation that the reactor's management assumes (Alternatives, 9/93).

A very large crack caused by water damage is visible in the viewing room to the reactor room. The reactor, a few yards from the damaged wall suffers the same structural stresses from foundation shifting due to underground hydrologic activity (Glenn Carroll, eyewitness).

The credibility of Georgia Tech is again called into question by their treatment of this area in the SAR. The SAR gives a general description of the geology of the Atlanta region and the southeastern United States but largely ignores the specific site (S AR, p.21-23).

The SAR does provide some information which should inspire caution but seems to be unappreciated by Georgia Tech. The water table is as close as 11 feet under the surface in some places (SAR, p. 23) and the parking lot and reactor building lie in a low area which is a natural ;

drainage path (SAR, map, p.30). This low-lying area experiences regular flooding and tends to be damp and saturated.

5. GANE contends that GTRR is unsafe to the public because of j inadequate security systemm. Reactor security is grossly inadequate. ,

The reactor building may be accessed directly from the outside, no personnel are assigned to the building outside of normal business ,

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e hours. Essentially, the entire security system consists of a chain- ;

line fence with some barbed wire on top. Wire-cutters would be f sufficient to breach the fence (Glenn Carroll, eyewitness). l The presence of the Olympics in Atlanta in 1996 creates a specific ,

situation which has h1storically attracted terrorist activity and !

threats. The reactor uses highly enriched uranium as fuel. During l refueling this bomb-grade uranium fuel is a tempting target for ;

terrorists. The presence of fissionable and highly radioaccive fission byproducts at the reactor, make the reactor not only a terepting target for theft of bomb-grade or hazardous materials, but a target for a -

World Trade Center-type bombing which would not only injure residents .

and visitors to Atlanta, but create an international diplomatic ;

disaster for the United States.

The roof which is nothing but 7/16" thick steel sheet-metal (SAR, ,

p.44, Fig. 4-8) and would easily be breached by a rocket-launcher or hand-thrown grenade.

6. GANE contends that the GTRR is unsafe to the public because it has not been and is not now beino monitored adequatelv. Georgia's EPD is charged with monitoring the facility (Georgia Radiation Control Act of I 1976). In the Act EPD is given responsibility for monitoring air, water and sediments. The EPD reports are inadequate in several respects. No air monitoring has been performed around the facility. !

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Some isotopes are monitored for effluent discharge to city sewers and f deposition around the site. Many isotopes are unmonitored altogether. ,

Off-site monitoring has never been done Over the years EPD has shown a !

consistent pattern of diminishing oversight, dropping whole categories from monitoring. The weak monitoring and reporting effort culminates in EPD's not even publishing the annual reports sinc 6 1989. Water monitoring was discontinued in 1980. Further, a TLD error was detected ,

in 1985, so that all data from 1979-1984 had to be corrected (Georgia DNR-EPD Radiation Surveillance Report). We have no confidence that we really know what is going on at the Tech reactor. .

From discussion with certain personnel from EPD Environmental Radiation Division it appears that regulatory authority may not be clear to the regulators themselves. This regulatory void places the public in serious harm.

Strontium-90 and cesium-137, two isotopes with a high uptake profile i are unmonitored as previously noted (SAR, p.204, Table C.1).

There are some areas which hint of conflict of interest. The Georgia ;

EPD is a big customer of the Tech reactor. What little air monitoring -

is done on the GTRR is done'by students of Georgia Tech (for ar-41 only) which in essence has Georgia Tech in a self-regulating position ;

(Environmental Report, Sec. 4.3), i Even more disturbing are the several outright untrue statements ;

contained in th'e SAR. Georgia Tech claims that gas is monitored as it f leaves the building (S AR, Sec. 4.5.1, P. 98). Unsafe assumptions that ar-41 is the only notable isotope are made about the composition of emissions and untrue claims that environmental monitoring will demonstrate the validity of the assumption by direct measurement are repeated (SAR, p. 100-101).

Georgia Tech repeats its claim of a 30-year history of safe and reliable operation (see Contention 1) (Environmental Report, Sec. II) and states: "The long-term effects on the environment from renewing the operating license for the GTRR are insignificant" (Env. Report, Sec. IX). In the face of the monitoring voids this statement has not basis. ;

GANE is concerned that a long-term contamination has already occurred in the environment and that the only acceptable course of action now is to deny the license to operate this unsafe facility for another 20 years, and to commence an immediate and stringent i investigation of the contamination already present and to formulate a plan to recover and contain any and all radioactive contaminants which have escaped from the GTRR.

7. GANE contends that the GTRR is not safe because it does not have an adequate omergency response plan. The emergency response plan for the Neely reactor is uncoordinated and unknown to local and state authorities. Georgia Tech considers an accident scenario not credible and has held drilla only to evacuate the reactor building (Emergency Preparedness Plan, Rev. #3, Sec. 1.1). A campus-wide evacuation drill i has never been held. The emergency command center is planned within the facility (Sec. 1. 6 ) . If a core-melt occurred, this is an !

unworkable plan. The EPZ is only a 100-meter radius of the facility (Sec. 2.12). Even if the containment held following a core-melt, 10,000 curies per day would be escaping into the environment and would range much further than 100 meters. Again, the failure of Georgia Tech to appreciate the risk and to preparc for the eventuality of a large release from the facility is negligent and in this case results in the failure to plan effectively on behalf of public health and safety.

8. GANE contends that a major City of Atlanta reservoir is vulnerable to extensive contamination from the GTRR. The Hemphill Reservoir, 9- ,

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, which supplies drinking water for the greater Atlanta area, is within a mile of the facility. Rapidly growing population and deteriorating infrastructure have combined to cause a chronic water shortage in the Atlanta region. The contamination of the Hemphill Reservoir following an accidental release from the Georgia Tech research reactor would :

greatly exacerbate the problem, j

9. GANE contends that management problems at the GTRR are so gngat that safety for the public cannot be assured. Safety concerna at the j Georgia Tech reactor are the sole responsibility of Dr. R.A. Karam (SAR, Fig. 6.1, P. 157). Dr. Karam is the director who withheld !

information about a serious accident from the NRC (1987 cadmium-115 accident). The NRC was advised of the 1987 cadmium-115 accident by the ;

safety officer at that time, who was later demoted, and left the GTRR operation claiming harassment. Since the incident, management has been restructured giving the director (Dr. Karam) increased authority, l including increased authority over the Manager of the Office of i Radiation Safety. Although the safety officer has a line to higher-ups l than the director, since he/she works for the director on a day-to-day l basis, the threat of reprisal would be a huge disincentive to defying the director.

The Nuclear Safeguards Committee which has theoretical oversight of the GTRR operations has a distinct flaw in having no concern with j health issues. The Office of Radiation Safety Manager is sought for !

its knowledge of law more than its knowledge of health physics. (S AR, Sec. 6.1, p. 156-159).

10. GANE contends tha s L3e GTRR is a financial liability to taxcayers l Of the State of Georcia and to Georgia Tech. Georgia taxpayers pay I over half of the operating costs of the GTRR every year which amounts {

to nearly a half-million dollars. The other half is supposed to be generated by contract work, but the GTRR has a very public history of lack of use. In fact, in 1993 the reactor was only used for 132 hours0.00153 days 0.0367 hours 2.18254e-4 weeks 5.0226e-5 months , l and only for seven hours did the output exceed 1 Mw. In 1992 the reactor only clocked 158 hours0.00183 days 0.0439 hours 2.612434e-4 weeks 6.0119e-5 months , again, very few above 1 Mw. (GTRR )

Annual Reports, see also, Environmental Report, Sec. 4.3.) i Georgia Tech claims it cannot afford its yearly $60,000 fee to sustain a license from the Commission and has asked for a waiver ,

T (Atlanta Journal / Constitution). This underscores the fact that the reactor is a financial burden to the university.

The GTRR holds yet a stiff fee for Georgia taxpayers who have fiscal

responsibility for decommissioning the facility. The SAR states that the decommissioning cost of the reactor will be $10,000,000. Since the rule for decommissioning is still under development by the NRC, and no real decommissioning has been performed in the United States, this figure is theory. Given the failure of nuclear waste policy in this country to date, it is anyone's guess where the contaminated portions of the reactor and the spent fuel will end up. We state again, that we envision a noble role for Georgia Tech, if they will but accept it, to treat the nuclear waste and decommissioning aspects of the reactor seriously, and immediately, and make the needed discoveries for humanity on the thorny issues of nuclear waste and decommissioning.

Respectfully submitted, enn Carroll Representative for GANE Dated and signed December 30, 1994 in Decatur, Georgia l

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UNITED STATES OF AMERICA l

l ATOMIC SAFETY AND LICENSING' BOARD 1 Before Administrative Judges:

l Charles Bechhoefer, Chairman j Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren ,

In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR l Atlanta, Georgia Facility License No. R-97 AFFIDAVIT I am a duly elected officer of Georgians Against Nuclear Energy (GANE). I am personally aware of the October 26, 1994, petition for leave to intervene in the above-styled matter filed by Glenn Carroll on behalf of GANE. Glenn is a volunteer member in good standing of GANE. GANE supports and directs her to continue this intervention on ,

our behalf. GANE has authorized her to do so, and to obtain the assistance of whatever experts as she deems appropriate, by consensus of the group at the October 6, 1994, GANE business meeting. !

This statement is made under penalties of perjury, o A '

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Patricia M. Richardson, Treasurer Datg[ l t

, UNITED STATES 0F' AMERICA

ATOMIC SAFETY AND LICENSING BOARD l

Before' Administrative Judges: ,j Charles Bechhoefer,. Chairman Dr. Jerry R. Kline j i Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of .

ASLBP No. 95-704-01-Ren -

GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT l l

I I am a duly elected officer of Georgians Against Nuclear Energy. !

(GANE). I am personally aware of the October 26, 1994, petition for !

leave to intervene in the above-styled matter filed by Glenn Carroll on behalf of GANE. Glenn is a volunteer member in good standing of GANE. GANE supports and directs her to continue this intervention on our behalf. GANE has authorized her to do so, and to obtain the assistance of whatever experts as she deems appropriate, by consensus of the group at the October 6, 1994, GANE business meeting.

This statement is made under penalties of perjury.

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/H d_AAA) /2 27 /99'l F. ' Kay h'ontillius, Coordinator Date 1

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UNITED STATES OF AMERICA ATOMIJ SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now CHUCK ALEXANDER, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me'and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside at 1087 McMillan Street, Atlanta, Georgia. I own substantial household goods. I believe my health, home and property are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home is less than one mile from the Neely Research Reactor.

In the event of a release of radiation from the facility, my personal l 1

health would suffer serious consequences. ;

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4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

UCK ALEXANDER

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ,

ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 1

AFFIDAVIT Comes now KISHI ANIMASHAUN, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside at 710 Peachtree Street NE, Atlanta, Georgia 30308 and work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I own substantial household goods. I believe my health, home and property are jeopardized by Georgia Tech's :

request to continue operating the Neely Research Reactor.

3. Both my home and my office are within one mile of the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences. l

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor ; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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. .w UNITED STATES OF-AMERICA l i

ATOMIC SAFETY AND LICENSING BOARD '

Before Administrative Judges: ;

i Charles Bechhoefer, Chairman

. Dr. Jerry R. Kline Dr. Peter S. Lam t

Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren

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GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 i

AFFIDAVIT Comes now kh h. b M ,

i who being duly sworn, deposes and states as follows: '

1. I authorize and request Georgians Against Nuclear Energy ;

(GANE)'to represent me and my interests in the above proceeding involving Georgia Tech's request to renew. the license of the Neely. !

Research Reactor on Atlantic Drive in downtown Atlanta. More -;

specifically, I authorize Ms. Glenn Carroll or anyone she designates a

to represent me and m it ts yg

2. I.resi / work at Sekel cd- CJad. h ha.TcM , i Atlanta, Georgia. I believe my life and health ake jeopardized by (

Georgia Tech's request to co ti ue operating the Neely Research !

Reactor. * ^\'*

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3. My home work & tj ^ c Me rd us from the !

Neely Research Reactor. In the event of a release of radiation from I th'e facility, my personal health would suffer serious consequences. i t

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4. I.have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at.Neely Research Reactor; the reactor will be safer. I am :

less likely to suffer injury from it. !

This statement is made under penalty of perjury, i

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UNITED STATES OF AMERICA !

ATOMIC SAFETY AND LICENSING BOARD !

i Before Administrative Judges: l i

-Charles Bechhoefer, Chairman Dr. Jerry R. .Kline Dr. Peter S. Lam Docket No. 50-160-Ren l In the Matter of -

ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY i RESEARCH REACTOR Atlanta, Georgia '

Facility License No. R-97 '

AFFTDAVIT l t

Comes now' (dt )(7 w 3.

O d ./ N 7k ,

who being duly sworn, deposes and states as follows:

1. I authorize and. request Georgians Against Nuclear Energy. .

(GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she. designates tp represent me and my interests.

2. I 1.aee:de/ work at am dt N I believe my ./09life and 3 health are,A 9,j .

Atlanta, Georgia. jeopardized by Georgia Tech's request to continue operating the Neely Research l Reactor. j

3. My.home/ work is tea, 4m 44m WA from the Neely Research Reactor. In the event of a release of radiation from i the facility, my personal health would suffer serious consequences.

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. 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor! ~ the reactor will be safer. I am less likely to suffer injury from it, This statement is made under penalty of perjury.

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, 4. I have read GANE's'10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

A hu % ~

NW (Signature)

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/ Af f (Print Name) t' 9

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now ANGELA BROWN, who being duly sworn, deposes and states as follows:

1. I authorize and request Geor- ans Against Nuclear Energy (GANE) to represent me and my inte!$ sts in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I believe my life and health are ,

jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

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3. GREENPEACE's office is about one-half mile from the Neely l Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of rerious accident at Neely Research Reactor; the reactor will be safer. I am i

less likely to suffer injury from it.

This statement is made under penalty of perjury.

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now iCOTT BROWN, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgiana Against' Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. 2 believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. GREENPEACE's office is about one-half mile from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

' lot !}s,_ %

SCOTT BROWN l

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren .

GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now //4d84#d N, [ f/6 C ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside / work at /0 )/ CGe16dr J C, ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is #!

/L /9s <? from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there f: . reduced likelihoco of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

b (Signature)

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman i

Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TEC'hNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now IRA CAMP, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I believe my life and health are jeopardized by Georgia Tech's request to continue opercting the Neely Research Reactor.

3. GREENPEACE's office is about one-half mile from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

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4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious l accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it. i This statement is made under penalty of perjury.

/Af44Y/

IRA CAMP [7

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Cha rles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now W Jl '

whobeingdulyswork,,keposeskhndstatesasfollows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reacter on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates 3,o represent me and my interests.

2. I reside / work at \\@ MhTbdQ b_ ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is 7_ O l from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

. 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's positior. is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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(Print Name)

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now b NMbb.N '

who being duly sworn, dep ses and states as follows: )

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests jn the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorizo Ms. Glena Carroll or anyone she designates Ap represent me and my interests.

2. I reside / work at bb O_ Y( T ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is / '- tlk

/ I(. from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

, 4. I have read GANE's 10/26/94 Petition for Leave ';o Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury .

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now CW i e, l lill E '

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates lo represent me and my interests.

2. I reside / work at 6 #b I e Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research j Reactor.

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3. My home/ work is kh kto . IS S from the l Neely Research Reactor. In the event of a release of radiation from 1

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the facility, my personal health woQld suffer serious consequences.

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, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious ,

accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury, t

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-a UNITED STATES OF AMERICA t

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF* TECHNOLOGY !

RESEARCH REACTOR Atlanta, Georgia '

Facility License No. R-97 i

AFFIDAVIT Comes now bbCIl- '

(SANb '

who being duly sworn, deposes and' states as follows:

1. I authorize and xequest Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely 5 Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates t Ap represent me and my interests.

2. I reside / work at ,Yo u V 6dv d- ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My'home/ work is !)EI Yb o* C from the Neely Research Reactor. In the event of a release of radiation from '

d the facility, my personal health would suffer serious consequences.

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. 4. I have read GANE's 10/26/94 Petition for Leave to Intervene. ,

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

'fh4Ak e (Signature)

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman a

Dr. Jerry R. Kline ;

Dr. Peter S. Lam ,

t Docket No. 50-160-Ren In the Matter of

, ASLBP No. 95-704-01-Ren .

GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 f

AFFIDAVIT Comes now ot W 4 [h f* 4 who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy #

(GANE) to represent me and my interests in the~above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyrne she designates Ag represent me and my interests.

2. I sid / work at A o- ,

Atlanta, Georgia. Ibelievemylifeandhealtharejeohardizedby Georgia Tech's request to continue operating the Neely Research f Reactor. !

3. My h / work is 2 i from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

i e -w... , - - .,----y . , - . -, - , . - . , , , . . . - . .

, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene. .

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely.Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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AM6 (le; Print Name) d e

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now b c%+ o\ Dav;s u< .

who bei.ng duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Resaarch Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside / work at M .2-v M dvo ,

Atlanta, Georgia. I believe my life'and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is /c95 ) y+'fc from the I

Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

l 1

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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.bb Rhh 2r__.

(Print Name)

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now .hd [@ L daIMA/7 ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates Ag represent nle and my interests.

2. I work at f0k l /lk)))' Albh ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

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3. My home/ work is 2//r:t ' (DW v 8 Mrom the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

i

. 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am ,

less likely to suffer injury from it. ,

This statement is made under penalty of perjury.

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam '

Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now GINGER DOLLAR, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I believe my life and. health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor. ,

3. GREENPEACE's office is about one-half mile from the Neely ;

Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

i

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4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious ;

accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 i

AFFIDAVIT C

Comes now ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in thd above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates Ao represent me and my interests.

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2. I reside / work at (All $4 Ccf@E hG"TS ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is N 7b CC ME '5I hD40 GO from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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W Nd C TER %\\

(Print Name) ;

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: i Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now CASE EDWARDS, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. GREENPEACE's office is about one-half mile from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Inter se.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less.likely to suffer injury from it.

This statement is made under penalty of perjury.

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now D M / ,

whobeingduly/ g worn,deposesandstatesasfollowff ) '

l. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the-Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates Zo represent me and my interests.

2. I reside / work at\ ) Oh>, h) .,

Atlanta, Georgia. I believe my life'and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

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3. My home/ work is i from the Neely Research Reactor. In'the event of a release of radiation from j

the facility, my personal health would suffer serious consequences.

l 1

, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

I

/(Signature) b,0 ] O R n !

V r m JD _ Y J " OV

, 0-(Print Name) .,

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+- J UNITED STATES OF AMERICA '

ATOMIC SAFETY AND-LICENSING BOARD t

Before Administrative Judges:

l Charles Bechhoefer, Chairman ;

t Dr. Jerry R. Kline ;

e Dr. Peter S. Lam Docket No. 50-160-Ren

In the Matter of ASLBP No. 95-704-01-Ren i GEORGIA INSTITUTE OF' TECHNOLOGY RESEARCH REACTOR $

Atlanta, Georgia ~

Facility License No. R-97 t

AFFIDAVIT ;

Comes now d' M A '

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy :

(GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely i Research Reactor on Atlantic Drive in downtown Atlanta. More i specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside / work at Mf2 b . Nd, '

' Atlanta, Georgia. I believe my life dnd health are jeopardized by Georgia Tech's request to continue operating the Neely Research !

Reactor.

3. My home/ work is

! ffk cdh from the -

Neely Research Reactor. In'the event of a release of radiation from l the facility, my personal health would suffer serious consequences.

. 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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OI t i Kl6 n0lhid (Print Name) ,

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UNITED STATES OF AMERICA f ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: ;

Charles Bechhoefer, Chairman Dr. Jerry R. Kline !

I Dr. Peter S. Lam I

Docket No. 50-160-Ren In the Matter of L ASLBP No. 95-704-01-Ren

~

GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 i

AFFIDAVIT Comes now G77 O /) c.+ D/JA ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgiane Against Nuclear Energy j (GANE) to represent me and my interests in the sbove proceeding !

involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I ork at 0 b ha/W/ffDA f a Atlanta, Georgia. I believe my life and bealth are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My h work is <I fd from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences. '

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9

4. I'have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious ;

accident at Neely Research Reactor; the reactor will be safer. I am.

less likely to suffer injury from it.

I This statement is made under penalty of perjury. ,

t

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(Signature)' [ [

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now JOHN GALLOWAY, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

Geo nece< Place CeMer rp P.stal address Unduguduan L:v.,n9 _

2. I teside at 256 85 GT Station, Atlanta, Georgia 30332 on Georgia Tech campus and attend classes at Georgia Tech. I own substantial household goods. I believe my health, home and property are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor. T a 1 4 t n h C ft1S Sf !> l- to'Mf (IO bG.) Mf heo C We'fh.'n f3 t$lC 6h ' '

3. My home i s Awo- = M o uu4 > ' r lec k # m=the Neely Research ,

Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

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4. I have read GANE's 10/26/94 Petition for Leave to' Intervene. ;

If GANE's position is upheld, there is a reduced likelihood of serious i accident at Neely Research Reactor; the reactor will be safer. I am ;

less likely to suffer injury from it.

This statement is made under penalty of perjury. ;

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UNITED STATES OF AMERICA !

d ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: 3 I

Charles Bechhoefer, Chairman i Dr. Jerry R. Kline ,

Dr. Peter S. Lam Docket No. 50-160-Ren l In the Matter of ASLBP No. 95-704-01-Ren !

GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOh !

Atlanta, Georgia '

t Facility License No. R-97 !

I AFFIDAVIT f A t)l Comes now _,

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who being duly sworn, deposes and states as follows:

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1. I authorize and request Georgians Against Nuclear Energy-f (GANE) to represent me and my interests in the above proceeding !

involving Georgia Tech's request to renew the license of the Neely i Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates !

Ap represent me and my interests.

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2. I reside / work at /D9'3 /dmAM,'// MVI ,

Atlanta, Georgia. I believe my life and health are jeopardized by '

Georgia Tech's request to continue operating the Neely R3 search f Reactor. !

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3. My home/ work is h M i3 0 #// men from the -

Neely Research Reactor. In the event of a release of radiation from !

the facility, my personal health would suffer serious consequences.

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, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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(Signature)

A i t ,' t'iS fH '7679 (Print Name) h.

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY

RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 APFIDAVIT Comes now DbM -

ULDEf[f] ,

sho being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I(jeside/ work at \bb1 bn ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is\ ich D.te vt Cs r\c(14-

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from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petit s s #nr Leave to Intervene.

If GANE's position is upheld, there is a rede Velihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

(Signatur'e )

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OLD SER.6 (Print Name) .

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT i '

Comes now s E Nis t FE3 0:DC%IN - ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Te?h's re ,uest to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates ao represent me and my interests.

2. I reside / work at '

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Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

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3. My home/ work is l / 'Ch from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

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, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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(Print Name)

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT 1

Comes now Vl5~7) ~)b i 'LO 9)i '

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GATE to represent me and my interests in the above proceeding inv ang Georgia Tech's request to renew the license of the .Jeely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates ao represent me and my interests.

2. I @ ork at C) P! kh ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3 . Mi [omp2 work is CSS MM G tv\ ( from the P'e',j asea";h Reactor. In the event of a release of radiation from the

:11.ity, .;v personal health would suffer serious consequences.

i

. 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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(Print Name) I 44.

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now I e Ne'd2 t..% W ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside / work at d3 Lo,hh Mye Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

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3. My home/ work is :(OfhYv . 'zin,le from the '

Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

i

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY -

RESEARCH REACTOR Atlanta, Georgia '

Facility License No. R-97 AFFIDAVIT Comes now \ / M Ab ,

who being duly sworn, depos# s and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates Ao represent me and my interests.

2. I reside / work at ( b '

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is @N - AM M , from the fleely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If-GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Adminictrative Judges:

Charles Bechhoefer, Chairman Jr. Jerry R. Kline Dr. Peter S. Iam r

f Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA _NSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now ROBERT JOliNSON, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy s (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my intercsts.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. GREENPEACE's office is about one-half mile from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am ,

less likely to suffer injury from it. ;

This statement is made under penalty of perjury.

'}' ./q,f gpOBERT JOHN dN ~

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UNITED STATES OF AMERICA -

ATOMIC SAFETY AND LICENSING BOARD ,

Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam ,

Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEA'RCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now c C ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates

,to represent me and my interests.

2. I resi /' work at O hm e_ L m <M Gh C O E_5 ,

b Atlanta, Georgia. I elieve my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My ho e s -Na a n ) a l m ,' f g s from the Neely Research etb'r . In the event of a rel' ease of radiation from the facility, my personal health would suffer serious consequences.

. 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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&~f4EFJ Y LEE (Print Name)

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR At it.r.t a , Georgia Facility License No. R-97 AFFIDAVIT Comes now ALVIN LENOIR, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the licensa of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neoly Research Reactor.

3. GREENPEACE's office is about one-half mile from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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ALVIN LENOIR i

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY -

RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now dA u t.- Od.T/ ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside / work at (O(do CEQTQ $T. ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

i

3. My(home)) work is li D filAd k (( AL E b\td from the l Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences, i

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement _is made under penalty of perjury.

f a n . e.rsa b (Signature)

~Innd 7 LE.CU\Ch (Print Name) .

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- .- . ~ . . - . . .. .- . - -. _. - . . - - - .

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman !

Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren ;

In the Matter of ASLBP No. 95-7 04 Ren GEORGIA INSTITUTE OF TECHNOLOGY l

RESEARCH REACTOR Atlanta, Georgia '

Facility License.No. R-97 :

l AFFIDAVIT -

Comes'now L n i N

il i (cs , ;

who being duly swdrn, dgposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy ;

(GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely l Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates Ag represent me and my interests.

2. I reside / work at -

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Atlanta, Georgia. I believe my life and health are jeopardized by ,

Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is )k > from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If Gnt;E's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be cFrea.. I am less likelp to suffer injury from it.

This statement is made under penalty of perjury.

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t UNITED STATES OF AMERICA ATOMIC SAFETY'AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline r

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Dr. Peter S. Lam ,

Docket No. 50-160-Ren-In the Matter of !

ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia '

Facility License No. R-97 ,

AFFIDAVIT i

Comes now /h6f4l 4bl/M Oh '

who being duly sworn,Ideposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in tne above proceeding involving Georgia Tech's request to renew the license of the Neely l Research Reactor on Atlantic Drive in downtown Atlanta. More !

specifically, I authorize Ms. Glenn Carroll or anyone she designates f39 represent me and my interests. i

2. I eside ork'at 601 Lvh6h A% ,

Atlanta, Ge rgia. I believe my life and health are jeopardized by [

Georgia Tech's request to continue operating the Neely Research .{

Reactor.

lLSS & ct y} j y& l.g l 3.My(hh,g2/workis from the Neely Research Reactor. In the eve t of a release of radiation from the facility, my personal health would suffer serious consequences.

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, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene. !

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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UNITED STATES OF AMERICA r

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOh Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now IO O..W d u _,

who being duly sworn, deposes and sta'tes as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More -

specifically, I authorize Ms. Glenn Carroll or anyone she designates

,to represent me and my interests.

2. I reside / work at \DbS O PA ,

Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is C{dL/h', C from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

I

, 4. I have read GAFE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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(Signature)

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kWD mi%l (P2 nt Name) \

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. UNITED STATES OF AMERICA ,

ATOMIC SAFETY AND LICENSING BOARD [

i Before Administrative Judges:

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Charles Bechhoefer, Chairman i Dr. Jerry R. Kline Dr. Peter S. Lam }

l Docket No. 50-160-Ren !

In the Matter of !

i ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF. TECHNOLOGY -

RESEARCH REACTOR Atlanta, Georgia i

Facility License No R-97 i i

AFFIDAVIT i

Comes now E @W4 whb4b '-

f who being duly sworn, deposes and states as follows: I

1. I authorize and request Georgians Against Nuclear Energy t (GANE) to represent me and my interests in the above proceeding !

involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More 1 i

specifically, I authorize Ms. Glenn Carroll or anyone she designates .{

tg represent me and my interests.

2. I reside / work at (O@ N AVAVLou E. Nh- ,

Atlanta, Georgia. I believe my life and health are jeopardized by :

Georgia Tech's request to continue operating the Neely Research Reactor.

3. My home/ work is w&du A h uAYVt. from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

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, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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(Signature)

REE&t htAD b Y -

(Print Name) 4 i

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UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now DANIEL SALMOND, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. Mot specifically, I authorize Ms. Glenn Carroll or anyone she designates l to represent me and my interests.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th l Street, Atlanta, Georgia 30309. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. GREENPEACE's of fice is about one-half mile fror- the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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/ 74:r pkas/n o'AMQLMOND h

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now / k ,

who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside / work at /A e ,

i Atlanta, Georgia. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor, ,

3. My home/ work is G5b h VM 1 C. from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

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SXO)O (Print Name) l

t UNITED STATES OF AMERICA F

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: !

d.

Charles Bechhoefer, Chairman ,

Dr. Jerry R. Kline Dr. Peter S. Lam ;

Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren

-GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT thf( D k, bHAfALG % )'

Comes now ,

who being duly sworn, deposes and states as follows: '

l. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More j specifically, I authorize Ms. Glenn Carroll or anyone she designates j

.tjp represent me and my interests. '

2. I-reside / work at b.T. EON MN b6AfM ,

Atlanta, Georgia. I believe my life and health are jeopardized by ,

Georgia Tech's request to continue operating the Neely Research Reactor.

3.Myhome/workisWLlk'n 64 $ ld_. from the Neely Research Reactor. In the event of a release of radiation from .

the facility, my personal health would suffer serious consequences.

, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upneld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made u6 der pena?.ty of perjury.

~

,. ~ '^[

- - Laf)

(Signature hr%J4 D M GI ACELEFogi3 (Print Name) .

4 O%e

i i

UNITED STATES OF AMERICA l

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Cha :les Bechhoefer, Chairman Lr. Jerry R. Kline l Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY .

RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 i AFFIDAVIT Comes now MARGARET SMITH, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyonc uhe designates to represent me and my interests.

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. GREENPEACE's office is about c'e-half mile from the Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

/ -

c l1;,p,..llll.o,ft MARGARET SMITH t

i 9

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now HELEN SCOTT SWAIN, who being duly sworn, deposes and states as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates ;

to represent me and my interests.

l

2. I work at the Atlanta Field Office of GREENPEACE U.S., 20 13th Street, Atlanta, Georgia 30309. I believe my life and health are jeopardized by Georgia Tech's request to continue operating the Neely Research Reactor.

3. GREENPEACE's office is about one-half mile from the Neely i Research Beactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences.

l

4. I have read GANE's 10/26/94 Petition for Leave to Intervene.

If GANE's position is upheld, there is a reduced likelihood of serious accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.

This statement is made under penalty of perjury.

HELEN SCOTT-SWAIN

UNITED STATES OF AMERICA ATOMIC SAFETY AND LICENSING BOARD Bef ore Administrative Judges:

Charles Bechhoefer, Chairman Dr. .',erry R. Kline Dr. Peter S. Lam Docket No. 50-160-Ren In the Matter of ASLBP No. 95-704-01-Ren GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 AFFIDAVIT Comes now } ras a no \ e st ,

who being duly sworn, deposes and sthtesl as follows:

1. I authorize and request Georgians Against Nuclear Energy (GANE) to represent me and my interests in the above proceeding involving Georgia Tech's request to renew the license of the Neely Research Reactor on Atlantic Drive in downtown Atlanta. More specifically, I authorize Ms. Glenn Carroll or anyone she designates

,t,o represent me and my interests.

2. I reside / work at ok ~~}) ] !~~

(Sigdature fs k iN (Print Name)
- -. = .
l UNITED STATES OF AMERICA >
ATOMIC SAFETY AND LICENSING BOARD
)
Before Administrative Judges:
Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam i Docket No. 50-160-Ren !
In the Matter of -
ASLBP No. 95-704-01-Ren .j GEORGIA INSTITUTE OF TECHNOLOGY e I RESEARCH. REACTOR !
Atlanta, Georgia
. Facility License No. R-97 4
AFFIDAVIT i
,i Comes now M AT M b . \Aj R lfr 4 T '
who being duly sworn, deposes and states as follows: j;
~~1. I authorize and request Georgians Against Nuclear Energy '~~
(GANE) to represent me and my interests in the above proceeding !
involving Georgia Tech's request to renew the license of the Neely j Research Reactor on Atlantic Drive in downtown-Atlanta. More :
specifically, I authorize Ms. Glenn Carroll or anyone she designates ;
..o represent me and my interests.
t I htto & 0iL h L / i
~~2. I reside / work at M 3 E4hP[ b./Y M b8%~~
Atlanta, Georgia. I believe my life and health are jeopardized by !
Georgia Tech's request to continue operating the Neely Research '
Reactor.
~~3. My home/ work is !d #~~
[J from the .
Neely Research Reactor. In the event of a release of radiation from the facility, my personal health would suffer serious consequences. l l
i
l l
1 i
, 4. I have read GANE's 10/26/94 Petition for Leave to Intervene. l If GANE's position is upheld, there is a reduced likelihood of serious l accident at Neely Research Reactor; the reactor will be safer. I am less likely to suffer injury from it.
This statement is made under penalty of perjury.
0M?0'AY - -
T h w a d (L]n h f (Print Name)
.J
~.
J
DOCKETED CERTIFICATE OF SERVICE - Docket No.(s) 50-160-REN ,
Office of Commission Appellate Adjudication 35 JAN 13 P2 :21 U.S. Nuclear Regulatory Commission Washington, DC 20555 0FFICE Di SEEPE iARY Sherwin E. Turk, Esq. 00CKETING & SERV 4CE Susan S. Chikadel, Erg. BRANCH Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Charles Bechhoefer, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Peter S. Lam Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 r Administrative Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Randy A. Nordin Manager - Legal Division Office of Contract Administration Georgia Tech Atlanta, GA 30332-0420 GANE Addresses: i Georgians Against Nuclear Energy P.O. Box 8574 Atlanta, GA 30306 1 i
Glenn Carroll GANE ,
139 Kings Highway I Decatur, GA 30030 1
iI

ML20078D002

Text

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