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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20141C5901997-05-13013 May 1997 Order.* Informs That Time within Which Commission May Take Sua Sponte Review of Initial Decision LBP-97-7 Extended Until 970530.W/Certificate of Svc.Served on 970513 ML20137R4191997-04-0303 April 1997 Initial Decision (License Renewal).* Requested License Renewal Approved.Suggests That Licensee Consider Making Certain Changes in Mgt Organizational Structure. W/Certificate of Svc.Served on 970404 ML20134L6531996-11-13013 November 1996 Georgia Institute of Technology Reply to Proposed Findings of Fact & Conclusions of Law of Gane & NRC Staff.* Board Should Dismiss Intervention Due to Lack of Evidentiary Basis to Support Mgt Contention. W/Certificate of Svc ML20129J5611996-10-25025 October 1996 NRC Staff Proposed Findings of Fact & Conclusions of Law.* Findings & Rulings Address Outstanding Contentions in Proceeding Re 940419 Application for Renewal of License to Operate Gtrr.W/Certificate of Svc ML20129D4731996-10-11011 October 1996 Georgians Against Nuclear Energy Proposed Findings of Fact in Consideration of Application for Renewal of Facility License.* W/Certificate of Svc ML20117N8341996-09-13013 September 1996 Georgia Institute of Technology Proposed Findings of Fact & Conclusion of Law.* Ordered & Adjudged That Georgians Against Nuclear Energy Intervention in Instant Application of Georgia Institute Be Dismissed.W/Certificate of Svc ML20116G6131996-06-28028 June 1996 Intervenor Exhibit I-GANE-71,consisting of 891026 Memo Re Leak of Coolant,Light Water,Used to Remove Heat Deposited by Gammas,Neutrons & Activation Products in Inner Bismuth Block on 890918 ML20116G6161996-06-28028 June 1996 Intervenor Exhibit I-GANE-72,consisting of Minutes of Nuclear Safeguards Committee Meeting of 900215 ML20116G6181996-06-28028 June 1996 Intervenor Exhibit I-GANE-73,consisting of Minutes of Nuclear Safeguards Committee Meeting of 900322 ML20116G6221996-06-28028 June 1996 Intervenor Exhibit I-GANE-74,consisting of Minutes of Nuclear Safeguards Committee Meeting of 900719 ML20116G6241996-06-28028 June 1996 Intervenor Exhibit I-GANE-75,consisting of Minutes of Nuclear Safeguards Committee Meeting on 910131 ML20116G6261996-06-28028 June 1996 Intervenor Exhibit I-GANE-76,consisting of Minutes of Nuclear Safeguards Committee Meeting on 910509 ML20116G6301996-06-28028 June 1996 Intervenor Exhibit I-GANE-77,consisting of Minutes of Nuclear Safeguards Committee Meeting of 910627 ML20116G6311996-06-28028 June 1996 Intervenor Exhibit I-GANE-78,consisting of Minutes of Nuclear Safeguards Committee Meeting of 910801 ML20116G6341996-06-28028 June 1996 Intervenor Exhibit I-GANE-79,consisting of Minutes of Nuclear Safeguards Committee Meeting of 910926 ML20116F9691996-06-28028 June 1996 Staff Exhibit S-29,consisting of 870729 Memo Re Policy of Keeping Personal Logs ML20116F9511996-06-28028 June 1996 Staff Exhibit S-26,consisting of 920930 Appeal from Us District Court for Northern District of Ga ML20116F9241996-06-28028 June 1996 Staff Exhibit S-25,consisting of 911031 Order Re Sn Millspaugh & Pb Sharpe Vs RA Karam ML20116G6071996-06-26026 June 1996 Intervenor Exhibit I-GANE-70,consisting of Minutes of Nuclear Safeguards Committee Meeting of 880216 ML20116G6051996-06-26026 June 1996 Intervenor Exhibit I-GANE-68,consisting of Re Radiological Analyses of Samples Collected from Clayton Water Treatment Plant in Atlanta,Ga ML20116G5871996-06-25025 June 1996 Intervenor Exhibit I-GANE-62,consisting of Rept Re Board Academic ML20116G1851996-06-24024 June 1996 Applicant Exhibit A-9,consisting of Re Response to Insp Rept 50-160/87-03 on 870407-10 ML20116G1941996-06-24024 June 1996 Applicant Exhibit A-10,consisting of 880218 Rept Re, Organization Review of Nuclear Research Ctr of Georgia Institute of Technology ML20116G1991996-06-24024 June 1996 Applicant Exhibit A-11,consisting of Aug 1987 Daily Masslinn Survey Rept DPM X 1000 ML20116G2011996-06-24024 June 1996 Applicant Exhibit A-12,consisting of Re Current Condition of Reactor Top & Containment Bldg Following Decontamination Efforts of Cd-115 Spill on 870818 ML20116G2111996-06-24024 June 1996 Applicant Exhibit A-14,consisting of Forwarding Results of Smear Surveys Taken During Aug 1988.W/o Encls ML20116G3181996-06-24024 June 1996 Applicant Exhibit A-19,consisting of Re Application to Renew Gtrr License R-97 Until 140606 ML20116G4791996-06-24024 June 1996 Intervenor Exhibit I-GANE-53,consisting of 951115 Transcript of Broadcast Excerpt for Georgia Tech Nuclear Facility ML20116F9951996-06-24024 June 1996 Applicant Exhibit A-6,consisting of 870506 Memo Re Reorganization of Nuclear Research Ctr ML20116F9811996-06-24024 June 1996 Applicant Exhibit A-5,consisting of 870126 Memo Re Reorganizing Neely Nuclear Research Ctr ML20116F9751996-06-24024 June 1996 Applicant Exhibit A-4,consisting of RA Karam Resume ML20115F7751996-05-31031 May 1996 Applicant Exhibit A-31,consisting of 830301 Transcript of tape-recording ML20115G5501996-05-30030 May 1996 Intervenor Exhibit I-GANE-49,consisting of Re Jm Puckett Appointment ML20116G3741996-05-30030 May 1996 Intervenor Exhibit I-GANE-37,consisting of Broad Scope Licenses.Related Correspondence ML20116G3841996-05-30030 May 1996 Intervenor Exhibit I-GANE-38,consisting of List of Board of Directors for 1955-1972.Related Correspondence ML20115G5801996-05-30030 May 1996 Intervenor Exhibit I-GANE-52,consisting of Re NRC Concerns About Gtrr Operation Requiring Comprehensive Assessment of Activities at Neely Nuclear Research Ctr ML20115G5721996-05-30030 May 1996 Intervenor Exhibit I-GANE-51,consisting of Paper on Wrong Way to Handle Radiation Safety ML20115G5691996-05-30030 May 1996 Intervenor Exhibit I-GANE-50,consisting of Info Re Pattern of Presidency ML20115G4701996-05-30030 May 1996 Intervenor Exhibit I-GANE-48,consisting of Re Hot Cell - Storage Pool Operations ML20115F7301996-05-30030 May 1996 Applicant Exhibit A-28,consisting of 940317,Radiation Safety Manual,Revised 950921 ML20115F7361996-05-30030 May 1996 Applicant Exhibit A-29,consisting of 6.0, Administrative Controls ML20115F7691996-05-30030 May 1996 Applicant Exhibit A-30,consisting of 6.0 Adminstrative Controls ML20115G4281996-05-30030 May 1996 Intervenor Exhibit I-GANE-41,consisting of Re Facility Passing Insp W/No non-compliance Items ML20115G4301996-05-30030 May 1996 Intervenor Exhibit I-GANE-42,consisting of Organizational Chart ML20115G4321996-05-30030 May 1996 Intervenor Exhibit I-GANE-43,consisting of Neewly Nuclear Research Ctr Organizational Chart ML20115G4361996-05-30030 May 1996 Intervenor Exhibit I-GANE-45,consisting of 880218 Memo Re Meeting W/President Crecine ML20115G4261996-05-30030 May 1996 Intervenor Exhibit I-GANE-40,consisting of of Appreciation Re Help W/Insp ML20115G4251996-05-30030 May 1996 Intervenor Exhibit I-GANE-39,consisting of List of Items Inspectors Look for During Insp ML20115G4451996-05-30030 May 1996 Intervenor Exhibit I-GANE-46,consisting of Re Organization Arrangements & Radiation Safety ML20115G4481996-05-30030 May 1996 Intervenor Exhibit I-GANE-47,consisting of 880226 Minutes of President Crecine Address to General Facility 1997-05-13
[Table view] Category:PLEADINGS
MONTHYEARML20117G3161996-05-15015 May 1996 Motion to Bar Appearance as Witness & to Exclude Any & All Testimony by G Carroll.* Moves to Bar Testimony Due to Failure to Comply W/Board Direction That Testimony Be Submitted in Written Form by 960503 ML20117G3331996-05-15015 May 1996 Memorandum in Support of Motion to Bar Appearance as Witness & to Exclude Any & All Testimony by G Carroll.* Opposes Filing 960222 Suppl Discovery Responses in Lieu of Board- Ordered Written Testimony.W/Certificate of Svc ML20101C0941996-03-0808 March 1996 Georgians Against Nuclear Energy (Gane) Motion to Compel NRC to Release R Long Documents Re Gane Contention That Mgt Problems at Georgia Tech Research Reactor So Bad That License Renewal Must Be Denied....* W/Certificate of Svc ML20149L2401996-02-10010 February 1996 Georgians Against Nuclear Energy Motion to Compel Request for Production of Documents from NRC Concerning Mgt Contention.* Urges Release of Documents to Enable Parties to Provide Response to Discovery Requests.W/Certificate of Svc ML20096G3891996-01-11011 January 1996 Georgians Against Nuclear Energy Request Permission to Enter & Inspect.* Discusses Presence of Fresh & Spent Fuel at Georgia Tech Research Reactor.W/Certificate of Svc.Related Correspondence ML20096C6811996-01-0202 January 1996 Georgians Against Nuclear Energy Motion for Extension of Deadline to Answer Georgia Tech & NRC Discovery Requests.* Parties Agreed Deadline for Disposition Moved from 960112 to 0126.W/Certificate of Svc.Served on 960102 ML20096C6471995-12-22022 December 1995 Georgians Against Nuclear Energy Motion for Extension of Deadline to Answer Georgia Tech & NRC Staff Discovery Requests.* W/Certificate of Svc ML20094S3301995-12-0404 December 1995 Georgia Institute of Technology'S Responses to Gane Discovery.* Permission from Ga Tech to Enter & Inspect Neely Nuclear Research Ctr Physical Security Sys,Requested. W/Certificate of Svc.Related Correspondence ML20094N0031995-11-10010 November 1995 Georgians Against Nuclear Energy Addl Contention That Georgia Tech Is Unable to Provide Security for Georgia Tech Research Reactors & Facility License Renewal Should Be Denied.* Requests NRC Cease Operations.W/Certificate of Svc ML20094M4181995-11-10010 November 1995 Georgians Against Nuclear Energy Motion to Compel Request for Production of Documents & Interrogatories to Ga Tech on Mgt Contention.* W/Certificate of Svc ML20093F9301995-10-13013 October 1995 Ga Institute of Technology Response to Board Memorandum & Order of 950926 Concerning Contention 9 (Mgt).* W/Certificate of Svc ML20093B6881995-10-0404 October 1995 Georgians Against Nuclear Energy Motion for Extension of Comment Deadline on Georgia Tech Mgt Structure Changes.* Request Will Be Granted If Other Parties Involved Agree. W/Certificate of Svc ML20092M5961995-09-22022 September 1995 Georgia Institute of Technology Response to Board Memorandum & Order of 950907.* Georgia Tech Requests That Board Reverse Order W/Respect to Contention 5 & Determine That Contention Is Moot.W/Certificate of Svc ML20091K9161995-08-28028 August 1995 Petition to NRC & Agency for Toxic Substances & Disease Registry Us Dept of Health & Human Svcs ML20087C0271995-08-0707 August 1995 Georgia Institute of Technology Response to Gane Request for Hearing on Conversion Order.* Georgia Tech Adopts Arguments & Authorities Cited by NRC in Response to Gane Request for Hearing.W/Certificate of Svc ML20086D3051995-06-26026 June 1995 Georgians Against Nuclear Energy Response to Georgia Tech & NRC Staff Comments on Housekeeping Stay.* Requests Clarification as to Fuel That Georgia Tech Intends to Remove.W/Certificate of Svc ML20085L2601995-06-21021 June 1995 Georgia Institute of Technology Response to Commissioner'S Order Issuing Housekeeping Stay.* W/Certificate of Svc ML20085K5081995-06-20020 June 1995 Georgians Against Nuclear Energy Response to Commission Order for Housekeeping Stay.* W/Certificate of Svc ML20085H5211995-06-0505 June 1995 Request of Georgians Against Nuclear Energy for Protective Order.* Requests Cooperation of Parties in Developing Protective Order for Georgians Against Nuclear Energy to Examine Security Plans as Stated.W/Certificate of Svc ML20084L3691995-05-26026 May 1995 Georgians Against Nuclear Energy Response to NRC & Georgia Tech Appeals on Atomic Safety & Licensing Board Prehearing Conference Order of 950426.* Urges NRC to Percieve Urgency of Matter.W/Certificate of Svc ML20081L4401995-03-20020 March 1995 Gane Response to Board Inquiry Re Relevance of 10CFR73.60(f) to Petition to Intervene.* Discusses Passage Cited by Board as Relevent to Petition.W/Certificate of Svc ML20082B1611995-03-20020 March 1995 Georgia Institute of Technology Response to Board Memorandum & Order & Objection to Proposed Intervenor Contention Number 5.* Board Should Reject Georgians Against Nuclear Energy Contention.W/Certificate of Svc ML20080Q9621995-03-0909 March 1995 Petition to NRC & Agency for Toxic Substances & Disease Registry,Supporting P Blockey-O'Brien Petition for Director'S Decision Under 10CFR2.206 to NRC on 941003 1996-05-15
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,- '/772BfC/ 9 DOCKETED UNITED STATES OF AMERICA USHRC ATOMIC SAFETY AND LICENSING _ BOARD 125 . NOV 14 P6 :20 ;
, Before Administrative Judges: !
OFFICE OF EECRETARY 00CKETING & SERVICE Charles Bechhoefer, Chairman BRANCII Dr. Jerry R. Kline Dr. Peter.S. Lam ,
Docket No. 50-160-Ren I In the Matter of
- ASLBP No. 95-704-01-Ren !
GEORGIA INSTITUTE OF TECHNOLOGY RESEARCH REACTOR Atlanta, Georgia Facility License No. R-97 j
! i l
i l GEORGIANS AGAINST NUCLTAR ENERGY '
ADDITIONAL CONTENTION i THAT GEORGIA TECH IS UNABLE TO PROVIDE SECURITY FOR THE GEORGIA TECH l RESEARCH REACTOR AND FACILITY LICENSE RENEWAL SHOULD BE DENTED j Georgians Against Nuclear Energy (GANE) respectfully petitions the l Atomic Safety and Licensing Board to accept this new contention concerning Georgia Tech's request to renew its operating license for the Neely Nuclear Reactor Center through the year 2015.
New information is available concerning the inability of reactor I personnel and Georgia Tech University to provide security from sabotage or terrorism.
l GANE contends that the Neelv Nuclear Research Facility is unsafe to the public because of inadequate security systems. Neely Reactor Research Center 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 hours. Essentially, the entirc security system consists of a chain-link fence with some barbed wire on top. Wire-cutters or amateur fence-climbing would be sufficient to breach the fence (Glenn Carroll, eyewitness, "A Current 9511270325 951110 0 PDR ADOCK 05000160 G PDR
4 Affair" TV-crew).
The presence of the Olympics in Atlanta in 1996 creates a specific situation which has historically attracted terrorist activity and threats. The reactor uses highly enriched uranium as fuel. During refueling this bomb-grade uranium fuel is a tempting target for terrorists. The presence of fissionable and highly radioactive fission byproducts at the. reactor (250,000 curies of cobalt-60 and heavy water for example), make the reactor facility not only a tempting target for theft of bomb-grade or hazardous materials, but a target for a World Trade Center- or Oklahoma City-type bombing which would not only '
injure residents and visitors to Atlanta, but create an international ;
diplomatic disaster for the United States.
The reactor roof is nothing but 7/16" thick steel sheet-metal (S AR, p.44, Fig. 4-8).and would easily be breached by a rocket-launcher or hand-thrown grenade. The adjacent research facility is an ordinary brick building with 250,000 curies of cobalt-60 kept in a shielding pool next to wall which is on Atlantic Drive directly across from where 8th Street plunges into it. A roll-away truck would break through the wall and land in the pool spreading radiation into the environment. The Atlanta news has carried two reports in the past year of unrecovered stolen fertilizer of the type used in the Oklahoma City bombing. A casually dropped book-bag or baby buggy full of explosives could breach the poorly shielded facility spreading radiation into the environment. There are no security cameras to detect entry through the roof.
In early October, 1995, a TV crew from Fox Network's "A Current Affair" wandered freely around the reactor facility (see attached newspaper article). The crew scaled the barbed-wire security fence and wandered around the site and climbed on the roof in broad daylight.
The TV show is scheduled to air November 15 and that story will be more fully revealed then. Neither reactor nor campus security personnel knew of the security breach until the TV crew (which fortunately had no harmful intentions) showed them camera footage of the exploit. Additionally, Georgia Tech failed to properly notify the NRC of the situation upon learning of it.
The Olympics creates a situation where the Tech reactor is likely to attract increased attention from terrorists, but GANE submits that both Georgia Tech and reactor personnel are unable to secure the facility against even the simplest of intrusion efforts. To protect the public health the NRC must immediately order operations to cease at Neely Nuclear Center and deny a license for further operation.
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' Security should be immediately increased ~and the process of removing.
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l the various radioactive isotopes should commence now. -!
GANE willl submit a videotape of the "A CurrentfAffair" story to the. -
service. list when it'becomes available, f i
Respectfully submitted, l~ i l
e-s enn Carroll ;
( Representative for GANE {
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I-j Dated.and signed November 10, 1995 l in Decatur, Georgia !
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I Securityviolated near Tech reactor N CMera CTCW CNS The TV crew breached no secure run the reactor for another 20 years.
zones, said James M. Langley, Tech s NRC officials, who investigated the fence at researCh Center vice president for externai afrairs. The incio,,,131, ,,,x, ,,i, , ,,,11 ,1,,,,
crew did walk up to the zones, but, be- assessment shows thr.t the TV crew en-cause of locked doors, had no access to By Charles Seabrook tered no " controlled areas," and no ra-STAFF WRfTER
. dioactive material was affected. The re-However, he acknowledged the TV actor contains less than 11 pounds of A two-person camera cre,v from a crew's unannounced ramblings "have bomb-grade uranium.
nationally syndicated news show the appearance of [ uncontrolled] access The 5 million-watt reactor is a few roamed uninvited and unchallenged in to the facility; and we recognize that we blocks from the Olympic Village, where a
the building that houses Georgia Tech's fgc conc m " safe facility and allay pub- of athletes will be housed dur-thousands nuclear reactor, raising concerns about Those concerns were heightened this ing the Olymptes.
security at the facility.
'ye'ar when a citizens antinuclear group, Tech officials said the reactor will be Tech officials said they are embar- Georgians Against Nuclear Energy shut down this month and its bomb-rassed over the incident last week, in (GANE), told the federal Nuclear Regu. grade fuel removed. The reactor will which a reporter and cameraman from latory Commission that security at the stay idle until after the Olympics. When the tabloid news show "A Current Af ' 30-year-old reactor is inadequate 'and it is re-started,it will be fueled by a low-fair" stimiled down hallways of the Neely ' the facility's bomb-grade uranium could er grade of uram,um.
-Nuclear Research Center and climbed a become a tempting target for terrorists WheelerJackson,an assignment edi-fence around the building. The building during next summer's Olympics in At. tor for Fox television's "A Current Af-houses Tech's 30-year-old reactor in the lanta. GANE has demanded that the fair," said the piece on Tech security middle of the downtown campus, commis'sion deny Tech a new license to will be aired this month.
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00CKETED ,
CERTIFICATE OF SERVICE - Docket No. (s) 50-160-REN USHRC .
Secretary _ .. h U.S. Nuclear Regulatory' Commission 95' NOV 14 P6 :21 i Docketing and Service Branch i Washington, DC 20555 !
0FFICE OF EECRETARY. !
Office of' Commission Appellate Adjudication DOCKETlHG & CERVICE j U.S. Nuclear Regulatory-Commission BRANCH ;
. Washington, DC:20555 -
Admiriistrative Judge '!
l I Charles Bechhoefer, Chairman l Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 i
Administrative Judge Peter S. Lam !
Atomic Safety and Licensing Board ;
i U.S. Nuclear Regulatory Commission f i
Washington, DC 20555 ,
Administrative Judge Jerry R. Kline i Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission i Washington, DC 20555 Sherwin E. Turk, Esq.
-Susan S. Chikadel, Esq.
Office of the General' Counsel
.U.S. Nuclear Regulatory Commission Washington, DC 20555
-Mr. Randy A. Nordin l
Manager - Legal Division l Georgia Tech
!_ Atlanta, GA 30332-0420 E. Gail Gunnells Office of Contract Administration Georgia Tech Atlanta, GA 30332-0420 ,
Ms Pamela Blockey O'Brien D23 Golden Valley Douglasville, GA 30134
< Ms. Patricia Guilday, Esq.
! Assistant' Attorney General 4 40 Capitol Square NW Atlanta, GA 30334-1300
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