ML20094S273
| ML20094S273 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 12/04/1995 |
| From: | Darrell Dunn, Guilday P GEORGIA, STATE OF |
| To: | Neely Research Reactor, ATLANTA, GA |
| References | |
| CON-#495-17334 95-710-01-REN, 95-710-1-REN, REN, NUDOCS 9512060097 | |
| Download: ML20094S273 (7) | |
Text
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MA1TO CORRESPONDENCE o.
DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'95 DEC -4 P2 :56 ATOMIC SAFETY AND LICENSING BOARD OFFICE CF SECRETARY Before Administrative Judges:
DOCKEi!j!ji "9VICE Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam
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In the Matter of
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GEORGIA INSTITUTE
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OF TECHNOLOGY
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Docket No. 50-160-Ren
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ASLBP NO. 95-710-01-Ren
' Atlanta, Georgia
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Georgia Tech Research
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Reactor
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Renewal of License No. R-97
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GEORGIA INSTITUTE OF TECHNOLOGY'S INTERROGATORIES REQUEST FOR PRODUCTION OF DOCUMENTS TO GANE Licensee Georgia Institute of Technology
(" Georgia Tech")
propounds its Interrogatories and Request for Production of Documents to GANE and requests that responses to these Interrogatories be served upon Georgia Institute of Technology by December 15, 1995.
All interrogatories refer to GANE Contention 9 regarding i
management of the Georgia Tech Research Reactor ("GTRR").
1.
Please identify each aspect of the management organization or structure, operations, supervision, budgetary functions, or otherwise which you contend serves as a basis for the denial of renewal by the NRC cf Georgia Tech's license.
2.
Please identify and describe all facts in your 9512060097 951204 PDR ADOCK 05000160 a
eDR 9
P a
J possession or control or within your knowledge which supports each of the aspects of management listed in response to Interrogatory no.
1.
3.
Please identify and describe-all documents in your possession or control or within your knowledge which supports eacn or the aspects of management. listed in response to Interrogatory no.
1.
4.
Please identify, giving name, address, and business and home telephone numbers, each person having knowledge of the aspects of management identified by you in response to Interrogatory no. 1 above.
5.
Identify any person GANE presently intends to call as a witness in this proceeding to testify regarding this contention.
For each such person, please state:
- a. name, address, business and home telephone number;
- b. place of employment, title; and education;
- c. whether such individual was at any time an employee of Georgia Tech.
6.
If GANE expects to call an expert witness to testify on its behalf, please provide the following information:
a.
name, address, business and home telephone number; b.
place of employment, title, education; c.
professional experience; d.
the subject matter on which the expert will testify e.
the substance of the facts and opinions as to which the P
c.
4 expert is expected to testify; f.
a summary of the grounds for each opinion.
7.
Identify all documents which GANE intends to admit into evidence at the hearing of this case.
8.-
Identify the specific NRC regulation which you. contend has been violated or is currently being violated by Georgia Tech.
9.
Provide all information and produce copies of all
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documents in your' possession which document or describe in any.
h
' manner any incidents or problems involving the;GTRR which have occurred from 1998 to the present, which GANE contends i
demonstrate significant, serious, or continuing management problems at Georgia Tech.
10.
State whether GANE contends that the corrective actions taken by the Licensee following the events in 1987 failed to adequately resolve any management problems which might have existed at the GTRR prior to the taking of such actions.
If the answer to this interrogatory is yes, please
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explain fully why such corrective actions did not resolve any such problems.
11.
State whether GANE contends that the Nuclear Safeguards Committee (NSC), the Office of Radiation Safety (ORS), or the Manager of ORS have failed to properly perform their respective roles, at any time from 1988 to the present.
If the answer to this interrogatory is yes, please explain fully all examples of improper or inadequate perfc2mance of l,. _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ -. _ _ _ _ _ _ _ _ _ - _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _
l these entities since 1988.
12.
Does GANE have a management plan that it contends should be instituted at GTRR?
If the answer to this interrogatory is yes, please state the following:
a.
the identity of the person (s) who developed such plan; b.
describe such plan, giving specific details as to
- organization, safety assurance, and operation; c.
describe a,11 differences between the organizational structure and management currently in place at GTRR and the plan suggested by GANE.
13.
Does GANE contend that management at the GTRR should be changed in any respect?
If so, please describe all such proposed changes and the purpose of all such changes.
14.
Docs GANE contend that the GTRR cannot be managed appropriately and safely under any management plan?
If the answer to this interrogatory is yes, please provide the factual basis of such contention.
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Request for Production 1.
Please produce each of the documents identified in any of your responses to Georgia Tech's Interrogatories.
i 2.
Please identify any other document which you claim has any' relevance to your contention concerning GTRR management.
Respeccfully submitted, MICHAEL J. BOWERS 174567 Attorftey General
[
AAAdik o3 Am L DENNIS R. DUNN 234098 Senior Assistant Attorney General Y
[n))a.]
PATRICIA GUILDAY U
315113 i
Assistant Attorney General i
e 1
PLEASE ADDRESS ALL COMMUNICATIONS TO:
PATRICIA GUILDAY Assistant Attorney General Georgia Department of Law 40 Capitol Square, S.W.
Atlanta, Georgia 30334-1300
. oc
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f 00CKETED USNRC i
UNITED STATES OF AMERICA NUCLEAR REGULATORY' COMMISSION 95 E -4 P2 56 i
ATOMIC SAFETY AND LICENSING BOARD OFFICE 0F SECRETARY Before Administrative Judges:
DOCKETlHG & SERVICE BRANCH Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam l
)
In the Matter of
)
)
GEORGIA INSTITUTE
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1 OF TECHNOLOGY
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Docket No. 50-160-Ren
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ASLBP NO. 95-704-01-Ren t
Atlanta, Georgia
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j
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Georgia Tech Research
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Reactor
)
l
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Renewal of License No. R-97
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GEORGIA INSTITUTE OF TECHNOLOGY'S CERTIFICATE OF SERVICE I
I do hereby certify that copies of the foregoing Georgia I
Institute of Technology's Interrogatories and Request for 1
Production to GANE have been served upon the following persons by U.S. Mail, except as otherwise noted and in accordance with the requirement of 10 C.F.R. Sec. 2.712:
Administrative Judge Atomic Safety and Licensing Peter S. Lam Board Panel Atomic Safety And Licensing Mail Stop: T-3 F23 Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C. 20555 i
1 a e
a Administrative Judge Administrative Judge Jerry R.
Kline Charles Bechhoefer, Chairnan Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Sherwin E.
Turk, Esq.
Randy A. Nordin, Esq.
Susan S.
Chidakel, Esq.
E. Gail Gunnels, Esq.
Office of the General Counsel Georgia Institute of U.S. Nuclear Regulatory Technology Commission 400 10th Street Washington, D.C. 20555 Atlanta, Georgia 30332 Glenn Carroll Office of the Secretary (2)
Georgians Against Nuclear Attn: Docketing and Service Energy Mail Stop: OWFN-16 G15 Post Office Box 8574 U.S. Nuclear Regulatory Atlanta Georgia 30306 Commission Washington, D.C.
20555 Adjudicatory File (2)
Dr. R.A.
Karam Atomic Safety and Licensing Neely Nuclear Research Board Center Mail Stop: T-3 F23 900 Atlantic Drive U.S. Nuclear Regulatory Atlanta, Georgia 30332-0425 Commission Washington, D.C. 20555 This A day of M @, 1995.
h bha $AAlAk PATRICIA GUILDAY V Assistant Attorney General l
l 7-c.