ML20094S330
| ML20094S330 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 12/04/1995 |
| From: | Darrell Dunn, Guilday P GEORGIA, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#495-17335 95-710-01-REN, 95-710-1-REN, REN, NUDOCS 9512060128 | |
| Download: ML20094S330 (52) | |
Text
{{#Wiki_filter:- . __ . _ . t bY MAED CORRESPONDENCE DOCKETED t
. USNRC UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION
'95 DEC -4 P2 :56 -
ATOMIC SAFETY AND LICENSING BOARD OFFICE 0F SECRETARY Before Administrative Judges: 00CKETil!G & SERVICE BRANCli Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam
) l In the Matter of )
)
GEORGIA INSTITUTE ) OF TECHNOLOGY ) Docket No. 50-160-Ren
) ASLBP NO. 95-710-01-Ren Atlanta, Georgia ) .
) l Georgia Tech Research ) !
Reactor )
)
Renewal of License No. R-97 ) 1 GEORGIA INSTITUTE OF TECHNOLOGY'S RESPONSES TO GANE'S DISCOVERY j Licensee Georgia Institute of Technology (" Georgia Tech")
- responds to the discovery served by GANE on June 5, 1995 as j l
follows: l , I Introduction { I GANE's discovery includes requests which obviously relate < l to Contention 5, regarding security at the Georgia Tech j facility during the 1996 Olympic Games. The Licensing Board , has determined that Georgia Tech's agreement to remove its high , I energy uranium from its facility before the Olympics has rendered Contention 5 moot as respects the reactor fuel.- For this reason, Georgia Tech will not respond to those discovery i 9512060128 951204 PDR ADOCK 05000160 Q PDR cp])
, o 1
I l requests which relate purely or primarily to security and which , have no obvious relationship to Contention 9, the management ; i issue. ; The Licensing Board has also determined that it does not have authority to hear any issues regarding the cobalt-60 and cesium-137 and Georgia Tech will not respond to any discovery requests which' pertain to either of these substances. t j General Objections Many of GANE's requests state a time frame from either 1964 ^ forward or 1980 forward. Georgia Tech objects to production of information or documents which relate to any document, event, 4 ! person, or specific information dating prior to 1985. This objection is based upon grounds of relevancy, overbreadth, and burdensomeness. Contention 9 raises the issues of current j management practices and changes in such practices because of 1 or subsequent to events in 1988. Information more than three j years prior to 1988 has no relevance to those issues nor is l
- \
such information likely to lead to the discovery cf admissible
- evidence. The task of identifying information dating back j fifteen or thirty years from today would be overwhelming. i Georgia Tech would be required to spend time and financial
, resources searching for information which would provide no ! l useful information to GANE or to the Atomic Safety and i Licensing Board. 1 l i
.e . e Georgia Tech states that it raises the above objection in !
response to every discovery request including the overbroad time frames. Georgia Tech states that in every such case, it i is producing information dating 1985 forward. , 9 h l l I l i i i
+ p I
f i t b O ' ~
, _ . . . . . . , ,,, ,, _,_,.__y.. ._.. ,. , ,, . , , _ _ ,._ . .
~ _ _ _ __ . . _ _ . . _ _ _ _ - - _ .
4
?
Interrogatories Interrogatories 1 through 12 relate purely or primarily to i the security issue and no response is required of Georgia Tech j to these interrogatories. ;
- 1. What security is now in place for the Neely Nuclear f Research Center including but not limited to guards, alarus and camera' surveillance? ,
- 2. How do you respond to each different type of alarm or threat. ;
i
- 3. What is the response time?
- 4. Has anyone ever made an attempt to break in and how fast did the police respond? ,
- 5. What training do Georgia Tech police have to deal with real sharp terrorists and saboteurs inside and around the Neely Nuclear Research Center? )
- 6. How do you test the present security plan?
l
- 7. What scenarios does the security plan'for the Neely I Nuclear Research Center cover?
- 8. What is the worst case scenario envisioned in the i formation of the present security plan?
- 9. What is the emergency response plan for each scenario?
- 10. What is the criteria for notifying the following agencies: campus police, Atlanta Police Department, Fulton County Police Department, Nuclear Regulatory Commission, Georgia Environmental Protection Division, local fire departments?
d l l 1
' 1k -
- . - - . . . - , - - -~ . . - - . - . _ . - .. - .
4-t
- i
- 11. What is the security plan for the 1996 Olympic Games and which agencies or institutions are responsible for its implementation?
- 12. What drills or tests of the Olympic security plan or other simulated emergency response activities will take place l 5
before the 1996 Olympics and what agencies and institutions are ; 4 responsible for these tests? s ! 13. List an inventory of all radioactive and hazardous a
- materials contained in the Neely Nuclear Research Center,
' including the number of curies for each radioactive substance listed and exact locations.
, Response: Attachment I lists all radioactive and hazardous , l
- materials at GTRR. The exact location of the material is classified information.
- 14. Where is the spent fuel?
Response: GTRR has no spent fuel. All fuel is used in the reactor.
- 15. Is there a load of fresh fuel on the premises, and if so, where is it?
Response: GTRR does not have a load of fresh fuel on the premises.
- 16. What are Georgia Tech's current plans to switch to low-enriched uranium fuel at the Neely Nuclear Research Center and what effect if any would this change have on the security plan?
Response: To the extent that this interrogatory relates to
....- e
l the security issue, no response is required of Georgia Tech to i . this interrogatory. For information concerning the replacement ' i of the high-enriched uranium fuel to low-enriched fuel, see
)
~ documents provided to the NRC.
; 17. Describe the Nuclear Safeguards Committee including i its functions; when formed and why and to whom it reports.
- 1 Response: The charter and responsibilities for the Nuclear Safeguards Committee are as specified in the Technical ,
Specifications of the license from NRC an' are set forth below: A Nuclear Safeguards Committee shall be established by the ! 4 .l President of Georgia Tech which shall be responsible for maintaining the health and safety standards associated with the
- use of radioactive materials on the Georgia Tech campus l (regulated by the State of Georgia) and the operation of the !
2 ' I GTRR (regulated by the U.S. Nuclear Regulatory Commission). * { A. Membership ' The Nuclear Safeguards Committee shall be ' composed of senior technical personnel who !
- provide experience in radiological safety, v
- radiation protection, reactor engineering,
- reactor operations, chemistry and radiochemistry, i
instrumentation-control systems, and mechanical ! and electrical systems. ! B. Responsibilities {
- 1. The Committee shall meet quarterly at a f i
minimum. [ i i f j t
. e I
i l
- 2. The Committee shall review and approve
-l proposed experiments and tests utilizing )
radioactive material, the reactor facility, I 1 the hot cell facility, and all other types of ionizing radiation on the Georgia Tech campus, t
- 3. The Committee shall. review and approve J
proposed operating procedures and health physics procedures for the GTRR and the Georgia Tech campus. It shall also review j and approve revisions to already existing procedures. Minor modifications to procedures which do not change the original 4 intent of the procedure may be approved by the Director, Neely Nuclear Research Center (NNRC), or his designee. ,
- 4. The Committee shall review reportable i
I occurrences.
- 5. The Committee shall review and approve proposed changes to the GTRR made pursuant [
i ; to 10 C.F.R. 550.59 (c) , and the regul'ations i of the State of Georgia as contained in ! i: Chapters 290-5-22 and 391-3-17 of the State ! i Rules and Regulations. !
- 6. The Committee shall audit reactor operations 4 i for adequacy and reactor operational records 7 ,
h
t for compliance with internal rules, procedures, regulations, license conoitions and Technical Specifications on an annual basis.
- 7. For the GTRR, the Committee shall audit plant equipment performance with particular attention to operating anomalies, reportable ,
occurrences, and the steps taken to identify d and correct their causes on an annual basis.
- 8. Minutes of the Committee meetings, including
- any recommendations or occurrences, shall be ,
recorded and distributed to all committee ; 1 members and the President's Office. , Committee minutes will also be filed in the j NNRC office. j
- 9. The Committee shall review and approve all l
applications for the use of ionizing i radiation on the Georgia Tech campus i including radioactive materials and radiation generating devices. i 10. The Committee may delegate authority to the Chairperson or a Subcommittee to act in its . behalf between normal meeting dates in certain matters. In such a case, r.c the next meeting of the Committee, the full membership shall be informed of any such i [ l i k
.. h I
i i action that has taken' place (e.g. , I authorization for a new PI to'use
- c ..
1 radioactive materials). j 11. : Appointments of members to the Committee shall be for.three years. The Committee
- reports to the President of the Institute.
- l. 18. Describe the_ selection process for the Nucleari l' Safeguards Committee. Include criteria for membership,-
nomination process and who'is responsible for final selection. Response: See Georgia Tech's answer to interrogatory 17
~ above. In further response to this interrogatory, Georgia Tech ,
- states that the names are. selected from a list of names the NSC prepares. If a person whose name is on the list is willing to serve, he/she is nominated to the President of the Institute.
The. resume of.that person is submitted to the President for j evaluation. The selection of members of NSC is done ty the j President.
- 19. List the names of all persons currently serving on the Nuclear Safeguards Committee, including the process by which l
- each person was chosen, by whom each person was nominated and each person's qualifications for the position on.the committee.
l
- Response
- See Attachment II to these discovery responses.
- 20. Describe the Radiation Protection Committee, including its functions, when it was formed, when it was dissolved, and why.it was dissolved.
l Response: There was no charter of which any current
staff member of NNRC is aware for the Radiation Protection Committee. The function (s) of that Committee overlapped significantly with the functions and charter of NSC (see answer to Question 17). No one currently on the NNRC staff knows when the RPC was formed. It was dissolved in May of 1987. Its functions were merged with the Nuclear Safeguards Committee.
- 21. List the names of all persons who formerly served on the Radiation Protection Committee, including, for each person listed, the dates of service, position held, last known telephone number and address and whether they at any time ever served on the Nuclear Safeguards Committee and when such service took place.
Response: Georgia Tech incorporates its General Objection as to time frame as set forth above and states that all information responsive to this request was long ago archived. It would take literally months to retrieve such information. Georgia Tech has attached the requested information for the years 1985 forward.
- 22. List the names of all persons who formerly served on the Nuclear Safeguards Committee, including their dates of service and qualifications, position held, last known telephone number and address. !
Response: See Georgia Tech's response to interrogatory no. 21 above. 1
- 23. Describe any changee to the function and responsibility of the Nuclear Safeguards Committee during its
[ m.
i 4 4 1 .; 2 history.
. What was the rationale for changes made? ! Response: :See Georgia Tech's response to.interrogatcries. (
i . . ! no. 17 and 21 above. j
- . .. i
- 24.. Describe, with specificity, the event which took place l 4 . .
l atethe Neely Nuclear Research Center on March 23, 1995, , ! involving the cobalt-60 shielding pool. Include all response ) i l actions taken, naming each person involved and their respective j i i i positions, including their department, agency or institution. 1 i
- j. Response: See Attachment III~to these discovery responses. j
- 25. Describe,Ewith specificity, the' measures and actions i
taken to correct the problem which caused'the event involving i k-i the cobalt-60 pool on 3/23/95. l Response: The pool is designed to be self-protecting, j e.g., it cannot be drained under normal conditions. Additionally, the technician who left the valves open was i l trained and counseled about performing this job properly. 1
- 26. What was the basis for firing two highly specialized i
health physicists--Steve Millspaugh and Paul Sharpe in February ! 1988? Response: See Attachment IV to these discovery responses.
- 27. List.the people from 1980 to the present who have held
! the position.of Radiation Safety Officer or equivalent, their i experience level, qualifications, and reasons for leaving. i j Response: See Georgia Tech's response Lu interrogatory no. 21 above. In further response to this interrogatory, deorgia !
. Tech states that the following individuals have held the i
1 1 I l l
...- ._. . . _ _ _ . _ - . _ _ . . _ _ __ a
... - ..- . - - - - . . . --. . - . ~. -. ~-
I position of Radiation Safety Officer: Bob Boyd, B.S., Meteorologist j
-left because of policy differences with management 4 i Dr. Betty Revsin, Ph.D., Health Physicist ,
l -left because of health reasons i Dr. Drian Cupcutt, Ph.D., Health Physicist 1
-left for higher paying job in California ;
- Dr. Rodney Ice, Health Physicist ;
current manager of the Office of Radiation Safety. [ There were also two temporary appointees to this office: j 141ke Puckett, B.S., Psychology ; Jim O'Hara, B.S., Mechanical Engineering l Interrogatories 28 through 31 relate purely or primarily to j the security issue and no response is required of Georgia Tech to these responses. Georgia Tech also incorporates its General objections herein as set forth above. I
- 28. What is the security plan for a truck bomb?
i
- 29. How many campus police are sent in response to alarm activation?
4 f 30. How does the security plan provide against arson?
- 31. Is there an alarm that is activated by radiation levels?
Interrogatories 32 through 36 relate to cobalt-60 and cesium-137, matters over which the NRC has no jurisdiction and which are not at issue in this license-renewal proceeding. Accordingly, no response is required of Georgia Tech to these interrogatories.
- 32. How many times has the cobalt-60 pool-water level dropped?
- 33. How many times has the alarm on the cobalt-60 pool
-been activated?
- 34. What is the evaporation rate of the cobalt-60 pool?
- 35. Describe, with specificity, for what contract work and purposes the cobalt-60 is used. Include all contract work and specific projects from 1980 to the present. l
- 36. Describe, with specificity, for what contract work and purposes the cesium-137 is used. Include all contract work and :
?
specific projects from 1980 to the present.
- 37. Describe, with specificity, for what contract work and purposes the reactor is used. Include all contract work and specific projects from 1980 to the present, accounting for all time logged in State of Georgia records.
Response: Georgia Tech will make documents which include the information sought in this interrogatory available for l review by GANE at a mutually convenient date and time. i _ _ _ _ _ _ _. -.___- _ _ . t .l
.- .- -. .. -_ _ - - . - _ .- = . = . .
i Request for Production of Documents l Requests 1 through 9 and 12 through 15 relate purely or primarily to the security issue and no-response is required of ; Georgia Tech to these requests. j i
- 1. Entire security plan for the Neely Nuclear Research t center. l l
~ 2. Preamble to security plan for Neely Nuclear Research ;
Center.
- 3. Amendments to security plan for Neely Nuclear Research i
Center. i ! { 4. Special security plan for Neely Nuclear Research Center ; for 1996 Olympic Games, i i
- 5. All correspondence to date, and continuing, related to development and all phases of security plan for Neely Nuclear )
i Research Center, including but not limited to FBI, CIA, GBI, Georgia Emergency Management Agency, FEMA, National Guard, Alcohol, Tobacco, and Firearms, City of Atlanta Police, Fulton County Police, Georgia State Patrol, Atlanta Olympic Committee, International Olympic Committee, Georgia Tech campus security, City of Atlant: Fire Department, Fulton County Fire Department, William James Ray's office, Department of Energy, Department of Defense, NRC and Georgia Environmental Protection Division.
- 6. All Georgia Tech campus police audit records, inspection reports and test records pertaining to Neely Nuclear Research C2nter.
- 7. All audits, inspection reports and test records of I
r
i I 1 Georgia Tech campus security, both internal and independent.
- 8. Georgia Tech campus police security log from 1980 to ,
present.
- 9. Minutes from all meetings (1964 to present) of Georgia ,
Tech Nuclear Safeguard Committee and Radiation Protection l Conatittee. ; Response: Georgia Tech will make documents responsive to this request available for review by GANE at a mutually convenient date and time.
- 10. All correspondence, 1964 to present, between Neely [
Nuclear Research Center and Georgia Tech administration i concerning security at Neely Nucleer Research Center.
- 11. All correspondence, 1964 to present, between Neely Nuclear Research Center and Georgia Tech campus security ;
concerning security at Neely Nuclear Research Center.
- 12. All internal correspondence, 1964 to present, within i
Neely Nuclear Research Center concerning facility security.
- 13. All documents related to protection of Neely Nuclear Research Center from truck bombs.
- 14. All correspondence which was shared, traded or j exchanged between Ptlanta, Georgia Tech, State of Georgia or NRC officials and local hospitals or medical clinics relating 1
to the actions and precautions to be taken in the event of a nuclear accident, including any data involving radiation 1 poisoning and the hospitals' and medical clinics' response. l l
- 15. Campus police logs and Nuclear Research Center logs li m J
... . .- . -. . . - . . ~.
i j for all alarm activations and responses (1964 to present). d
.i I
16 . . All documents relating to March 23, 1995 incident ; where alarm activated from water level drop in cobalt-60 pool. - Response: See answer to Interrogatory no. 24. . Requests-17 through 23 relate purely or primarily to the security issue and no response is required of Georgia Tech to these requests.
- 17. Entire emergency response plan for Neely Nuclear t
i Research Center.
- 18. Any and all Georgia Tech employee manuals that relate to employee responsibilities during emergency response ;
l situations at the Neely Nuclear Research Center, including but i not limited to employees of the Neely Nuclear Research Center and campus police.
- 19. All Georgia Tech campus police reports and records I
which refer to activities and/or security breaches at Neely Nuclear Research Center from 1980 to present.
- 20. All internal reports, memoranda and other correspondence generated by Neely Nuclear Research Center staff relating to any security breaches or in response to any alarms or other security alert mechanisms from 1980 to the present.
- 21. All documents generated in both planning and evaluation of any drills, evacuation plans or other such i
simulated emergency response activities designed to test the j adequacy and efficecy of the current security plan for the I
~ Dj
Neely Nuclear Research Center.
- 22. All documents relating to changes in the existing security plan for the Neely Nuclear Research Center as a result of Georgia Tech's intended change from high-enriched ure.nium fuel to low-enriched uranium fuel.
- 23. All records related to the division of authority / responsibility between the State of Georgia and the NRC with regard to the safety requirments at the Neely Nuclear Research Center from 1964 to the present.
- 24. Records showing the complete inventory of radioactive and hazardous materials at the Neely Nuclear Research Center including their original locations, current ownership and regulating authority.
Response: See answer to Interrogatory no. 24. The location of the fuel is not divulged for security reasons.
- 25. Records instructing employees of Georgia Tech how to I
implement and apply Georgia Tech's rules for evacuating the Neely Nuclear Research Center and issuing an emergency alert to the surrounding community. Response: This request relates purely or primarily to the security issue and no response is required of Georgia Tech to this request.
- 26. All insurance inspections, reports, and audits concerning Neely Nuclear Research Center.
Response: This request relates purely or primarily to the l o
security issue and no response'is required of Georgia Tech to this-request.
- 27. Dr. Ratib A. Karam's resume or curriculum vitae at time of hiring (1982-A4).
Response: Georgia Tech will make these documents available to GANE for review at a mutually convenient date and time.
- 28. All documents which describe the criteria for nominations and selections for membership on the Nuclear Safeguards Committee.
Response: See answers to Interrogatory nos. 17 and 18 above. l l
- 29. All resumes or curriculum vitae for all persons :
1 currently serving on the Nuclear Safeguards Committee. Response: Georgia Tech will make these documents available to GANE for review at a mutually convenient date and time.
- 30. All documents generated for the purpose of authorizing each person currently serving on the Nuclear Safeguards Committee.
Response: Georgia Tech does not understand exactly what documents are sought by this request but will make documents it believes to be responsive to this request available to GANE for review at a mutually convenient date and time.
- 31. Entire personnel files, including resumes, performance reviews and reasons for termination, from 1964 to present, for all radiation safety officers, health physicists (or equivalent) and all other staff employed at the Neely Nuclear Research' Center. .
Response: Georgia Tech ~ incorporates its General Objections as to timeframe as set forth above and will respond to this Request only as to documents which relate to 1985 or later. Documents otherwise responsive to this' request are available for review by GANE at a mutually convenient date and ; time.
- 32. Entire personnel file for Dr. Ratib A. Karam.
Response: Documents responsive to this request are attached. ;
- 33. All documents, logs, manifests and other bills of lading relating to the transport of hazardous and radioactive materials and wastes, including heavy water, to and from the Neely Nuclear Research Cenr3r from 1964 to the present.
1 Response: See Georgia Tech's response to Request no. 31 ! I above. Documents otherwise responsive to this request are l 3 available for review by GANE at a mutually convenient date and
- time.
- 34. Mission statement for the Neely Nuclear Research Center and/or Georgia Tech Research Reactor.
l Response: See Attachnent V to these responses. . 35. Detailed records cf all financial resources (income) for the Neely Nuclear Research Center, including but not i limited to, contracts, grants, endowments, State of Georgia j
, i i
a 4
i !
. . j i
~
appropriations, Federal appropriations,-Department of Energy, { Department of Defense, Georgia Environmental Protection Division, Savannah River Site,. Westinghouse, General Electric, Tennessee Valley Authority, Oak Ridge, Georgia Power Company,
' Duke Power Company, Coca Cola Company, and other universities ;
and colleges. Response: See Georgia Tech's response to Request no. 31 above. See also Attachment VI to these responses which shows total state appropriated funds and total sponsor support. For specific list of sponsors, see answer to Request nos. 45-48 l below.
]
- 36. All annual reports on Neely Nuclear Research Center.
1964 to present. Response: See Georgia Tech's response to Request no. 31 above. Georgia Tech will make documents otherwise responsive to this request available to GANE for review at a mutually convenient date and time.
- 37. All audit reports on Neely Nuclear Research Center relating to safety matters, management matters, or financial matters.
Response: See Georgia Tech's response to Request no. 31 above. Georgia Tech will make documents otherwise responsive to this request available to GANE for review at a mutually convenient date and time. 35 Records describing the steps necessary to decommission ! the Neely Nuclear Research Center, including responsible
7 entities, where'the radioactive material is planned to be shipped, containment systems to be used, shipping methods, and associated costs. Response: Georgia Tech objects to this request on grounds of relevancy. Georgia Tech further objects to this request on the ground that it calls for a legal conclusion. The information requested is a matter of statutory or regulatory law.
- 39. All correspondence of Georgia Tech to NRC responding to violations cited or noted in NRC Inspection Reports from 1980 to the present.
Response: See Georgia Tech's response to Request no. 31 above. Georgia Tech will make documents otherwise responsive i to this request available to GANE for review at a mutually l convenient date and time. I
- 40. Blueprints re design and construction of containment !
l building as provided the NRC on or about 10/22/93. ! Response: Georgia Tech will make documents responsive to this request available to GANE for review at a mutually convenient date and time.
- 41. All records relating to AGN-201 reactor and fuel elements.
Response: Georgia Tech will make documents responsive to this request available to GANE for review at a mutually convenient date and time.
- 42. Georgia. 'ech's response to NRC request for information 1
xw - . .
i l on sewer line condition dated 11/4/94. Response: Georgia Tech-will make documents responsive to , this request available to GANE for review at a mutually convenient date and time. ! 1 l
- 43. All documentation relating to the firing of Steve i
Millspaugh and Paul Sharpe in 2/88 beyond that included in the personnel files. Response: Georgia Tech will make documents responsive to this request available to GANE for review at a mutually convenient date and time.
- 44. All records of communication between Neely Research l Center and local fire authorities concerning arson or emergency l response to fire.
Response: This request relates purely or primarily to the security issue and no response is required of Georgia Tech to l this request.
- 45. All logs concerning the specific usage of the reactor. j Reaponse: A printout of the contracts will be provided.
Georgia Tech will make available to GANE any contracts it designates, assuming such contract is not classified.
- 46. All contracts relating to work done by the Neely Nuclear Research Center for any and all entities which required use of the reactor.
Response: See Georgia Tech's response to Request no. 31 above. Georgia Tech will make documents otherwise responsive i to this request available to GANE for review at a mutually i
.~ .
e 4 I
. i convenient date and time ~.
- 47. All contracts relating to work done by the Neely ,
r Nuclear Research Center for any and all entities which required [. use of the cobalt-60. , Response: Georgia Tech objects to this request on the ; grounds that the cobalt-60 is not at issue in this license renewal proceeding.
- 48. All contracts relating to work done by the Neel
, Nuclear Research Center for any and all entities which required ! use of the cesium-137. , L Response: Georgia Tech objects to this request on the f i grounds that the cesium-60 is not at issue in this license renewal proceeding. i t I l l l 1
. a .J
Permission to Enter and Inspect GANE requests permission from Georgia Tech to' enter'and inspect the Neely Nuclear Research Center's physical security system with an independent security consultant and an independent electrical engineer to inspect the alarm system, intrucien alarms and how they operate. Response: This request relates purely and primarily to the security issue and Georgia Tech is not required to permit a GANE representative and its security consultant access to the
' Georgia Tech facility.
Respectfully submitted, MICHAEL J. BOWERS 174567 Att ney General PAtMAN l 2
~
12 d ^ DE'NITIS R. DUNN ' 234098 Senior Assistant Attorney General (i i/ 15 & PATRICIA GUILDAY l/ 315113 Assistant Attorney General PLEASE ADDRESS ALL COMMUNICATIONS TO: 1 PATRICIA GUILDAY l Assistant Attorney General l Georgia Department of Law 40 Capitol Square, S.W. l l Atlanta, Georgia 30334-1300 l J t 4 I O
STATE OF GEORGIA COUNTY OF FULTON VERIFICATION Personally appeared before the undersigned attesting cfficer R.A. m 1M , who, after being first duly l cworn, deposes and states on oath that the facts set forth in the I within and foregoing are true and correct to the best of his , 1,,,~.,,adge and belief. kEl4 - R.A. Karam Director Neely Nuclear Research Center Georgia Institute of Technology Sworn to and subscribed . before me this _ M day of 476Wp/2w ,1995 l l
\
)
04w due 7kkmw NOTARY PUBLIC~ Mycongsgopjyfy?s: ud s,j,,.. Asva21, ten i
. .. . p-
. m. ~-
l 1 l
.i u
1 i i ATTACHMENT I (Interrogatory no. 13.) l i i i I t 4 e "m@
~ ~ ~ ~ ~ - ~ -
~~ GEORGIA INSTITUTE F' TECH'NO' LOG -- RADIOlSOTdPE S'OURCE INVEST RV ~ ~~ 18 Octobeh 1995 ~~ ~ - ~
~ ISO _ TOPE
_. - -_~ -.
~ ASSA D5TE 'PHY5_ FORM ~I CHEM FORMULA ~~ ~ [
~HL. l. DAYS)-- - - .- - -. _. . . -.
TOTAE CT. '.} ' AMOUNT USED' { ~ AMOUNT LEFT---_X.
- = ::- :----- ___-- __m==~~~^~-- -
~
-_ ' ^~ -- -
f ^ ~ ~ ^ ~ - ; f -- ___L - = - - ~ =:=-----. . . _ _ _ _7 AM-241 167284 05/30/80 LIQUID SA = 0.001/mi ~ PDT095~~~~ 7 - 0.095 9.28E-02
~ is241 l ~57284 1 12/22/66 5E^L5D ~ Density Gauge -~100 [- 100 9.57E+01
~hM-241' ~ i67284 11/01/7i-[ SEALED NA 100 I~~~~ 100 5.64EiO1
~
- M-241 157284 02116/82 SEELED Alh 0.000067 j 0.000067 i-~~5.~56E25 AM-241 167285 05/03R3 SEALED N/A ~
10 J 10 i 9.67E+00 Am-241 167170 07/31/73 SEALED L
}I 5AKIA~G SdifRUE *i T0001 i 0.0001 } 96is%5
~
i ~
~ m-241 157956~ 03/iS/94 SEhi_ED STDT436 5f-I^~~I'~ 0.001365 ] 0.001365 _ 1736E~03_
Am-241 157936 03/15/94 SEALED STD # 446-52-2A ! 0.001399 ! 0.001399 1.40E-03
~ Ba ~~i53 Ba-133 f 2628 2630
~i0l0_ii80 09/01/88 L_lQUID SEALED [I' (([ _N/A HCi.
0.1_ 0.001
]
~~
l 0.1 0.001 _ K54E42 5.03E-04
]Bs15~3 3832.5 11/15/93 lS_EALED l 0.0 1 0.001 8.80E-04 STD # 167-C16_i Ba-133 3832.5 11/15/93 l SEALED
! STD # 149-C17 60d1 : 0.001 8.80E-04
~ Bi2d7- 11000 07/50/73 '
~N/A ~ T 0.001 i 0.001 6.00E-04
, Bi-207 11000 07/30/73 N/A i 0.001 [- 1~ 0.001 6.00E-04 I ~ ~ AlA~
~
Bi-207 11000 07/30R3 l 0 001 } ! 07001 ~5.'005-04 Bi-207 I 11000 07 50/73 I } ~~ ~~NIA I 0.001 T-~ l OI001~
-~600E44 I - N/A-~~ 7 " ~
Bi-207~I 11000 07I50R3 0?OD1 ~i~ 0.001~ 7-~5.~00E'O4 ~ Bi-207 11000 07/30/73 ~~ I A/A 6 001I ~~ 0 001 6 00E-04~~ Bi-207 11000 07/30/73 ~l-~ N/A 0.001 I~~ 0.001 550E-04 C-14 2091450 ; 02/21/79 LIQUID l SODIUM CARB. ~ 0.2 T 0.2 2.00E-01
~~
C-14 2098400 02/28/79 LIQUID ~ f Sh = 0.0000iIml I 0500071 I 0.0607T 7.09 54 C-14 2091450 08/04/88 [ LIQUID STD l S/h i OT00006 7 ~ 0.06005~ ~ 57965-65 C-14 2091450 08/01/95 ISOLID I ~^ - -~~-~I~ b.'0D001617 T OI00001057 1.02535 C-14 2090000 08/17/70 ! SEALED N/A ! 0.00000343 1
~
0.00000343 3.42E-06 ~
~N/ -
~ ~ ~
C-14 2090000 09/17/70 l~000000345'~ 0000d6542 3I41E 06 _ C-14 _ 2090000 08/6dI81 l~ 1 ~ ' - ~ ' NIA i 0l000165 l 0.000161 1.61E-04 Cd-109 453 3 09/01/88_ [ SEALED ~
! N/A [ OLOO1 i 0.001 1.85E-05
_Cd-109_I Cd-109 464 464 11/15/93 11/15/93
~
jSEALED 7 ~ STD # 169-C58
- SEALED
~
f STD # 151-C4 I ___0.00_1 0.001 i _ []~l ! Of0d1 0.001 3.47534 3.47E-04 _ _CF-252__ i 10,04/82] SEALED _ T ~ ~ ~ ~ N) - ' ~T 1.07]{ __j 1T7 3.5IE32 968__l CF-252
~
968 12i15/82 iSEALED I N/A 5.36 l i 5.36 .1.86E-01
~~ ~ ~
~CF-252__ 968 1_12if5/8' 2__ N/A 5.36
. . g' _ _ _ T i
9g , SEALED g _5.36 1T86E-Oi 00 9T57EIO1
'CI -252T~~968' ~~~~*~~~
1.07-1~~
~
! 10.04/82 SEALED ~ ~~ T ~ N/A I" 1707 I~ 3.52E-02
_g
GEORGIA INSTITUTE OF TECHNOLOGY - RADIOlSOTOPE SOURCE INVENTORY [ CHEM FORMU_LAj } TOTAL hCT]{ USED 18 October,1995~}NADUNTi.
~ ~
ISOTOPE]iiL(DAYSCASSA lDATC[HYS FORM _ _ _ _ _ _ AMOUNT _ ]CT.T'ODAY . _ mci _m mci mci [_ _ . _ _1 l i L C_i.=_ - -. _ p_ __ _ _ _ , =
~CF-252 968 16158'i SEALED
~~
N/A ~~' ~5.36 I SW ~ 'i.86Eht-CF-252 968 12/15/82 SEALED N/A 5.36 , 5.36 1.86E-01 Cl-36 308000 01/30/70 N/A ~ T 0.000044~ ~t ~ 0.000044 7 4.31E-05
~~
Cl-36 308000 01/23/70 N/A ~^}~0.0000282 i ~~ 0.0000282 2.76E-05 Cl-36 308000 11/30/80 N/A 0.00002'33~! 0.0000233 [ 2.30E-05 ~~ Co-57 270 09/01/88- SEALED N/A 0.001 I ~~ ' ~ 6.00I 1.23E'-06
~ ~
Co-57 271 11/15/93 SEALED STD # 165-C16 0.001 1 d.'001 ~~ 163E 04~~ Co-57 271 11/15/93 SEALED STD # 161-C8 . 0.001 l OT 01- ~ ~ ' ~ ' 1.63E-04
~~COTO 1921 052654 ~ SEMED ~N/A ~~
I~ s200 l~ 5200 2 724E+01 CO-60 1921 08/15/55 SEALED Calibrator 7000 I~ 7000 3.51E+01 CO-60 1921 06/28/63 SEALED l ~ N/A 11800 ~ f 11800 1.67E+02 CO-60 1921 12/09/75 SEALED SAND} ! 0.057 ! 0.057 4.15E-03
~
_CM0 1898 1898 01/17/51 10/10/72 SEALED SEALED N/A N/A 1614660 5500_ )) 55dd ___ __1[40E+01] 7.48E+04 _CO-60 _ l _ . 1614660 _ ! Co-60 1921 06/28/73 SEALED N/A i 99450000__. _. 9945_0000 l 5.25E+06__ Co-60 1921 02/01/82 SEALED N/A i 73500000 , 73500000 1.20E+07 3'56937000-[
~ ~
Co-60 1921 07/11/86 SEALED NIA 7 356937000 l ~~ ~ 1.05E+08 Co-60 1921 07/15/86 SEALED N/A __2_92977000 f~ ~ ~ 29f977ddO__ 8.63E+07 ]- Co-60 1910 07/30/73 N/A i 0.001 , 0.001 5.25E-05 Co-60 1910 07/30/73 N/A ! 0.001 i 0.001 5.25E-05 Co-60 1910 07/30/73 i N/ 07001 I 0.001 sT25E-65 Co-60 Co-60 1910 1910 Oif/30/73 03/30/82 N/A N/A 0.001 0.001 [~ 1 0.001 0.001 5'.2sE-05 1.66E-04
}. '
Co-60 1921 09/01/88 l SEALED N/A l 0.001 ~~ O.001 3.90E-04 Co-60 1924 11/15/93 l SEALED STD # 169-C28 ~ ~~
'[ 0 7001 ~
} 0.001 I 7.75E-04 1924 11/15/93 jSE[ED sTD # 15@21-l [0 001 O! 1 [ 7.75E-04
_._.Co-60_ l_ CO-60 1921 12/09/75 ! SEALED (WAND) 0 057 : 0.057 l 4.15E-03
~~CSd37[ 10950 11/6435]SE^ LED [_ N/A _
1000_ ] 1000 } 5.00E+02 CS-137 10950 11/01/72 iSEALED i N/A . _ 250 _ _ ; 25_0 i, 1.47E+02 CS-137 ~ ~ 10957 09/26/88 [ SEALED l N/A _[_' O.00114 0.00114
~~
[ 9.68E-04
~~CS i37 l 10950 05/ii/88 IS'6 LID ~ ! CSCL 0.174 7 ~~ O'.174- ~~I ti6E41 06/01/88]_ ]_]_- N/A ))(
~
~[C{137- 109d0 0.00002]_] ]
1).00002 ]1.68E-05 {} 1.68E-0 N/A _ 0.00002 _ 0.00002 __Cs _137 . 1_0900 _ 10900 06/01/88 _ 4 _ l N/A _.Cs-137 j 06/01/88_ E i 0.00002 ! 1.68E-05 ,,__ _ 0.00002_ _.._ 1.68E-05 Cs-137 l 10900 06/01.88 ! i N/A i 0.00002 .
! 0.00002 l - ~ ~N/A Cs-137 ! 10900 06/01.88 I ' 6~00002 ~l'~~ 0.00002 l 1.68E-05
i l l I l . .. . I i
~ ~ ~ ~ ~ - ~ -~~~ ~ ~~
l GEORGIA INSTITUTE OF TECHNOLOGY - RADIOISOTOPE SOURCE INVENTORY 18 October,1995 l~ ~ -
~
~
ISOTOPE _ ' jilD S)]I SSAY 6 T5 PHYSWORM CHEM F6RMOi.A I ~ TOT L ACT.- AMOUNT t.iSED{AMO_UNT L' EFT' ECT TOD_A [] mci mci _ mci _ 4_ _ _ mci _
'~~
Cs-137 10900 06/01/88 ~} ~ ~~~ N/A 0.00002 0.00002 1.68E-05
~}~~-
~Csi37 16900 07I30/73 N/A OT001 0.001 5.97E-04 Cs-137_
Cs-137 10900 10950 09/30/72 07/31/73 SEALED L N/A NEN SK-1 Source Kit 0.00113 0.001 { 0.00113 0.001 6.61E-04 5.98E-04 Cs-137 11023 11/15/93 SEALED STD # 163-C3 0.001 0.001 9.56E-04 Cs-137 11023 11/15/93 7 SEALED STD # 159-C17 0.001 0.001 9.56E-04
~ C5 I31 10957 0526i88 S5 deb Nh 0.00114 F IfUO114 9.68E44 10950 05/11/88 CSCL 0.174 0.174 3 -137 SDi_i~D 1.46E31 2.28E-02 FE-55 978 02/08/90 N/A l 0.1 _ _ _
0.1 . FUEL NA 3/31/84 Fuel elements; 4656 gm initial - 4549 gm as of 4/6/93 (10 mci) #VALUE!
'^
H-3 4500 07/17/87 SEALED N/A 0.2 [~ 0.2 1.26E-01 H-3 } 4500 05/31/72 Neutron Generator 4000 4000 1.07E+03 H-3 i 4500 07/31/75 LIQUID SA = 0.04/mi 39 5.46 33.54 1.07E+01 H-3 l 4500 07/09/79 Ll6UID SA = 0.00383/mi 0.345 . 0.345 1.38E-01 H-3 l 4500 04/28/87 LIQUID 400 ml 100 I" 85 9 f.~5 SI685A01 H-3 4489 Of0i/88 LIQUID water /500 ml Batch 88' O.054 [~~ d.054 3.51E-02 H-3~ 4500 09/11/90 LIQOID Aih 50 !_ 500 3.75E{U2 H-3 4500 09/11/90 LIQUID N/A 250 { 250 1.87E+02 H-3 H-3 4490 4490 07/26/88 01/23/90 LIQUID STD GAS N/A Methane Gas 0.000114 0.2244 (_ 1 0.000114 0.2244 7.58E_-0_5 1.62E-01 H-3 4490 10/19/94 LIQUlD
~ ~
TAROL (EtiiaE)l) 0.' ~4 I-~ 0.04 3.78E-02 H-3 4490 10/19/94 LIQUID Tetra-Cocane (Hexanei* 0.04 0.04 3.785~-U5~ MFi)/U NA 06/15/88 N/A 0.1 0.1 #VALUE! MFP/U NA N/A 0.1 0.1 #VALUEl _06/1_5/88 . MIXED NA 07/05/88 SOLID _ N/A <1 j <1 #VALUE! NA 07/05/88 ISOLID N/A l <1 i <1 WALUEl MIXED { #VALUEl MIXED ' NA 07/05/88 jSOLID N/A { <1 ! <1
~MIXEb~ 04/0i/91 IS5'ALED NIA~ i 0.001471 I 0.001471 #DIV/0!
~ N/A #VALUE!
^
~ MIXED ' ~'~ ~ N/A 160iI94 55ALED l 0.0dI947
~ ~
l - [ N/A 10/0i/94 5E LED E -'N/A l--~0.001898 r l #VALUEl
]silXED]1_
_ MIXED _N/A 10/01/94 SEALED i N/A 0.00213 j #VALUEl MIXED l N/A i 10/01/94 N/A 0.002068 #VALUEl [~ SEALED I~~
. Mixed ! NA l 01I0i50 SEALED - ~~~ii#1152-St ~ T O.00001149 l 0.00001149 #VALUE!
Mixed I NA 01/0160 SEALED ~I ~Std #11281 0.0000148 l l 0.0000148 #VALUEl
-uised T NTA 1iT15/93 ,SEhl56 'I~ STD # 16'9-C26~-~~0 00i i ~ '~~ ~ ~~
~~I O 00f~ NALUE!
~
~~~uixed-~i N/A 11/15f93~~~ISEALEb T~ STD # iS9-C18 ~ 0.001~I 6 001 ! #VALUEl -
s
. -- , +
. .,.m _ , . . . , , , _ , . . . . . . .
. GEORGIA INSTITUTE OF TECHNOLOGY - RADIOISOTOPE SOURCE INVENTORY ! 18 October,1995 ! !
~lSOTOPE HL(D YS)l ASS ^Y DAT5 ' PHYS FORM ~ ' CHEM FORMULA ~ TOTAL' ACT. [ AMOUNT OSED I AMOUNT LEFT I 'ACT.TOD
______; , __ -_ n -- _ _ _j- _--~_________________.g_ ' __ _ t _-_ ____ - - - ~ . _ . _ _ _ _ ~ _____ ___- 4_ g_-. D~ ~
~d 898-[ l ~~T MC
~~ MIXED Nih~~ 50/0i/94 ~ISEALED~ ' - - ~ ~ ~N/A' l 0.00213'~ I' ~ ~ ' I ~ ~ ~~~ ~ ~ ~ ~ ~ !
-~~
#VALUE! ~~
l
~~ ~ ~
~MIXEDI-~ SIA ~10/
~d1I94 I5E LED N/A 0.002068 ~ ~ I~ ~ ~ [ ~#VALUE!~'~
Mn-54 303 09/01/88 SEALED N/A 0.001 ' ~ b ~~ ~ I 2.56E-06 l
]~~ ~ ~dIO01 ~~
I
~~
~~Mn-54~ ~313 51/15/93 SEALED - STD '# I69-C'14 ~ ~ I~ 0.01 - ~ ~ l 0.001 2.08E-04
-Mn-54 3i3 ii/I5/93 iSEALED STD # 155-C7 ~{ 0.001 I ~~ ~~0'0'01~ l 2'.08E'-04 Na-22 I 950 07I36f737 N/A I 0.001 7d0i- ~~ I 2.67E-06 Na-22 950 07/30/73 -
N/A ~i-~~ 0.001 l 0.001 i 2.67E-06 Na-22 250 09/01/88155NL D I Ni ~ ~~ [ 0. 01 i' ~ 0 001 l 7.22E-07
~
Na-22 949 11/15/93 [ SEALED STD # 165-C15 0 001 0i001 I 5596E 04 [~~ .001 Na-22 949 l 11/15/93 [ SEALED STD # 155-C8 ~ 0 . 0.001 ! 5.96E-04
~
NI-63 33580 [ 11/15/88 i- I N/A ~ ~~! 15
~~~ I ~
i i 15 l 142E+0 l~ - - I~ ~T
~
NI-63 l 33580- l 11/is88 S/ ~ T ~ 5 - 5 : 4.75E+00 NP-237 780000000 [ 02I26'i65I5EALED~
~
~~ N! ~ ~ ~ i~ ~~0.353~~ !~~~ 07553~~ ~~ I~~ ~3I53E-01-~
~ P5505 10956060dOO 12/27/67- SOLID N/A ~~^ I'~ ~ 0.1 ~ f ~ ~
0.1 ~ i~ 10dE G'i~ ~ ~ Pb-205 10950000000 12/27/67 ISOLID ! N/A ; 0.00006 I ~~ ~05 000 ~~I 6.00E-05 I'
~
__Pb-210 7400 i 08/06/70 l'~~ ~ ~ N!A i 0.000051 , [~['{]dO0d55] 215E-05] Prn-147 950 i 09/21/81 l : ~ ~ ~ ~ N/A ; 0.000113
~
!___ ~
O000113 ; 2.65E-06
~~i62TO 158T576 ~
l 05I15/92-~l500D/SE LE0i ~ ~ T 0.0000189 ~ I ! 0.0000189~7 3.48E-08
~~P 52i 138 38~I i2/15/927 SEALED SOLID ~ ~~i 0l0000152 l ~ ~ ~I~ 60000iS2'N 8.18E-08 ~'~ P 5250-~i 15f [~~~UNidN Ws l5EkLED I NEN Sid-1 Source Kit [- ~~ 0.1 ~~~~I~ ~~~~~~~~ ~ ~~01~~ ~ ~# #VAEUE!
PU-2397~ 8962350 - i 01/25I71 I[i60lD N/A-~ ~ ~7 0.00114 i 0.00114 1.14E-03
~PU-239 I 890255b 89/28/62 iSEALED N/A i 5000 I - 5000 ~~~ ST00E+d5
~ PU-2397 8916800 02/26/65 ! SEALED . ~5gm t 306.85 - I 306.85 3.07E+02 PU-239 l 8800000 f 05/23/64 [ SEALED T-~7 54 gm ~~ I~ 462.2 ;
, 462.2 I 4.62E+02 P 5239'l 8800000 03/15/94 l SEALED Bonded Oxide i 6.0001054 l 0.6001054_ _[ 1.05E-04
~ l W D+E l
~
Sh , 04/01/63 i N/A : 0.00003 .
~
l 0.00003 i #VALUE!
'Ra 226' I 08/07/77 I'- ~~ ~ I ' N/A ~ ~ ~ ~ ~ ~ 10 ' ~ I ; 10 l 9.92E+00
~RA-2267 584-75U-{~ EiO/05d60 595300~~ ~~~ISEALED ' ~ I Casbration Source I -- ~ ~ 1 i
1 -~ I ~ 9.85E RA-226 585131 ~I 11/0f./71 ! SOLID I-~ Inside Gauge ~ I ~ ~ 0102~~!~~~ -~ i ~ ~ ~ ~ 0.02 ~~~ -1.98E 02
~ ~
RA-226 591300 l 04/0 /70 ; LIQUID ~~T ~' N/A ~I l0093
~
~ ~ ' ' ' ~ - ~
~~' ~~~
~I~~~0.0093 I 9.20E-03 RA-226N 2643307 09I1t;/89~~~~[P' WDER~~ ~ ~ l ~ ~ ~ NIA~ ~l-~ ' O.064 ~ ~ '
~^ ~ ~-
! ~ ~ ~ Of064-~ ~~
6.36E-02~
~RA-2267 591300- ~i 10/0!d60 : SEALED , Calibration Source i~ 1
~ ~ ~ ~
I 1 ~ ~ ! 9185E ' Ra-228 SB/BE ! L2098.75__ NA i 10/0*/64 i LIQUlO { _09/0!d65] SEALED._ _NA [~~~~N/4~ _i ' [ ~0f1 50000 i [d.1 ~~ 'i]2.64'E-03 ] 50000 #VALUEl_
1 ! t i l ~
~ ~ '
~GEORGl INSTITUTE OF TECWNOLOGY -- RADiOISOTdPE SOURCE lNVENTbRY~ ~~ ! 18 October,1995 I ~
~
iSOTUPE [~'HLlO YS) ~ E SSAY DATE ] PHYS FO__RM . I~ C. HEM FORMULA ,[ ' TOTAL ACT_ . ! AMOUNTUShD~~ _. MOONT L_ EFT * ' ^CT.'T6DdY_ __________ x _i___ r__ n - - - _ _ _x _ _ _ __ x'
- Tr '
g__;- ] ___________ -._______
~
SR-90 10111 05/21/69 t LIQUID SA = 0.0001/mi 0.001 I 0.001 5.16E-04
'~
~
~'
SR-90 10111 02/28U4 !LiOUID~~ ' SA = 0.0000mf ~~~ 0. 0124~ ~~ ~ ~~ - ' 0.00124 ~l ~ 7.2is-04~~~ SR-90 8800000 02/01/74 IllOU[lD____ _ { ~ - NI ~~ 0(d3 ~ I~ O!03 ' ~ ~3.00E-02~~ Sr-90 10402.5 05/15/92 } SOLID / SEALED. 0,0000135
~
0.0000135 1.24E-05 Sr-90 7 10100 07/29R0 N/A 0.0000045'l -- 0.0000045
~~
2.39E-06
~
Sr-90 10100 06/23/88 N/A 0.0000076 I 0.0d00076-~ ~ ~'6.32E Sr-90 10100 07/08/81 N/A___ _ [ 0.0000207 .[____ _ 0.0000207 _ . _1.45E-05_ Sr-90 10950 07/2990 } SEALED i NEN SK-1 Source Kit 0.000004144 1 0.000004144 2.31E-06 Sr-90 10402.5 05/15/92 _ SOLID / SEALED"~~ O.dOOO135 ~]. I~ 0.0000135 l __1.24E-05__
~ ] I]000000558
_TC-99 77400000 10/10/88_ SEALED _ _ _ _N/A .
~
i 0.00000558__l 5.58E-06 Tc-99 2200 06/24/81 N/A I 0.000041- 'i' ~~ 0.000041 -~ i 7.88E-06 TC-99 77400000 10/10/88 SEALED i N/A i 0.00000558 I^ 0.00000558 l 5.58E-06
~T5230 2560000 10/11I85 SEALED ~[~ '~ N/A ! 0.00000494 , [ #VALU5! I~~~#VALdEi--
I133E-05
~
TH-230 29200000 : 7/13/94 ISEA'L'ED ~ ~T- N/A ~l 0.0000133 . 0.0000133
#VALOEf E #\T LUEf-
^
~TH-230 I 2900000i 10ii1/88 ! SEALED [' ~~ ~ ~ N ~ ~[~ .00000494~I N 1.33E-05
~~
~TH-230 I~255~000d0 7/i3I94 'SENLED~ ~I ~ ~ N/A - [~ ~d.0000133~~ 0.0000133
] ]I-~ ___ N/A _ __ [ [ _0l001 [ {[
~
0.001 1)74E-05 _]TI-204 l_ 13_90 0_7/3U R 3 __ __ 1390 I N/A 0.001 1.74E-05 _Tb204__ } __ i_ ____0.001__ _ '! 07_/30R3_l TI-204 ! 1390 07/30R3 ! N/A l 0.001 1.74E-05 I ~ ~~ 0.001~
~TI-204 I 1390 07/30R3 i ~~I~ N/A 0.001 I ~~- {' 0.001 ; 1.74E-05 C~~
~
-TI-204 ! 1390 07/36/73 ~l N/ ~~ [ 0.001 01001
~
i~ 1.74E-05
]Tf204l 5390 07/30/73___ ___
N/A I~-~~0l005- 0.d0i'-~~~I 1.74E-05_ TI-204 1 1390 07/3063 i N/A [ 0I001 0.001 1 1.74E-05 I~
}
il204l 0.0 i 2.33E-05
~
1390 05/28/75 l ~~ N/A l 0.00i-~~ ( _i- ~
~
~ T5204~i 2.33E-05 13s l 02/28/f5T- - - - -
N/ - ~ ' ~ 0001 i~ -- ,! 0.001
--y i
7
- ~~
~~Ti204~! 1390 02/28I75 I~ ~ 0.001 0.001 i 2.33E-05 N/A ~ ~ '~ ~~~
~~~ T f204 ~ i i390~~~ i 02/2865~[~~ T '~ NIA ~ ~ '0.001~ l- 0.001 I~ ~2.33EM5~~
l ~2.33E%5-
~
T ~ 0001
~
~
TI-204 1390 f~ 02/28R5~I i N/A 0.001 ,
~d2}28R5~T~~~~~~! ~ ' ~N/A
~
~-TI-204 ~-~~1390~ l . 0.001 [ ~ ~ ~~ 0.001 [~ 2.33E-05~
~
' ~
~~TI-204~! ~i350 i~ 02/2865 l l N/A I~" ' ~ 0.001 ~ ~I 0.001 2.33E-05
~~~ - l-~ ~0I001-
~
~
I~~ 2.33E-05~~
~
TI-204 ! 13s0~ ~ Y 02/28H5 i~ ~ N/A l~ 0.001 i
~ ~ ~ ~ ~ "
~TL204 7 "~ ~1390~ l^07A1/73- ISEALED ~~ ~ i NEN SK-1 Source Kd I~ ~ ~~ 0.001 ' ~ I
- - - - - . - - - - - .O.by1' ~ ~ ' ~ I ~ 1.74 E-0 7 __
.--_.~_q.- --
I l . -- _ . _ - E _ ._ _ . L - ._ -.- . _ _ _ l_ __._____I__ L ._ _
' GEORGIA INSTITUTE OF TECHNOLOGY - RADIOtSOTOPE SOURCE INVENTORY
~~
18 October,1995 ~~ T5dTOPE ' ~5LTDK 5)~~55SKYDdTE 'PS 5~FDRM~ ~DHEM FDRMOLA TT6TAL CT.~{~_A M_OONT tiSED. AMdONfLEFT~ ACTTT DT - mci J mci mci mci
~ ~~
03tf6/id~ ~FUhriter; 5.6'mg
~
U-55 NA i TALiJ5i U-235 NA 04/27/70 Fission Counter; 5.0 mg "
#VALUEl
_U,-235 NA 02/18/65 Fis_sion Foil Chamber-75 mg #118883 G.T. #VKO51 _U-235_ . NA 07/08/67 s/n Counter; 0.075 gm _
#VALUEl U-235 2.5696E+11 1_0/2_3/63 17 env_ elopes @ 5 gm each ERR U-DEPL 1.6473E+12 06/08/88 SOLID METAL 200 200 2.00E+02 U-NAT 5.11E+12 - 07/05/88 SOLID URANYL ACE. 7 oz 7 oz #VALUEl Zn-65 245 09/01/88 SEALED i N/A 0.501 0.001 6.55-i)7 G
0 9
,8 A - _.J s 4 ak- , 4JJ p e 4 9
d b i P f a 1 ATTACHMENT II
- (Interrogatory no. 19.)
i
?
9 t e t P s 4 i I 4 8 4 k
*o _.o
o - - - l I l REVISED:03/02/95 NUCLEAR SAFEGUARDS COMMITTEE MEMBERS ADDRESS MAIL CODE PHONE NUMBERS NAME Em Cobb, (2) Georgia Power Company (205) 868-5161 : Chairman P.O. Box 1295 FAX # (205) 868-5124 Birmingham, AL 35201 (1) Mechanical Engineering 0405 894-3244, 4-2775 Dr. P.V. Desai Dr. Bernd Kahn (2) Mechnical Engineering 0405 894-3776 , Fax # 853-0232 Dr. T.G. Tornabene (3) Biology 0230 853-0322 Mr. Jackie Vickery (1) Police Department 0440 894-4588 Dr. B.R. Livesay (3) PSD/EML Baker 0800 894-3489 i Home# 664-8742 Dr. Peggy Girard (2) Biology 0230 894-3375 Dr. S.M. Ghiaasiaan (3) Mechanical Engineering 0405 894-3746 Dr. Robert Braga (3) Chemistry 0400 894-3031 j Mr. Len T. Gucwa (1) Westinghouse 429-4680 2825 Cobb International Blvd. Kennesaw, GA 30144 Mr. Steven C. Ewald (2) Georgia Power Company 526-7710 P.O. Box 4545 Atlanta, GA 30302 Mr. James O'Hara (2) 3393-P Peachtree Corners Circle 449-8067 Norcross, GA 30092
ATTACHMENT III (Interrogatory no. 24.) P l 1 I a .o
- + . - . . . , .. ,_ _ _ _ _ , _ _,____ _ _ _ _ _ _ _
i [ 7- , g 9 Q. Georgia Institute of Technology l l L- NEELY' NUCLEAR RESEARCH CENTER ] 4 900 ATLANTIC DRIVE ATLANTA, GEORGIA 30332-0425
-24, 1995 - usa (d 41894-38 I 1
- Mr. Thomas Hill, Manager-
- i. Radioactive Materials Program )
- Environmental Protection Division- ;
! Department of Natural Resources
- ~4244 International Parkway, Suite 114 l- Atlanta, GA 30354 Dear Mr. Hills
- This is to advise you that on March 23, 1995 an alarm at the 4 Neely Nuclear Research Center (NNRC) was actuated at NNRC and also
- .at the Georgia toch Police Department. The Georgia tech Police j l -notified me of this alarm at 2
- 30 A.M. I responded to the alarm l
, and arrived at NNRC at 3:04 A.M. I found the water level at the . ! pool to be about 18 inches below normal. Inspection revealed that ! three different valves which should have been closed were open. l These open valves were responsible for back drainage from the pool to the suspect waste tank. Total amount of water drained from the pool was about 1200 gallons. Total amount of water collected in the suspect waste tank was about 1200 gallons. { l The pool is 6 feet wide x 20 feet deep and 20 feet long. It l l is used to store 223,000 Ci Co. It is also used to store spent i i- fuel from the reactor. (Spent fuel has not been stored in the pool l j for more than 15 years.) i The pool water is circulated, from time to time, through a i resin bed to keep the water clean and free from algae growth. l During circulation, water is drawn from the bottom of the pool i through a pipe by a pump. This pipe has a hole in it 3-4 inches ! below the surface of the water. If the water level in the~ pool drops below the hole in the pipe, the pump will cavitate and the i circulation of the water will cease. It is not possible to pump I the pool to levels below the location of the hole in the pipe, i ! Return water to the pool during circulation is through another
; pipe located three feet below the top of the pool. It is possible j' that back flow through this pipe would take place if certain valves i are left open. On March 23, 1995 three valves were left open after
- circulation was stopped. This allowed water to back flow. The s
water level cannot possibly drop below 3' feet unless there is a i crack in the pool bottom.
; A water level sensor is located at the top of the pool. This i sensor actuates' an alarm at NNRC and also at the GT police when the i level drops.6 inches. This sensor has always been positioned to j actuate when the level drops six inches, not six feet. l
) ) Teles: 542507 GTRIOCAATL Far 404453-9325 (VerWy 404494-3600) __ AUnd @ @G WWc0Ta kwa remran . _ _ _ _ _ _ __ _ An Equal Educaten and Emptoyment opportunity instituten
l . . l Mr. Thomas Hill, Manager l Radioactive Materials Program April 24, 1995 Page 2 i The water that back flowed from the pool was collected almost 4n its entirety in the suspect-waste tank. There was a very small l! leak around the connection to the resin bed. The amount which leaked by this route was very small. This water goes to sump and is eventually pumped in the suspect-waste tank. No water at NNRC flows from any sink directly into the sewer system. All liquid effluents are collected in the suspect-waste tank. All liquids are analyzed for radioactive content before any discharge.
- The pool water is clean and contains no radioactivity above i
J detection limits. Should you have any questions, please let me know.
. Sincerely, ;
06 hb- _ R.A. Karam, Ph.D., Director
- Neely Nuclear Research Center e
i RAK/ccg / k s 4 1 1 1 4 i
/.;A. . . ,\ Georgia Institute of Technology j g g, '
j! NEELY NUCLEAR RESEARCH CENTER 900 ATLANTIC ORIVE ( L y-@
',, ' ' '"" ' [ ATLANTA, GEORGIA 30332-0425 USA (404)894 3600 March 23, 1995 i
MEMORANDUM TO: File FROM: R. A. Karam
SUBJECT:
Alarm at NNRC i At 2:30 A.M., I recieved a call at home from the GT Police l that the criticality alarm was actuated. I arrived at NNRC at 3:04 l A.M. , stopped at Emergency Command Center, got one Geirger counter i and one Dose Rate Meter. Also obtained one pocket ionization chamber for myself, my wife, and for GT Police officer. The Emergency Panel in EMC indicated that the pool level was low. Proceeded to investigate. The pool level was low abut 18 inches. 4 Investigated further and found two valves to the resin bed open and > water was leaking slightly at the hose connection to the bed. Called-Dixon Parker and Jerry Taylor. Mr. Parker inspected other valves and found the followings valves 303B, 312A and 333 were open. Closed valves. Started adding water. Alarm was reset. ; Time was 4:00 A.M. Thanked GT Police for their help. Read PICS. No one received any dose. i Faz 404 853-9325 (Ven'y 404 894 3600) Teles:542507 GTRIOCAATL An Eoual Education ana Empiovment Oroonunov ins:,:an A Und of the unneersitv Svstem et Gera .
GEORGIA TECH POLICE DEPARTMENT GA0601000 Incident Report on.e .. i 950831 seweesa Locavoiw u,cumanca,ase e H-03-234224 NEELY NUCLEAR PESEARCH CEffTER / 900 ATLANTIC DR / was suscvaar j coca utmoei osme esacwa _ - - -2 o. Criticality / intrusion alatin at reactor REAC'IOR s0 $0 l oaos s'me o.it mt==recas mare a=a tem asamuso g- g- e i Mut 23 95 02:26 Mut 22 95 03:39 Otsee EX CLENE C anneet g , ,% )
**"a"*'* **="*" O *=s O seawas"" O P='s w Om a**'a M O=
Om e n.=1_ _ e 6.e ves E'" MAR 23 $5 02:26 TAYIra era anot sun ass aos at en nam esv esam. at.eset.mmas V GA TEO! REAC'!OR eaan eamm, no. nsaasecs anomassaacoon aes m ewms onnensua o. I 900 Atlantic Drive AE.AlfrA, GA. 3C332 l
. m aa . = . - l i m m s.. .c
..-a u ,,-
Officer Pestle and myself responded to an alarm at the Reactor. Upon our arrival, we noticed a flashing red light at the front door. We notified dispatch and asked him to make contact with someone in charge of the building. Mr. Kamm was advised of the situation and he came to check the 0311, he discovered the alarm was activated due to a drop in the water leve 4 Approving officer: Lt. Bellville, John P., #6 l FAX TRAN8MITTAL Deae g 4 / c aofpeone / To: d4. @n% Peon ' Chief JackVIckery Co/ Dept. p,e 4 Georgia Tech Polce Peu e (- 93 A 5 Phone s (404) 894 4688 commener ,(/,b g,fg Pas e (404) 853 9327 Ve*f ^ S n1.YA i rMr (Aus s ArG rtR* _._ - e.... _ 45% SMITH 30 MAR 23 95 03 :39 . w -
%ub7 - ^ - =m araueJcA- s a m c a m ca m :sti ss. s2 a
t t j . . d 1 1 P W 1 i ( l. t 4 4
- 1 1
1 . 4 1 1 a, 4 ATTACHMENT IV i (Interrogatory no. 26) t d t u 3 4 4 l l t 1 1 I I e i s 1 I i 6 i i l D ., - -
/,, - .. ,,,t .
Georgia Institute of Technology
'f f NEELY NUCLEAR RESEAACH CENTER
, 4- y 900 ATLANT10 QAIVE ,
ATLANTA, GEORGIA 30332-0425 l
's,3 s . ,,,, O/ (404]894-3600 ;
February 15, 1988 j l MEMORANDUM TO: Dr. John Patrick Crecine, President FROM: R. A. Karam W ely Nuclear Research Center SUB3CT: Performance of Mr. Steve Millspaugh and Mr. Paul Sharpe Elements which contributed to the disn'ilssal of Mr. Millspaugh and Mr. Sharpe are as following:
- 1. Mr. Millspaugh was habitually late coming to work, often as late as 11:00 A.M. His normal entry was through the back gate. Our policy and practice is that a work day started at 8:00 A.M. and ended at 5:00 P.M., with an hour for lunch and two short breaks ,
t mornings and afternoon.
- 2. Mr. Millspaugh often used obscene vulgarity to ,
i graduate students and staff.
- 3. NRC assessment was that our health physics program is inadequate and based on technology that is 25 years old.
- 4. Mr. Millspaugh was argumentative, uncooperative and insensitive to the needs of others.
I
- 5. Mr. Sharpe registered for two courses in management without permission.
- 6. Mr. Sharpe comes in and out of the NNRC without informing' secretaries despite the existence of a policy requirin,g everyone to do so.
A vaw tw u=esar system of oppa An Eaust Educaten and Empse yment @portunny instituten <e- y
. . j l
Dr. John P. Crecine l Page 2 ; February 15, 1988 ; l 7 Both health physics technicians, Mr. Millspaugh and l Mr. Sharpe, often kept infractions of rules and : regulations in private logs. These infractions were ! rot brought to the attention of Georgia Tech , oft 2cials. This is contrary to Georgia. Tech's written t policy and a possible violation of the responsi- l bilities of radiation' workers described in the Code of i Federal Regulations 10 CFR 19.12. This failure to ! carry out the responsiblities of their position is ; considered dereliction of duty.
- 8. Both technicians refused to' accept the authority of ,
the President of Georgia Tech over matters relating to ; policy and organization. They answered to no one. t
- 9. Both technicians discharged their duties in an l unprofessional and highly irritating manner. l
- 10. Dr. Michael O' Bannon, a management psychologist at l Georgia Tech recommended that health physics function for the operation group be performed by new health physics individuals. He stated further that physical separation between the health physics group and the operation group is a good' idea.
a J 1 i i
- 1 i
e d y
February 16, 1988 i' i This letter concerns the unprofessional ~ activities of the s health physics staff at Georgia Tech Neely Nuclear Research Center. [ First of all' let me el arify that the amin player in the ; infortmtion that follows centers mainly around the conduct of Millspaugh with minor details of other health physics Steve i activity. My first encounter with the attitude they project ; occurred soon after I was hired and told to work with the nealth physics staff. Steve Millspaugh and the rest of the staff seemed to think that they were better than everyone else and i Steve in particular often expressed ill feelings about much of l the reactors personnel including Theragenics. On one such occasion, Theragenics was trying to accomplish some instrument calibrations and Steve was noted as saying that they were [
" Fuck-ups" and would probably not calibrate the instruments correctly. It was also added that he wouldn't help them because j one person was making more money than he was worth. When asked ,
I for assistance in the barn, both he and Paul Sharpe were " Busy" t yet they' both remained in the health physics office not doing ! anything of importance. .
~
l
{ Being 'new to the facility I paid no attention to.their .I J occasionally loose remarks and did not ' realize their actual upper level management until the-day the- i disrepset of 'the Technique during fall quarter. At editorial appeared in the time. most everyone was exuberant about the article Susan f this
* ]
Selman had written. Everyone was saying how they had put . the . l screws to'Dr. Karam when Susan revealed the cadmium spill in.the-containment building. Having served at a similar operation at ; Texas A & M, I was interested in knowing what had happened. .I was informed by the~ health physics group that the cadmium had- l j gotten loose in the form of fine powder which they told me the j best I can recall was no more than 100 mR/hr (not sure of actual l number quoted but I am positive that it was less than 100 mR). . When I inquired why all the fuss (since the research team I worked with at Texas A & M had similar incidents if not worse). ; Susan made it appear that Dr. Karam had no respect for safety. However, she did show he had proper judgment when she described l t a Cs-137 low activity sample that spilled in the hall of. the uncontrolled accesss area .that she said Dr. Karam reprimanded , t her for. Dr. Karam's position was to see to the welfare of the l l public and since the containment has an airlock clean it up and j report to proper heirarchy. Whereas the health physics could not see the harm of the Cs-137. Anyone could have walked l through that mess and gotten contaminated; even the general k public . , r Shortly thereafter.I spent less time with the health l
- t i
physics staff on my own accord, since their ' conduct and views provided an adverse work environment mentally. I felt I was more of a team when working for Dave Cox or Jerry Taylor. I also'was told that the health physics staff, in particular Steve J Millspaugh, referred to me as.the " Company Spy" which I thought was cute but only reinforced my view of their unprofessional
- attitude and paranoid ideas.
When I returned from Christmas break Dr. Karam had provided two other graduate students and I an office at the reactor site. l Desks had to be moved and one desk in particular had to be surveyed since it was in the control zone of the facility. l Knowing enough about safety I knew the desk would have to be j surveyed. When I entered the health physics office to obtain a G. M. counter I was greeted by profane name calling of not only myself but also Hwang Moon and Rajendra Nahrain. I paid no ettention to this at first but when I returned with an order from Dr. Karam to have Steve take some smears and count them Steve exploded and stated verbatim "If Dr. Karam wants fucking smears taken he can come in here and do them himself". I then had to figure out how to use the equipment and do the smears myself while Steve sat at his desk. Soon after everything seemed out of place. How can staff members call the press and NRC about what they term a safety related incident when they themselves care so little about safety. This quarter tha'h they were only concerned about safety
$$ ^ #
when it fit their plans and their main plan was to have Dr. Karam removed as director.. It wasn't until the news informed me that Steve and Paul were seeking a lawyers advice on a suit for illegal dismissal l that I confronted Dr. Karam with the facts, until February 12, 1988 only Dave Cox and a few of my graduate associates knew of these or any other grievances I had with the health physics staff. r w na
& ff 9 J
s 4 d 0 A .m
ATTACHMENT V (Request to Produce no. 34.) r o b 4 4 I I l I s l
1 ' l . * . j .. Stronger coupling between NNRC and academic units should 1
! o I be vigorously pursued, especially NE/HP programs.
4 l 4 D. MISSION STA'IEMENF J To contribute to the fulfillment of the scientific and technical nuclear needs of the State of Georgia and the
! country throught h
o the education of those who will pioneer the advancement i of. knowledge in the nuclear field and be future leaders; o the conduct of research of both a basic and applied i nature in nuclear engineering and health physics; o service to the profession, to the State of Georgia, to the country, and to the further development of nuclear applications for the benefit of mankind and the ,
- environment. Successful accomplishment of this mission will be necessary to insure the president's vision of l Georgia Tech as
- The Technological University of the 21st Century.
j E. VISION i
- o NNRC, through the BNCT program, will be the center where i
terminally sick people from all over the world will come
- for treatment and restoration to health and vigor. It is a simple goal with immense potential for impact on the lives of people.
- o NNRC will be the center where NE/HP students and faculty l
will perform much if not all of their graduate research.
- o NNRC's director is playing a major role in bringing many ,
! contracts (worth more than $3.3 million) to Georgia Tech ! and the Education, Research and Development Association i of Georgia Universities (ERDA). F. OBJECFIVES, STRATEGIES AND ACTION SIEPS l 1 Obiective #1: Design, construct and install the BNCT filter. j Strateav: Establish agreements with Neutron Technology
- and INEL on or before March 31, 1994, so that financing i for the neutron beam optimization through the installation of the filter may begin.
5 i
k r ATTACHMENT VI (Request to Produce no. 35) l l
page 1 GeorgiaInsstute of Technology
- Schedule of Nuclear Reador Center Expenditures . .
Covenn0 the FocalYeam 1985 thfough 1995 . State Sponsored Total Personal Travel Operahng Equipment Year Funds Funds Serv'cos Supplies & Expenses 1985 450,948.77 33,756.17 484,704.94 363,137.27 3,551.96 85,809.82 32,205.89 1986 542,156.78 58,712.01 000,868.79 460,049.50 3.053.84 111,803.99 25,961.46 180,430.56 336,859.35 517,280.91 448,650.77 2,815.44 54,684.38 11,139.32 1967 1988 330,882.28 271,2d6.41 602,148.69 483,782.17 465.11 115,299.95 2.621.46 435,967.00 193,126.69 629.093.78 568.547.75 2,534.89 53,306.74 4,644.40 - 1989 1990 399,285 00 233,979.34 633,264.43 555,682.62 1,163.26 68,500.60 7,917.95 538,180.01 137,070.52 675,251.03 557,647.16 1,881.81 112,705.06 3,017.00 1991 449,789.82 131,792.45 581,582.27 497,741.63 5,247.43 48,491.46 30,101.75 g 1992 448,014.25 206,348.72 654,362.97 587,224.90 4,645.06 61,282.14 21,210.07 1993 506,369.21 135,107.45 640,476.86 531,191.15 1,896.96 64,105.45 43,281.08 1994 494,699.59 176,928.04 671,627.63 561,745.10 1,495.31 65,406.74 42,980.48 1996 y[jz p k g, d e)t f f 7~O f f
- 0 W E W' S -
T
DOCKETED USNRC' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION % DEC -4 P2 :56 ATOMIC SAFETY AND LICENSING BOARD OFFICE 0F 5ECRETARY Before Administrative Judges: SERVICE DOCKET!gt Charles Bechhoefer, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam
)
In the Matter of )
)
GEORGIA INSTITUTE ) OF TECHNOLOGY ) Docket No. 50-160-Ren
) ASLBP NO. 95-704-01-Ren Atlanta, Georgia )
)
Georgia Tech Research ) Reactor )
)
Renewal of License No. R-97 ) GEORGIA INSTITUTE OF TECHNOLOGY'S CERTIFICATE OF SERVICE : I i I'do hereby certify that copies of the foregoing Georgia Institute of Technology's Responses to GANE's Discovery have l
.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 2 .n o
4 Administrative Judge Administrative Judge Jerry R. Kline Charles Bechhoefer, Chairman 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 i
). 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 2 Post Office Box 8574 U.S. Nuclear Regulatory Atlanta Georgia 30306 Commission Washington, D.C. 20555 Adjudicatory File (2) R.A. Karam Atomic Safety and Licensing Neely Nuclear Research Board Center Mail Stop: T-3 F23 Georgia Institute of U.S. Nuclear Regulatory Technology Commission 900 Atlantic Drive Washington, D.C. 20555 Atlanta, Georgia 30332-0425 i This /V day of 8 M , 1995. , ha A h n W PATRICIA GUILDAY U Assistant Attorney General i 4 m}}