SRS Sign (copy)

The entrance to the Savannah River Site, a federal nuclear complex near Aiken.

The management and operations contractor at the Savannah River Site is battling back a negligence lawsuit levied by an Augusta man.

Savannah River Nuclear Solutions, in a Nov. 28 filing, asked a district court to dismiss the negligence suit after having responded to all the allegations made. SRNS also is seeking any other relief the court deems appropriate, according to court documents.

SRNS's response came less than a month after a complaint was first filed by Henry Bradley, the Augusta man who has worked for Savannah River Remediation.

SRR — an AECOM-led team with partners Bechtel National, BWXT and CH2M — is the liquid waste contractor at the Site. SRNS's parent companies are Fluor, Honeywell International and Newport News Nuclear.

In his original complaint, Bradley blamed SRNS oversight for his debilitating, permanent injuries.

Roughly two years ago, according to the complaint, Bradley was working in a trailer with a rotted and hole-ridden floor. While securing something, Bradley fell through the floor and seriously injured his spine, groin and right shoulder, according to the same information.

Bradley alleges SRNS was responsible for maintaining the trailer and furthermore should not have given the trailer to SRR for extended use given its unsafe condition.

In its response, SRNS admits it owned the trailer but denies certain related details.

"Defendant denies the allegations of paragraph 14 of plaintiff's complaint as stated," the SRNS filing reads. The contractor later argues it depended on SRR and its employees to alert it to any deficiencies or issues. That never happened, according to the management and operations contractor.

SRNS also argues Bradley — as a "a DOT licensed commercial driver" at the Site, according to court documents — should have identified the trailer's poor state in pre- and post-use inspections.

Any injury or damage Bradley suffered is "principally" caused by his own negligence, SRNS argues in the Nov. 28 filing.

"Plaintiff knew about the risk, and voluntarily undertook the risk that led to the accident or injuries complained of in this case," the filing later reads.

Bradley, in his complaint, requested at least $75,000 for damages, a reimbursement of legal fees and a trial by jury. 

Bradley has received workers' compensation from SRR. He settled his compensation claim on June 27, 2017, according to a response to questions filed with the court. His medical expenses have surpassed $66,000, according to his complaint.

Neither the original filing nor SRNS's response pinpoint Bradley's exact job; they do not say if Bradley still works for SRR, either.

Colin Demarest is the government and Savannah River Site reporter with the Aiken Standard. Follow him on Twitter: @demarest_colin