ML20112B138

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Response to Applicant Request for Production of Documents & Interrogatories.Related Correspondence
ML20112B138
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 03/12/1985
From: Jay Dougherty
CONCERNED CITIZENS OF LOUISA COUNTY
To:
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
Shared Package
ML20112B132 List:
References
OLA-1, NUDOCS 8503190035
Download: ML20112B138 (16)


Text

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REtATED CORHESPONDDsX g CCLC, 3[yg  ;

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CO M FTEC USMC UNITED STATES OF AMERICA N Nl OI NUCLEAR REGULATORY COMMISSION FICr 0F SECRETAR,  ;

BEFORE THE ATOMIC SAFETY AND LICENS 191M SERVICf.

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In the Matter of ) ,  !

) Docket Nos. l' VIRGINIA ELECTRIC AND POWER CO. ) 50-338 OLA-1

) 50-339 OLA-1 (North Anna Power Station, )

Units 1 and 2) )

)

)  !

CONCERNED CITIZENS OF LOUISA COUNTY RESPONSE TO APPLICANT'S REQUEST  ;

FOR PRODUCTION OF DOCUMENTS AND INTERROGATORIES (

Interrogatory 1. Identify the person or persons whom CCLC l relies upon to substantiate in whole or in part CCL's positions with respect to Consolidated contention 1.

! Responses As of this date CCLC has reached an agreement with l

one expert witness - Dr. Marvin Resnikoff.

Interrogatory 2. Provide the addresses and educational and professional qualifications of each person identified in CCLC's response to Interrogatory 1. ,

Response Dr. Resnikof f's address is River Road, Columbia NJ 07832. He has ten year's experience in issues relating to the [

t l economics of and cafety risks associated with the transportation t of radioactive materials. A copy of his professional resume accompanies these responses.

See Enclosure A. 1 i

Interrogatory 3. Identify those persons listed in response to l Interrogatory 1 whom CCLC will or may call as a witness in this proceeding.

i Response Dr. Marvin Ronnikof f.

D50)

s Interrogatory 4. Provide a summary of the views, positions or proposed testimony of each person listed in response to Inter-rogatory 1.

Response The transportation of spent fuel entails environmental ribha, safety risks, and economic costs that are not even hinted at in the Environmental Impact Appraisal prepared by the NRC Staff in connection with this proceeding. In particular, a Surry-to-North Anna transshipment programs gives rise to a sig-nificant risk of incidents which would Icad to substantial per-sonal injury and environmental harm. Among these incidents are aabotage or diversion of a spent fuel cask, and transportation accidents.

VEPCO's and the NRC's apparont willingnosa to accept thono radiological and environmental riska cannot bo justified in light of the f act that it would be proforable, f rom ovory standpoint, including an economic one, to construct a dry cask storage facility at the Surry Station in lieu of shipping Surry opont fuoi to North Anna. The uno of dry storago casks at Surry would reduce the occupational radiation exposuren from the fuoi accomblica involved, and would similarly reduce the possibility of fuel handling, transportation, and other accidenta. In addition, relianco on dry otorago would produco a ahort-term oconomic naving of up to $50 million, including trannportation to, and final dinponal at, a goologic repository.

l

1 Interrogatory 5. Identify all documents and other material that CCLC intends to use during this proceeding to support Con-solidated Contention 1 and that CCLC may of fer. as an exhibit in this proceeding or refer to in connection with the examination in this proceeding of any witness.

Response

Resnikoff, M., The Next Nuclear G a,m, b l e , Transportation and storage of g clear waste, Council on Economic Priorities, 1983.

NRC, FinalMaterIafs Radioactive Environmental Statement

~by Afr~and on theIf77, Other Means, Ha_ n_sE~o (NUREG 6T70T~r t of Battelle Pacific Northwest Laboratories, 0?portunities to Increase the Productivity of Spent Puel Shipp:,nq Casks in tlie '

United States, 1980 (PNL-301T) ~

l NRC, Potential Crush Loading of Radioactive Material Packages in Highway, Rail, and Marine Acc @ nts,, 1980 (NUREG/CR-1588) ~

Oak Ridge National Laboratories, Cask Designers Guide, 1970 (ORNL-NSIC 68) l E.R. Johnson & Associates, A Preliminary Assessment of '

A l te r n a t ive M S to r age M e thod s~ f o r tTe~ s to r ag e77~ 'co ~ ~

m m e r c iaT .

Spent Nuclear Fuol, 1981 fDOE/ET/47Tf9-1) l i

R. E. Hoskins, Integrated Cask Storage Systems for Storage, i Transportation, and Disposal of Spent Nuclear ruel~,1984. ,

Westinghouse Electric Corp., Preliminary Cost Analysin of a Universal Package concept in the Spent Fuel Management System,

~~ ~

1984 (WTSD-TME-032)

NRC, Transportation of Radionucliden in Urban Environs, 1980 '

(NUREG-CR-0743) i i

P. Eggero, Sevare Rail and Truck Accidentn Toward a Definition  !

of nounding Environments for TransportatTon PacTages,

~ 1983  :

TNUREG/CR-3499) '

NRC, Reactor _ Safoty Study, 1975 (WASil-1400 )

Interrogatory 6. Identify each document upon which a person i

! listed in CCLC's responao to Interrogatory 1 may roly to substan- l tiato his or her viewn regarding Connotidated Contention 1.

Response Goo conponoo to Interrogatory 5.

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! l

o Interrogatory 7. Describe the accidents that could occur dur-ing the transportation of spent fuel casks f rom Surry to North Anna, the probability of each such accident and . the consequences CCLC would expect to result from each such accident.

Response: By definition, accidents cannot be predicted or quantified in advance. It can be said, however, that among the general types of accidents (each of which would result in loss of cask integrity and possibly significant releases of radioactive materials) that are mado possible by the proposed transshipment programs are accidents in which the cask being transported is struck by another object, such as another vehicle or a train; accidento in which the cask itself strikes another object, such an a bridge abutment or a road surface after a fall from a bridge; accidents involving high-tomparature and extended duration firos; accidents involving aabotago, diversion, or attempted diversion; accidento involving human errorsand combinations of the above.

The probabilition of those accidents is uncertain. To ontablich the probabilition of the first throo categocios listed above, CCLC will rely on data obtained from the Virginia !!ighway Department or the fodoral Bureau of Motor Carrior Safety, proba-bilition nanociated with the other categorion are diacusand below in connection with Intorrogatorien 9 and 13.

estimating the connoquencon of apont fuel transportation accidents involvon a high degroo of uncertainty due to the largo numbor of var tablon that como into play, auch an number of annom-blion involvod, ovocall cladding intogrity, longth of cooling l

l

time since removal f rom core, severity of cask and/or assembly damage, atmospheric conditions (particularly wind and precipita-tion), population density and environmental sensitivity of sur-roundings, and type of emergency response.

CCLC has yet to calculate the probable consequences asso-ciated with an accident involving one of VEPCO's proposed ship-ments. In the past, however, Dr. Resnikof f has estimated the probable consequences of a similar accident occurring in a rural area. See The Next Nuclear Gamble, cited in tosponse to Inter-rogatory 5, at chapter VI, particularly pp. 268-278. As this analysis shows, exposed individuals would probably receive inhal-ation as well as ingestion doses many times the current stan-dards. In addition, f armland within a 1.4-square mile area would be soverely contaminated.

Interrogatory 8. Describe the basis for and any data or anal-yses that tend to support CCLC's responses to Interrogatory 7.

Response: See The Next Nuclear Gamble, chapter VI, and author-ities cited thoroin.

Interrogatory 9. Describe the forms of sabotago that could result in accidents occurring during the transportation of spent fuel casks from Surry to North Anna, the probability of each such form of sabotage and the consequences CCLC would expect to result from each such form of sabotago.

Response CCLC has not calculated the probability of possible forms of sabotago. In Dr. Ronnikof f's view, however, commonly-available industrial explosivou, such as thoso used for drilling aids and oconnographic cablo cuttors, would easily ponotrato most transportation casks. Such explosive devicos aru conical-shaped,

i weigh less than one kilogram, and can penetrate 355 mm of steel [

i with a hole diameter of 45 mm.  !

Presumably, the consequences of such an incident would be comparable to other transportation accidents involving breach of cask containment.

Interrogatory 10. Describe the basis for and any data or anal-yses, that tend to support CCLC's responses to Interrogatory 9.

Response See R.T. Barbour, Pyrotechnics M Industry, 1981 -

(McGraw !!ill), p, 47.

Interrogatory 11. Describe, for each form of sabotage listed in response to Interrogatory 9, what would be required of the sabo-

  • teurs in terms of planning, equipment, personnel skills, staffing and execution.

Response CCLC has not studied t'his issue.

Interrogatory 12. Describe the ways in which, and the extent to .

' which, compliance with 10 C.F.R. S 73.37 would be inadequato to prevent a successful sabotage effort.

Responses Seo response to Interrogatory 11. Compliance with  ;

regulatory requiroments does not assure safety; the risk of sabotage can never be reduced to a negligible lovel because of the consequences of such an incident.

Interrogatory 13. Describo procinoly the respects in which human error by Applicant's employees in preparing casks for shipment could result in accidents occurring during the transpor-tation of spent Cuol casks f rom tho Surry Station to the North Anna Station, tno probability of each such error and the con-l sequences CCLC would expect to resuit from each such arror.

i

i i

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Responses Accidents caused by human error can never be described  !

l or evaluated, with precision, before they happen. VEPCO's pro- {

t l posed transshipment programs creates a risk of the following l l kinds of accidents caused by human error l - Failure to adequately inspect the shipping cask and/or trans-l port vehicle. A similar failure led to the uncoupling of a truck I cab and its trailer, on which was mounted a spent fuel cask, on i

the Indiana Turnpike in September of 1983.  ;

r t

j - Failure to properly seal and prepare the cask after loading it with spent f uel. A cimilar incident was reported to the NRC by Duke Power Company on December 1,1981. l t

- Transport vehicle /oscort vehicle driver negligence. Such neg- [

l 119ence led to an accident involving a shipment of fuel to North  !

Anna on June 28, 1984.

- Failuro to proporly secure the cask tie-downs, impact limiters,  !

I overpacks, or other shipping paraphernalia.  !

5 l

l Interrogatory 14. Describe the basis for and any data or anal- t yses that tend to support CCLC's responses to Interrogatory 13.

I Responses CCLC has, a'nd will make available to VEPCO, copies of t

news articles regarding the accidents identified above. Also l

availaolo is a lottor f rom Wm. O. Parker, J r., Duke PoWor Co, to ,

1 John Davis, llRC, concerning the improperly sealed cask describud -

above.

l Intorrogatory 15. Indicato the wayn in which, and the extant to which, compliance with Applicant's proceduron governing the load-ing, unloading and handling of spent fuol easkn would be inad-oquate to provent tho orrors doseribed in CCLC'a responso to  :

Interrogatory 13.

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  • Response: Spent fuel handling procedures do not prevent accidents [

if they are not complied with. CCLC contends that accidents, f like the accidents identified in response to Interrogatory 13,  !

may occur because of failure to follow prescribed procedures.

I Interrogatory 16. Indicate whether there are any unresolved l conflicts over proceeding and,theif there use ofare available any, listresaurces them. involved in this t f

Response: The resource commitments that are implicated by the proposed transshipment program include the hecith risks and envi-ronmental risks that it poses. Hundreds and perhaps thousands of ;

people, and thousands of acres of farmland are threatened by the selection of the transshipment alternative over the dry cask '

storage alternative.

Furtner, the selection by VEPCO and the NRC of the trans- r shipment alternative represents a choice between two fundamen-tally different approaches to the problems of managing the nation's nucioar wasto. Dry cask storage in now accepted as the I soundest means of opent fuel management because it la safer, more t economical, and it will f acilitato the uno and management of a geologic nucioar wanto repository if and when one is constructed.

On the other hand, the attornative of shipping Surry upont fuel  !

to North Anna will ontail higher economic costa and will reduce the available storago capacity at North Anna. Thus, dry cank [

l storage reprononto a commitment of now resources (money, toch-(

nology, and land) to this promiaing method of reducing the onvi-  !

ronmental hazarda of nuclear wanto atorage. The alternativo of L

l

1 1

t transshipment and pool storage represents simply a waste of resources (the existing storage capacity at North Anna). t VEPCO is the first private utility in the nation to seek a license amendment authorizing dry cask storage, and the NRC Staf f's treatment of that application, in the context of this proceeding, will have a substantial ef fect on the storage method that is chosen for the 500 spent fuel assemblies that are at  ;

i issue in this proceeding, as well as other spent fuel stocks  ;

around the nation.  !

Interrogatory 17.

Specify .why dry cask atorage at Surry is the

" safest" method for spent fuel disposal.  !

Response

Dry cask storage at Surry is safer than transshipment l

to and pool storage at North Anna because there is virtually no I accident that can befall a dry storage cask that poses a signif-i icant health or environmental risk. There is no form of electri-  !

cal failure, mechanical failure, or human error which could i i

forseeably lead to offsite radioactive releases.

Transshipment to North Anna, on the other hand, is attended i

by numerous risks, such as sabotage, human error, materials fail-utes, etc.

Moreover, transferring the shipped fuel to the North i Anna pool (and oventually transferring it back out again) in- l i

volves a riak of fuel handling accidents and will necessarily entail unnecessary occupational exposures. There is a large e i

l number of forseeable incidents at North Anna or its spent fuel pool that would damage the Surry opont f uel and cause of fsito  ;

I releasos. Among thono aro pump failuro, chillor failure, fuel or -

l

{ cask handling accidents, and LOCA.

.t

Interrogatory 18. Specify the basis for CCLC's contention that dry cask storage can be "ef fected in a timely manner."

Response: There are several commercially-avail able casks that are adequate for both shipping and storage of spent fuel. While the NRC Staf f has yet to certify such casks, such certification is said to be expected this year.

Interrogatory 19. Indicate the basis for CCLC's contention that dry cask storage is " feasible."

Responses Many of the documents referenced in response to Inter-rogatory #5, e .g . , Resnikoff, Johnson, Hoskins, and Westinghouse, conclude that dry cask storage is not only feasible, but the most advantageous form of opent fuel storage yet developed. This method had receivrd substantial testing in West Germany and by the Tennessee Valley Authority.

Interrogatory 20. Identif y the documents named in CCLC's re-sponses to Interrogatories 5 and 6 by author, title, date of publication and publisher if the reference is published: if the reference is not published, identify the document by the author, title, date it was written and qualifications of the author relevant to this proceeding, and indicate where a copy of the document may be obtained.

Response CCLC's response to Interrogatory 5 contains all avail-able information regarding these documents. If VEPCO cannot obtain a copy of any of these documents, CCLC will be pleased to provido a copy at $0.10 per page.

Inter rogatory 21. Indicato, whether the Staf f han erroneously concluded in its Safety Evaluation Report that the probability of a nabotago ovent la comoto and that attempted nabotage, if nuc-cosaful,'would not produce serious radiological connequences. If the ronponse in "yes," state the basis for CCLC'n response.

Responset Yes. CCLC's position regarding sabotage is set out in ,

its responses to Interrogatories 9, 10, and 11.

Interrogatory 22.

Indicate in what significant ways Applicant's proposal is different from the proposal in the Duke transshipment case where the Commission held that the transportation by truck of 300 spent . fuel assemblies over a 170 mile distance neither presented a substantial national resources commitment question nor significant environmental impacts (14 NRC at -322), i

Response

In the Oconee-to-McGuire case the Commission ruled that the record did not show that the proposed license amendment presented significant environmental impacts. CCLC intends to prove this on the record. Moreover, dry cask storage was not held out in that case as a viable alternative to transshipment. l Respectfully submitted, 82f8t Dated this Mh day )

MifyW' k .3 Ja,mes Tri Doughergyf Counsel for Concerned C1,tizens of Louisa County e

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l MARVIN RESNIK0FF River Road -

Columbia, N.J. 07832 201/841-9529 PERSONAL: Date of birth, June 5, 1938; single; height 5'7"; weight 145 lbs.

EDUCATION: PhD, Physics, U of Michigan, Ann Arbor, Michigan, 5/65 M.S., Physics, U of Michigan, Ann Arbor, Michigan, 2/61 B. A. , Phys / Math, U of Michigan, Ann Arbor, Michigan, 6/59 POSITIONS:

5/83- Co-Director, staff scientist, Sierra Club Radioactive Waste 12/78-6/81 Campaign, Buffalo and New York, NY 6/81-5/83 Project Director, Transportation and Storage of Nuclear Waste, Council on Economic Priorities, New York, NY 9/74-6/81 Part-time lecturer, Rachel Carson College, State University of New York at Buffalo, Buffalo, NY r

8/77-11/78 Project Director, Environmental Protection Agency grant for research on the economics of uranium, plutonium recycle, Rachel Carson College, State University of New York at Buffalo '

9/75-6/77 Staff scientist, New York Public Interest Research Group, State University of New York at Buffalo  !

2/73-1/74 Fulbright lecturer at Universidad de Chile, Santiago, Chile (terminated 10/73 by military coup) 2/67-1/73 Assistant Professor of Physics, State University of New York at Buffalo ,

Summer 68/59 Director, Neighborhood Science Centers, Board of Education, City of Buffalo; New York Research Foundation Fellowship; Invited lect-urer, Summer Theoretical Physics Institute, Boulder, Colorado,'68 i 9/65-8/67 Research Associate, Department of Physics, University of Maryland s Summer 65 National Science Foundation participant, Latin-American School of Physics, Mexico City -

8/6?-5/65 Research Assistant, Department of Physics, University of Michigan i

ACN EMIC GRANTS:

National Science Foundation grant for Research in Elementary Particle Physics, with M. Ram, 6/69 6/71, 534,500. Renewed from t 6/71-1/73 for an additional $20,000; Environmental Protection Agency grant for research on the economics of uranium, plutonium recycle

O MARVIN RESNIK0FF Page 2 CONSULTANTSHIPS:

1975 New York Attorney General, to prepare testimony on hazard af shipping plutonium from Kennedy International Airport 1978 Illinois Attorney General, to review application by General Clectric to expand Morris, Illinois spent fuel pool 1979 Illinois Attorney General, to prepare testimony on hazard of re-racking spent fuel pool at Zion 1 and 2 nuclear reactors 9/78-4/79 State of Lower Saxony, West Germany, to review plans of West German nuclear industry to reprocess nuclear fuel, solidify and dispose of high-level waste, and decommission facilities at Gorleben 9/82- Town of Wayne, N.J., to advise on cleanup of thorium waste dump 5/83- Southwest Research and Information Center, Albuquerque, N.M., to prepare testimony on transportation impacts of WIPP f acility for federal court case 1/84- Town and Country Planning Association, London, England, to prepare Proof of Evidence for the Sizewell "B" Public Inquiry on transpor-tation of irradiated nuclear fuel through London TESTIMONY / COMMENTS / POPULAR ARTICLES (post 1974):

1974-1978 Comments on all draft EIS and proposed criteria and regulations by Federal agencies related to reprocessing and waste management on behalf of Sierra Club (e.g " Comments on Generic Environmental Statement on Mixed Oxide Fuels," Oct.1974; " Comments on WASH-1535, LMFBR Program," Joint NRDC-Sierra Club Comnents, April 1975; "On the Report by the Interagency Review Group on Nuclear Waste Management," Nov.1978; "On Criteria for Radioactive Waste, EPA,"

1979) 1975 " Occupational exposures at the West Valley nuclear fuel reprocessing plant," American Public Health Association paper 1975 testimony, US District Court, Southern District of New York, New York Attorney General, on the hazard of shipping plutonium from Kennedy International Airport 1975 testimony before the State Siting Board, Sterling Nuclear Plant on the cost of nuclear fuel and waste disposal, on behalf of Ecology Action of Oswego, NY 1976 invited paper, American Nuclear Society meetirg, Toronto, Ontario,

" Dispersion of plutonium due to an air transport accident" 1977 testimony, hearings on plutonium recycle, NRC docket no. RM-50-5, on U.S. commercial reprocessing experience, on behalf of the Sierra Club, 172 pages

.O l

MARVIN RESNIK0FF Page 3 1978 testimony, hearings on environmental impact of waste management, NRC docket no. RM-50-3, on radiation releases from commercial reprocessing operations, on behalf of the Sierra Club 1978 testimony before the State Siting Board, Jamesport Nuclear Reactor, on the status of radioactive waste disposal, on behalf of the Oil Heating Institute of Long Island n

1979 testimony, hearings on reracking the Zion nuclear reactors spent fuel pool, NRC docket nos. 50-295, 50-304, on the possibility and consequences of spent fuel pool boiling, on behalf of the Illinois 4

Attorney General

" Expensive Enrichment," Environment, July /Aug 1975, pp.28 (on the economics of uranium and plutonium recycle)

"The Cost of Turning It Off," Environment, Dec 1976, pp.17 (on decommissioning nuclear reactors)

" Nuclear Waste: Myths and Realities," Sierra Club Bulletin, San Francisco, July /Aug 1980 "57th Street and Broadway: Hiroshima," Op-Ed piece, The New York Times, Feb 1982 "No One's Ready for a Nuclear Spill," Op-Ed piece, USA Today,i August 18, 1983 "When Does Consultation Become Co-Optation? When Does Information Become

. Propaganda? An Environmental Perspective," in The Politics of Nuclear Waste, edited by William Colglazier, Pergamon Press,1 Mil -

The Next Nuclear Gamble, Transportation and Storage of Nuclear Waste, Council on Economic Priorities, New York, March 1983 -

" Shipping Flasks in Severe Rail Accidents," in UTIF Conference Proceedings, Macmillans, London, Dec 1983 Y

" Review of Nuclear, Inc.," Sierra Club Bulletin, San Francisco, Nov/Dec 1983 1984 Proof of Evidence, Sizewell "B" Public Inquiry, The Maltings, Snape, England, on the transportation of irradiated fuel through London, England, on behalf of the Town and Country Planning Association, 65 pages In collaboration with M. Hamilton, the following in-depth popular articles, called fact sheets, of the Sierra Club Radioactive Waste Campaign:

Feb 1984 "' Low-Level' Nuclear Waste: Options for Storage," on alternatives for storing nuclear waste, 8 pages Nov 1980 " Shipping Casks: Are They Safe?", on the safety of irradiated nuclear fuel shipping containers, 8 pages Sept 1979 "On the Job at NFS," on occupational hazards in commercial nuclear fuel reprocessing, 6 pages

A

-l MARVIN RESNIK0FF

[ Page 4 April 1979 " Salt Will Not Work," on problems of disposing of high level waste in a salt geologic medium, 4 pages In collaboration with Lisa Finaldi, the following fact sheet of the Sierra Club Radioactive Waste Campaign:

Dec 1985 "A ' Low-Level' Nuclear Waste Primer," background information on

" low-level" nuclear waste, 8 pages COURSES TAUGHT AT SUNY/ BUFFALO:

67-68 Phys 501-2 Introduction to Mathematical Physics Phys 521R Advanced Topics in Elementary Particle Physics 68-69 Phys 501-2 Introduction to Mathematical Physics College A Non-Authoritarian Community Schools 69-70 Phys 107R General Physics' Phys 608 High Energy Physics College F Consciousness and Society 69-71 EPIS Remedial Math Courses 70-71 Phys 307-8 Mechanics 71-72 Phys 103 Physics for Poets Phys 307-8 Mechanics 72-73 Phys 103 Physics for Poets 74-77 RCC 404 Environmental Action

'75-76 RCC 254 Electric Utilities and the Consumer 77-78 RCC 180 Energy, Employment and the Environment 78-81 RCC 130 Energy for the Future SCIENTIFIC PUBLICATIONS:

"The General Coupling Coefficients for the Group SU(3)", J. iiath Phys.8, d3 (1967). -

"The Recoupling Coefficients for the Group SU(3)", J. Math. Phys.8_, 79 (1967).

"A Few Comments on the Representations of SU(3)", Rev. Mexicana de Fisica 15, 255 (1966). -

"A Useful Relation Among Casimir Operators", Phys. Letters 19, 596 (1966).

" Mass Formulas for the 405 Multiplet of SU(6)", with RR Silbar, Phys. Rev.148, 1341 (1966).

s

!%RVIN RESNIK0FF Page 5 s

"Are the Positive Parity fiesons in the 405 iiultiplet?", with RR Silbar, Phys.

Rev. 149, 1245 (1966).

"The U(n):) R(n) Problem. I.", aucl. Phys. 83, 632 (1966).

" Matrix Products and the Explicit 3,6,9,12-j Ccefficients of the Re sentaticns of SU(n)", with I. Kaplan, J. tiath. Phys. 8, 2194 (1967) gular Repre-

"A General Class of SU(3) Recoupling Coefficients", U of Maryland Technical Report No. 676, May 1967. Not for publication.

"The Symmetric Quark Mcdel of Baryon Resonances", with 0.W. Greenberg, Phys.

Rev.163,1844 (1967).

"Analyticity Requirement for Regge Poles and Backward Unequal-Hass Scattering",

with Y.S. Kim, Phys. Rev. 169, 1288 (1968).

" Applications July, of the Poincare Group", U of Maryland Technical Report No. 706, 1967. Review talk presented at Faculty Seminar.

"un the Representation Theory of the Inhomogeneous Lorentz Group as a Foundat-ion of Quantum-Mechanical Kinematics", by Hans Joos, Fortschritte der Physik 10,65-146(1962). Translated and circulated as an unpublished monograph. -

"The Represcntations of U(4)m V(2) O U(2), with M. Brunet, J. Math. Phys.11, 1474(1970). -

" Branching Rules for U(n)oS0(n)", with M. Brunet, J. liath. Phys. --11, 1471 Ms70).

"The Representations of U(4)3 U(2) O U(2) and the Nuclear Quasi-Spin Model".

Talk presented at the Summer Theoretical Physics Institute, U of Colorado, Boulder, Colorado. Published in the Proceedings, Vol.XID, Mathematical Physics (Gordon & Breach Science Publishers, Inc.)(1970).

"Jegeneracy of the SU(3) Direct Product and the Symmetric Representations of SU(6)o SU(3) @ SU(2)", J. Math. Phys. 11, 1885 (1970).

"The Representations of U(n)oSO(n)", SUNY/ Buffalo preprint, May 1969, with M. Brunet, J. Math. Phys.12_, (1971).

" Extension of the Mass Operator in the Symmetric Quark Model for Negative Parity Baryon Resonances", SUNY/ Buffalo preprint, June,1970, Phys. Rev. (1971).

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