ML20154A857
| ML20154A857 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 09/29/1998 |
| From: | Schen D UTAH, STATE OF |
| To: | |
| Shared Package | |
| ML20154A856 | List: |
| References | |
| 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9810050026 | |
| Download: ML20154A857 (9) | |
Text
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o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of:
Docket No. 72-22-ISFSI PRIVATE FUEL STORAGE, LLC ASLBP No. 97-732-02-ISFSI (Independent Spent Fuel Storage Installation)
STATE OF UTAH
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COUNTY OF SALT LAKE
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AFFIDAVIT OF DAVID C. SCHEN l
I, DAVID C. SCHEN, being first duly sworn upon oath, depose and state as follows:
1.
I am employed as Ecosystem Management Coordinator at the Division of Forestry, Fire, and State Lands, Utah Department of Natural Resources, and have worked within this Division since 1971.
2.
I earned a Bachelors of Science degree in Forestry in 1971, from l
Utah State University.
3.
I worked as Area Forester (1971-1979) in the Division's Bear River Area office, where I was responsible for the fire protection program; as 9010050026 980929 PDR ADOCK 07200022 C
1 the Division's Regional Manager (1979-1982) responsible for delive-ing fire protection services to three areas; and as Forest Stewardship Coordinator (1982-1995).
4.
As Ecosystem Management Coordinator (1995 to present), my j
duties have included ovenight of the fire management program and management of fire crews within the Division, which is responsible for fire protection services on 15 million acres of forest, range, and watershed lands within the State of Utah. I have taken part in numerous fire qualification and certification connes as part of my duties. In addition, since 1985 I have served on incident management teams which are used for fire suppression, and am qualified as operations section chief, responsible for directing fire suppression during particularincidents.
5.
As part of my duties, I have reviewed the License Amendment Application dated August 28,1998, submitted to the Nuclear Regulatory Commission by Private Fuel Storage, LLC, Applicant for an Independent Spent Fuel Storage Installation on the Skull Valley Goshute Reservation.
6.
The License Amendment Application describes a new transponation route along which the Applicant proposes to transpon spent 2
nuclear fuel by rail spur from the Union Pacific main rail line near Low, Utah to the Skull Valley Goshute Reservation. The spur is proposed to be constructed along the eastem edge of the Cedar Mountains for a distance of 26 miles.
7.
In my opinion, based upon my experience and taining, the License Amendment Application does not adequately address a number of fire hazard issues pertinent to this new transponation corridor (the Low rail corridor), because this area is prone to wildfires. There is a history of fires moving south to nonh through Skull Valley along the eastem side of the Cedar Mountains; such fires have been known to frequently cross over the Cedar Mountain from the west spreading into the westem pan of Skull Valley.
8.
The vegetation in Skull Valley is primarily desen shrub and 1
grass land. Fuels in this plant community dry in early June and ignite very easily. Vegetation includes native grasses, sage brush, Utah juniper, and introduced species such as June grass (cheat grass) and crested wheat grass. Due to frequent and recurring wild fire and a history of heavy grazing, the primary vegetation isJune grass.
9.
I am aware of only a few irrigated areas in Skull Valley, but they 3
are located nearby the ranches on the east side of the valley and close to the reservation. There are also some mudflats in the north end of the valley.
Neither of these two types of areas are sufficient to intermpt a wildfire occurdngin Skull Valley.
10.
The activity associated with the constmetion and maintenance of the rail spur, such a welding, grinding of rail and the presence of fuel for the operation of machinery will present potential fire hazanis.
11.
Additionally, fires can result in sparks caused by friction or from the train exhaust stack, or from a hot bnke shoe sheering off the locomotive or rail carriage wheels.
12.
The rail spur may result in an increase in the occurrence of human caused fires. Raillines typically have an acess zoad alongside to facilitate maintenance. In this case additional or improved points of accan to the west side of Skull Valley might be developed from the highway during construction of the railline. Since the Low Corridoris proposed to cross primarily public land, the improved access on the west side is likely ta result in more recreational use of the area, and thus, a greater potential for human caused fires.
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13.
Access to the west side of Skull Valley has always been poor for fire response vehides and penonnel. In this area responders typically use four-wheel drive vehides and drive cross country to fight wild land fires. Hand crews may also be used but generally, heavy equipment is not used because of the damage it may cause to the fragile ecosystem. The four-wheel drive vehides carry a water tank containing 200-300 gallons of water. The vehicles will have difficulty directly crossing the railline. Even if the rail spur is constructed close to existing grade, fire fighting vehides will be unable to climb up the venical profile of the grade and rail, especially given the gross weight of the vehide and water tank and also because the vehide will be unable to get any traction from the ballasted rail bed.
14.
Responden to fires will be put at increased risk because of the potential for collisions with trains in the dense smoke of a range fire.
15.
In my opinion, if fire fighten were aware that high level nudear waste was within the perimeter of the fire, they would err on the side of caution and personal safety. Firefighten will be reluctant to pursue a wildfire in the vicinity of a train load of spent nudear fuel casks. They may very likely back off until a subject area specialist ascenained that the hazardous cargo was 5
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FURTHER AFFIANT SAYETH NOT.
- Septempr M,1998.
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Voluntarily signed and sworn to before me this b day of September, 1998, by the signer, whose identity is personally known to me or was proven to me on satisfactory evidence.
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