ML20154H250

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Forwards M Resnikoff Original Declaration,Which Had Not Been Available at Time of Filing of State of UT Contentions Relating to Low Pail Transportation License Amend,
ML20154H250
Person / Time
Site: 07200022
Issue date: 10/05/1998
From: Braxton J
UTAH, STATE OF
To: Julian E
NRC OFFICE OF THE SECRETARY (SECY)
References
CON-#498-19623 ISFSI, NUDOCS 9810140117
Download: ML20154H250 (1)


Text

/4dN S TATE OF UTAH OFFICE oF THE ATTORNEY GENER AL DOCKETED USNRC a

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ATTORNEY oENER AL CAROL CLAWSON REED RicHARos PALMER DEPAuus Solicdor General Cruet Deputy Attomey General' Chief of Staff i

October 5,1998 Emile L.Julian, Assistant for Rulemakings and Adjudications Rulemakings and Adjudications Staff Office of the Secretary U.S. Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint North Mail Stop: 016G15 Washington, D.C. 20555 Re: In the Matter of Private Fuel Storage, LLC, Docket 72-22 MN Dear Mr.Julian; Enclosed is Dr. Marvin Resnikoff's original Declaration, which had not been available at the time of filing of " State of Utah's Contentions Relating to the Low Rail Transportation License Amendment," dated September 29,1998. The faxed version of Dr. Resnikoff's Declaration was attached as Exhibit 3 to this pleading.

Please replace the faxed version of this Declaration with the enclosed original Declaration.

Thank you.

Yours truly,

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,s Je n Brpton, egal Assistant

Enclosures:

as stated 9810140117 981005 PDR ADOCK 07200022 3

C PDR Cp 160 East 300 South 5th Floor, P.O. Box 140873, Salt Lake City. Utah 84114 0873 Telephone: (801) 366-0290 Facsimile: (801) 366 0292 i

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1 UNITED STATES OF AMERICA BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION -

1 ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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PRIVATE FUEL STORAGE, L.L.C.

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(Independent Spent Fuel

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Docket No. 72-22-ISFSI Storage Installation)

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September 29,1998

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DCCLARATION OF DR. MARVIN RESNIKOFF I, Dr. Marvin Resnil;off, declare under penalty of perjury that:

1. I am the Senior Associate at Radioactive Waste Management Associates, a private consulting firm based in New York City. On November 20,1997 and January 16,1998, I prepared declarations which were submitted to the Licensing Board by the State of Utah in support ofits contentions regarding Private Fuel Storage, L.L.C.'s proposed Independent Fuel Storage Installation. A statement of my qualifications was attached to November 1997 declaration.
2. I am familiar with Private fuel Storage's ("PFS's") license application and Safety Analysis Report in this proceeding, as well as the nonproprietary versions of applications for the storage and transportation casks PFS plans to use. I am also familiar with NRC regulations, guidance documents, and environmental studies relating to he transportation, storage, and disposal of spent nuclear power plant fuel, and with NRC decommissioning requirements.
3. 'I assisted in the preparation of, and have reviewed, the State of Utah's Contention B-1, License Needed for Intermodal Transfer Facil'ty. The technical facts presented in the State's Reply regarding those contentions are true end correct to the best of my knowledge, and the conclusions drawn from those facts are bared on my best professionaljudgment.

D arvin Resnik'off

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