ML20197B210
| ML20197B210 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 02/27/1998 |
| From: | Braxton J UTAH, STATE OF |
| To: | Julian E NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#198-18852 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9803100222 | |
| Download: ML20197B210 (6) | |
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CAnot CLAwsoN Rtto RicHARos PAmw OtPdis soictor Generai CNef Dewty Attorney Ceae<ai Chet of StaM February 27,1998 Emile L Julian, Assistam for Rulemakings and Adjudications
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Rulemakings and Adjudications Staff Office of the Secretary U.S. Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint North Mail Stop: Ol6G15 Washington, D.C, 20555 Re: In the Matter of Private Fuel Storage, LLC, Docket 72 22 Dear Mr.Julian; Enclosed are original Declarations which had not been available or were inadvertently omitted at the time two of Utah's pleadings were filed. Since these pleadings contain proprietary information, the original pleading were sent to you, but the Decleations accompanying those original pleadings were either copies or fued versions. Please replace the copied or faxed versions of those Declarations with the enclosed original Declarations.
Those phadings and accompany.ag Declarations are:
1.
"Stace of Utah's Request for Considerrtion of Late-Filed Contentious EE and FF," dated December 23,1997, supported by the Declarations of Lawrence A. White (dated December 22,1997) and Lawrence L Holish (dated Decemt ar 19,1997) (originals enclosed), Exhibits 25 and 26 respectively; and 2.
" State of Utah's Reply to the NRC Staff's and Applicant's Responses to State of Utah's Contentions EE and GG, and Notice of Withdrawal of Contention FF," dated February 11,1998, supported by the Declaration of Lawrence L Holish (dated February 9,1998) (original enclosed), Exhibit 1.
Enclosed also is a copy of the first page of each pleading for your convenience.
Yours trcly, f
/-
'1 an Braxton, Legal Assistant
Enclosures:
as stated b.
{[IlIlllll ll ll lIll lll 9003100222 980227 I Il II ll li 1: I PDR ADOCK 07200022 C
PDR 160 East 300 South, 5th Floor. P O Box 140873. Salt Lake City. Utah 84114 0873 Telephone- (801) 366 0290 Facsimde: (801) 36i G292
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
in the Matter of:
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Docket No. 72 22 ISFSI
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PRIVATE FUEL STORAGE, LLC
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ASLBP No.97 732 02ISFSI (Independent Spent Fuel
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Storage Installation)
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December 23,1997 STATE OF UTAH'S REQUEST FOR CONSIDERATION OF LATE FILED CONTENTIONS EE AND FF I
Introduction Pursuant to 10 C.F R. $$ 2.714(a)(1) and (b)(1), the Scare of Utah hereby requests considerat:on of Contentions EE and FF. These contentions address issues raised by the vendor's proprietary reports on seismic stability and radiation shielding for the Holtec HI STORM cask, which the State received under a confidentiality agrecment on November 13,1997. These reports are HI 971631, Multi-Cask Seismic Response at the PSF [ sic]ISFSI (May 19,1997) (hereinafter "Holtec Seismic Report"),
and HI 971645, Radiation Shielding Analysis for the Private Fuel Storage Facility (March 1997) (hereinafter "Holtec Radiation Shielding Repon").
The State submits that it satisfies the criteria for late-filing of these contentions under 10 C.F.R. $ 2.714(a)(1):
First, the State has good cause for la:e filing, because the State was not able to s '
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION hs}L}8 ATOMIC S AFETY AND LICENSING BOARD Before Administrative Judges:
G. Paul Bollwerk, III, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam
)
In the Matter of
)
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l PRIVATE FUEL STORAGE, LLC
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Docket No. 72-22 ISFSI
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(Independent Spent
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ASLBP No. 97-732-02-ISFSI Fuel Storage Installation)
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DECLARATION OF LAWRENCE A WIIITE, P.E.
- 1. I am an Executive Vice President of Versar, Inc., an engineering and consulting firm headquartered in Springfield, Virginia. I have extensive experience in the areas of nuclear licensing and radioactive waste management, including the siting, design, construction, operation, and decommissioning of nuclear facilities. Copies of my resume, which further describes my qualifications, and a description of Versar, Inc., are attached as Exhibit I to the contentions filed by the State of Utah in this proceeding on November 23,1997.
- 2. I am familiar with Private Fuel Storage's ("PFS's") Safety Analysis Report and the design of the casks that PFS proposes to use at its Private Fuel Storage Facility
("PFSF"). I am also familiar with the seismic and radiation shielding analyses prepared by lloitec, which are relied on by PFS ir, support of its license application.
- 3. I assisted in the preparation of, and oave reviewed, the State of Utah's Contention EE, regarding Failure to Demonstrate Cask-Pad Stability During a Seismic Event, and Contention FF, regarding Radiation Shielding. The technical facts presented in : hose contentions are true and correct to the best of my knowledge, and the conc usions drawn from those facts are based on my best professionaljudgment.
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Lawrence A. White Date
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UNITED STATliS OF AMERICA i
i NUCLEAR REGULATORY COMMISSION i
l ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
1 i
G. Paul Hollwerk,111, Chairman Dr. Jerry R. Kline i
Dr. Peter S. Lam i'
)
In the Matter of
)
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i PRIVATE FUEL STORAGE, LLC
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Docket No, 72 22 ISFSI
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(Independent Spent
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Fuel Storage Installation)
)
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DECLARATION OF LAWMENCE L. HOLISil, P.E.
l 3
- 1. I am employed as head of the Engineering Division at Versar,Inc Midwest Regional l
Office. I have extensive experience in geotechnical engineering and seismic analysis for nuclear t
j power plants and oher facilities. A copy of my resume, which f urther describes my qualfications, is attached.
I
- 2. I am familiar with Private Fuel Storage's ("PFS's") Safety Analysis Report and the
[
design of the casks that PFS proposes to use at its Private Fuel Storage Facility ("PFSF"). I am also familiar with the seismic analysis prepared by lloitec, which is relied on by PFS in support l
of its license applicatlan,
- 3. I assisted in the preparation of, and have reviewed, the State of Utah's Contention EE, 4
regarding Failure to Demonstrme Cask-Pad Stablility During a Seismic Event. Tne technical facts presented in that contention are true and correct to the best of my knowledge, and the conclusions drawn from those facts are based on my best professional judgment.
[U ahbH(( b Lawrence L. Ilolish, P.E, CCnt hiL lhil
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICINSING BOARD
)
In the Matter of:
)
Docket No. 72 2?-ISFSI
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PRIVATE FUEL STORAGE, LLC
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ASLBP No. 97 732 02 lSFS1 (Independent Spent Fuel
)
Storage Installation)
)
February 11,1998 STATE OF UTAH'S AEPLY TO THE NRC STAFF'S AND APPLICANT'S RESPONSES TO STATE OF UTAH'S CONTENTIONS EE and GG, AND NOTICE OF WITHDRAWAL OF CONTENTION FF In accordance with the Licensing Board's Memorandum and Order of February 2,1998, the State of Utah hereby replies to the Responses filed by the NRC Staff (Staff) and the Applicant on January 9,1998 with respect to Contentions EE, and the hesponses filed by the Staff and Applicant on January 20,1998 with respect to Contention GG. With respect to Contentions EE and GG, this Reply is supported by the Declaration of Lawrence Holish, PE, Versar, Inc., attached hereto as Exhibit 1.
The State also hereby notifies the Board and parties ofits withdrawal of Contention FF, By withdrawing the contention, however, the State does not accede to any of the arguments made by the Applicant and Staff regarding its admissibility and of the State's good cause to file it late.
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[XMQ l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION MOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
G. Paul Bollwerk, Ill, Chairman Dr. Jerry R. Kline Dr. Peter S. Lam in the Matter of
)
)
Docket No. 72 22 ISFSI PRIVATI! FUEL STORAGE, LLC
)
)
ASLBP No. o'.32 02 lSFSI (Independent Spent
)
Fuel Storage Installation)
)
February 0,1998 DECLARATION OF LAWRENCE L. HOLISH, P.E.
- 1. I am employed as head of the Engineering Division at Versar, Inc. Midwest Regional Office. I have extensive experience in geotechnical engineering and seismic
- analysis for nuclear power pir.ats and other facilities. A copy of my resume, which further describes my qualifications,is attached as Exhibit 26 to State of Utah's Contention EE, Gled December 23,1997.
- 2. I am familiar with Private Fuel Storage's ("PFS's") Safety Analysis Report and the design of the casks that PFS proposes to use at its Private Fuel Storage Facility
("PFSir'). I am also familiar with the seismic analyses prepared by Holtec and Sierra Nuclear, which are relied upon by PFS in support ofits license application.
- 3. I assisted in the preparation of, and have reviewed, the State of Utah's Reply to Applicant's and NRC Staff's Response to State's Contentions EE and GG regarding Failure to Demonstrate Cask Pad Stability During a Seismic Event. The technical facts presented in this Reply are true and correct to the bes.. ' v knowledge, and the conclusions drawn from those facts are based on my best professionaljudgment. r 4W '
Lawrence L. Itolish, P.E.
Date February 9.1998