ML20198N213
| ML20198N213 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/31/1998 |
| From: | Resnikoff M AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20198N186 | List: |
| References | |
| 99-754-01-LA-R, 99-754-1-LA-R, LA, NUDOCS 9901060056 | |
| Download: ML20198N213 (19) | |
Text
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I 00CKETED l- UNITED STATES OF AMERICA USHRC NUCLEARREGULATORY COMMISSION Before the -
. 99 JAN -5 P 3 :46 r
ATOMIC SAFETY AND LICENSINGBOARD l
Of g Administrative Judges:
Charles Bechhoefer, Chariman j Dr. Thomas S. Ellman i
Thomas D. Murphy l
t In the Matter of Docket No. 50-029-LA l
l YANKEE ATOMIC ELECTRIC COMPANY ASLBP No. 99-754-01-LA-R !
(Yankee Nuclear Power Station) l License Termination Plan
- DECLARATION OF DR. MARVIN RESNIKOFF l
l I, Dr. Marvin Resnikoff, 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. A statement of my qualifications is attached hereto as l Exhibit A.
l l 2. I am familiar with the License Termination Plan application. I am also familiar with
! and have reviewed the documents in this case listed as Exhibit B.
- 3. I assisted in the preparation of, and have reviewed the New England Coalition on Nuclear Pollution's contentions submitted in this proceeding. The technical facts presented in the
- contentions are true and correct to the best of my knowledge, and the conclusions drawn from i those facts are based on my best professionaljudgment.
.d 5 DATED:This h day of . fI u.m ke1 [.
6 . Marvin Resrillioff enior Associate 7
Radioactive Waste Management Associates 526 W. 26* Street Room 517 New York, NY 10001 9901060056 990102 I
PDR O
ADOCK 05000029 PDR
Exhibit A Page A-1 Exhibit A. Resume of Marvin Resnikoff, Ph.D.
l Dr. Marvin Resnikoffis Senior Associate at Radioactive Waste Management Associates and is an international consultant on radioactive waste management issues. He is Principal Manager at Associates and is Project Director for risk assessment studies on radioactive waste
- facilities and transportation of radioactive materials. Dr. Resnikoff has concentrated exclusively on radioactive waste issues since 1974. He has conducted studies on the remediation and closure of the leaking Maxey Flats, Kentucky radioactive landfill for Maxey Flats Concerned Citizens, Inc. under a grant from the Environmental Protection Agency, the Wayne and Maywood, New Tersey thorium Superfund sites and on proposed low-level radioactive waste facilities at Martmsville (Illinois), Boyd County (Nebraska), Wake County (Nonh Carolina), Ward Valley (California) and Hudspeth County (Texas). He has conducted studies on transportation accident risks and probabilities for the State of Nevada and dose reconstruction studies of oil pipe cleaners in Mississippi and Louisiana, residents of Canon City, Colorado near a former uranium
! mill, residents of West Chicago, Illinois near a former thorium processing plant, and residents and former workers at a thorium processing facility in Maywood, New Jersey. In West Chicago he calculated exposures and risks due to thonum contammation and served as an expert witness for plaintifTs A Muzzey, S Bryan, D Schroeder and assisted counsel for plaintiffs KL West and KA West. He is presently serving as an expert witness for a separate group of plaintiffs in West Chicago, includir.g R Dassion. He also evaluated radiation exposures and risks in worker compensation cases involving G Boeni and M Talitsch, former workers at Maywood Chemical Works thorium processing plant.
Under a contract with the State of Utah, Dr. Resnikoff is a technical consultant to DEQ on the proposed dry cask storage facility for high-level waste at Skull Valley, Utah and proposed storage /transponation casks. He is assisting the State on licensing proceedings before the Nuclear Regulatory Commission. In addition, at hearings before state commissions and in federal court, he has investigated proposed dry storage facilities at the Point Beach (WI), Prairie Island (MN) and Palisades (MI) reactors.
In Canada, he has conducted studies on behalf of the Coalition of Environmental Groups and Nonhwatch for hearings before the Ontario Environmental Assessment Board on issues involving radioactive waste in the nuclear fuel cycle and Elliot Lake tailings and the Interchurch Uranium Coalition in Environmental Impact Statement hearings before a Federal panel regarding the environmental impact of uranium mming in Northern Saskatchewan. He has also worked on behalf of the Morn:ngside Heights Consortium regarding radium-contaminated soil in Malvern and on behalf of Northwatch regarding decommissioning the Elliot Lake tailings area before a FEARO panel. More recently he completed a study for Concerned Citizens of Manitoba regarding transportation ofirradiated fuel to a Canadian high-level waste repository.
He was formerly Research Director of the Radioactive Waste Campaign, a public interest organization conducting research and public education on the radioactive waste issue. His duties with the Campaign included directing the research program on low-level commercial and military waste and irradiated nuclear fuel transportation, writing articles, fact sheets and reports, l formulating policy and networking with numerous environmental and public interest or-l ganizations and the media. He is author of the Campaign's book on " low-level" waste, Living Without Landfills, and co-author of the Campaign's book, Deadly Defense, A Citizen Guide to Militarylandfills.
l Between 1981 and 1983, Dr. Resnikoff was a Project Director at the Council on Economic Priorities, a New York-based non-profit research organization, where he authored the 390-page study, The Next Nuclear Gamble, Transportation and Storage ofNuclear Waste. The CEP study details the hazard of transponing irradiated nuclear fuel and outlines safer options.
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ExhibitA Page A-2 l- '
l In February 1976, assisted by four engineering students at State University of New York j at Buffalo, Dr. Resnikoff authored a paper which changed the direction of power reactor
! decommissioning in the United States. His paper showed that power reactors could not be l entombed for long enough periods to allow the radioactivity to decay to safe enough levels for unrestricted release. The presence of long-lived radionuclides meant that large volumes of dismantled reactors would still have to go to low-level waste disposal facilities. He has assisted public interest groups NECNP and CAN on the decommissioning of the Yankee-Rowe reactor.
Dr. Resnikoffis an international expert in nuclear waste management, and has testified often before State Legislatures and the U.S. Congress. He has extensively investigated the safety of the West Valley, New York and Barnwell, South Carolina nuclear fuel reprocessing facilities.
l His paper on reprocessing economics (Environment, July / August,1975) was the first to show the
! margmal economics of recycling plutonium. He completed a more detailed study on the same subject for the Environmental Protection Agency," Cost / Benefits of U/Pu Recycle," in 1983. His paper on decommissioning nuclear reactors (Environment, December,1976) was the first to show tinat reactors would remain radioactive for hundreds of thousands of years.
l Dr. Resnikoff has prepared reports on incineration of radioactive materials, transportation ofirradiated fuel and plutonium, reprocessing, and management oflow-level radioactive waste.
He has served as an expen witness m state and federal court cases and agency proceedings. He has served as a consultant to the State of Kansas on low-level waste management, to the Town of Wayne, New Jersey, in reviewing the cleanup of a local thorium waste dump, to WARD on disposal of radium wasks in Vernon, New Jersey, to the Southwest Research and Information Center and New Mexico Attorney General on shipments of plutonium-contaminated waste to the
, WIPP facility in New Mexico and the State of Utah on nuclear fuel transport. He has served as a
! consultant to the New York Attorney General on air shipments of plutonium through New York's Kennedy Airport, and transport of irradiated fuel through New York City, and to the Illinois Attorney General on the expansion of the spent fuel pools at the Morris Operation and i the Zion reactor, to the Idaho Attorney General on the transponation ofirradiated submarine fuel l to the INEL facility in Idaho and to the Alaska Attorney General on shipments of plutonium.
through Alaska. He was an invited speaker at the 1976 Canadian meeting of the American Nuclear Society to discuss the risk of transporting plutonium by air. As part of an international l team of experts for the State of Lower Saxony, the Gorleben International Review, he reviewed
!. the plans of the nuclear industry to locate a reprocessing and waste disposal operation at Gorleben, West Germany. He presented evidence at the Sizewell B Inquiry on behalf of the l Town and Country Planning Association (England) on transporting nuclear fuel through London. i In July and August 1989, he was an invited guest of Japanese public interest groups, Fishermen's l Cooperetives and the Japanese Congress Against A- and H- Bombs (Gensuikin).
l
.Between 1974 and 1981, he was a lecturer at Rachel Carson College, an undergradum
! environmental studies division of the State University of New York at Buffalo, where he taught energy and environmental courses. The years 1975-1977 he also worked for the New York Pubhc Interest Group (NYPIRG).
In 1973, Dr. Resnikoff was a Fulbright lecturer in particle physics at the Universidad de Chile in Santiago, Chile. From 1967 to 1973, he was an Assistant Professor of Physics at the State University of New York at Buffalo. He has written numerous papers in aanicle physics, under grants from the National Science Foundation. He is a 1965 graduate of t le University of
- Michigan with a Doctor of Philosophy in Theoretical Physics, specializing in group theory and i particle physics.
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ExhibitA Page A-3 1
Dr. Marvin Resnikoff 1 Radioactive Waste Management Associates i 526 West 26th Street, Room 517 241 W.109* St, Apt. 2A l New York, NY 10001 New York, NY 10025 !
(212)620-0526 FAX (212)620-0518 (212) 663-7117 l EXPERIENCE:
April 1989 - Senior Associate, Radioactive Waste Management Associates, management of I I
present consulting fh m focused on radioactive waste issues, evaluation of nuclear transponation and military and commercial radioactive waste disposal facilities. i 1978 - 1981; Research Director, Radioactive Waste Campaign, directed research program for 1983 - Campaign, including research for all fact sheets and the two books, Living April 1989 Without Landfills, and Deadly Defense. The fact sheets dealt with low-level i radioactive waste landfills, incineration of radioactive waste, transportation of l high-level waste and decommissioning of nuclear reactors. Responsible for fund-raising, budget preparation and project management.
1981 - 1983 ' Project Director, Council on Economic Priorities, directed project which 3roduced the report The Next Nuclear Gamble, on transponation and storage of ),
tigh-level waste.
1974 - 1981 Instructor, Rachel Carson College, State University of New York at BufTalo, taught classes on energy and the environment, and conducted research into the economics of recycling of plutonium from irradiated fuel under a grant from the i EnvironmentalProtection Agency. !
1975 - 1976 Project Coordinator, SUNY at Buffalo, New York Public Interest Research Group, assisted students on research projects, including project on waste from decommissioning nuclear reactor.
1973 Fulbright Fellowship at the Universidad de Chile, conducting research in l
elementary particle physics.
1967 - 1972 Assistant Professor of Physics, SUNY at Buffalo, conducted research in elementary particle physics and taught range of graduate and undergraduate physics courses.
1965 - 1967 Research Associate, Department of Physics, University of Maryland, conducted research into elementary particle physics.
EDUCATION University ofMichigan Ph.D. in Physics, June 1965 Ann Arbor, Michigan M.S. in Physics, Jan 1962 B.A. in Physics / Math, June 1959
ExhibitA Page A-4 Publications 1985-1998 January 1985 "U.S. Radioactive Landfill Experience," paper, 3 resented to the Annual Insti;ute of British Geographers in Leeds, England. Incorporatec into A. Blowers and D. Pepper, i
Publ)shing i Co.,1987.(eds. , Nuclear Power in Crisis: Politics and Planningfor the . Nu February 1985 " Comments on the transportation sections of the draft Environmental Assessment for a high level waste repository m Utah," prepared for the State of Utah.
. March 1985 Testimony before the House Committee on Interior and Insular Affairs on the long-lived hazard of" low-level" radioactive waste.
May 1985 " Radioactive Waste Incineration in Bladen County, What's Coming Out of the Stack?" Campaign report on the environmental impact ofincinerating radioactive waste in Bladen County, North Carolina,33 pages.
. August 1985 Paper submitted to the House Energy and Commerce Committee, on the hazard of long-lived low-level waste.
September 1985 " Radioactive Waste Incineration in Parks Township, Pennsylvania, What's Coming Out of the Stack?" Campaign report on the environmental impact ofincinerating radioactive waste in Parks Township, Pennsylvania,32 pages.
September 2,1985 " Critique of Submission by Dr. John Till to the House Committee on Interior and Insular Affairs."
February 1986 " Alternatives to Radioactive Landfills, An Environmental Perspective," paper presented at the International Symposium on Alternatives to Radioactive Landfills, Chicago, Ill. Paper incorporated ,m symposium Proceedings, published by the Illinois Dept of Nuclear Safety and the Central Midwest Compact Commission.
June 1986' " Feed Materials Production Center, Uranium Contamination of Off-site Wells,"
Campai,gn report prepared with Dana Coyle on the health impact of uranium contammation of off-site wells,35 pages.
June 1986 Testimony for the Northwest Inland Waters Coalition, a public interest organization, for the Federal District Court, State of Washington, on the need for an Environmental Impact Statement to evaluate the import ofirradiated nuclear fuel from Taiwan through the Port of Seattle.
July 1986 Paper on the Kerr-McGee uranium conversion facility near Salisaw, Oklahoma presented to conference organized by Native Americans for a Clean Environment.
. September 1986 AfTidavit in Federal Court in New York City for a Warwick, New York public interest group (WARD), and in New Jersey State Courts for the New York-New Jersey Trails Conference, opposing plans by the New Jersey Department of Environmental Protection to move radium residues from Montclair to Vernon, New Jersey.
August,1986 Supplement to June 1986 Campaign report on the Feed Materials Prod'uction Center discussing contamination of public water supplies,20 pages.
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ExhibitA Page A-5 September 1986 " Disposal of high-level waste in Canada," paper presented at high-level waste conference, Wmnipeg, Manitoba. Workshop on the transportation of irradiated fuel in Canada. Incorporated into A. Weiser (ed.), Challenges to Nuclear Waste, Proceedings of Nuclear Waste issues Conference, Sept 12-14, 1986, Concerned Citizens of Manitoba, Winnipeg, Manitoba,1987. ,
November 1986 Associates report to the State of Kansas on draft Request for Proposal for contractor to the Central States Compact,10 pages.
4 November 1986 " Transportation ofirradiated fuel," paper presented to a subcommittee of the National Association of Attomeys General, Las Vegas, Nevada.
December 1986 Associates amdavit prepared for the Coalition on West Valley Nuclear Wastes and the Radioactive Waste Campaign in a successful U.S. District Coud action on the ,
need for a federal Environmental Impact Statement before disposing oflow-level waste at '
West Valley, February 1987 "Off-site radioactive contamination at DOE's Oak Ridge, Tennessee facility,"
Campaign report prepared with Dana Coyle on radioactive leakage from the Oak Ridge Reservation,65 pages. ,
1 May 1987 "At-reactor storage ofirradiated fuel," paper 3 resented at conference sponsored by i Blue Ridge Environmental Defense League and otier citizen organizations at Maryville, !
Tennessee. !
June 1987 Associates amdavit prepared for the Sierra Club Legal Defense Fund on the need for
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an Environmental Impact Statement before incinerating plutonium-contaminated waste at ;
the Rocky Flats Plant. ;
September 1987 Living Without Landfills, Campaign book on the hazard of radioactive landGls, and safer alternatives,119 pages.
. September 1987 Associates amdavit pre?ared for the Alaska Attorney General in a U.S. District Coun action on the need for a fec eral Environmental Impact Statement for air shipments ofplutoniumin Alaska.
November 1987 " Low-level waste in Michigan," talk before a joint session of the Michigan Legislature, East Lansing, Michigan.
February 1988 Testimony before the Vermont House Committec on Natural Resources and the Environment, Montpelier, Vermont.
May 1988 Talks at Chadron State College (Chadron, Neb), Alliance, and Scottsbluff, on " low-level" waste in the Central States.
June 1988 Co-authored the Radioactive Waste Campaign's Deadly Defense,170 page book on radioactive waste at nuclear weapons facilities. Released at a national press conference in Washington, D.C.
' June 1988- Wayne and Clark counties, Illinois; public meetings near proposed LLRW dump sites; jointly-sponsored with local groups (Individuals for a Clean Environment)
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ExhibitA , Page A-6 July 1988 ' Briefing before Congressional Legislative Assistants on the findings of Deadly.
Defense, jointly conducted with the Sierra Club and sponsored by Representative Don l Bonker. ,
~ September 1988 Reno, NV; talk before Northern Colorado Gaming Executives re. transportation ofirradiated fuel to a proposed high-level waste repository; jointly sponsored by Citizens
. Alert and State ofNevada September 1988 " Rebuttal of NRC Critique ofLiving Without Landfills," 12 pages.
l October 1988 Boulder, Colorado; talk, participation in conference and chapter of book, Environmental Impacts of Warfare; sponsored by the Sierra Club.
I November 1988 Nucla, Colorado; prepared testimony before Colorado Department of Health re.
suitability of proposed " low-level" waste disposal site in Uravan, Colorado for Western Colorado Congress ;
November 1988 Augusta, Maine; participation in debate sponsored by the Maine Low-Level RadioactiveWaste Authority December 1988 Preparation of court affidavit re. proposed irradiated fuel shipments from Taiwan through Portsmouth, Virginia, before the United States District Court, District Of l . Columbia, for the Sierra Club Legal Defense Fund.
' February 1989 " Uranium Releases ht Fernald, Radiation Doses to Nearby Residents," report released by the Radioactive Waste Campaign at Cincinnati, Ohio press conference.
April 1989 " Risks of Low-Level Radioactive Waste Transportation," 8-page fact sheet, prepared for the Radioactive Waste Campaign.
f May.12,1989, " Preliminary Report on Rl/FS Study," prepared for Maxey Flats Concerned Citizens, Flemingsburg, Kentucky.
' August 30,1989, " Analysis ~of RADTRAN Computer Model," paper presented at meeting of the American Nuclear Society Meeting, Las Vegas, Nevada.
October 1989 " Report on Maxey Flats Remediation Program," 75-page report, prepared for Maxey Flats Concerned Citizens, Inc.
November 1989 "RADTRAN Analysis," 60-page report on the probability and consequences of accidents in transporting high-level waste to the proposed Yucca Mountain repository, prepared for the University ofNevada, Las Vegas.
February 1990 " Radioactive Waste Mismanagement at Nine Mile Point 1."
l .
l April 9,1999 " Comments on the Final Supplemental Environmental Impact Statement, Waste Isolation Pilot Plant," for Concerned Citizens for Nuclear Safety, Santa Fe, New Mexico.
l April 25, 1990, talk before the Hazardous Materials / Nuclear Symposium on nuclear transportation issues, Ely, Nevada.
ExhibitA Page A-7 April 26,1990, Statement before the Nevada Commission on Nuclear Projects on nuclear transportation issues, Las Vegas, Nevada.
July 19,1990," Report on Feasibility Study, Risk Assessment, App. D, iodine hazard," prepared for Maxey Flats Concerned Citizens, Flemingsburg, Kentucky.
August 1,1990, " Report on the State of Kentucky, Maxey Flats Closure Plan," prepared for Maxey Flats Concerned Citizens, Flemingsburg, Kentucky.
August 1990 Preparation of second court affidavit re. proposed irradiated fuel shipments from Taiwan through Portsmouth, Virginia, before the United States District Court, District Of Columbia, for the Sierra Club Legal Defense Fund.
September 1990 "The Generation Time-Bomb: Iladioactive and Chemical Defense Wastes," in A.H. Ehrlich and J.W. Birks (eds.), Hidden Dangers, Environmental Consequences of Preparingfor War, Sierra Club Books, San Francisco October 22,1990, " Review of Environmental Report for the Central Interstate Compact Low-level Radioactive Waste Facility," for Heanland Operation to Protect the Environment, Auburn, Nebraska.
December 1990 Declaration re. the constitutionality of the Low-Level Radioactive Waste Policy Act before the U.S. District Court, Distnct of Nebraska for Concerned Citizens of Nebraska.
December 1990 Preparation of third coun affidavit re: proposed irradiated fuel shipments from Taiwan through Ponsmouth, Virginia, before the United States District Court, District Of Columbia, for the Sierra Club Legal Defense Fund.
February 8,1991, " Review of ' Risk Assessment and Safety Analysis, University of Michigan Waste Handling Facility,' for North Campus Residents Council, Ann Arbor, Michigan.
April 1,1991, " Health and Safety Impact of NMI," for Citizens Concerned About NMI, Concord, Massachusetts.
May 6,1991, " Comments on Final Environmental Impact Statement, Prairie Island Independent Spent Fuel Storage Installation," for the Sioux Tribal Council, Red Wing, Minnesota.
May 16,1991, " Managing Low-Level Radioactive Waste," talk at Future Options Symposium, International Institute for Low Level Radioactive Waste, East Lansing, Michigan.
May 23,1991, "Radiac Accident Analysis," prepared for the Radioactive Waste Campaign, Brooklyn, New York.
May 30,1991, " Nuclear Power in the United States," talk sponsored by the Green Party, Rikstag, Green Party Group Room, Stockholm, Sweden.
June 20,1991," Comments on the Department of Energy Environmental Assessment on Off-Site Fuels Policy," prepared for the Sierra Club Legal Defense Fund, Washington,1C.
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V ExhibitA Page A-8 L
July 1,1991, " Comments on the Final Environmental Impact Statement for the Proposed Ward Valley Low-level Waste Landfill," submitted to the California Department of Health i Services, for Don't Waste California, l July 12,1991, " Comments on EPA Proposed Plan," prepared for Maxey Flats Concerned Citizens, Flemingsburg, Kentucky.
1 September 8,1991 Preparation of fourth coun affidavit re. proposed irradiated fuel shipments '
from Taiwan'through Ponsmouth, Virginia, before the United States District Court, District Of Columbia, for the Sierra Club Legal Defense Fund.
l l
September 20,1991 " Consequences of a Severe HEU Ship Accident," memo to Greenpeace
, September 30,- 1991~ " Prairie Island Independent Spent Fuel Storage Facility, Cost and Radiation
! Analysis," before the Minnesota Public Utility Commission for the Prairie Island I Mdewakanton Sioux Indian Commu.nity.
l l
October 23,1991 " Health and Safety Impacts of NMI, 2nd Repon," prepared for Concerned if .
Citizens about NMI, Concord, Mass.
October 31,1991 Preparation of fifth coun affidavit re. proposed irradiated fuel shipments from Taiwan through Portsmouth, Virginia, before the Umted States District Court, District Of Columbia, for the Sierra Club Legal Defense Fund.
i November 4,1991 Statement before the City of Albuquerque Common Council regarding disposal of radioactive waste into the city sewer system.
- November 9,1991 Affidavit re. shipments of Pu-contaminated waste to the proposed WIPP facility, before the US District Coun, District of Columbia, for the New Mexico Attorney General.
November 1991 " Prairie Island Independent Spent Fuel Storage Facility, Prefiled Reply Testimony," before the Minnesota Public Utility Commission for the Prairie Island Mdewakanton Sioux Indian Community.
Radioactive Waste Management Associates [RWMA], White Paper #1, Sources of Low-Level Waste in Connecticut, prepared for the Towns of East Windsor, Ellington and South Windsor, September 30,1991.
RWMA, White Paper #2, Low-Level Waste Transportation in Connecticut, prepared for the Towns of East Windsor, Ellington and South Windsor, October 2,1991.
L l
RWMA, White Paper #3, Statement by Dr. Marvin Resnikogon Chem-Nuclear, prepared for the
- Towns of East Windsor, Ellington and South Windsor, October 29,1991.
l 'RWMA, White Paper #4, Leakage From Existing ' Low-Level' Waste Disposal Facilities, l prepared for the Towns of East Windsor, Ellington and South Windsor, January 6,1992.
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1, ExhibitA Page A-9 Resnikoff, M., and Anne Vantentaghem, Prr':,ninary Review of US Ecology Safety Analysis Report, Proposed Boyd County, Nebraska Low-Level Waste Facility, prepared for the Boyd County Local Monitoring Committee, February 2,1992.
7 Resnikoff, M., Radon Releasesfrom Uranium Tailings and Projected Health Efects, prepared for Northwatch Coalition, February 17,1992.
RWMA, White Papei #5, Storage ofLow-LevelRadioactive Waste, prepared for the Towns of
' East Windsor, Ellington and South Windsor, February 19,1992.
Resnikoff, M., Scope: McArthur River and Cigar Lake Projects, Memo to Inter Church Uranium Council, February 27,1992.
Resnikoff, M., Leigh, R. L., and Anne Vanrenterghem, EnvironmentalImpacts of Elliot Lake Mill Tallings, prepared for Northwatch Coalition, March 30,1992.
' Resnikoff, M., Canadian High-Level Waste Repository Costs, Memo to David Poch and David Argue, Coalition ofEnvironmental Groups, April 2,1992.
Resnikoff, M., Comment on Midwest Joint Venture EIS, Memo to Inter Church Uranium Council, April 23,1992.
Resnikoff, M., and Lee DiTullio, Review of Safety Analysis Report Part 1: Geology, Hydrology Proposed Low-Level Waste Facility Butte, Nebraska, prepared for the Boyd County Local Monitoring Committee, June 29,1992.
Resnikoff, M., Mythbuster#8, " Low-Level" Radioactive Waste, for Safe Energy Communications Council, Summer 1992.
Resnikoff, M., Comments on Final Guidelinesfor the Preparation of an EnvironmentalImpact Statement on the Nuclear Fuel Waste Management andDisposal Concept, July 22,1992.
Resnikoff, M., NMI's Proposed Hydromet Project, Memo to Judy Scotnicki, Concerned Citizens of Concord, July 29,1992.
Resnikoff, M., and Lee DiTullio, Review of Safety Analysis Report Part 2: Risk Assessment Proposed Low-Level Waste Facility Butte, Nebraska, prepared for the Boyd County Local Monitoring Committee, August 7,1992.
- RWMA, Comments on McClean Lake Project EIS, prepared for the Inter-Uranium Coalition,
' June 30,1992.
' ResnikofT, M., Plutonium Ship Akatsuki Maru Consequences ofFire at the Pearl Harbor Naval Shipyard, prepared for Greenpeace, August 24,1992.
ExhibitA Page A-10 1'
Resnikoff, M., Waste Impacts of the Nuclear Fuel Cycle, prepared for Coalition of Environmental Groups, November 1992.
Resnikoff, M., Declarations on the safety of shipping naval fuel from shipyards to Idaho before the Federal District Court, prepared for the Idaho Attorney General, March 1993.
Resnikoff, M., Declaration on the safety of the VSC-24 storege cask before the Federal District Court for the Lake Michigan Federation, May 1993.
Resnikoff, M., Talk at a Town Meeting in Grand Rapids, Michigan, June 22, regarding the safety of the VSC-24 storage container at the Palisades reactor.
Resnikoff, M., Reports to two environmental assessment panels reviewing the environmental impact of proposed mining operations in Northern Saskatchewan, prepared for the Interchurch Uranium Coalition, May 12 and June 14,1993.
Resnikoff, M., Presentation before the Ohio Governor's Blue Ribbon Committee on siting a low-level waste facility in Ohio for the Midwest Compact, July 1993.
Resnixoff, M., Report on the safety of processing and storing radium-contaminated wastes in the Tapscott district of Scarborough, Toronto, prepared for the Coalition Against Radioactive Tapscott, November 1,1993.
Resnikoff, M., Remarks before the Department of Energy meeting on the Multi-Purpose Canister, Washington, D.C., November 16,1993.
Resnikoff, M., Report on the scoping guidelines for production of an Environmental Impact Statement (EIS) for decommissioning of the Elliot Lake uranium tailings and report on the draft EIS by Rio Algom for the decommissioning of Quirk and Panel tailings, Elliot Lake, prepared for Algoma-Manitoulin Nuclear Awareness, December 15,1993.
Resnikoff, M., and R. Haaker, " Estimated Radiation Dose received by James E Case, et al, during Pipe De-scaling Operations at Brookhaven, Mississippi," report prepared in the case Case
- v. Chevron, January 23,1994.
Radioactive Waste Management Associates, " Soil Separation: What It Means For Wayne,"
report prepared for the Town of Wayne, New Jersey, May 24,1994.
Resnikoff, M., and P. Fuchsman, " Comments on the Department of Energy's Baseline Risk Assessment for the Wayne Site, Wayne, New Jersey, January 1994," May 31,1994.
Resnikoff, M., " Radiation Dose Exposures Received by William Davis During Lens Polishing Operation," report prepared for the case Davis v. Transelco, et al., July 1,1994.
ExhibitA Page A-11 Resnikoff, M., and R. L. Leigh, " Estimated Exposure to Radiation and Metals Received by Lincoln Park Residents from Cotter Mill Operations," repon prepared for the case J. Dodge et al.
- v. Commonwealth Edison, July 1,1994.
Resnikoff, M., Affidavit prepared for plaintiffs before the United States District Court for the Eastern District Of Tennessee, Knoxville, for the case Euchee Afarina & Campground Inc., et al., y Unicn Carbide Corporation, et al., July 15,1994.
Resnikoff, M., and K. Knowlton, " Preliminary Critique of the Safety Analysis Report, Wake /Chatham Proposed Low-Level Waste Facility," report prepared for the Chatham County Preferred Site Local Advisory Committee, July 19,1994.
Resnikoff, M., Leigh, R.L., and P. Fuchsman, " Comments on the Department of Energy's Baseline Risk Assessment for the Maywood Site, Maywood, New Jersey, April 1993,"
July 27,1994.
Resnikoff, M., "Prefiled Testimony Of Marvin Resnikoff, Ph.D. On Behalf of Lake Michigan Federation, before the Public Service Commission of Wisconsin, in the case of Application of Wisconsin Electric Power Company for Authority to Construct and Place in Operation an Independent Spent Fuel Storage Facility Utilizing Dry Cask Storage Technology at the Point Beach Nuclear Plant...," September 11,1994; " Rebuttal Testimony," September 27, 1994;
" Supplemental Testimony," October 3,1994.
Resnikoff, M., affidavit prepared for plaintiffs in the United States District Coun for the District of Massachusetts, Citizens Awareness Network, Inc., v. United States Nuclear Regulatory Commission, October 4,1994.
Resnikoff, M., affidavit in opposition to motion of Westinghouse for summary judgment, prepared for plaintiffs in the United States District Court for the Western District Of Washington at Yakima, In re HanfordNuclear Reservation, October 15,1994.
RWMA, " Comments on proposed rule change: radiation standards for low-level waste facilities," January 9,1995.*
Resnikoff, M., " Nuclear waste transportation and the role of the public, Las Vegas, Nevada:
unresolved safety issues," February 1,1995.
Resnikoff, M., " Ohio low-level waste legislation," Lobby Day, Ohio Environmental Council Border Opposes Nuclear Dump," February 22,- 1995.
Resnikoff, M., Fuchsman, P., Hamilton, M., Knowlton, K., and K. Levine, " Wayne Health Survey," prepared for the Town of Wayne, April,1995.
Resnikoff, M., and K. Knowlton, "A review of the phase II field investigation and financial resources of NMI," report prepared for CREW, May 22,1995.
- All publications in the year 1995 have appeared since my Rule 26 statement in the Muzzey/ Bryan case.
ErhlbitA Page A-12
- Resnikoff, M., Knowlton, K., and P. Fucl.sman, " Low-level waste transporation in Texas," '
prepared for Alert Citizens for Environmental Safety, June 29,1995.
i Resnikoff, M., and K. Knowlton, " Comments on ' Engineering evaluation / cost analysis for the cleanup of residential and municipal vicinity properties at the Maywood site, Bergen County, ;
j New Jersey'," for Concerned Citizens ofMaywood, August 11,1995.
l Resnikoff, M., Fuchsman, P., and K. Knowlton, " Low-level waste transportation in North Carolina," prepared for the Chatham County Preferred Site Local Advisory Committee, August 13,1995.
l Resnikoff, M., Knowlton, K., and P. Fuchsman, " Comments on environmental impact statements
- for the Cigar Lake and Midwest Joint Ventures proposals," prepared for the Saskatchewan j Uranium Coalition, October,27,1995.
Resnikoff, M., Knowlton, K., and P. Fuchsman, " Review of the license application for the l Proposed LLRW facility near Sierra Blanca, -Texas," prepared for Alert Citizens for Environmental Safety, November 30,1995.
l Resnikoff, M., " Scoping Comments for the Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca l Mountain, Nye, County, Nevada," December 1,1995.
Resnikoff, M., " Calculation of Radiation Exposures Received by Donald A. Schroeder, West Chicago, Illinois." Prepared for case Schroeder v. Kerr-McGee, February 21,1996.
Resnikoff, M., Knowlton, K., and K. Island, " Comments on Environmental Impact Statemsnt for i
the McArthur River Proposal," prepared for Saskatchewan Uranium Coalition, March 1,1996.
! Resnikoff, M., Knowlton, K., Fuchsman, P., and K. Island, " Site Suitability and Impact of l Proposed Radioactive Waste Facility, Wake /Chatham Counties, Nonh Carolina," prepared for l Chatham County Preferred Site Local Advisory Committee, March 20,1996.
l Resnikoff, M., " Mississippi Oil and Gas Board Proposed Rule 69: Control of Oilfield NORM,"
l March 25,1996.
- Resnikoff, M., "Before the Illinois LLRW Task Group: Comments on Revised Siting Criteria," !
May 15,1996.
Resnikoff, M., " Decommissioning of Big Rock Point," prepared for Don't Waste Michigan -
- Northern Chapter, July 1996.
Resnikoff, M., " Preliminary Report: Occupational Exposures for Plaintiffs Garza and Depain from Uranium Solution Mining Activities, Bruni, Texas," July 31,1996.
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ExhibitA Page A-13 RWMA, " Comments on the IRP Remedial Design Work Plan, Maxey Flats, Kentucky,"
prepared for Maxey Flats Concerned Citizens, August 2,1996.
' Resnikoff, M., and K. Knowlton, " Review of the License Application for the Proposed LLRW Facility Near Sierra Blanca, Texas," prepared for Sierra Blanca Legal Defense Fund, updated August 14, .1996, (original November 30,1995).
Resnikoff, M., " Radiation Dose Exposure Received by Milt Vercher During Oil Pipe Cleaning Operations," September 27,1996.
Resnikoff, M., and K. Knowlton, " Comments on the Department of Energy's Draft Feasibility Study and Draft Record of Decision for the Wayne, New Jersey Site," October 15,1996.
Resnikoff, M., Knowlton, K., and M. Medina, " Comments on Fall 1996 Addendums to JEB Pit Tailings Disposal Plans," prepared on the behalf of the Saskatchewan Uranium Coalition, December 2,1996.
Resnikoff, M., Critique of Ontario Hydro Irradiated Fuel Transportation Assessment, prepared for Concerned Citizens of Manitoba, January 1997.
Resnikoff, M., and S.J. Waligora, Jr., Estimated Radiation Doses Received by Victor Ferguson, Martha, Kentucky, report prepared in the case Victor Ferguson v. Ashland Oil Inc., et al.,
January 16,1997.
Resnikoff, M., " Preliminary Report, Environmental and Health-Related Impacts of the Mobil Mining and Minerals Phosphoric Acid Plant," February 1997.
Resnikoff, M., Affidavit, before the Court of Appeals, State of Minnesota, re: appeal of decision by the Minnesota Dept of Environmental Quality, Prairie Island dry storage facility, for the Prairie Island Indian Community, February 1997.
Resnikoff, M., " Comments on 'EnvironmentalManagement Advisory BoardReport " Report of a Stakeholder Process to Develop Guiding Principlesfor the Formerly Utilized Sites Remedial Action Project, Background Information Document'," prepared for Thorium Advisory Committee, Town of Wayne, New Jersey, March 7,1997.
ResnikofT, M., " Comments On ' Report of a Stakeholder Process to Develop Guiding Principles for the Formerly Utilized Sites Remedial Action Project, Background Information Document',"
prepared for Concerned Citizens of Maywood, Maywood, New Jersey, March 12,1997.
Resnikoff, M., Wastes Generated in Decontaminating and Decommissioning a Nuclear Power Plant, presented at the conference, " Impacts of Nuclear Power and Nuclear Waste on Indigenous and Local Communities, Prairie Island Indian Community," March 25-26,1997.
Resnikoff, M., " Radiation Risks on Reclaimed Phosphate Mined Lands," April 30,1997.
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v ErhibitA Page A-14 Reinikoff, M., and A. Champion, Transjx>rtation Accident ofShip Carrying VitnfiedHigh-Level Radioactive Waste: Part 1. Impact on the Federated States of Micronesia, prepared for Greenpeace Pacific, July 31,1997.
Resnikoff, M., Prepared statement before the Joint Federal-Provincial Panel on Uranium Mining on Cigar Lake and McArthur River, for the Saskatchewan Uranium Coalition, August 27,1997.
Resnikoff, M., " Comments on the Department of Energy's Draft Feasibility Study and Draft Record of Decision for the Wayne Site," prepared for Thorium Advisory Committee, Town of Wayne, New Jersey, Sept 15,1997.
Resnikoff. M., " Presentation Before I anel on the Waste Management System, Nuclear Waste Technical Review Board," November 19,1997.
Resnikoff, M., and I. Fairlie, No Dose Too Low, article prepared for The Bulletin of The Atomic Scientists, November / December 1997.
Resnikoff, M., Calculation ofRadiation Exposures Received by Rebekah Dassion, prepared for Hagens & Berman as part of a federal personal injury case, November 23,1998.
Resnikoff, M., Comments on Preliminary Safety Evaluation Report and Proposed Certificate of Compliance H/-Star 100 Storage Cask, prepared for The State of Utah, Department of Environmental Quality, October 26,1998. 7 pages.
Resnikoff, M., and Tsui, C., Health Impacts of Oil Production in Brookhaven, Mississippi prepared for Sacks & Smith, July 30,1998. 34 pages.
Resnikoff, M., Comments on FGR No.13, Part I-Interim Version, Health Risksfrom Low-LevelEnvironmentalExposure to Radionuclides, June 30,1998,2 pages.
Resnikoff, M., Radioactive Waste Trends, prepared for the Chatham County PSLAC, June 1998.
8 pages.
Resnikoff, M., Comments on Draft PEISfor the Long-Term Management and Use of Depleted Uranium Hexafluoride, March 1998. 3 pages.
Resnikoff, M., Affidavit prepared for Giordano, Halleran, & Ciesla, in the case Robert Keimy v.
Shore RegionalHigh School, et al., March 1998. 7 pages.
Resnikoff, M., Comments on the draft Safety Evaluation Report (DSER), Proposed LLRW Facility at Boyd County, Nebraska by the State of Nebraska, prepared for the Boyd County Monitoring Committee, February 1998. 31 pages.
Resnikoff, M., Proposed Remediation Work at Marey Flats, prepared for Maxey Flats Concerned Citizens, January 1998.12 pages.
ExhibitB Pcge B-l Exhibit B. References
- 1. Berger, J.D., Manual for Conducting Radiological Surveys in Support of License Termination, NUREG/CR-5849, Environmental Survey and Site Assessment Program, Energy / Environmental Systems Division, Oak Ridge Associated Universities, June 1992.
- 2. Beyeler, W. E., Davis, P.A., et al., Residual Radioactive Contamination Frm Decommissioning, Vol. 3, Parameter Analysis, NUREGICR-5512, Science Applicatlana International Corporation, Albuquerque, NM, U.S. Nuclear Regulatory Commission, Sandia National Laboratories, Albuquerque, NM, April 1996.
- 3. Edward Boon, Aspen Trailer Company, Letter to Wayne Lewis, Stone & Webster Engineering Corporation, March 25,1997.
- 4. Daily, M.C., HufTert, A., et al., Working Draft Regulatory Guide on Release Criteriafor Decommissioning: NRC Sta.g's Draft for Comment, U.S. Nuclear Regulatory Commission, NUREG-1500, August 1994.
- 5. Eckerman, K.F., et al, " Health Risks ' from Low-Level Environmental Exposure to Radionuclides, Federal Guideline Report No.13," EPA,1998.
- 6. Halstead, R. and R. Ballard, " Nuclear Waste Transportation Security and Safety Issues; The Risk of Terrorism and Sabotage Against Repository Shipments," Nevada Agency for Nuclear Projects, October 1997.
- 7. Huffert, A. M., Meck, R.A., and K.M. Miller, Background as a Residual Radioactivity Criterion for Decommissioning, NUREG-1501, U.S. Nuclear Regulatory Commission August 1904.
- 8. Kennedy, Jr., W.E. and D.L. Strenge, Residual Radioactive Contamination From Decommissioning, Vol.1, Battelle Memorial Institute, NUREG/CR-5512, (October 1992).
- 9. Mancini, A. and R. Applebaum, " Decontamination of Large Components - Test Case,"
paper presented at ANS Winter Meeting, Washington, D.C., November 10-14, 1996.
- 10. O' Leary, Hazel, Statement before the Committee on Energy and Natural Resources, U.S.
Senate, December 14,1995.
I 1. U.S. Department of Energy, " Acceptance Priority Ranking and Annual Capacity Reper's" OCRWM, March 1995.
- 12. U.S. Nuclear Regulatory Commission, Termination of Operating Licenses for Nuclear Reactors, Regulatory Guide 1.86, June 1974.
- 13. U.S. Nuclear Regulatory Commission, Memorandum and Order in the Matter of Yankee Atomic Electric Company, 0ctober 1998.
l
6 i ExhibitB - Page B-2
- 14. U.S. Nuclear Regulatory Commission, Comparison of the Models and Assumptions used in the DandD 1.0, RESRAD 5.61, and RESRAD-Build Computer Codes with Respect to the Residential Farmer and Industrial Occupant Scenarios Provided in NUREG/CR-5512, October 1998,
- 15. U.S. Nuclear Regulatory Commission, Region I, Inspection Repon 50-29/98-03, (conducted Junel-July 31,1998), Oct.1,1998.
- 16. U.S. Nuclear Regulatory Commission, Region I, Combined Inspection Repons 50-29/98-01 and 50-29/98-02, (conducted January 1,1998-March 31,1998), June 24,1998.
- 17. U.S. Nuclear Regulatory Commission, Final Rule on Radiological Criteria for Decommissioning, 62 Fed. Reg. 39057, July 21,1997,
- 18. Wells, Jim, statement, " Yucca Mountain Project Management and Funding Issues,"
GAOff-RCED-93-58,1993.
- 19. Yankee Atomic Electric Company, Yankee Nuclear Power Station License Termination Plan, Revision 1 (December 1997).
- 20. Yankee Atomic Electric Company, Yankee Nuclear Power Station License Termimition Plan, Revision 0 (May 1997).
- 21. Yankee Atomic Electric Company, " Annual Radiological Environmental Operating Report, January-December 1995," (April 1996) J I
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UNITED STATES OF AMERICA T NUCLEAR REGULATORY COMMISSION {
Before the ATOMIC SAFETY AND LICENSING BOARD .
- J M' -5 P1:' ' 42 i
Administrative Judges: G-Charles Bechhoefer, Chariman p'~ ' - 1 Dr. Thomas S. Ellman !
Thomas D. Murphy In the Matter of Docket No. 50-029-LA YANKEE ATOMIC ELECTRIC COMPANY ASLBP No. 99-754-01-LA-R (Yankee Nuclear Power Station)
License Termination Plan Served: January 2,1999 CERTIFICATE OF SERVICE FOR NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S CONTENTIONS AND EXPERT'S DECLARATION ;
I, Jonathan M. Block, counsel for New England Coalition on Nuclear Pollution, Inc.,
certify, under penalty of perjury, that on this 2d day of January,1999, copies of the within materials were served upon the parties below by mailing them U.S. Postal Service, Express Mail, postage pre-paid (except for party denoted by "' served First Class mail at direction of Chairman ;
Bechhoefer):
Original and two copies to: One copy to:
Rulemakings and Adjudications Staff OfTice ofCommission Appellate Adjudication (Mail Stop 0-16-Cl) (Mail Stop 0-16-C1)
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1 White Flint North I White Flint North 11555 Rockville Pike 11555 Rockville Pike RockMilE M&f0852-2738 Rockville, MD 20852-2738 Tel. (301) 415-1675) Tel. (301) 415-2184)
One copy to:
Thomas G. Dignan, Jr., Esq. Deborah B. Katz, President Ropes & Gray Citizens Awareness Network, Inc.
One International Place P.O. Box 3023 Boston, MA 02110-2624 Charlemont, MA 01339-3023 Tel. (617) 951-7511 Tel. (413) 339-5781
II
- ,w 4 :
- Docket no. 50-029-L4 Page 2 CERTIFICATEOFSERVICE FOR NECNP...
One copy each to:
One conv to:
Atomic Safety and Licensing Board Thomas S. Elleman, Administrative Judge, Charles Bechhoefer, Chairman, and Atomic Safety and Licensing Board Thomas Murphy, Administrative Judge . 704 Davidson Street
' (Mail Stop T-3 F23) Raleigh, NC 27609 U.S. Nuclear Regulatory Commission 2 White Flint North Diane Curran 11545 Rockville Pike Rockville, MD 20852-2738 Harmon, Curran, Spielberg & Eisenberg 2001 'S' Street, N.W., Suite 430 Tel. (301) 415-7399 Washington, D.C. 20009 Tel. (202) 328-6874 James L. Perkins, President Adam Laipson New England Coalition on Nuclear Pollution Franklin Regional Council of Governments P.O. Box 545 -
425 Main Street Brattleboro , VT 05302 Greenfield, MA 01301 Tel. (802) 257-0336 Tel. (413) 774-3167
&n W 1athan M. Block, Counsel for NECNP Ihe followine oersons were served the above referenced materials as a courtesv:
David Rothstein U.S. EPA Region I Suite 1100-RCA 1 Congress Street Boston, MA 02114-2023 Ted Bolen, Esq.
Environmental Protection Division Officebf 5e Aw&rney General 200 Portland Street Boston, MA 02114 January 2,1999 ., s 2
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