ML20198N238

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Declaration of M Resnikoff.* Declaration of M Resnikoff Re Info Contained in Contentions Submitted by CAN in Response to Yaec License Termination Plan for Yankee Rowe Nuclear Power Station
ML20198N238
Person / Time
Site: Yankee Rowe
Issue date: 01/02/1999
From: Resnikoff M
RADIOACTIVE WASTE MANAGEMENT ASSOCIATES
To:
Shared Package
ML20198N159 List:
References
99-754-01-LA-R, 99-754-1-LA-R, LA, NUDOCS 9901060062
Download: ML20198N238 (16)


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UNITED STNITS OF AMERICA NLJCLEAR REGULATORY COMMISSION Before the ATOMIC SAFETY AND LICENSING BOARD I 1

Administratisc Judges-Charles BechWefer, Chariman Dr. Thotr'ses S. Ellman .

Thomas D. Murphy la the Matter of Docket No. 50-029-LA YANKEE ATObHC ELECTRJC COMPANY l ASLBP No. 99-754-01-LA-R (Yankee Nuclear Power Station) l .

License Termmation Plan l l l

DECl AllAIlON OF DR. MAllyIN RESNIKOIT 1, Dr. Marvin Resnikoff, declare under penalty of perjury that:

1. I am the Senior Associate at Radioactive Wa:,te Management Associates, a private consulting firm based in New York City. A statement of my qualificatium is anached hereto as Exhibit A.

2.' E am thmiliar with the License Termissation Plan application. J am also famikt with and have reviewed the documents in this case lined as Exhibit B.

3. I assisted in the prepar ation of, and have reviewed the Citizen Awateiwst Network's contentions subnntted in this pwoooding. The techmca) facss presented in the contentions are true and correct to the best of my knowledge, aiwi the conclusions drawn from those facts are based on my best praksionaljudenwns.

DATED: This 2 %) day of dasasa.H ,1993

/

Nf 'iarvin stu off /'

S 'or Associate dioactive Waste Maagement Associates

, 526 W. 26* Street Roorii 517 New York, NY 10001 9901060062 990105

{DR ADOCK 05000029 PDR O

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Exhibit A Page A-1 Exhibit A. Resume of Marvin Resnikoff, Ph.D.

Dr. Marvin Resnikoffis Senior Associate at Radioactive Waste Management Associates and is an international consultant on radioactive waste management issues. lie is Principal Manager at Associates and is Project Director for risk assessment studies on radioactive waste facilities and transportation of radioactive materials. Dr. ResnikotThas concentrated exclusively on radioactive waste issues since 1974. lie 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 Enviromnental Protection Agency, the Wayne and Maywood, New Jersey thorium Superfund sites and on proposed low-level radioactive waste facilities at Maninsville (Illinois), Boyd County (Nebraska), Wake County (Nonh Carolina), Ward Valley (California) and Hudspeth County (Texas). He has conducted studies on transponation 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, ll!inois 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 thorium contamination and served as an expen witness for j plaintitTs A Muzzey, S Bryan, D Schroeder and assisted counsel for plaintiffs KL West and KA  !

I West. He is presently serving as an expert witness for a separate group of plaintiffs in West Chicago, including R Dassion. He also evaluated radiation exposures and risks in worker compensation cases involving G Boeni and M Talitsch, fonner workers at Maywood Chemical Works thorium processing plant.

Under a contract with the State of Utah, Dr. ResnikotTis a technical consultant to DEQ on the proposed day 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 investi6ated 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 Northwatch 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 I Uranium Coalition in Environmental Impact Statement hearings before a Federal panel regarding the environmental impact of uranium mining in Northern Saskatchewan. He has also worked on behalf of the Morningside Heights Consortium regarding radium-contaminated soil in Malvern and on behalf of Northwatch regarding decommissioning the Elliot Lake tailing 2 area before a FEARO panel. More recently he completed a study for Concemed Citizens of Manitoba regarding transponation 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 anicles, fact sheets and repons, for-mutating policy and networking with numerous environmental and public interest organizations and the media. He is author of the Campaign's book on " low-les el" waste, l.ning Without landfills, and co-author of the Campaign's book, I)eadly Deferne, A Citi:en Guide to Mditary Landfills.

Between 1981 and 1983, Dr. ResnikofTwas 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 Ne.xt Nuclear (iamble. Transportation and Storage ofNuclear Waste. The CEP study details the hazard of transponing irradiated nuclear fuel and outlines safer options.

Exhibit A Page A 2 in February 1976, assisted by four engineering students at State Unisersity of New York at BufTalo, Dr. ResnikoiT authored a paper which changed the direction of power reactor decommissioning in the United States. His paper showed that power reactors could not be entombed for long enough penods to allow the radioactisity to decay to safe enough levels for unrestricted release. The presence oflong-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. ResnikofTis 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 Bamwell, South Carolina nuclear fuel reprocessing facilities.

His paper on reprocessing economics (Environment, July / August,1975) was the first to show the marginal 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 that reactors would remain radioactive for hundreds of thousands of years.

Dr. ResnikofT has prepared reports on incineration of radioactive materials, transportation ofirradiated fuel and plutonimn, reprocessing, and management oflow-level radioactive waste. ,

He has served as an expert witness in state and federal court cases and agency proceedings. He I 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 loca! thorium waste dump, to WARD on 1 disposal of radium wastes in Vernon, New Jersey, to the Southwest Research and Information Center and New Mexico Attorney General r, shipments of plutonium-contaminated waste to the WIPP facility in New Mexico and the State af 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 Airpon, and transport ofirradiated fuel through New York City, and to the Illinois Attorney General on the expansion of the spent fuel pools at the Morris Operation and the Zion reactor, to the Idaho Attomey General on the transportation ofirradiated submarine fuel 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 i Society to discuss the risk of transponing plutonium by air. As part of an international team of I experts for the State of Lower Saxony, the Gorleben Intemational 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 Inquity on behalf of the Town and Country Planning Association (England) on transporting nuclear fuel through London. In July and August I 1989, he was an invited guest of Japanese public interest groups, Fishermen's Cooperatives and the Japanese Congress Against A- and H- Bombs (Gensuikin)

Between 1974 and 1981, he was a lecturer at Rache' Carson College, an undergraduate environmental studies division of the State University of N .w York at Buffalo, where he taught energy and environmental courses. The years 1975-1977 he also worked for the New York Public interest Group (NYPIRG).

In 1973, Dr. ResnikofT was a Fulbright lecturer in panicle physics at the Unis ersidad de j Chile in Santiago, Chile. From 1%7 to 1973, he was an Assistant Professor of Physics at the State University of New York at BufTalo. He has written numerous papers in particle physics, under grants from the National Science Foundation. He is a 1965 graduate of the University of ,

Michigan with a Doctor of Philosophy in Reoretical Physi;s, specializing in group theory and  !

particle physics.

Exhibit A Page A-3 Dr. Marvin Resnikoli Radioactive Waste Management Associates 526 West 26th Street, Room 517 24i W.109* St, Apt. 2A New York, NY 10001 New York,NY 10025 (212)620-0526 FAX (212)620-0518 (212)663-7117 EXPERIENCE:

April 1989 - present Senior Associate, Radioactive Waste Management Associates, management of consulting firm focused on radioactive waste issues, evaluation of nuclear transportation and military and commercial radioactive waste disposal facilities.

l 1978 - 1981; 1983 - A?ril 1989 Research Director, Radioactive Waste Campaign, directed research program for Campign, including research for all fact sheets and the two books, l.iving K about I.andfills, and Deadly Defeme.

The fact sheets dealt with low-level radioactive waste landfills, incineration of radioactive waste, transportation of 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 produced the report 7he Next Nuclear Gamble, on transportation and storage of high-level waste, 1974 - 1981 Instructor, Rachel Carson College, State University of New York at Buffalo, 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 Environmental Protection Agency.

1975 - 1976 Project Cooi linator, SUNY at BulTalo, New York Public interest Research Group, assisted students on research projects, including project on waste from decommissioning nuclear reactor.

J 1973 Fulbright Fellowship at the Universidad de Chile, conducting research in elementary particle physics.

1967 - 1972 Assistant Professor of Physics, SUNY at BulTalo, conducted research in elementary particle physics and taught range of graduate and undergraduate physics courses.

1965 - 1967 Research Associate, Department of Physics, Unisersity of Maryland, conducted research into elementary particle physics.

EDUCATION University of Michigan PhD in Physics, June 1965 Ann Arbor, Michigan M.S. in Physics, Jan 1962 B.A. in Physics / Math, June 1959 l

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  • Exhibit A Page A-4 Publications 1985/1998 January 1985 "U.S Radioactive Landfill Experience," paper, presented to the Annual Institute of British l Geographers in Leeds, England Incorporated into Nuclear Power in Crisis: Politics and Planning l for the Nuclear State, edited by Blowers, A., and Pepper, D , Nichols Publishing Co. (1987). 4 j- February 1985 " Comments on the transportation sections of the dratl Environmental Assessment for a high l level waste repository in Utah," prepared for the State of Utah l March 1985 Testimony before the House Committee on Interior and Insular Affairs on the long-lived hazard of" low-level" radioactive waste.

l May 1985 " Radioactive Waste incineration in Bladen County, What's Coming Out of the Stack?,"

Campaign repon on the environmental impact ofincinerating ra.iioactive waste in Bladen County, North Carolina,33 pages.

August 1985 Paper submitted to the llouse Energy and Commerce Committee, on the hazard oflong-lived J low-level waste.

1 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 j insulst AfTairs l l

February 1986 ' Alternatives to Radioactive Landfills, An Environmental Perspective," paper presented at i the International Symposium on Alternatives to Rad.oactive Landfills, Chicago,111 Paper incorporated in the Proceedings, published by the Illinois Dept of Nuc! car Safety and the Central Midwe* Compset Commission June 1986 " Feed Materials Production Center, Uranium Contamination ofOff-site Wells," Campaign report prepared with Dans Coyle on the health impact of uranium contamination of off-site wells, 35 pages.

June 1986 Testimony on behalf of the Northwest inland Waters Coalition, a public interest organization, l for the Federal District Coun, 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

  • aper on the Kerr-McGee uranium conversion facility near Salisaw, Oklahoma presented to conference organized by Native Americans for a Clean Environment July 1986 September 1986 Aflidavit in Federal Court in New York City on behalfora Warwick, New York public interest group (WARD), and in New Jersey State Courts on behalf of the New York-New Jersey Trails Conference, opposing plans by the New Jersey Department of Environmental Protection to move radium residues from Montclair to Vemon, New Jersey August,1986 Supplement to June 1986 Campaign report on the Feed Materials Production Center discussing contamination of public water supplies, 20 pages September 1986 " Disposal of high-lesel waste in Canada," paper preser.ted at high-level waste conference, l

Winnipeg, Manitoba Workshop on the transportation ofirradiated fuel in Canada. Incorporated

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Exhibit A Page A-5 into Challenges to Nuclear Waste, Proceedings of Nuclear Waste issues Conference, Sept 12-14, 1986, edited by Weiser, A , Concerned Citizens of Manitoba, Winnipeg, Manitoba,1987.

Nosember 1986 Associates repon to the State of Kansas on dratl Request for Proposal for contractor to the Central States Compact,10 pages.

November 1986 "Transponation ofirradiated fuel," paper presented to a subcommittee of the National Association of Attorneys General, Las Vegas, Nevada December 1956 Associates aMdavit prepared for the Coalition on West Valley Nuclear Wastes and the

, Radioactive Waste Campaign in a successful U S. District Court action on the need for a federal i Environmentallmpact Statement before disposing oflow-level waste at West Valley.

February 1987 "OtT-site radioactive contamination at DOE's Oak Ridge, Tennessee facility," Campaign report prepared witn Dana Coyle on radioactise leakage from the Oak Ridge Reservation,65 pages May 1987 "At-reactor storage ofirradiated fuel," paper presented at conference sponsored by Blue Ridge Environmental Defense League and other citizen organizations at Maryville, Tennessee.

June 1987 Associa:es afEdavit prepared for the Sierra Club Legal Defense Fund on the need for an Environmental Impact Statement before incinerating plutonium-contaminated waste at the Rocky Flats Plant.

Septeinber 1987 1.srang }rnhilavalji/Is, Campaign book on the hazard of radioactive landfills, and safer alternatives,119 pages September 1987 Associates afEdavit prepared on behalf of the Alaska Attorney Generalin a U.S. District Court action on the need for a federal Environmental impact Statement for air shipments of l

plutoniumin Alaska November 1987 " Low-level waste in Michigan," talk before a joint session of the Michigan Legislature, East Lansing, Michigan February 1988 Testimony befoie the Yemom tiouse Committee 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 l.

June 1988 Co-authored the Radioactive Waste Campaign's lhlly lAA nw,170 page book on radioactive l 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 llw dump sites, jointly.

sponsored with local groups (Individuals for a Clean Environment)

July 1988 Briefmg before Congressional Legislatise Assistants on the fmdings of fkudlylAA nse, jointly conducted with the Sierra Club and sponsored by Representatis e Don Bonker.

September 1988 Reno, NV, talk before Northern Colorado Gaming Executives re. transportation of l

irradiated fuel to a proposed high-lesel w aste repository, jointly sponsored by Citizens Alert and State of Nevada i

i September 1988 " Rebuttal of NRC Critique ort.itmg Wuhilausd/ ills,12 pages.

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Exhibit A Page A-6 j l

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October 1988 Boulder, CO, talk, panicipation in conference and chapter of book, Environmental impacts l

of Warfare; sponsored by the Sierra Club.

. Noven"wr 1988 Nucla, CO, prepared testimony before Colorado Department ofIlealth re. suitability of proposed " low level" waste disposal site in Uravan, Colorado on behalf of Western Colorado Congress November 1988. Augusta, Maine, participation in debate sponsored by the Maine Low-Level Radioactive '

- Waste Authority thW 1988 Preparation of coun affidavit re. proposed irradiated fuel shipments from Taiwan through l Portsmouth, Virginia, before the United States District Court, District Of Columbia, on behalf of the Sierra Club Legal Defense Fund 1

February 1989 " Uranium Releases at Femald, Radiation Doses to Nearby Residents," report released by ,

the Radioactive Waste Campaign at Cincmnati, Ohio press conference. l i  ;

! April 1989 " Risks of Low-Level Radioactive Waste Transportation," 8-page fact sheet, prepared for the Radioactive Waste Campaign.

i l May 12,1989, " Preliminary Report on Rl/FS Study,' prepared on behalf of Maxey Flats Concerned  :

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! Citizens, Flemingsburg, Kentucky. '

l. l lq-  : August 30,1989, " Analysis of RADTRAN Computer Model," paper presented at meeting of the American l' Nuclear Society Meeting, Las Vegas, Nevada i

! October 1989 " Report on Maxey Flats Remediation Program " 75-page report, prepared for Maxey Flats Concerned Citizens, Inc.

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l November 1989 "RADTRAN ' Analysis," 60-page report on the probability and consequences of accidents i l< in transponing high-level waste to the proposed Yucca Mountain repository, prepared for the  ;

l' University of Nevada, Las Vegas )

l February 1990 "Radioactise Waste Mismanagement at Nine Mile Point I

  • April 9,1990 " Comments on the Final Supplemental Environmental Impact Statement, Waste Isolation Pilot Plant," on behalf of Concerned Citizens for Nuclear Safety, Santa Fe, New Mexico.

, April 25,1990, talk before the llazardous Materials / Nuclear Symposium on nuclear transportation issues, Ely, Nevada.

! , April 26,1990, Statement before the Nevada Commission on Nuclear Projects on nuclear transponation l issues, Las Vegas, Nevada l.

! - July 19,1990, " Report on Feasibility Study, Risk Assessment, App D, iodine hazard," prepared on behalf

- of Maxey Flats Concerned Citizens, Flemingsburg. Kentucky.

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l. August 1,1990, " Report on the State of Kentucky, Maxey Flats Closure Plan," prepared on behalf of
Maxey Flats Concerned Citizens, Flemingsburg, Kentucky i'

. August 1990 Preparation of second coun affidavit re. proposed irradiated fuel shipments from Taiwan

- through Portsmouth, Virginia, before the United States District Court, District Of Columbia, on behalf of the Sierra Club Legal Defense Fund.

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Exhibit A Page A-7 September 1990 "The Generetion Time-Bomb Radioactive and Chemical Defense Wastes," in Rdlen Ikmgers, Dnmm:nentalt'omequences of Preturmgfor War, edited by Al1 EhrIich and JW Birks, Sierra Club Books, San Francisco October 22,1990, " Review of Environmental Report for the Central Interstate Compact Low-level Radioactive Waste Facility," on behalf of Heartland 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, District of Nebraska on behalf of Concerned Citizens of Nebraska.

December 1990 Preparation of third court aflidavit te proposed irradiated fuel shipments from Taiwan through Portsmouth, Virginia, before the United States District Court, District OfColumbia, on behalf of the Sierra Club i egal Defense Fund.

February 8,1991, " Review of' Risk Assessment and Safety Anal) sis, University of Michigan Waste Handling Facility,' on behalf of No Campus Residents Council, Ann Arbor, Michigan.

April 1,1991, " Health and Safety impact of NMI," on behalf of Citizens Concerned About NMI, Concord, Massachusetts May 6,1991, " Comments on Final Environmental Impact Statement, Prairic Island independent Spent Fuel l Storage Installation," on behalf of the Sioux Tribal Council, Red Wing, Minnesota May 16,1991, " Managing Low-Level Radioactive Waste," talk at Future Options Symposium, I

international Institute for Low Level Radioactive Waste, East Lansing, Michigan.

1 May 23,1991, "Radiac Accident Analysis," prepared on behalf of the Rad'oactive 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 OtT-Site Fuels Policy," prepared on behalf of the Sierra Club Legal Defense Fund, Washington, D C.

July 1,1991, " Comments on the Final Environmental Impact Statement for the Proposed Ward Valley Low-level Waste Landfill," submitted to the Califomia Department of Health Services, on behalf of Don't Waste California-l July 12,1991, " Comments on EPA Proposed Plan," prepared on behalf or Maxey Flats Concerned Citizens, Flemingsburg, Kentucky September 8,1991 Preparation of 4th court ailidavit te proposed irradiated fuel shipments from Taiwan through Portsmouth, Virginia, before the United States District Court, District Of Columbia, on behalf of the Sierra Club Legal Defense Fund September 20,1991 " Consequences of a Sesere HEU Ship Accident," memo to Greenpeace j September 30,1991 " Prairie Island independent Spent Fuel Storage Facility, Cost and Radiation

! Analysis," before the Minnesota Public Utility Commission on behalf of the Prairie Island l Mdewakanton Sioux Indian Community I

i Exhibit A Page A-8 October 23,1991 " Health and Safety impacts of NMI,2nd Report," prepared on behalf of Concerned Citizens about NMI, Concord, Mass October 31,1991 Preparation of 5th coun alEdavit re. proposed irradiated fuel shipments from Taiwan )

through Ponsmouth, Virginia, before the United States District Court, District Of Columbia, on j behalfof the Sierra Club Legal Defense Fund ,

i Nosember 4,1991 Statement before the City of Albuquerque Common Council regarding disposal of t radioactise waste into the city sewer system. i November 9,1991 A!Edavit re. shipments of Pu<ontaminated waste to the proposed WIPP facility, before the US District Coun, District of Columbia, on behalfof the New Mexico Attorney General.

November 1991 " Prairie Island independent Spent Fuel Storage Facility, Prefiled Reply Testimony,"

before the Minnesota Public Utility Commission on behalf of the Prairie Island Mdewakanton  ;

Sioux Indian Community. .

RWM A White Paper #I, Sources off.ow-1.evel Wasse in Cauwcucnt, prepared on t chalf of the Towns of ,

l East Windsor, Ellington and South Windsor, September 30,1911.

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RWMA, White Paper #2, l.ow-lewt Wasse Trattyxersasuus en Cauwctscia, prepared on behalf of the l Towns of East Windsor, Ellington and South Windsor, October 2,1991.

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. RWM A, White Paper #3, Stasemens by I)r. Alarvm Resmkoffm Chem-Nuclear, prepared on behalf of the

Towns of East Windsor, Ellington and South Windsor, October 29,1991.

RWMA, White Paper n4, f.eakage From JOcuturg 'I.vw-l.ewl' Waste lhyswd Facihties, prepared o e i behalf of the Towns of East Windsor, Ellington and South. Windsor, January 6,1992. i Marvin Resnikotiand Anne Vantenterghem, Prehmmary Revsew ofIIS Ecology Safety Analysis Report, l Preynned BoniCounty, Nebraska 1.uw-l.ewi Waste Facshly, prepared on behalf of the Boyd County Local Monitoring Committee, February 2,1992.

1 Marvin ResnikotY, Radnas Releasesfrenn ifran<um Taihngs and Projected Heahh l]fects, prepared on l l.

l behalf of Nonhwatch Coalition, February 17,199' i y

l RWMA, White Paper #5, S#orage of/.ow-l.cwl Raduxscuw Wasse, prepared on behalf of the Towns of

! East Windsor, Ellington and South Windsor, February 19,1992 Marvin ResnikotT, Scryw: AlcArthur Riwr and Utgar lede Projects, Memo to Inter Church Uranium Council, February 27,1992 Richard Leigh, Marvin ResnikotTand Anne Vanrenterghem, /Osrsronmensalimpacts ofEthos /2de Aldt

[ huhngs, prepared on behalf of Nonhwatch Coalition, March 30,1992.

Marvin ResnikotY, Casuahan #sgh-lewl Wasic Refunnory Cosa. Memo to David Poch and David Argue, Coalition of Environmental Groups, April 2,1992 p

l Minard Hamilton, l.uw I.cul Wenic Facshtws m C<usado mulile ll.S., repared on behalf of Northwatch

! Coalition, April 22,1992.

Marvin Resnikoff, Canment me Abdaest tonu l' ensure E/S, Memo to Inter Church Uranium Council, April 23,1992.

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[ Edibit A Page A-9 Beniamin A. Goldman, Review ofIOntronmental Retwrt SocialwulEctnunnicImluct Aswuments:

Preymsedlow-l.ewt Radunctne Waste Dopoud lincdsty, prepared on behaif of Northwatch Coalition, June 25,1902:

Lee DiTullio' and Marvin ResnikotT, Rerww ofSafety Arulym Report Part 1: Geology, Ilydrtdogy Preymredlow-lew/ Waste Facday Rutte, NebrasAa, prepared on behalf of the Boyd County Local '

Monitoring Committee, June 29,1992 l

Marvin Resnikoff, Mythbu'sterw8, " low-l.evel" Raduuctnv Wcnte, for Safe Energy Communications

. Council, Summer 1992.

Marvin ResnikotT. Canments <xu Fnul Guadeluwsfor the Preturatum ofan EnvorownentalImpact Statement em dw Nuclear Fuel Waste Afanagement wulDntmud Concept, July 22,1992; i

Marvin Resnikoti, NMPs Prrym.wd Hydrennet Project, Memo to Judy Scotnicki, Concerned Citizens of

Concord, July 29,1992.  ;

i Marvin ResnikofTand Lee DiTullio, Rerww of Safety Amdy.m Report Part 2: Risk Auexunent Prcqwsed L

low-lewi Wasic Facihty Rutte, Nebraska, prepared on behalf of the Boyd County Local Monitoring .

, ' Committee, August 7,1992.

l l' RWM A, Canments on Md */ean /. ale Project E/S, prepared on behalf of the Inter-Uranium Coalition, June

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- Lee DiTullio and Karen Levine, Crunments on Cluff1. ale EIN, prepared on behalf of the Inter-Church Uranium Coalition, July 20,1992.

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^ Marvin Resnikoti, Plut<nuum Ship Akatsuki Alaru Connettuences of Fire at the Pearl Harbor Nam! -

Shipyurd, prepared on behalf of Greenpeace, August 24,1992 Marsin ResnikotT, Waste Impucts of the Nuclear Fuel Cyr/c, prepared on behalf of Coalition of

Environmental Groups, November 1992.

Marsin Resnikoti, Declarations on the safety of shipping naval fuel from shipyards to Idaho before the l Federal District Court, prepared on behalf of the Idaho Attorney General, March 1993.

Marvin Resnikoff, Declaration on the safety of the VSC-24 storage cask before the Federal District Court on behalf of the Lake Michigan Federation, May 1993  ;

l Marvin ResnikotT, Talk at a Town Meeting in Grand Rapids, Michigan, June 22, regarding the safety of the j VSC-24 storage container at the Palisades reactor.

L ' Marsin Resnikoff, Reports to two environmental assessment panels reviewing the environmental impact of

. proposed mining operations in Northern Saskatchewan, prepared on behalf of the Interchurch Uranium j Coalition, May 12 and June 14,1993.

Marvin ResnikotT, Presentation before the Ohio Governor's Blue Ribbon Committee on siting a low-level

waste facility in Ohio for the Midwest Compact. July 1993 Mar in ResnikotT, Report on the safety of processing and storing radium-contaminated wastes in the Tepscott district ofScarborough, Toronto, prepared on behalf of the Coalition Against Radioactive j l apscott, November 1,~ 1993.

L F Marvin ResnikolT, Remarks befor: the Department of Energy meeting on the Multi-Purpose Canister, j i

t Washington, D C., Nosember 16,1993.

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1 Exhibit A Page A-10 Marvin ResnikotT, 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 dratt EIS by Rio Algom for the decommissioning of Quirk and Panel tailings, Elliot Lake, prepared on behalf of Algoma. 1 Manitoulin Nuclear Awareness, December 15,1993.

Resnikoff, M and Haaker, R," 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 Resnikoti, M znd Fuchsman, P," Comments on the Department of Energy's Baseline Risk Assessment for the Wayne Site, Wayne, New Jersey, January 1994," May 31,1994.

ResnikotT, M," Radiation Dose Exposures Received by William Davis During Lens Polishing Operation,"

report prepared for the case Davis v Transe!co et ut, July 1,1994 i

Leigh, RL and Resnikoff, M," 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.  ;

l Resnikoff, M, AfEdavit prepared on behalf of plaintitTs in the United States District Court for the Eastern District Of Tennessee at Knoxville, Euchee Marina & Campground, Inc. ci al plaintitTs, v Union Carbide Corporation, et al, defendants, July I 5,1994.

- Resnikoff, M and_ Knowlton, K," Preliminary Critique of the Safety Analysis Report, Wake /Chatham Proposed Low-Level Waste Facility," report prepared for the l' Chatham County Preferred Site Local Advisory Committee, July 19,1994.

Resnikoff, M, Leigh, RL and Fachsman, P " Comments on the Departrr. nt of Energy ~ s Baseline Risk ,

Assessment for the Maywood Site, Maywood, New Jersey, April 1993,"

July 27,1994 j Resnikoff, M. "Pretiled Testimony Of Marvin ResnikotT, 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 Located in the Town of

. Two Creeks, Manitowoc County, September 11,1994 Also Rebuttal Testimony, dated September 27, 1994 and Suplementti Testimony, dated October 3,1994 Resnikoff, M, athavit prepared on behalf of plaintitTs in the United States District Court for the District of Massachusetts, Citizens Awareness Network, Inc , plaintitT, v United States Nuclear Regulatory Commission, defendant, October 4,1994-Resnikoff, M, afEdavit in opposition to motion of Westinghouse for summary judgment, prepared on behalf of plaintiffs in the United States District Court for the Western District Of Washington at Yakima, in

re Hanford Nuclear 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

  • All publications in the year 1995 hase appeared since my Rule 26 statement in the Muzzey/ Bryan case

+ x.

Edibit A Page A-11 Resnikoti, M. " Ohio low-level waste legislation," Lobby Day, Ohio Environmental Council Border Opposes Nuclear Dump," February 22,1995 Fuchsman, P, llamilton, M, Knowlton, K, Levine, K and ResnikotT, M. " Wayne llealth Survey," prepared for the Town of Wayne, April,1995.

Knowlton, K and Resnikiti, M. "A review of the phase 11 field insestigation and financial resources of NMI," repon prepared for CREW, May 22,1995.

ResnikotT, M. Knowlton, K and Fuchsman, P, "I ow-level waste transportation in Texas," prepared for Alen Citizens for Environmental Safety, June 29,1995 Resnikoff, M and Knowlton, K," Comments on ' Engineering evaluation / cost analysis for the cleanup of 4 residential and municipal vicinity fropenies at the Maywood site, Bergen County, New Jersey,'" on behalf of Concerned Citizens of Maywood, August 11,1995.

Resnikoff, M. Fuchsman, P and Knowlton, K, " Low-level waste transportation in North Carolina,"

prepared for the Chatham County Preferred Site Local Advisory Committee August 13,1995.

Edelman, G and Fuchsman, P," Business survey on the Socioeconomic impact of the low-lesel radioactive waste facility proposed for North Carolina," prepared for Chatham County, August, 16,1995 ResnikofT, M, Knowlton, K and Fuchsman, P," Comments on environrnental impact statements for the Cigar Lake and Midwest joint Ventures proposals," prepared for the Saskatchewan Uranium Coalition, October,27,1995 Knowlton, K, Resnikoff, M and Fuchsman, P," Review of the license application for the Proposed LLRW facility near Sierra Blanca, Texas," prepared for Alert Citizens for Environmental Safety," November 30, 1995.

ResnikotT, M," Scoping Comments for the Environmental impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and thgh-Level Radioactise Waste at Yucca Mountain, Nye, County, Nevada, December 1,1995.

ResnikotT, M," Calculation of Radiation Exposures Received by Donald A. Schroeder, West Chicago, Illinois." Prepared for case Schroeder v Kerr-McGee, February 21,1996 ResnikotT, M K Knowlton, and K island," Comments on Environmental impact Statement for the McAnhur River Proposal," prepared for Saskatchewan Uranium Coalition, March I,1996.

ResnikotT, M K Knowlton, P Fuchsman, and K island," Site Suitability and Impact of Proposed Radioactise Waste Facility, Wake /Chatham Counties, North Carolina," prepared for Chatham County Preferred Site Local Advisory Committee, March 20, f 996 ResnikotT, M," Mississippi Oil and Gas 150 aid Proposed Rule 69 Control of Oilfield NORM," March 25, 1996 ResnikotT, M,"Before the Illinois LLRW Task Group: Comments on Revised Siting Criteria," May 15, 1996 Resnikoti, M," Decommissioning of Big Rock Point," prepared for Don't Waste Michigan - Northern Chapter, July 1996 ResnikotT, M," Preliminary Repon: Occupational Exposures for PlaintilYs Garza and ikpain from Uranium Solution Mining Activities, Bruni, Texas" July 31,1996

I . .

Exhibit A Page A-12 RWMA," Comments on the IRP Remedial Design Work Plan, Maxey Flats Kentucky," prepared for Maxey Flats Concerned Citians, August 2,1996  ;

Knowlton K, and M ResnikotT," 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) t Resnikoti, M," Radiation Dose Exposure Received by Milt Vercher During Oil Pipe Cleaning Operations,"

September 27,1996.

ResnikotT, M, and K Knowlton,-Comments on the Department of Energy's Dran Feasibility Study and Dran Record of Decision for the Wayne, New Jersey Site " October 15,1996.

Knowlton, K, M Medina, and M Resnikoti," Comments on Fall 19% AJJesulums to JEB Pit Tailings Disposal Plans," prepared on the behalf of the Saskatchewan Uranium Coalition, December 2,19%.

Resnikoti, M , Critique ifOstm Hydro irradoated Fuel hanynelatum Auessment, prepared on behatf of Concerned Citizens of Manitoba, January 1997.

ResnikotT, M , and Waligora, Jr., S J., lhamated RaJoatoon ikam Rece:wJ by I'ocaw Ferguum, Alartha, Kensucky, report prepared in the case, Victor Ferguson v. Ashland Oil Inc, et al, January 16,1997.

Resnikoff, M.," Preliminary Report, Environmental and llealth-Related Impacts of the Mobil Miaing and Minerals Phosphoric Acid Plant," February 1997.'

ResnikolT, 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, on behalf of the Prairie Island Indian Community, February 1997. ,

1

' Resnikoti, M , *C<xnments <m Davirummental Afarurgement AJvivey RourJ Reptet ' Report ofa Stakeholder Proceu to Dewhqu Guidmg PrmcqJesf<w the Fewmerly Iluli:ed Saes Remedsul Actum Project.

Rockgromullnf<smanem ik;cument." prepared on behalf of Thorium Advisory Committee, Town of Wayne, New Jeney, March 7,1997 ResnikotT, M , Comments Un ' Report ofa Stakeludder Proceu te ikwhy> Guidmg Prmciplesfor the Fremerly i1rJ :ed Saes RemeJoal Actwn Project, RackgrennulInf<wmanon Ik>cument, prepared on behalf of Concerned Citizens of Maywood, Maywood, New Jersey, March 12,1997.

ResnikotT, M., Waues Generated m Ikconnamnunmg wulDecommonwoung a Nuclear Pou er Phuu, presented at the conference, " Impacts of Nuclear Power and Nuclear Waste on Indigenous and Local Communities, Prairie Island Indian Community," March 25 26,1997.

ResnikotY, M. " Radiation Risks on Reclaimed Phosphate Mined Lands," April 30,1997.

ResnikotT, M., andChampion, A , hanyswaanon Accodent ofSlup Carrymg l'anped High-l.ewi Radwacaw Waste: Part I. Impact <m the Federated States ofAhcr<mesia, prepared on behatf of Greenpeace Pacific, July 31,1997.

Resnikoti, M., Prepared statement before the Joint Federal-Provincial Panel on U Mining on Cigar Lake and McArthur River, on behalf of the Saskatchewan Uranium Coalition August 27,1997.

Resnikoti, M ," Comments on the Department of Energy's Dratl Feasibility Study and Drail Record of Decision for the Wayne Site," prepared on behalf of Thorium Advisory Committee, Town of Wayne, New Jersey, Sept 15,1997.

Exhibit A Page A-13 ResnikofT, M.," Presentation Before Panel on the Waste Management System, Nuclear Waste Technical Review Board," November 19,1997.

Fairlie, ! , and Rew wi , No lksv /<us / nw, anicle prepared for The ilulletin of The Atomic Scientists, November /Decem, s w 7.

ResnikotT, M., Calculation ofRadiation Exposures Received by Rebekah Dassion, prepared on behalf of11 agens & Berman as part of a federal personal injury case,  :

November 23,1998.

ResnikotT, M., Comments on Prelunmary Safety Evaluatwn Report and Propo.,ed Cert:Jicate ofCompliance HI-Star 100 Storage rask, prepared on behalf of The State of Utah, Department of Environmental Quality, October 26,1998.

7 pp.

ResnikotT, M., and Tsui, C., Heahh Impacts of Od Productwn m Brookhaven.

Ahssi3sippi prepared on behalf of Sacks & Smith, July 30,1998. i 34 pp.

! ResnikotT, M., Comments on FGR No.13. Part i Interun l'erswn Health Risksfrom Low-Level Environmental Exposure to Radionuchdes, June 30,1998.

2 PP.

ResnikofT, M., Radwactive li'a3te Tresidy, prepared on behalf of the Chatham County J l

PSLAC, June 1998 l i

l 8 pp.

ResnikotT, M., Comments on Draft PKISjor the Long-Term Afanagement and Use of Depleted Urantum Hexajiuoride, March 1998.

3 pp.

Resnikoff, M., Affidavit prepared for Giordano, llalleran, & Ciesla,in the case Robert Kenny v. Shore Regional High School, et al., March 1998.

7 pp.

ResnikotT, M., Comments on the drall Safety Evaluatwn Report (DSER), Proposed LLRIl'Facdoty at Boyd County, Nebraska by the State ofNebraska, prepared on behalf of the Boyd County Monitoring Committee, February 1998.

31pp.

! ResnikotT, M., Propo3ed Remedeatmn li'ork at Ataxey Flats, prepared on behalf of Maxey Flats Concemed Citizens, January 1991

. 12 PP-e

.____-____._-___._._____._-___.___q t

Exhibit B. Refgrences

1. Berger, J.D., Alanualfi>r Conductmg RadmlogicalSurveys in Support ofI.icense Ternunalmn, 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 Radmactive Contanunation From Decommissioning, Vol. 3, Parameter AnalySos, NUREGICR-5512, Science Applications international Corporation, Albuquerque, NM, U.S. Nuclear Regulatory Commission, Sandia National Laboratories, Albuquerque, NM, April 1996.
3. Comparison ofthe Aladels and Assumptions used in the DandD 1.0, RESRAD 5.61, and RESRAD-Budd Computer Codes wah Respect to the Residential Farmer and Industrial Occupant Scenarios Provided in NUREG CR-SS12, U.S. Nuclear Regulatory Commission, October 1998.

' 4. Daily, M.C., HufTert, A. et al, Working Drafl Regulatory Guide on Release Criteria fi>r Decormaissiomng: NRC Staffs Drallfi>r Comment, NUREG-1500, U.S. Nuclear Regulatory Commission, August 1994.

5. Fmal Rule on I.icense Termmation, Rule Texts 20.1401 - 20.1406, July 1997.
6. IlufYert, A. M., Meck, R. A., and Miller, K.M., Rackground as a Re3idual Radit> activity Cruermnfiar Decommissiomng, NUREG-1501, U.S. Nuclear Regulatory Commission, August 1994.

. 7. Kennedy, Jr., W.E. and Strenge, D.L., Residual Radioactive Contamination From Decommissioning Vol.1, NUREGiCR-5512, Battelle Memorial Institute, October 1992.

8. Alemorandum and Order in the Mauer of Yankee Atomic Electric Company, U.S.

L Nuclear Regulatory Commission, October 1998.

9. Radmlogical Crueriafi>r I.scense n>rminatirm; Final Rule and Radudogical Criteria fi>r I.icense Termmation: Uranium Recovery Facitutes; Proposed Rule - Part 11,10 CFR Part 20, et al., U.S. Nuclear Regulatory Commission, July,1997.

L 10. U.S. Regulatory Umde I.M. U.S. Atomic Energy Commission, June 1974.

I1. Yankee Nuclear Power Statmn 1.icense Ternunation Plan, Revision 0, Yankee Atomic

- Eledric Company, May 1997.

l2. Yankee Nuclear PowerStation 1.icense h rminatmn Plan, Revasion I, Yankee Atomic

, Electric Company, December 1997.

i-5 l

i' l

13. YAEC," Annual Radiological Environmental Operating Report, January-December 1995,"( April 19961
14. K.F. Eckerman, et al," Health Risks from 1.ow-Level Environmental Exposure to Radionuclides, Federal Guideline Report No.13,"(EPA 1998).
15. A. Mancini and R. Applebaum , " Decontamination of Large Components - Test Case," paper presented at ANS Winter Mgeting, Washington, D.C. (November 10-14, j 19%) ,

i l

16. R. Halstead, R. and Ballard, " Nuclear Waste Transportation Security and Safety Issues; The Risk of Terrorism and Sabotage Against Repository Shipments," Nevada  ;

Agency for Nuclear Projects (October 1997). 1

17. Hazel O' Leary, Statement before the Committee on Energy and Natural Resources, U.S. Senate, December 14,1995.
18. G AOff-RCED-93-58," Yucca Mountain Project Management and Funding issues,"

statement of Jim Wells (1993).

19. U.S. Department of Energy, " Acceptance Priority Ranking and Annual Capacity-Report," OCRWM (March 1995).
20. Letter from Edward Boon, Aspen Trailer Company, to Wayne Lewis, Stone &

Webster Engineering Corporation (March 25,1997).

21. NRC Inspection Report 50-29/98-03.
22. NRC Combined Inspection Reports 50-29/98-01 and 50 29/98-02.

g,

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