ML20198R002
| ML20198R002 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 01/03/1998 |
| From: | Chancellor D UTAH, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#198-18725, CON-#198-18728 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9801230195 | |
| Download: ML20198R002 (7) | |
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-UNITED STATES OF AMERICA 2 JAN -9 P4 :14
- NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSI b5NibECIII/III ANUDM N-I$,r-
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In the Matter of:
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Docket No. 72 22-ISFSI
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PRIVATE FUEL STORAOE, LLC ASLBP No. 97-732-02-ISFSI (Independent Spent Fuel
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Storage Installation)
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January 3,1998 i
STATE OF UTAH'S CONTENTIONS SECURITF-A THROUGH SECURITY-I BASED ON APPLICANT'S CONFIDENTIAL SAFEGUARDS SECURITY PLAN introduction The State of Utah hereby submits Contentions numbered Security-A through Security I pursuant to the Memorandum and Order dated December 17,199'/, and subsequent amendments thereto, whereby the Board granted the State of Utah until Monday, January 5,1998 to file any contentions regarding the Applicant's security plan. The State anticipates that the NRC Staff and Applicant will respond to these contentions, thus the State requests in camera oral argument on the protected information contained in these contentions during the pre-hearing conference scheduled for the week of January 26,1998.
In accordance with the December 17,1997 Order, the remainder of this pleading (Contentions and Bases) is being submitted as confidential because it contains protected safeguards information
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.. DATED this 3rd day of January,1998,
. Resp fully submitted,
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Denise Chancellor Fred G Nelson Assistant Attomeys Genem!
Connie Nakahara.
Special Assistant Attomey Genem!
Attomeys for State of Utah
. Utah Attomey Geneml's Office 160. East 300 South,5th Floor-P.O.- Box 140873 Salt Lake City UT 84114 0873 Telephone:
(801) 366-0286 Fax:
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e 00CKETED USNRC CERTIFICATE OF SERVICE -
W JAN -6 P 4 :59 I hereby certify that copics of STATE OF UTAH'S CONTENTIONS 4 SE i
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OFFIC6 SECURITY-A THROUGH SECURITY I BASED ON APPLICANT'S ADJUD:C/, * '
MT CONFIDENTIAL SAFEGUARDS SECURITY PLAN were served on the persons listed below, in accordance with the Pamgraph H.I of the Board's Memorandum and Order dated December 17,1997, by Federal Express this 3rd day of January,1998.
Emile L. Julian, Assistant for Dr. Peter S.12m Rulemakings and Adjudications Administrative Judge Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Office of the Secretary U. S. Nuclear Regulatcry Commission U. S. Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint i1555 Rockville Pike, One White Flint Nonh Nonh Mail Stop T-3F23 Mail Stop 016G15 Rockville, MD 20852-2738 Rockville, MD 20852-2738 (Original only)
Sherwin E. Turk, Esq.
Catherine L. Marco, Esq.
G. Paul Bollwerk, III, Chairman Office of the General Counsel Administrative Judge Mail Stop 015 B18 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission i1555 Rockville Pike, One White Flint 11555 Rockville Pike, One White Flint Nonh North Rockville, MD 20852-2738 Mail Stop T-3F23 Rockville, MD 20852-2738 Jay E. Silberg, Esq.
Ernest L. Blake, Jr., Esq.
Dr. Jerry R. Kline Shaw, Pittman, Potts & Trowbridge Administrative Judge 2300 N Stmet, N. W.
Atomic Safety and Licensing Board Washingto, DC 20037-8007 U. S. Nuclear Regulatory Commission
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11555 Rockville Pike, One White Flint la 1 Stop T-3F23 Mu/. #
Rockville, MD 20852-2738
'De'nise Chance'llor' Assistant Attorney Genem!
State of Utah
CERHFICATE OF SERVICE
' I hereby certify that copies of the Introduction to STATE OF UTAH'S CONTENTIONS SECURITY-A THROUGH SECURITY-I BASED ON APPLICANT'S CONFIDENTIAL SAFEGUARDS SECURITY PLAN but not the Contentions and Bases, were served by First-Class Mail on the persons listed below, this 3'd day of January,1998:
Attn: Docketing & Services Bmnch Jean Belille, Esq.
= Secretary of the Commission land and Water Fund of the Rockies U. S. Nuclear Regulatory Commission 2260 Baseline Road, Suite 200 Mail Stop: Ol6G15 -
Boulder, Colorado 80302 11555 Rockville Pike, One White Flint North Danny Quintana, Esq.
, Rockville, MD 20852-2738 Danny Quintana & Associates, P.C.
(two copies) (U. S. First Class Mall) 50 West Broadway, Fourth Floor Salt lake City, Utah 84101 Clayton J. Parr, Esq.
Parr, Waddoups, Brown & Loveless Office of the Commission Appellate 185 South State Street, Suite 1300 Adjudication P. O. Box 11019 Mail Stop: 16-G-15 OWFN Salt lake City, Utah 84147-0019 U. S. Nuclear Regulatory Commission Washington, DC 20555 John Paul Kennedy, Sr., Esq.
1385 Yale Avenue Salt Lake City, Utah 84105
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DeriIse Chancfilor -
Assistant Attomey General State of Uta 1
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L UNITED STATES OF AMERICA l
NUCLEAR REGULATORY. COMMISSION ATOMIC SAFETY AND LIFFNSING BOARD Before AdministrativeJudges:
1 G. Paul Bollwerk,III, Chairman Dr. Jerry R. Kline
- Dr. Peter S. L am In_ the Matter of
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PRIVATE FUEL STORAGE, LLC
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Docket No. 72 22 ISFSI
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1 (Independent Spent
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Fuel Storage Installation)
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DECLARATION OF WILLIAM J. SINCLAIR 1.-
I am employed as the head of the State of Utah's radiation control program, which includes the NRC Agreement State Program for the State of Utah. I L
have extensive experience in the siting, licensing, and control of radioactive materials and radioactive waste. Also I am the Governor's designee under 10 CFR $ 73.21(c)(iii) for all spent fuel shipment through the State of Utah and the Governor's designee to the Northwest Compact of Low Level Radioactive Waste. A copy of my resume, which further describes my qualifications, is attached.
- 2.
I am familiar with Private Fuel Storage's (PFS's) license application for an Isdependent Spent Fuel Storage Installation (ISFSI) on the Skull Valley Goshute Reservation, and in particular the PFS's Phyrical Security Plan.
3.
I assisted in the preparation of, and have reviewed, the State of Utah's Contentions regarding the PFS Physical Security Plan The technical facts presented in those contentions are true and correct to the best of my knowledge, and the conclusions drawn from those facts are based on my best professional judgment.
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William J. Sinbi'r Date:
/D./RF/97 I
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CURRICULUM VITAE.
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- William J, " Bill" Sinclair -
! 378 South 775 East j
- L'ayton, Utah ~ _84041 j
.i Educational
Background:
1 B.S.E.H. and M.S.E.H. (Bachelor and Master of Science in
- Environmental Health), East Tennessee State University Certifications:-
Registered Sanitarian, State of Utah.
. Registered Hazardous Substances Professional, National Environmental Health
. Association Experience:
1 Worked in the environmental sanitation area in the U.S. Air Force from 1970-77
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. Worked in the environmental sanitation area for the Bureau of General Sanitation, Utah s
.Depanment of Health from 1980-82 Transferred to the Bureau of Solid and Hazardous Waste, Utah Department of Health and:
worked as a Environmental Health Scientist from 1982-85 doing RCRA compliance and permitting work.
9 RCRA and Solid Wasts Permits Section Manager of the Bureau of Solid and Hazardous 1 Waste from 1985-1990.
1 Hazardous Waste Branch Manager of the' Division of Solid and Hazardous Waste from -
10:tober 1990 until May 1993. Respcasible for all hazardous waste permitting and 1 compliance / enforcement activities for the' Division. Supervised 'a0 professional staff and three Section managers.
4 1 ppointed'to position of Director of Division of Radiation Contrel, June 1,1993 A
- Responsible for management of 20 professional staff and x-ray registration / inspection,
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- radioactive materials / licensing, environmental monitoring / low level waste programs within.
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-Memberships / Activities Voting Member for_ Utah, Conference of Radiation Control Program Directors (CRCPD)
- Past President and Current Member, Utah Environmental Health Association Committee Member (representing Utah), Northwest Interstate Compact on Low Level Radioactive Waste State Liaison Officer with the Nuclear Regulatory Commission Voting Member for Utah, Organization of Agreement States Mmber, Joint Nuclear Regulatory CommisGn/ Agreement States Task Corce on Training Member, Great Salt Lake Chapter of the Health Physics Society Past Ex-offici member, National Governor's Association Federal Facility Task Force on Mixed Waste Past Member, Assr ciation of State and Territorial Solid Waste Management Officials (ASTSWMO) Radiation Site Cleanup Regulation Task Force Resource Person, Low-Level Waste Forum Pav. Chairman and Member, ASTSWMO RCRA Corrective Action Task Force Past Member, ASTSWMO Cleanup Consistency Task Force Past Member, Govemmental Refuse Collection and Disposal Association (GRCDA)
Past Membe.. Joint Training and Technical Committee, Utah Valley Community College Past Speaking Engagements Availabic Upon Request Publications:
Master thesis: "Wat3r Conservation Practices in a River Basin with a Water Surplus, Unicol County, Tennessee"
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