ML20198R022
| ML20198R022 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 01/08/1998 |
| From: | Chancellor D UTAH, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#198-18729 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9801230200 | |
| Download: ML20198R022 (18) | |
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USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION y 312 P5 *.32 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD--
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In the Matter of:
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Docket No. 72 22 ISFSI
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PRIVATE FUEL STORAGE, LLC
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ASLBP No. 97 732-02 ISFSI (Independent Spent Fuel
)
Storge Installation)
)
January 8,1998 r
STATE OF UTAH'S REQUEST FOR CONSIDERATION OF LATE FILED CONTENTION GG Introdaction Pursuant to 10 CFR. 55 2.714(a)(1) and (b)(1), the State of Utah hereby requests consideration of Contention GG. This contention addresses issues raised by the vendor's proprietary reports on seismic stability for the Sierra Nuclear Corporation TranStor storage cask, which the State received under a confidentia!ity agreement on December 12,1997. These reports are PFS01 10.02.04 Soil Structure Interaction Analysis for Evaluation of TranStor Storage Cask Sesmic [ sic) Stability Guly 24, 1997) (hereinafter " Sierra Nuclear Report No. PFS01 10.02.04") and PFS01 10.02.05 TranStor Storage Cask Seismic Stability Analysis for PFS Site Guly 24,1997)
(hereinafter " Sierra Nuclear Repon No. PFS01 10.02.05*).
The State submits that it satisfies the criteria for late-filing of this contention under 10 CFR $ 2.714(a)(1):
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'I First, th. State hu good cause for late filing, because the State was not able to q
obtain and review the proprietary information on which Contention GG is based until l
recently. The Sierra Nuclear Repons are pan of Private Fuel Storage, LL.C.'s
' Calculation Pac kage" for the proposed Private Fuel Storage ("PFS*) Facility. The -
l State obtained nonproprietary pans of the Csiculation Jackage from PFS in September 1
of 1997, and began efforts to obtain the proprictuy ponions that same month. ~ A log of the State's effons to obtain the information from Sierra Nuclear is attached u l
Exhibit 27. Following negotiation and execution of a nondisclosure agreement (copy l
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- of " Confidentiality Agreement" between Sierra Nuclear Corporation and the Utah l
Depanment of Environmental Quality is sttached herein as Exhibit 28), the State received the proprietary ponions on Decem.%r 12,1997. The review of the complex technical information in the Sierra Nuclear repons, comparison with the SAR and j
- other repons referenced therein, and the draftint; of this contention, took expens and attorneys several weeks. The State submits that approximately 30 days was a reasonable time frame for this effon, especially in light of the other pleadings that w:re required to be filed and reviewed during this time period. It should also be noted that
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the contentions are being filed within a timeframe that is generally viewed as timely -
- under NRC regulations, i.e., more than 15 days prior to the prehearing conference. See a
.10 CFR $ 2.714(b)(1).
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Second, the State has no means, other than this proceeding, to protect its interests in assuring the adequacy of the PFS design with respect to seismic stability.
l Third, the State's panicipation in this proceeding can reasonably be expected to assist in developing a sound record. The State is represented by experienced counsel, and assisted by qualified experts whom the State has retained to provide expert assistance throughout this litigation. See Declarations of Lawrence A. White, P.E., nd Lawrence L. Holish, P.E., attached herein as Exhibits 29 and 30 respectively.
Fourth, there are no other parties who will represent the State's interests with respect to the issues raised in Contention GG.
Finally,it is difficult to evaluate the extent to which the admission of the requested contentions can be expected to broaden or delay the proceeding, because the Board has not yet ruled on the parties' standing or the admissibility of their contentions. However,it seems unlikely that admission of the contention would broaden or delay the proceeding significantly, as (a) the scope of issues submitted by the State on November 23 is quite broad already, and (b) Contention GG is related to issues already submitted under Contention L and Contention EE.
Accordingly, Contention GG satisfies the NRC's criteria for late consideration.
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t DATED this 8th day of January,1998 i
Respectfull submitted, i
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'Dknise Chanctflor' l
Fred G. Nelson Assistant Attorney. General Diane Curran Connie Nakahara Special Assistant Attorneys General Attorneys for State of Utah Utah Attorney General's Office 160 East 300 South,5th Floor P.O. Box 140873 Salt Lake City UT 84114-0873 Telephone:
(801) 366-0286 Fax:
(801) 366-0292 t
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CERTIFICATE OF SERVICE 1 hereby certify that copies of STATE OF UTAH'S REQUEST FOR CONSIDERATION FOR LATE FILED CONTENTION GG were served on the persons listed below, in accordance with the December 10,1997 Confidentiality Agreement," entered into between Sierra Nuclear Corporation and the State of Utah Department of Environmental Quality, by Federal Express this 8th day of January,1998:
Emile L.
- julian, Assistant for Dr. Peter S. Lam Rulemakings and Adjudications Administrativejudge Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Office of the Secretary U. S. Nuclear Regulatory Commission U. S Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint 11555 Rockville Pike, One White Flint Nonh Nonh Mail Stop T 3F23 Mail Stop 016G15 Rockville, MD 20852 2738 Washington, DC 20555 (Originalonly)
Sherwin E. Turk, Esq.
Catherinc L. Marco, Esq.
G. Paul Bollwerk, III, Chairman Office of the General Counsel Administrative Judge Mail Stop 015 B18 Atomic Safety and Licens,.;a Board U.S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint 11555 Rockville Pike, One White Flint Nonh Nonh Rockville, MD 20852 2738 Mail Stop T 3F23 Rockville, MD 20852 2738 jay E. Silberg, Esq.
Ernest L. Blake, Jr.
Shaw, Pi tman, Potts & Trowbridge Dr. Jerry R. Kline t
Administrative judge 2300 treet, N. W.
Atomic Safety and Licensing Board Wasl n'gton, DC 2005f,8007 iFNM g/4/
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U. S. Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint Nonh D!nise ChancTelior Mail Stop T 3F23 Assistant Attorney General Rockville, MD 20852 2738 State of Utah 10
i DOCKETED CERTIFICATE OF SERVICE USNRC I hereby cenify that copies of the Introduction to the STATE OF USHg g REQUEST FOR CONSIDERATION FOR LATE FILED CONTENT RUI Failure to Demonstrate Cask Pad Stability During Seismic Event for TranSv6D3Lbsks,j m
but not the Contention and rupporting basis, which is based on proprietary information, were served on the parsons listed below, by U.S. Mail First Class this 8th day ofJanuary, 1998:
Attn: Docketing & Services Branch Jean Belille, Esq.
Secretary of the Commission Land and Water Fund of the Rockies U. S. Nuclear Regulatory Commission 2260 Baselinc 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.
(tuo copics) 50 West Broadway, Fourth Floor Salt Lake City, Utah 84101 Clayton J. Parr, Esq.
Kimball, Parr, Waddoups, Drown & Gee Office of the Commission Appellate 185 South State Street, Suite 1300 Adjudication P. O. Box 11019 Mail Stop: 16-G 15 OTFN 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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s uo Denise Chancellor Assistant Attorney General State of Utah 11
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I EXHIBIT 27 Sierra Nuclear Log - Calculation Package J
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Sierra Nuclear Loc - Calculation Packace 9/11/97 Nakahara (DEQ)leamed about the PFS Calculation Package at the PFS Open llouse. Nakahara verbally wquested a Calculation Peckage from Scott Northard, PFS.
9/15/97 Walden (DEQ) left message for William McConaghy (SNC) 9/18/97 Chancellor contacted Jay Silberg, requested a copy of the Calculation Package. (Verbally and followed up in writing.)
Chancellor received Volumes I through 111 of the Calculat. sn Package.
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Provided contacts with 11oltec and Sierra Nuclear to obtain the proprietary Volume IV.
10/13/97 Per contestation with Walden, McConaghy agreed to send copies of non-proprietary SARs & draft confidentiality agreement.
10/15/97 Faxed and mailed letter to William McConaghy requesting Calculation Package.
10/22/97 State received faxed copy of draft confidentiality agreement.
10/27/97 Per conversation with Walden, " Linda" indicated that McConaghy left Sierra Nuclear, but had left instmetions to send S ARs.
10/28/97 Nakahara - Massey, requesting non proprietary versions of SARs and missing pages in confidentiality agreement.
State received faxed copy of comp!cte draft confidentiality agreement.
I1/5/97 Nakahara faxed and mailed letter to Paul Massey, again requesting non-proprietary SARs promised by McConaghy and provioing comments on the draft confidentiality agreement.
I1/7/97 Massey left Nakahara message.
11/10/97 Nakahara left Massey message.
11/11/97 Massey indicated he did not get either the 11/5/97 fax or letter.
Refaxed 11/5/97 letter at 0910.
9 11/21/97 Faxed and mailed letter to Massey, requesting status on draft confidentiality agreement.
12/3/97 Chancellor drafted and emailed draft confidentiality agreement to Dixon (SNC).
Dixon approvvi the draft confidentiality agreement.
12/4/97 State slgned and faxed confidentiality agreement to Pete Dixon who had agreed to immediately transmit the Calculation Package, sections 4 and 5.
State also next day expressed mailed agreement with original signatures (2 copies).
12/8/97 Lloyd A. Schmidt (Attomey for Sierra Nuclear) adviscs Pete Dixon not to sign the agreement signed by the State and forwards to Chancellor agreement in the form used by Sierra Nuclear 12/9/97 Negotiations complete between Schmidt and Chancellor on the form of the Confidentiality agreement.
12/10/97 DEQ signs and express mails confidentiality agreement and upon receipt Sierra Nuclear agrecs to Federal Express the Calculation Package to the State 12/12/97 Calculation Package received by the State 12/16/97 Calculation Package express mailed to State contractors for review (after receipt by State of non disclosure agreement signed by contractor staff who will review the proprietary infonnation).
DEQ = Utah Department of Environmental Quality SNC = Sierra Nuclear Corporation
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j EXHIBIT 28 CONFIDENTIALITY AGREEMENT BETWEEN 1
SIERRA NUCLEAR CORPORATION AND UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY l
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CONFIDENTIALITY AGREEMENT THIS CONFIDENTIALITY AGREEMENT (the "Agrcement")is entered into on December l@,1997, by the State of Utah Department of Environmeatal Quality ("DEQ") for the benefit of SIERRA NUCLEAR CORPORATION, a Nevada corporation (" Company").
and 1.
Purpose. DEQ requires access to certain proprietary technical docurr" 2 m hippingcasksystem information prepared by or on behalf of Company relating to the TranStor s
and the Transtor* Storage Cask System in order to more fully participste in the Private Fuel Storage, LLC, licensing proceeding before the United States Nuclear Regulatory Commission (th In substantial reliance upon the agreements and commitments of Recipient herein, "NRC").
Company agrees to provide to DEQ the Volume IV materisla, as de6ned below.
2.
Protection of Con AdendalInformadon. DEQ acknowledges, understands, and agrees that all Confidential Information, as defined below, is the exclusive and confidential property of Company, and shall be at all times regarded, treated, and protected as such in accordance Agreement. Failure to mark any writing confidential shall not affect the confidential nature o writing or the information contained therein.
3.
Densition of ConfidentialInformation.
" Confidential Information" shall mean information which is used in Companys buuness and is (i) proprietary to, about, or created by Company; (ii) gives Company some competitive business advantage or the opportunity of o such sdvantage or the disclosure of which could be detrimental to the interests of Company; (iii designated as Confidential Infonnation by Company, or from all the relevant circumstances sh reasonably be assumed by DEQ to be confidential and proprietary to Company; or 5,iv) not gen known by non-Cort.nany personnel. Such Confidential Infortnation include., but is not limited to, l
production data, technical and engineering data, test data and test results, the status and research and development of products and services. Without limiting the genulity of the foregoing for the purposes of this Agreement, ConfidentialInformation specifically consists of and include excetpts from Volume IV of the Private Fuel Storage, LLC, Calculation Package, consisting exclusively of Chapter 4. Soil Structurc Interaction Analysis for Evaluation cfTranStor Storage Cask Seismic, Stability, and Chapter 5, TranStorm Storage Cask Seisnaic Stability Analysis for de PF S Site (collectively " Volume IV").
4.
Exclusions from ConGdential laforrnatloa. " Confidential Information" shall not include information which is publicly known or is rightfully acquired by DEQ from a third party who is not subject to an obligation not to disclose. 'lhe phrase " publicly known" shall mean readily I
accessible to the pubil: in a written publication, and shall not inch.de information which is only availsble by a substar.tial searching of the published literature, and where the substance of such information must be pieced together from a number of different publications and nources. The b uden of proving that information or skills and experience are not Confidential Information shall be on the party asserting such exclusion.
5, Covennats of DEQ. As a consequence ofDEQ's acquisition or anticipated acquisition of copies of the Volume IV materials, DEQ will occupy a position of trust and confidence with respect to Company's affairs and businesa. In view of the foregoing, and 6 view of the consideration 1-egymma ce,.
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to be provided to DEQ by having access to the Volume IV matarials, DEQ agrees that it is l
reasonable and necessary that DEQ make the following covenants and agreements:
- s. No Disclosure. DEQ shall not disclose Confidential Infonnation to any person or entity other than (i) the NRC as a proprietary submittal, and (ii) to those ofits personnel listed on Exhibit -
i "A" attached hereto an ingvi.;ed herein by 4..we, which list may be supplemented torn time to time upon the prior wrinen app: oval of Company in its sole and absolute discretion. DEQ i.ys:::r= and warrants to Company that disclosure to each ofits personnel listed on Exhibit "A" i
Is necessary in order to carrying out its review of the Private Fuel Storage, LLC, License
.l Application, and in developing DEQ's list of contentions. DEQ thrther represents and warrants t each of such personnel have entered into a wrinen obligation to protect the confident ality of such !
i information. DEQ agr-es to take all reasonable precautions to prevent k hsmst disclosure ofsuch t
Confidential Information. This prohibition against DEQ's disclosure of ConfidentialInformsnon includes, but is not limited to, disclosing the fact that any similarity exists between the Confidential Information and infonsetien indeperd -'ly developed by another person or entity, and DEQ l
understands that such similarity dou a excuse DEQ flrom abiding by its covenant or other obligations under this Agreement. DEQ shall use not less than the same standard ofcare to protect the con 6dentiality of such information as it uses to protect its own confidential information. DEQ's obligation to maintain tlw confidenality of the Confidential Information shall survive DEQ's participation in the NRC administrative proceedings for review of the Private Fuel Storage, LLC, License Application. DEQ fbrther rgrees to immediately advise Company in writing of any misappropriation or misuses by any person of the Confidential Information.
- b. No Use, Copying or hansfer.
DEQ will not usa, copy, or transfer Confidential Information, other than as necessary in reviewing the acceptability of the designs for their proposed use at the Private Fuel Storage Project, and DEQ will take all reasonable precautions to prevent i
inadvertent use, copying, or transfer of such Con 6dential Information. This prohibition against l
DEQ's use, copying, or transfer of Confidential Information includes, but is not limited to, selling, licensing or otherwise exploiting, directly or indirectly, any products or services (including software in any form) which embody or are denved $ rom Con 6dential Information, or exercising judgment j
l in performing analysis based upon knowledge of Confidential Information.
6.
Delivery and Return of Materials. Notwie=&q any term or condition of this Agreement to the contrary, it is understood and acknowledged that Company shall have no obligation to deliver to DEQ any materials r: quested during the evaluation procest, and that delivery of requested materials shall be in the sole and absolute discretion of Company; provided, however, i
in the event that Co npany elects to deliver all or any portion of the materials roguested, the obligation of confidentiality and restriction on use shall arise with respect to the materials so delivered. Any materials, documents, booka, records or other written or recorded materials of Company which are fbmished to DEQ will be promptly retumed by DEQ to Company, accompanied by all copies of such items made by DEQ, upon completion of the NRC administrative proceedings in connection with the review of the Private Fuel Storage, LLC, License Application.
- 7.. No ImpIled Rights, it is understood that nothing herein shall be construed a granting or implying any right under any letters patent, or to use any information covered hereby, or as permitting DEQ to unfairly obtain the right to use the Con 6dential,Information which becomes
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publicly known through an improper act or omission on its part.
8.
Injunctive Rdlef.
It is hereby understood and agreed that damages shall te an inadequate remedy in the event of a breach by DEQ of any of said covenants and that any suc breach by DEQ will cause Company great and irreparable injury r.nd damage. Accordingly, DEQ agrees that Company shall be entitled, without waiving any additional rights or remedies other available to Company at law or in eqdty or by statute, to injunctive and other equitaole reliefin the event of a breach or intended or threatened breach by DEQ of any of said covenants.
9.
Miscellaneous.
- a. Goveming law. This Agreement and the rights and obligations of the parties shall be construed, interpreted and enforced pursuant to the laws of the State of Califomia.
- b. Severabflity. If any one or more oithe p:wisions of this Agreement shall be held invdid or unenforceable, it is the specific intent of the parties that such provision shall be modified to the minimum extent necessary 3 make it or its application valid and enforceable and the validity and enforceability of all other provisions of this Agreement and all other applications of such pmvis shall not be affected thereby.
- c. Waiver. No waiver by Company of any breach by DEQ of any of the provisions of this Agreement shall be deemed a waiver of any preceding or succeeding breach of the same or provisions hereof. No such waiver shall be effective unless in writing and then only to the exte expressly set forthin writing.
- d. Entire Agreement. 'Ihis Agreement constitutes the entire agreement of the parties with respect to DEQ's confidentiality and nondisclosure obligations,
- e. Nohsignment. DEQ shall not assign its rights, duties, or obligations under this Agreement.
l IN WITNESS WHEREOF, this Confidentiality Agreement is executed the day and year first l
written above.
RECIPIENT:
STATE OF UTAH, l
DEPARTMENT OF ENVIRONMENTAL QUALITY AfflE W
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M97 BY:
AGREED AND ACCEPTED:
SIERRANUCLE RATION:
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BY:
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h%Y, Preg 3-simmuurmuram wi d
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EXillBlT "A" CONFIDENTIALITY AGREEMENT l
Name Title Scope of Access Dianne R. Nielson, Ph.D.
Executive Director of DEQ All of Volume IV Fred G. Nelson.
Assistant Attorney General Pleadings based on for Utah information obtained from Volume IV Denise Chancellor Assistant Attorney General All of Volume IV for Utah Connie S. Nakahara Director for DEQ,llLWSO All of Volume IV Special Assistant Attorney General for Utah Diane Curran DEQ Contractor All of Volume IV liarmon, Curran, Spielberg Special Assistant Attorney General for Utah Lawrence White DEQ Contractor All of Volume IV Versar, Inc.
Paul Kendall DEQ Contractor All of Volume IV Versar, Inc.
Lawrence llolish DEQ Contractor All of Volume IV Versar, Inc.
Connie Rauen Nooyen Environmental Engineer for DEQ All of Volume IV ilarry Solomon Senior Geologist for Utah All of Volume IV Geological Survey Jean liraxton Pualegal for Attorney All of Volume IV General for Utah Karma Pathakis Secretary for Utah Attorney All of Volume IV for the purpose General of secretarial support Debbie Oberndorfer Secretary for DEQ All of Volume IV for the purpose of secretarial support Rebecca Walden Secretary for DEQ All of Volume IV for the purpo;e of secretarial support Janice llowell Secretary for DEQ Contractor All of Volume IV for the purpose Versar, Inc.
of secretarial support
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i EXHIBIT 29 s
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- 2 Declaration of I4wrence A. White, P. E.
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JAN-CO-De 13 33 FOCM,-..
ID PA2E 2/3, e
UNTIT.D STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE.THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
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PRIVATE FUEL STORAGE,Ilc
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Docket No. 72 22 ISFSI
)
(Independent Spent
)
ASLBP No.97-732 02 ISFSI Fuel Storage Installation)
)
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DECLARATION OF LAWRENCE A; WHITE, P.E.
- 1. I am an Executive Vice President of Versar,Inc., an engineering and consulting firm headquanered in Springfield, Virginia. I have extensive experience in the areas of nuclear licensing and radioactive waste management, including the siting, design, constmetjon, operation, and decommissioning of nuclear facilities. Copics of my resume, which further describes my qualifications, and a desc iption of Versar, Inc., are attached as Exhibit 1 to the contentions filed by the State of Utah in this proceeding on November 23,1997.
- 2. I am familiar with Ptivate Fuel Storage's ("PFS's") Safety Analysis Report and the design of the casks that PFS proposes to use at its Private Puel Storage Facility
("PPSF"). I am also familiar with the seismic analysis pwprJ by Sierra N'aclear, which is relied on by PFS in support ofits license application.
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- 3. I assisted in the preparation of, and have reviewed, the State of Utah's contention regantling Sierra Nuclear Corporation's Proprietary.Repotts on Seismic Stability and Transto: Storage Casks at the PFS Skull Valley site, h technical facts presented in that contention are true and correct to the best of my knowledge, and the conclusions drawn from those facts are based on my best professionaljudgment 8A&n
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s gg v'-er Dated thisg day of-1998.
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EXHIBIT 30 Declaration of Lawrence L. Holish, P. E.
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ovos/es trior rAl sac 2ss Osst, Vt*StR INC 6002/002 o
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATCMIC SAFE'rY AND LICINSING BOARD
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In tbe Matter of
)
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PRIVATE FUEL STORAGF,I.LC
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Docket Nol 72 22-ISPS1
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l (Independent Spnt
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ASLBP No.97-732 02 ISFSI Feel Storage Installation)
)
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DECLARATION OF LAWRENCE L. HOLISH, P.E.
- 1. I am ernployed as head of the Engineering DMslon at Versar, Inc Midwest Regior'al Office. I have extensive experience in geotechnical engineering and seismic analysis for nuclear power plants and oher faellities. A copy of my resume, which further describeu my qt.alfications, is attached as Exhibit 26 to contentions EE and PF filed by the St de of Utah in this proceedmg on December 23,1997.-
- 2. I am familiar with Private Fuel Storage's ("PFS's") Safety Analysis Report wi the design of the casks that PPS proposes to use at its Private Fuel Storage Pacility
("ifSF"). I am also familiar with the seismic analysis prepared by Sierra Nuclear, which is relied on by PFS in support ofits license application.
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- 3. I assisted in the preparation of, and have reviewed, the State of Utah's l
contention regarding Sierra Nuclear Corporation's Proprietary Reports on Seismic Stability and Transtor Storpse Casks at the PFS Skull hlley alte. The echnical facts presented in that contentiv are true and correct to the best of my knowledge, amt the i
cons!vions drawn from; ow facts an:
rny best fe ion judgment, 1 M; b
L Lawrence L.Holish,P.E.
Dated this y of n*
1998.
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