ML20199K433
| ML20199K433 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 11/18/1997 |
| From: | Silberg J External (Affiliation Not Assigned), SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#497-18624 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9712010121 | |
| Download: ML20199K433 (5) | |
Text
_- _ _____ _ __ _ _ _ - _
Y November 18,1997 2
y UNITED STATES OF AMERICA 4
4 NUCLEAR REGULATORY COMMISSION s-DOCKETED
.g Before the Atomic Safety and Licensing Board E
NGV j 01997 7,,
MIMArE3AND l'
"S"N In '.he Matter of
)
9
)
PRIVATE FUEL STORAGE L.L.C.
)
Docket No. 72-22 7~y#Ti)
)
(Private Fuel Storage Facility)
)
ASLBP No. 97-732-02-ISFSI s
APPLICANT'S ANSWER TO STATE OF UTAH'S RESPONSE TO ASLB's OCTOBER 24.1997 MEMORANDUM AND ORDER On November 10,1997, the State of Utah provided to the Atomi; Safety and
).
Licensing Board suggestions for the Board's planned site visit.' Pursuant to the Board's November 12,1997 Order, Applicant provides the following response to the State's suggestions.
He Stats.tuggests that the site visit should include a tour of the Dugway Proving Ground facility, which the State identifies as one of the areas " relevant to Private Fuel Storage LLC's (PFS's) license application." According to the State, the Dugway facility "is the closest military installation to the site and,,. has a significant asident
'The State's filing was transmitted electronically to the Board, but only by mail to the Applicants and others. As a result it was not received until November 12, after Applicant received the Boards November 12 Order. The Boards October 3,1997 Memorandum encourages parties providing courtesy copies of pleadings to the Board by e-mail to make copies available by e-mail to counsel for other participants.
9712010121 971110 PDR ADOCK 07200022 o
., o,.!
i.h,,l, nolll'l l.l ll
' lll lll'l' ll" C
PDR g
.i,
[.
i
-i'-
population." Applicant submits that the Dugway facility is not relevant to the license application and that a tour of that facility is unnecessary. The nearest point of the Dugway Proving Grounds is about 9 miles from the site of Applicant's proposed facility.
By road, the closest access point at Dugway is about 14 miles from the proposed facility.
The residential area on the Proving Grounds (known as English Village) is about 13 miles from the site and about 1 1/2 miles further by road. The proposed routes for transporting spent fuel to the site are equally far from Dugway. The fact that Dugway is the " closest military installation to the site" is simply irrelevant. Nor is its "significant resident population," which the Proving Ground's public affairs office estimates at between 1200 to 1500, since all live at least 13 miles from the site.
Applicant would also question the State's assertion that the "Dugway-Tooele route described above [i.e. State Roads 199 and 36) would be the usual route emergency providers would take from Tooele to the site." Whether any off site " emergency providers" would use State Roads 199 and 36 or Skull Valley Road for the few situations in which off site personnel might be relied upon as backup to on site capabilities will depend upon the location of the personnel and the road conditions at the time. Applicant does not object, however, to the site visit including these roads.
Based on the al,ove comments, Applicant believes that a site tour can readily be accomplished in the half day contemplated in the Board's October 24,1997 Memorandum and Order.
-2
\\
t.
Respectfully submitted, ASlA e n
Jay K()Sillerg
)
Erne t L. 31ake, Jr.
SHAW PITTMAN POTTS &
- TROWBRIDGE 2300 N Street, N.W.
Washington, D.C. 20037 (202) 663 8000 Counsel for Private Fuel Storage L.L.C.
Dated: November 18,1997
$1905101
<s
-3
Ih
\\.
November 18,1997
\\
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '
A 3
r.
POCKETED Before the Atomic Safety and Liceming Board gg g B B37 N
majM In the Matter of
)
ja
,[M PRIVATE FUEL STORAGE L.L.C.
)
Docket No. 72-22 g
(Private Fuel Storage Facility)
)
ASLBP No. 97-732-02-ISFSI CERTIFICATE OF SERVICE I hereby certify that copies of the " Applicant's Answer To State Of Utah's Response To.iSLB's October 24,1997 Memorandum And Order' date cm.
1997 were served on the persons listed below (unless otherwise noter.
c.uiewith confonning copies by US mail, first class, postage prepaid, thic 18* day of November 1997.
G 1%ul Bollwerk III, Esq., Chairman Dr Jerry R. Kline Administrative Judge Administrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission II.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washing.on, D.C. 20555-0001 Dr. Peter S, Lam
- Adjudicatory File Adminutrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission ~
Washington. D.C. 20555-0001 Washington, D.C. 20555-0001
v
't;,,-
l Catherine L. Marco, Esq.
- Charles J. Haughney Sherwin E. Turk, Esq.
Acting Director, Spent Fuel Project Office -
Office of the General Counsel Office of Nuclear Material Safety and Mail Stop O-15 BIS Safeguards.'
U.S. Nuclear Regulatory Commission -
U.S. Nuclear Regulatory Commission -
Washington, D.C. 20555-Washington, D.C. 20555 Denlac Chancellor, Esq.'
Jean Belille, Esq.
Assistsnt Attorney General Ohngo Gandadeh Devia Utah Attorney General's Office Land and Water Fund of the Rockies 160 East 300 Touth,5* Floor 2260 Baseline Road, Suite 200 P.O. Box 140873 Boulder, Colorado 80302 Salt Lake City, Utah 84114 0873 4
John Paul Kennedy, Sr., Esq.
Danny Quintana, Esq._
Confederated Tribes of the Goshute Skull Valley Band of Goshute Indians Reservation and David Pete Danny Quintana & Associates, P.C.
1385 Yale Avenue 50 West Broadway, Fourth Floor Salt Lake City, Utah 84105 Salt Lake City, Utah 84101 Clayton J. Parr, Erg.
OfTice of the Secretary Castle Rock, et al.
U.S. Nuclear Regulatory ocmmission Kimball, Parr, Waddoups, Brown & Gee Washington, D.C. 20f 55-0001 185 S. State Street, Suite 1300 Attention: Rulemakin 3 and Adjudications P.O. Box 11019 Staff Salt Lake City, Utah 84147-0019 (original and two copies)
- By U.S. mail only D
k b k tr cv Jay. Silberg
$19051it
. _ _ _ _ _ _ _ - _ - - - _ _. _ _ _ _ _ - _