ML20206F205
| ML20206F205 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 04/29/1999 |
| From: | Chancellor D UTAH, STATE OF |
| To: | AFFILIATION NOT ASSIGNED |
| References | |
| CON-#299-20339 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9905060032 | |
| Download: ML20206F205 (58) | |
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L-UNITED STATES OF AMERICA USIEC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'9 Imy -5 A o
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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
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Storage Installation)
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April 29,1999 STATE OF UTAH'S AMENDED RESPONSES TO APPLICANT'S FIRST SET OF FORMAL DISCOVERY REQUESTS The State of Utah files an amendment to its April 14,1999 response to the Applicant's First Set of Formal Discovery Requests (" Applicant's Discovery Requests"), an electronic copy of which was served on the State after the close of business on Friday, April 2,1999. This response amends General Interrogatory Nos.
1,3,4 and 5, and responses to Request for Admissions Nos. 14,15,16,17,25, and 26 for Board Contention 5 (Utah K/ Confederated Tribes B), Inadequate Consideration of Credible Accidents.'
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STATE'S AMENDED RESPONSES TO GENERAL INTERROGATORIES 8 Due to a personal emergency experienced by the State's technical expert, David B. Cole, the State is not able at this time to amend its discovery responses to Utah Contention M, but it will do so after Mr. Cole returns. See Affidavit of Norman E. Stauffer, Jr., supervisor of David B. Cole, attached as Exhibit 2 to State Response to Applicant's Motion to Compel Answers to Interrogatories and Admissions by the
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State of Utah i
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GENERAL INTERROGATORY NO.1.
State the name, business address, and job title of each person who was consulted and/or who supplied information for responding to interrogatories, requests for admissions and requests for the production of documents. Specifically note for which interrogatories, requests for admissions and requests for production each such person was consulted and/or supplied information.
If the information or opinions of anyone who was consulted in connection with your response to an interrogatory or request for admission differs from your written answer to the discovery request, please describe in detail the differing information or opinions, and indicate why such differing information or opinions are not your official position as expressed in your written answer to the request.
STATE'S AMENDED RESPONSE TO GENERAL INTERROGATORY N O. 1.
The State hereby incorporates its response to General Interrogatory No.1 dated April 14,1999 into this amended response, and supplements it as follows:
pursuant to agreement with PFS, the State herewith files declarations (included hereto as Attachment 1) for each person who assisted in answering specific interrogatories and requests for admissions, specifically David B. Cole, Martin Gray, Bronson W. Hawley, PhD, David Larsen, Brad Maulding, John L. Matthews, Major General USAF (Ret),
Marvin Resnikoff, PhD, David C. Schen, and William M. Wallner.
GENERAL INTERROGATORY NO.'3. For each admitted Utah contention, give the name, address, profession, employer, area of professional expertise, and educational and scientific experience of each person whom the State expects to call as a witness at the hearing. For purposes of answering this interrogatory, the educational and scientific experience of expected witnesses may be provided by a resume of the person attached to the response.
STATE'S AMENDED RESPONSE TO GENERAL INTERROGATORY N O. 3.
As verbally related to PFS on April 21,1999 and as supplemented herewith, to 2
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4 date, the State has identified the following persons whom it expects to call as witnesses at the hearing; included herein as Attachment 2 are the witnesses' resumes which provide answers to the questions of profession, employer, area of professional expertise, and educational and scientific experience:
Utah Contentions B, C, F/P & G Marvin Resnikoff, Ph.D.
Senior Associate Radioactive Waste Management Associates 526 West 26th Street, Room 517 New York, NY 10001 Utah Contentions M & N David B. Cole Senior Engineer Division of Water Resources State of Utah, Department of Natural Resources 1595 West North Temple Salt Lake City, UT 84114-6201 Utah Contention K John L. Matthews, Major General USAF (Ret)
Military Advisor to Governor of Utah Defense Consultant 116 State Capitol Salt Lake City, UT 84114 David Larsen Environmental Scientist, Geologist Division of Solid and Hazardous Waste State of Utah, Department of Environmental Quality 288 North 1480 West Salt Lake City, UT 84114-6880 Bronson W. Hawley, Ph.D.
Environmental Scientist Division of Solid and Hazardous Waste 3
Oe State of Utah, Depanment of Environmental Quality 280 Nonh 1460 West P.O. Box 144880 Salt Lake City, UT 84114-4880 Dane Finerfrock2 Section Manager, WIPP Program, Envirocare, and Vitro Division of Radiation Control State of Utah, Depanment of Environmental Quality 168 North 1950 West (bldg. # 2), Room 212 P.O. Box 144850 Salt Lake City, UT 84114-4850 Utah Contentions K & R David C. Schen State of Utah, Depanment of Namral Resources Division of Fire, Forestry, & Sovereign Lands 1594 West North Tempk, Suite 3520 Box 145703 Salt Lake City, UT 84114-5703 GENERAL INTERROGATORY NO. 4. For each admitted Utah contention, identify the qualifications of each expert witness whom the State expects to call at the hearing, including but not limited to a list of all publications authored by the 1
witness within the preceding ten years and a listing of any other cases in which the witness has testified as an expert at a trial, hearing or by deposition within the preceding four years.
STATE'S AMENDED RESPONSE TO GENERAL INTERROGATORY NO. 4.
Dr. Marvin Resnikoff has authored publications, a list of which is included 2 Mr. Finerfrock's resume is not presently available but will be provided at a i
later date.
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.C herewith as Attachment 3. David Schen's publications are listed in his resume. Dr.
Resnikoff's list of other cases in which he has testified as an expen at trial are also included in Attachment 3. The other witnesses do not have relevant publications, nor have they testified as expen witnesses in other cases; however, this interrogatory will be supplemented as appropriate.
GENERAL INTERROGATORY NO. 5. For each admitted Utah Contention, describe the subject matter ca which each of the witnesses is expected to testify at the hearing, describe the Ecs and opinions to which each witness is expected to testify, including a summary of the grounds for each opinion, and identify the documents (including all peninent pages or pans thereof), data or other information which och witness has reviewed and considered, or is expected to consider or to rely on for his or her testimony.
STATE'S AMENDED RESPONSE TO GENERAL INTERROGATORY N O,5.
Dr. Marvin Resnikoff will testify on issues relating to Utah Contentions B (the Intermodal Transfer Point), C (dose limits), F/P (training and radiation protection training) and G (quality assurance).
David B. Cole will testify regarding probable maximum flood and the potential for flooding and swamping by wind stacked water and waves of the new ITP site 1.8 miles west of Rowley Junction, as these issues relate to Utah Contentions M and N.
John L. Matthews, Major General USAF (Ret) will testify as to activities relating to Dugway, Utah Test and Training Range, and Hill Air Force Base, as well as other military and aviation activities, as these issues relate to Utah Contention K (inadequate consideration of credible accidents).
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David Larsen will testify about hazardous waste activities at Dugway as they relate to Utah Contention K.
Bronson W. Hawley, Ph.D. will testify as to hazardous waste and military training issues at Utah Test and Training Range, as these issues relate to Utah Contention K.
Dane Finerfrock will testify as to activities occurring at Envirocare as well as materials at or emanating from the Envirocare facility, as these issues relate to Utah Contention K.
David C. Schen will testify as to wildland fires as they relate to Utah Contentions K and R.
In general, the documents the above witnesses have reviewed and/or relied j
upon are applicable portions of the PFS License Application (including the SAR), as amended, and applicable supponing calculations, as well as relevant PFS's responses to Requests for Additional Information with supporting calculations, and other relevant documents produced by PFS and the State; in addition, they may review any new information that the State obtains.
II.
STATE'S AMENDED RESPONSES TO REQUESTS FOR ADMISSIONS FOR BOARD CONTENTION 5 (UTAH K/ CONFEDERATED TRIBES B)- INADEQUATE CONSIDERATION OF CREDIBLE ACCIDENTS In its April 14 response, the State qualified its responses to Contention K.
1 Response at 19 20. The State also filed a general objection to the Applicant's requests 6
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for Admissions. Response at 20-21. The State hereby incorporates the qualifications and general objection into this amended response. Notwithstanding the qualifications and general objection, the State hereby amends its April 14,1999 response as follows:
REQUEST FOR ADMISSION NO.14 - UTAH K: Do you admit that - as set forth at page 4-100 of the FEIS for the X-33 space plane - the planned flight paths for the X-33 do not cross over Skull Valley?
j STATE'S AMENDED RESPONSE TO REOUEST FOR ADMISSION NO.14 - UTAH K:
The State of Utah admits that page 4-100 of the FEIS for the X-33 space plane, shows the planned flight paths for the X-33 do not cross over Skull Valley.
REQUEST FOR ADMISSION NO.15 - UTAH K: Do you admit that - as set forth at page 4-87 of the FEIS for the X-33 space plane - the X-33 will make no more than approximately seven landings at Michael Army Airfield over the course of the program?
STATE'S AMENDED RESPONSE TO REOUEST FOR ADMISSION NO.15 - UTAH K:
The State of Utah objects to this request for admission on the basis that the phrase "no more than approximately" is contradictory and thus, vague.
Notwithstanding this objection, the State of Utah admits that page 4-87 of the FEIS for the X-33 space plane, states that the X-33 will make approximately seven landings at Michael Army Airfield over the course of the program.
REQUEST FOR ADMISSION NO.16 UTAH K:
Do you admit that -
as set forth at page 4101 of the FEIS for the X-33 space plane - the seven flights for the j
.X-33 to Michael Army Airfield are scheduled to be completed by mid-1999.
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STATE'S AMENDED RESPONSE TO REOUEST FOR ADMISSION NO.16 UTAH K:
The State of Utah admits that page 4-101 of the FEIS for the X-33 space plane, states that seven flights for the X-33 to Michael Army Airfield would occur in mid-1999.
REQUEST FOR ADMISSION NO.17 - UTAH K: Do you admit that the operations of the X-33 aircraft would pose no significant hazard to the PFS ISFSI or theITP?
STATE'S AMENDED RESPONSE TO REOUEST FOR ADMISSION NO.
17 - UTAH K:
To the extent all X-33 space plane flights are in fact completed by mid-1999, the State of Utah admits Request for Admission No.17. However,it should be noted for the record that it is now the end of April 1999 and no X 33 space plane flights have occurred to date, thus, completion of all planned X-33 flights to Michael Army Airfield, as contemplated in the FEIS, may not in fact be completed by mid-1999.
REQUEST FOR ADMISSION NO. 25 - UTAH K: Do you admit that activities at or emanating from Salt Lake City International Airpon, other than aircraft flying to or from the airport, would pose no significant hazard to the PFS ISFSI or the ITP?
l STATE'S AMENDED RESPONSE TO REOUEST FOR ADMISSION NO. 25 - UTAH K:
The State of Utah admits that activities at or emanating from Salt Lake City International Airport, other than aircraft flying to or from the airport, would pose no significant hazard to the PFS ISFSI or the ITP.
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l REQUEST FOR ADMISSION NO. 26 UTAH K: Do you admit that the PFS ISFSI site is more than five miles from the edge of the nearest federal airway,
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which runs nonh to south on the east side of the Stansbury Mountains?
STATE'S AMENDED RESPONSE TO REOUEST FOR ADMISSION l
l NO. 26 - UTAH K:
l The State of Utah objects to this request for admission on the basis that the term federal airway" is not defined and is vague and over broad. Notwithstanding the 1
- previous objection, the State of Utah admits that the federally designated commercial air corridor 110 is more than five miles from the PFS ISFSI.
DATED this 29'h day of April,1999.
Respectfulfy submitted, STATIOF UTAH
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AhE~2 Derds(Chancellor,Issistant Attorney General Fred G Nelson, Assistant Attorney General Diane Curran, Special Assistant Attorney General Connie Nakahara, Special Assistant Attorney General Daniel G. Moquin, Assistant Attorney 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 9
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_Cf1TIFICATE OF SERVICE I hereby certify that a copy of STATE OF UTAH'S AMENDED 99 m -5 All.07 RESPONSES TO APPLICANT'S FIRST SET OF FORMAL DISCOVEgg.
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REQUESTS was served on the persons listed below by electronic mail (unleADJUDUC
- otherwise noted) with conforming copies by United States mail first class, this 29'h day of April,1999:
Rulemaking &-Adjudication Staff Sherwin E. Turk, Esq.
i Secretary of the Commission Catherine L. Marco, Esq.
U. S. Nuclear Regulatory Commission Office of the General Counsel Washington D.C. 20555 '
Mail Stop 15 B18 E mail: hearingdocket@nrc. gov U.S. Nuclear Regulatory Commission (originalandtwo copies).
Washington, DC 20555 E-Mail: set @nrc. gov G. Paul Bollwerk, III, Chairman E-Mail: cim@nrc. gov AdministrativeJudge E-Mail: pfscase@nrc. gov Atomic Safety and Licensing Board
. U. S. Nuclear Regulatory Commission Jay E. Silberg, Esq.
Washington, DC 20555 Ernest L. Blake, Jr., Esq.
E-Mail: gpb@nrc. gov Paul Gaukler, Esq.
Shaw, Pittman, Potts & Trowbridge Dr. Jerry R. Kline 2300 N Street, N. W.
AdministrativeJudge Washington, DC 20037-8007 Atomic Safety and Licensing Board E-Mail: Jay _Silberg@shawpittman.com U. S. Nuclear Regulatory Commission E-Mail: ernest _blake@shawpittman.com Washington, DC 20555 E-Mail: paul _gaukler@shawpittman.com i
E-Mail: jrk2@nrc. gov John Paul Kennedy, Sr., Esq.
j Dr. Peter S. Lam 1385 Yale Avenue AdministrativeJudge Salt Lake City, Utah 84105 Atomic Safety and Licensing Board E-Mail: john @kennedys.org
- U. S. Nuclear Regulatory Commission 4
Washington, DC 20555 j
E-Mail: psl@nrc. gov-10 i
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Richard E. Condit, Esq.
James M. Cutchin Land and Water Fund of the Rockies Atomic Safety and Licensing Board 2260 Baseline Road, Suite 200 Panel Boulder, Colorado 80302 U.S. Nuclear Regulatory Commission E-Mail: rcondit@lawfund.org Washington, D.C. 20555-0001 E-Mail: jmc3@nrc. gov Joro Walker, Esq.
(electronic copy only)
Land and Water Fund of the Rockies 165 South Main, Suite 1.
Office of the Commission Appellate Salt Lake City, Utah 84111 Adjudication E Mail: joro61@inconnect.com Mail Stop: 16-G-15 OWFN U. S. Nuclear Regulatory Commission Danny Quintana, Esq.
Washington, DC 20555 Danny Quintana & Associates, P.C.
(UnitedStates mailonly) 50 West Broadway, Fourth Floor Salt Lake City, Utah 84101 E Mail: quintana @xmission.com
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'IIenTse Chancellor' Assistant Attorney General State of Utah 11
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l DECLARATION I, David B. Cole, hereby declare under penalty ofperjury and pursuant to 28 U.S.C. Q 1746, that the statements contained in State of Utah's April 14, 1999, Responses and Objections to Applicant's First Set of Formal Discovery Requests, with respect to Utah Contention M (Probable Maximum Flood) and Utah Contention N (Flooding) are true and correct to the best of my knowledge,information and belief.
Dated this 22nd day of April,1999.
By:
Ddvid B. Cole Senior Engineer Division of Water Resources Utah Department of Natural Resources l
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l DECLARATION I, Martin Gray, hereby declare under penalty of perjury and pursuant to 28 U.S.C. i 1746, that the statements contained in State of Utah's April 14, 1999, Responses and Objections to Applicant's First Set of Formal Discovery Requests, with mspect to Utah Contention K (Inadequate Consideration of Credible Accidents, specifically Dugway Proving Ground, and Hazardous Waste Facilities) are true and correct to the best of my knowledge, information and belief.
Dated this 22nd day of April,1999.
By:
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Martin Gray
~f Environmental Manager Division of Solid and Hazardous Waste Utah Department of Environmental Quality l
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DECLARATION I, Bronson W. Hawley, hereby declare under penalty of perjury and pursuant to 28.U.S.C. 9 1746, that the statements contained in State of Utah's April 14,1999, Responses and Objections to Applicant's First Set of Formal Discovery Requests, with respect to Utah Contention K (Inadequate Consideration of Credible Accidents, specifically Utah Test and Training Range, and Hill Air Force Base) are true and correct to the best of my knowledge,information and belief.
Dated this 22nd day of April,1999 I
By:
nrutis LU & 7s /f Bronson W. Hawley, Ph.D.
Environmental Scientist Division of Solid and Hazardous Waste Utah Department of Environmental Quality
DECLARATION I, David Larsen, hereby declare under penalty of perjury and pursuant to 28 U.S.C. i 1746, that the statements contained in State of Utah's April 14, 1999, Responses and Objections to Applicant's First Set of Fonnal Discovery Requests, with respect to Utah Contention K (Inadequate Consideration of Credible Accidents, specifically Dugway Proving Ground) are true and correct to the best of my knowledge,information and belief.
Dated this 22nd day of April,1999.
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By:
'(M David Larsen Environmental Scientist, Geologist Division of Solid and Hazardous Waste Utah Department of Environmental Quality
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DECLARATION
- 1. Devid Larsen, bereby declare under penalty of perjury and pursuant to 28 U.S.C. I 1746, that the statements contnned in State of Utah's
,1999, Amended Responses to Applicant's First Set of Formal Discovery Requests, with respect to Utah Contention K (Inadequate Consideration of Credible Accidents, specifically State's Response to Request for Admission No.
26 and State's Response to Request for Admissions No.14 No.15, and No.16) are true and correct to the best of my knowledge, infonnation and belief.
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Datedthis b day of
.1999.I By:
[Il I O-David Larsen Environmental Scientist, Geologist l
Division of Solid and Hazardous Waste Utah Department of Environmental Quality l
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i DECLARATION i
1, Brad Maulding, hereby declam under penalty of perjury and pursuant to 28 U.S.C. 91746, that the statements contained in State of Utah's April 14, 1999, Responses and Objections to Applicant's First Set of Formal Discovery Requests, with aspect to Utah Contention K (Inadequate Consideration of Credibie Accidents, specifically Utah Test and Training Range, Hill Air Force Base, and Alliant Techsystems) are true and correct to the best of my knowledge,information and belief.
Dated this 22nd day of April,1999.
By:
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Br'ad Maulding "
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Environmental Manager Division of Solid and Hazardous Waste Utah Depanment of Environmental Quality l
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[ l John Matthews - DECLARAT. MAT l'
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l DECLARATION I, John L. Matthews, hereby declare under penalty of perjury and pursuant to 28 U.S.C. $ 1746, that the statements contained in State of Utah's April 14, 1999.
Responses and Objections to Applicant's First Set of Formal Discovery Requests, with l
respect to Utah Contention K (Inadequate Consideration of Credible Accidents, specifically Dugway Proving Ground, Hill Air Force Base, Utah Test and Training i
Range, and General Aviation) are true and correct to the best of my knowledge,
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information and belief.
l Dated this 22nd day of April,1999.
>> S By:
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J' ohn L. Matthews, ajor General USAF (ret) i Military Advisor Governor of Utah Defense Consultant 1
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RADIOACTIVE WASTE MANAGEMENT ASSOCIATES l
DECLARATION I, Marvin Resnikoff, hereby declare under penalty of perjury and pursuant to 28 U.S.C. Q 1746, that the statements contained in State of Utah's April 14,1999, Responses and Objections to Applicant's First Set of Formal Discovery Requests, with respect to Utah Contentions B, C, F & P, G and K are true and correct to the
- best of my knowledge, information and belief.
Dated this 21st day of April,1999.
By:
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arvin Resnikoff, Ph.'. 7#
D enior Associate Radioactive Waste Management Associates I
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l Marvin Resnikoff, Ph.D. + senior Associate l
526 West 26th St.,Rm. 517 + NY, NY 10001 + 212-620-0526 + Fax 212-620-0518 + email radwaste@rwma.com l
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Ibve schen o DECLARAT.SCH Page 1l L.
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l DECLARATION l
1, David C. Schen, hereby declare under penalty of perjury and pursuant to 28 U.S.C. 91746, that the statements contained in State of Utah's April 14, 1999, Responses and Objections to Applicant's First Set of Formal Discovery Requests, with L-respect to Utah Contention K (inadequate Consideration of Credible Accidents, specifically Wildfires ) and Utah Contention R (Emergency Planning) are true and correct to the best of my knowledge, information and belief.
Dated this 22nd day of April,1999.
By:
A David C. ScHeVi Ecosystem Management Coordinator Division of Fire, Forestry, & Sovereign Lands Utah Department of Natural Resources t
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l DECLARATION I, William M. Wallner, hereby declare under penalty of perjury and pursuant to 28 U.S.C. !
1746, that the statements contained in State of Utah's April 14,1999, Responses and Objections to Applicant's First Set of Formal Discovery Requests, with respect to Utah Contention K (Inadequate Consideration of Credible Accidents, specifically Alliant Techsystems) are true and correct to the best of my knowledge, information and belief.
Dated this 22nd day of April,1999.
By:
Md William M. Wallner Environmental Scientist Division of Solid and Hazardous Waste Utah Department of Environmental Quality 1
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Dr. Marvin Resnikoff Radioactive Waste Management Associates 526 West 26th Street, Room 517 241 W.109* St, Apt. 2A New York, NY 10001 NewYork,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
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waste disposal facilities.
1978 - 1981; 1983 - April 1989 Research Director, Radioactive Waste Campaign, directed research program for Campaign, including research for all fact sheets and the two books, Living Without Landfills, and Deadly Defense. 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.
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1981 - 1983 Project Director, Council on Economic Priorities, directed project which produced the report The 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 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 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, Depanment of Physics, University of Maryland, conducted research into elementary particle physics.
EDUCATION l
University of Michigan PhD in Physics, June 1965
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Ann Arbor, Michigan M.S. in Physics, Jan 1962 B.A. in Physics / Math, June 1959
r 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.
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 is:;ues 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 Jersey thorium Superfund sites and on proposed low-level radioactive waste facilities at Martinsville (Illinois), Boyd County (Nebraska), Wake County (North Carolina), Ward Valley (Califomia) 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 fonner 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 expert witness for plaintiffs 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, including 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. Resnikoffis a technical consultant to DEQ on the proposed dry cask storage facility for high-level waste at Skull Valley, Utah and proposed storage / transportation 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 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 Uranium Coalition in Environmental Impact Statement hearings before a Federal panel regarding the environmental impact of uranium mining in l
Northem Saskatchewan. He has also worked on behalf of the Momingside Heights l'
Consortium regarding radium-contaminated soil in Malvem and on behalf of Northwatch L
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.
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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, formulating policy and networking with numerous environmental and public interest organizations 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 Citi:en Guide to MilitaryLandfills.
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 andStorage of Nuclear Waste. The CEP study details the hazard of transporting irradiated nuclear fuel and outlines safer options.
In February 1976, assisted by four engineering students at State University of New York at Buffalo, Dr. Resnikoff authored a paper that changed the direction of power reactor decommissioning in the United States.' His paper showed that power reactors could not be entombed for long enough periods to allow the radioactivity 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 I
decommissioning of the Yankee-Rowe reactor.
Dr. Resnikoffis an intemational expen 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 reproce; sing 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. 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 expert witness in 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 wastes in Vernon, New Jersey, to the Southwest Research and Informanon Center and New Mexico Attorney General on shipments of plutonium-contaminated waste to the WIPP facility in 3
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l-i 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 l
New York's Kennedy Airport, and transport ofirradiated fuel through New York City, l
and to the Illinois Attorney General on the expansion of the spent fuel pools at the Morris l
Operation and the Zion reactor, to the Idaho Attorney General on the transportation of irradiated submarine fuel to the INEL facility in Idaho and to the Alaska Attomey l
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 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 Town and Country Planning Association (England) on transporting nuclear fuel through London. In July and August 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 Rachel Carson College, an un-
'dergraduate 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 Public 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 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 Theoretical Physics, specializing in group theory and particle physics.
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,hl Ii DAVID B COLE i
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y 66I8 W 4143 South St. West Valley City, Utah 84128 n
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l LtC:E*N' EMPLOYMENT I
YEARS EMPLOYED (EX: 1971 - PRESENT) l Senior Engineer I
l State of Utah Division of Water Resources Salt Lake City, Utah Assistant Section Chief l
Develop and maintain river basin and project operation simulation computer programs.
Develop and maintain computer programs to solve complex engineering programs in areas of hydrology, hydraulics, statistics, economics, seismic data reduction and land survey reduction.
EDUCATION YEARS ATTENDED (Ex:1970 76)
CivilEngineering Bachelor ofScience Degree University of Utah, Salt L,ake City, Utah Graduated Cum laude Member of Tau Beta Pi National Engineering Honor Fraternity g'
Member of Chi F wilon National Civil Engineering Honor Fraternity SKILLS AND LV,ENSING Over 20 years of experience developing coinputer programs to simulate the operation of
=
reservoir and river systems.
Over 20 years of experience developing computer programs to perform hydrologic and hydraulic computations.
Over 20 years ofexperience computing design and probable maximum flood bydrographs, and flood routing.
Licensed Professional Eng*meer in State of Utah.
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John L. Matthews Major General USAF (Ret) 116 State Capitol Salt Lake City, UT 84114 801538-1640 (W)
Present Assignments MILITARY ADVISOR TO THE GOVERNOR OF UTAH DEFENSE CONSULTANT Career Summary General Matthews retired on 30 September 1994 after nearly 40 years of service.
He was commissioned a 2nd Lieutenant in the United States Air Force on 17 December 1954. He graduated from Flight School in June of 1956 and was i
assigned as an Instructor Pilot at Laredo AFB, Texas. During his flying career he flew T-33s, F-86s, C-97s, KC-97s, C-124s, KC-135s, and had brief experiences flying B-52s, EC-135s, F-16s, AH-64s, and C-130s. His flying career took him throughout the world, and included an assignment as Aircraft Commander of an around the world flight. His last assignment was Adjutant General of Utah, which he held from 1982-1994, serving under three different governors. During that period he was elected President of the Adjutants General Association of the United States and later President of the National Guard Association of the United States. He served as Chairman, Board of Advisors, of the Air National Guard Professional Military Education Center in Knoxville, Tennessee. He received several appointments from the Secretary of Defense, including:
Chairman, Air Reserve Forces Policy Committee; Readiness Chairman, Resen'e Forces Policy Board; Advisor to the DOD Task Force on Quality of Life; and a member of the Army Offsite Committee on Force Structure. He led the National Guard Delegation at the 50th anniversary commemoration of D Day in France which included a personal presentation to President Francois Mitterand at the Elysee Palace in Paris. Following his retirement he was appointed by President Clinton as a Commissioner, Commission on Rolls and Missions of the Armed Forces.
General Matthews holds a Masters Degree from Brigham Young University and
~ is a graduate of the Air War College. He presently sen*es as Chairman of the Citizen's Advisory Commission for the Tooele Chemical Demilitarization Facility and Chairman of the Dugway Technical Review Committee.
His 21 medals include the Air Force Distinguished Service Medal, Legien of Merit, Republic of Vietnam Service Medal, and the Utah Medal of Merit. ife has recieved the Distinguished Service Award and the Eagle Award from the National Guard Bureau and the Legion de Lafayette from the National Guard Association.
He holds a TS SBI clearance.
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David Larsen j
2646 East 3650 North Layton, Utah 84041 7712110 (home) or 538-6749 (work)
EDUCATION: 1983, B.S., Geology, Weber State College, Ogden, Utah 1987, M.S., Geology, Brigham Young University, Provo, Utah 1986, Utah Teachers Certificate, Re-certified 1993-1998 EXPERIENCE: August 1988 to Present, Environmental Scientist / Geologist, Utah Division of Solid and Hazardous Waste-RCRA. Duties preformed include: managing large projects and contracts, writing RCRA permits; preforming environmental site assessments; performing RCRA inspections, writing environmental reports; negotiating settlements; collecting soil and groundwater samples; reviewing sample and analysis plans; conducing public hearings and responding to public input; reviewing plans for clean up of I
contaminated sites and plans for site closures; acting as regulatory project manager for site soil and groundwater cleanups; interpreting regulations and writing positions papers; (see addendum below).
Winter 1995 & Fall 1997, Adjunct Professor, Columbia College, Salt Lake City, I taught historical geology and physical geology.
Summer 90, Fall 91, Winter 92, Adjunct Professor, Weber State College. I taught night school classes (Geology 101 and Geology 111)
February 1987 to June 1988, Science Teacher, Provo High School. I taught physical / earth science, duties included; teaching classes, grading papers, and managing about 90 kids / day.
August 1983 to December 1986, Teaching Assistant at Brigham Young University (Geology classes).
Summer 1985, Geologist for North American Exploration and Teaching Assistant at Brigham Young University. I staked claims and did geologic mapping.
Summer 1984, Geologist for Meyers Resources, duties included mapping, collecting soil samples, and staking claims in central Nevada.
Summer 1983, Geologist for Champlin Petroleum Co., Denver, duties included data analysis and mapping related to oil production.
Summer 1978, Technician for the US Forest Service, Ashton, Idaho. I mapped clear cuts and areas where trees were to be planted. I used compass and tape to map the areas and did plots to determine if an area needed to be planted.
. ACHIEVEMENTS:
Publication of my thesis work in BYU Geology Studies. Thesis title: Conodont Faunas of the Lower Siponodella crenulata Zone in Utah.
U.S. Environmental Protection Agency Grant,1990 Tuition scholarship, BYU,1985 ASBYU research grant 1984 o
Ten year DEQ employee - Five DEQ Incentive Awards
'h Addendum Since August of 1988, I have worked on several different types of environmental projects. Details are presented below:
Management of Envkw.tal Site Investigation and Remediation Projects I. As regulatory project manager for corrective actions, closures and interim measures, I evaluated soil and groundwater sampling and analysis plans, risk assessments and site remediation plans. The types of units assessed include landfills, storage areas, surface impoundments, sumps, petroleum tanks and waste piles. I have collected groundwater, soil and waste samples as part of the cleanup process for these sites and I am familiar with many types of sample collection methods and EPA analytical methods. I am also familiar with procedures for submitting samples to the State Health Laboratory. I have teamed with EPA on several of these projects.
- 2. I am familiar with EPA risk assessment protocols (RAGS) and I have reviewed and evaluated human health and ecological risk assessments. I have a good understanding of the information needed l
to complete a risk assessment and the types of decisions that are based on risk assessment. I have also l,
teamed with EPA and DEQ risk assessors as project manager.
guidance documents related to environmental sampling. I am also familiar with review of analytical
' data from a regulatory perspective (e.g., evaluation of chain of custody, holding times, surrogate recoveries (MS/MSD), dilutions, detection limits etc). I am also familiar with US Geological Survey l
ModFlow groundwater modeling software.
- 4. I acted as project manager for removal and management of chemical agent contaminated soil i
j generated by US Army Dugway. This project involved characterization of soil, on site treatment of-i l
soil and shipping the soil off site. This project required coordination with Army, Centers for Disease Control (CDC), safety, TSDF and other organizations.
- 5. I acted as regulatory project manager for design and set up of a system capable of cleaning up a large volume (estimated 36 billion gallons) of Trichloroethene contaminated groundwater. This project took several years to complete and required close coordination with the US Army Corp of Engineers to
' design a well system and air stripper. As part of the project, I also did oversight on installation and l
startup of the treatment system and installation of groundwater extraction, injection and monitoring L
wells.
- 6. I have been technical project manager for contract work. The contracts managed included preforming training, review of documents and field oversight. I tracked contractor work quality and cost to ensure that contract requirements were met. This included a one year contract through EPA for a full time employee. I made assignments to this employee and did an employee performance review.
Environmental Permitting 2
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I. I have written three RCRA facility assessments (RFAs) and been part of the assessment team for j
' contaminated sites at two military bases and one large explosives manufacturing facility. The
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about five other facility assessments. The three assessments involved identification and evaluation of assessment involves pre-inspection records review, interviews with site workers, visiting each site and i
preparing a report. ' The reports describe each site and make recommendations about the need for sampling, risk assessment or cleanup.
- 2. I acted as project manager two RCRA hazardous waste storage permits and was assigned to j
oversight permit compliance. The storage permits allow facilities to store hazardous waste on site for extended periods. The permits also include requirements for investigation and clean up of the contaminated sites identified in site assessments. One of the permits allows storage of hazardous waste and hazardous materials together and is operated by Defense Reutilization and Marketing Office
- (DRMO).
' 3. I wrote two RCRA Research Development and Demonstration (RD&D) permits. One of the permits involves treatment of hazardous waste munitions by cryo cooling and crushing and other permit involves treatment of chemical agent by chemical neutralization.
- 4. I wrote a RCRA Post-Closure Permit that included corrective action requirements for cleanup of groundwater contamination and for about 47 Solid Waste Management Units (SWMUs). I was regulatory project manager for installation, startup and prove out of the groundwater treatment system
. and for oversight of the RCRA Facility Investigation (RFI).
. 5. I have reviewed several Subpart X permit applications for open burning and open detonation of reactive wastes. I was a member of the EPA permit writers Subpart X workgroup that developed EPA guidance for permitting of Subpart X units. I was also a member of the workgroup that wrote the
- Utah guidance for Subpart X permitting.
Compliance and Other Projects
- 1. ~ I have been both team leader and team member for numerous RCRA compliance inspections. I also wrote associated inspection reports, notices of violation (NOV) and consent orders to resolve NOVs. I have also calculated penalties, negotiated settlemen's and worked with facilities to develop plans for I
compliance and for supplemental environmental projects. I have been part of the team for EPA multimedia inspections,
- 2. I completed a comprehensive groundwater monitoring evaluation (CME) that included an evaluation of 11 different groundwater monitoring well systems. This involved observing well installation and L
- sampling, reviewing well logs and well completion records and collecting gnundwater samples. This evaluation was part of a state-EPA agreement (SEA).
- 3. I track my corrective action, permitting and compliance work for entry into RICRIS. RCRIS is the system used by EPA to track and record environmental work completed by the state.
4.' I participated as part of a trial burn team with EPA to oversight trial burn activities at a chemical l
agent incinerator located on Johnston atoll.~ Johnston atoll is located about 700 miles west of Hawaii.
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- 5. I was part of the national military munitions rule and range rule (MMR) group. This group provided input to EPA and the Army in developing the military munitions rule and the range rule. This ti group developed guidance that is now included in the MMR.
- 6. I have made presentations to the Solid and Hazardous Waste Control Board regarding permitting i
and compliance activities. I also made presentations to EPA, US Army Corps and other groups.
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- 7. I have conducted public hearings, written notices to newspapers and radio and I have responded orally and in writing to public comments. I have interacted with Sierra Club, Families Against Incinerator Risk (FAIR) and other citizen environmental groups.
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A Bronson W. Hawley Utah Department of Environmental Quality P.O. Box 144880 Salt Lake City, UT 84114-4880 (80l) 538-6170 (work) l 4
Professional History l
Environmental Scientist 1994-Present Utah Department of Environmental Quality Conducts RCRA Compliance Inspections of Hill Air Force Base and Utah Test and Training Range.
Corrective Action Project Manager for Hill AFB & UTTR, oversees characterization and remediation of numerous sites with both soil and groundwater contamination.
Represented the Utah Department of Environmental Quality on the Interstate Technology and Regulatory Cooperation Work Group developing national policy for the adoption of new remediation technologies.
Senior Geophysicist 1985-1993 Applied Geophysics Inc.
Managed data processing department that significantly increased quality and productivity, while decreasing required manpower by 25%.
Wrote concise, high-quality project summary reports that improved customer understanding of data and interpretations and increased percentage of return clients.
Made technical sales presentations to major and independent oil companies; wrote proposals and negotiated comracts that resulted in more than 50 signed agreements.
Geolonist. Ph.D. Deeree 1980-1990 University of Utah Studied theory and applications of groundwater modeling, including review and critique of e
hazardous waste site case histories. Received a grade of'A' and an excellent evaluation.
Organized and executed field logistical operations for a three month geologic mapping and sample collection project on the Kenai Peninsula of Alaska which accomplished all goals.
Taught introductory geology coursed, achieving a high level of understanding by students and
1 excellent evaluations as an instructor.
Geonhysicist 1979-1980 Phillips Petroleum Company Managed quality control program for a $1M marine seismic survey, insuring a high degree of confidence in future exploration relying on that data.
Integrated marine seismic and geologic data for a California oil exploration project, including determination of well locations and presentation of results to management.
Geonbysicist. M.S. Deeree 1977-1 979 University of Utah Wrote the first computer modeling routine to simultaneously solve for both earthquake locations and 3D carth structure, using an iterative approach. I was awarded the Master of Science Research Award for this project.
Conducted microcarthquake surveys, including deployment and maintenance of ponable field stations in Utah, Idaho and Wyoming, obtaining excellent final data quality.
Operated a year long carthquake prediction survey of the Wasatch Fault, Utah, showing conclusively that the existing approach would not work for the Wasatch Fault.
Education University of Utah University of Utah University of Montana Doctor of Philosophy Master of Science Bachelor of Science Geology Geophysics Physics l
RESUME DAVID C.'SCHEN 1594 W. North Temple, Ste. 3520 Salt Lake City, UT 84114 801-538-5504 (office)
EDUCATION A.A.S.
PRE-PROFESSIONAL FORESTRY February 1969 Paul Smith's College, 1967 - 1969 Paul Smiths, New York.
B.S.
FOREST RECREATION /NANAGEIGNT June 1971 Utah State University, 1969 - 1971 Logan, Utah.
PROFESSIONAL EXPERIENCE BCOSYSTEM MANAGEMENT COORDINATOR December 1995 - Present Utah Division of Forestry, Fire, & State Lands 1594 West North Temple, Suite 3520 Box 145703 Salt Lake City, Utah 84114-5703 As Ecosystem Management Coordinator I am responsible for the administration of the Division's Technical Assistance / Resource Programs Work Unit.
This work unit encompases state office resource program staff including Forest Stewardship, Urban
- Forestry, Minerals Management & Leasing, Forest Health, Fire Management, and the Lone Peak Conservation Center (Nursery &
Conservation / Fire Crews).
My position reports directly to the State Forester.
FOREST STEWARDSHIP COORDINATOR July 1982 - November 1995 Utah Division of Sovereign Lands & Forestry 3 Triad Center, Suite 425 355 West North Temple Salt Lake City, Utah 84180 As Forest Management Coordinator I
was responsible for the administration and development of the forest stewardship and stewardship incentives programs.
Prior to the legislative split of
State Lands & Forestry in July 1994 I was also responsible for J
forest products sales programs on state trust lands.
Prior to 1990 I had oversight responsibility for the division's urban forestry, agro-forestry, forest pest management, forest products utilization, and nursery programs.
Since 1990 I have been successful in securing federal grants and guiding prioritization of available FTEs.
This allowed the division to staff the agro-forestry, forest pest management, and i
urban forestry programs.
Management and organizational input provided to the State Forester has resulted in restructuring of the nursery / conservation center.
Recent funding of the forest stewardship program has allowed development of the division's field infra-structure.
Specific responsibilities have included budget development and administration, federal grant negotiations, policy analysis and development, program targeting and reporting, identification of program needs and priorities, inter-agency & legislative liaison, development of uniform standards and procedures, special projects, supervising unit personnel, and leadership for the Forest Stewardship Coordinating Committee.
While on a six month detail to the USDA - Forest Service (S&PF, R-4) in 1990, I chaired the Western Urban Forestry Committee established by the Council of Western State Foresters and the seven i
western Forest Service regions.
In 1991 I also served on a national Stewardship Incentives Program (SIP) public information task group detailed to the Forest Service's Washington Office, Coop.
Forestry.
I served on the Council of Western State Forester's Western Stewardship Committee (October 1992 - December l
1995) and served as its chairman from October 1993 through December 1994.
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NORTHERN REGIONAL MANAGER November 1978 - July 1982
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Division of State Lands & Forestry j
Salt Lake City, Utah j
The northern region was comprised of Utah's 14 northern counties
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and included three area offices staffed by four full time professional foresters and twelve seasonal fire-wardens.
The professional staff included a secretary and three area (service) foresters.
As Regional Manager my responsibilities included the overall supervision of regional personnel and delivery of division programs.
Division programs included resource management and forest product sales on state trust lands, private forestry assistance, urban forestry, fire management, and forest products 2
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utilization.
Other responsibilities included budget preparation and administration, negotiating county and interagency agreements, inter-regional coordination, and setting area level program targets.
BEAR RIVER AREA FORESTER June 1973 - October 1978.
Division of State Lands Section of Forestry and Fire Control Logan, Utah The Bear River Area was comprised of the three northern most
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counties in Utah.
As Area Forester, I supervised three seasonal j
fire-wardens and one full time RC&D Forester.
Duties involved objective setting (MBO), budget preparation, and on the ground delivery of the division's service forestry programs.
Program involvement included fire management, resource conservation & development, private forestry assistance, urban forestry, fcrest products utilization, and timber sales on state lands. The position also required a close liaison and coordination with county and regional-government officials and agency representatives.
RC&D FORESTER November 1971 - June 1973 Division of State Lands Section of Forestry and Fire Control Brigham City, Utah As Resource Conservation & Development (RC&D)
Forester I was responsible for inventory of state and private forest lands in the Bear River Area.
I was also responsible for publication of inventory findings.
SEASONAL EXPERIENCE COMPLIANCE CHECKER 1970 & 1971 l
1 Flaming Gorge National Recreation Area j
Ashley National Forest, Utah Responsibilities included collection of fees, public contact, law enforcement, fire suppression, and timber stand improvement.
FOREST TECHNICIAN 1969 3
c Supervisor's Office Ashley National Forest, Utah Responsibilities included collection of watershed data for the Central Utah
- Project, Duchesne Ranger
- District, Rock Creek drainage.
LABORER 1967 & 1968 Iroquois Gas Company (National Fuel)
Wellsville, New York Labor involving installation and maintenance of natural gas service
& distribution lines.
ROUSTABOUT 1966 & 1967 Bradley Producing Company (Bradley Resources)
Bolivar, New York Labor involving drilling and bringing new oil wells on line and maintenance of related crude oil production facilities.
TRAINING & QUALIFICATIONS Administrative Management, 1973.
Land Use Planning, 1974.
Reforestation Planning, Supervision, and Contracting, 1974.
. Insect and Disease Workshop, 1975 & 1980.
Instructor Training, 1975.
Assisted as an instructor for the Division in 1977 & 1978.
Served as an Instructor at sessions for the Nevada Division of Forestry in 1977 and the Idaho Department of Lands in 1980.
State &' Private Forestry Workshop, 1975.
Fuel Management Workshop, 1976.
' Management by Objectives, 1976.
Timber Appraisal Training, 1977.
Organizational Management for Managers, 1977 & 1982.
Forestry Salesmanship Workshop, 1980.
Timber Sales Administration, 1982.
Reforestation Planning, Supervision, and Contracting, 1974.
Insect and Disease Workshop, 1975 & 1980.
Timber Appraisal Training, 1977.
Timber Sales Administration, 1982.
i Logging Systems Planning & Layout, 1983.
PROGNOSIS - FVS, 1994.
Forest Pest Management For Silviculturists.
Continuing Education for Ecosystem Management (CEEM-1), 1995 4
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Advanced Silviculture Training, 1995 Fire Qualification & Certification Record, See Attached.
ACTIVITIES Great Basin Type I Incident Management Team, 1985 - 1993.
Division Supervisor, 1985 - 1987.
Operations Section Chief 1988 - 1993.
Type II Incident Management Team, OSC, 1995 - 1996 RUL, 1997-present Utah Acid Deposition Technical Advisory Committee, 1987-1988.
State Nursery Task Force, 1988, Exec. Secretary.
Utah Arbor Day Committee, Chairman 1988 - 1990.
Utah Gypsy Moth Decision & Action Committee, 1988 - 1990.
Chairman, Utah Forest Stewardship Coordinating Committee.
CWSF Zone Representative, Western Stewardship Committee.
PUBLICATIONS RC&D Release # 1, State & Private Resources, Cache County, Utah, A Timber Inventerv, May, 1972.
RC&D Release 2,
State & Private Forest Resources, Bear River Area, Utah, A Timber Inventerv, June 1975.
" Prescribed Burning - Effective Control of Sagebrush & Juniper",
' Utah Science Magazine, Volume 36, Number 3, September 1975.
I have also supervised or contributed to several other publications including the " Community Forestry Manual"; " Ornamental & Shade i
Trees for Utah"; " Utah Wood As A Renewable Energy Resource"; " Tree
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& Shrub Planting Guide for Utah & Nevada"; " Utah SIP Handbook"; and
- a. variety of pamphlets.
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Publications of Marvin Resnikoff, PhD,1985/1998 January 1985 "U.S. Radioactive Landfill Experience," paper, presented to the Annual Institute of British Geographers in Leeds, England. Incorporated into Nuclear Power in Crisis: Politics and Planning for the Nuclear State, edited t>y Blowers, A., and Pepper, D., Nichols Publishing Co. (1987).
February 1985 " Comments on the transportation sections of the draft Environmental Assessment for a high level waste repository in 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 oflong-lived low-level waste.
September 1985 " Radioactive Waste Incineration in Parks Township, Pennsylvania, What's Coming Out of the Stack?," Campaign repon 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 in the 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," Campaign report prepared with Dana 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 j
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.
July 1986 September 1986 Affidavit in Federal Court in New York City on behalf of a Warwick, l
1 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 Vernon, New Jersey, j
August,1986 Supplement to June 1986 Campaign report on the Feed Materials q
Production Center discussing contamination of public water supplies,20 pages.
September 1986 " Disposal of high level waste in Canada," paper presented at high-level waste conference, Winnipeg, Manitoba. Workshop on the transportation of irradiated fuel in Canada. Incorporated 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, November 1986 Associates report to the State of Kansas on draft Request for Proposal for contractor to the Central States Compact,10 pages.
November 1986 " Transportation ofirradiated fuel," paper presented to a subcommittee of the National Association of Attorneys General, Las Vegas, Nevada.
December 1986 Associates affidavit 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 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.
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 Associates affidavit pre pared for the Sierra Club Legal Defense Fund on the need for an Emironmental ; mpact Statement before inemerating plutonium-contaminated waste at the Rocky Flats Plant.
September 1987 Living Without Landfils, Campaign book on the hazard of radioactive landfills, and safer alternatives,119 pages.
September 1987 Associates affidavit prepared on behalf of the Alaska Attorney General in a U.S. District Court action on the need for a federal Environmental Impact Statement for air shipments of plutonium in Alaska.
November 1987 " Low-level waste in Michigan," talk before ajoint session of the Michigan Legislature, East Lansing. Michigan.
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February 1988 Testimony before the Vermont House 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.
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 :3roposed llw dump sites; jointly sponsored with local groups (Individuals for a C lean Environment)
July 1988 Briefing before Congressional Legislative Assistants on the findings of Deadly Defense, jointly conducted with the Sierra Club and sponsored by Representative Don 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.
October 1988 Boulder, CO; talk, participation in conference and chapter of book, Environmental Impacts of Warfare; sponsored by the Sierra Club.
November 1988 Nucla, CO; pre 3ared testimony before Colorado Department of Health re. suitability of proposec " 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 December 1988 Preparation of court aftidavit 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.
February 1989 " Uranium Releases at 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.
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May 12,1989, " Preliminary Report on RI/FS Study," prepared on behalf of 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 "Re mrt on Maxey Flats Remediation Program," 75-page report, prepared for Maxey ?lats 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 of Nevada, Las Vegas.
l February 1990 " Radioactive Waste Mismanagement at Nine Mile Point 1."
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i April 9,1990 " Comments on the Final Supplemental Environmental Impact Statement, 1
Waste Isolation Pilot Plant," on behalf of Concerned Citizens for Nuclear Safety, I
Santa Fe, New Mexico.
April 25,1990, talk before the Hazardous Materials / Nuclear Symposium on nuclear transportation issues, Ely, Nevada.
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- April 26,1990, Statement before the Nevada Commission on Nuclear Projects on nuclear transportation issues, Las Vegas, Nevada.
i July 19,1990, " Report on Feasibility Study, Risk Assessment, App. D, iodine hazard,"
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prepared on behalf of Maxey Flats Concerned Citizens, Flemingsburg, Kentucky.
I August 1,1990, " Report on the State of Kentucky, Maxey Flats Closure Plan," prepeced on behalf of Maxey Flats Concerned Citizens, Flemingsburg, Kentucky.
August 1990 Preparation of second court affidavit re. proposed irradiated fuel shipments from Taiwan through Portsmouth, Virginia, betore the United States Distnct Court, District Of Columbia, on behalf of the Sierra Club Legal Defense Fund.
September 1990 "The Generation Time-Bomb: Radioactive and Chemical Defense Wastes," in Hidden Dangers, Environmental Consequences ofPreparingfor War, edited by AH Ehrlich 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 ofNebraska.
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December 1990 Preparation of third court aflidavit 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.
February 8,1991, " Review of' Risk Assessment and Safety Analysis, University of Michigan Waste Handling Facility,' on behalf cf 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.
4 May 6,1991, " Comments on Final Environmental Impact Statement, Prairic Island Independent Spent Fuel 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, International Institute for Low Level Radioactive Waste, East Lansing, Michigan.
May 23,1991, "Radiac Accident Analysis," prepared on behalf of the Radioactive Waste Campaign, Brooklyn, New York.
May 30,1991, " Nuclear Power in the United States," talk sponsored by the Green Pany, Rikstag, Green Party Group Room, Stockholm, Sweden.
June 20,1991, " Comments on the Department of Energy Environmental Assessment on Off Site Fuels Policy," prepared on behalf of the Sierra Club Legal Defense Fund, Washington, D.C.
- July 1,1991, " Comments on the Final Environmental Im act Statement for the Proposed Ward Valley Low level Waste Landfill," submitted to the California Department of Health Services, on behalf of Don't Waste California.
1 July 12,1991, " Comments on EPA Proposed Flan," prepared on behalf of Maxey Flats i
Concemed Citizens, Flemingsburg, Kentucky.
l September 8,1991 Preparation of 4th court affidavit re. proposed irradiated fuel shipments from Taiwan through Portsmouth, Virg, ia, before the United States m
District Court, District Of Columbia, on behalf of the Sierra Club Legal Defense l
Fund.
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 5
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ros Radiation Analysis," before the Minnesota Public Utility Commission on behalf of the Prairie Island Mdewakanton Sioux Indian Community.
October 23,1991 " Health and Safety Impacts ofNMI,2nd Report," prepared on behalf
- of Concemed Citizens about NMI, Concord, Mass.
October 31,1991 Pre paration of 5th coun affidavit re. proposed irradiated fuel shipments from Taiwan through Ponsmouth, Virginia, before the United States District Court, District Of Columbia, on behalf of the Sierra Club Legal Defense Fund.
November 4,1991 Statement before the City of Albuquerque Common Council regarding disposal ofradioactive 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 Court, District of Columbia, on behalf of the New Mexico Attorm -b:ueral.
November 1991 " Prairie Ish nd Independent Spent Fuel Storage Facility, Prefiled Reply Testimo iy," before th: Minnesota Public Utility Commissica on behalf of the Prairie Island Mdewakanton Sioux Indian Community.
RWMA, White Paper #1, Sources ofLow-Level Waste in Connecticut, prepared on behalf of the Towns of East Windsor, Ellington and South Windsor, September 30,1991.
RWMA, White Paper #2, Low-Level Waste Transportation in Connecticut, prepared on behalf of the Towns of East Windsor, Ellington and South Windsor, October 2,1991.
RWMA, White Paper #3, Statement by Dr. Marvin Resnikofon Chem-Nuclear, prepared l
on behalf of the Towns of East Windsor, Ellington and South Windsor, October 29,1991.
RWMA, White Paper #4, Leakage From Existing ' Low-Level' Waste Disposal Facilities, L
prepared on behalf of the Towns of East Windsor, Ellington and South Windsor, January L
.6,1992.
Marvin Resnikoff and Anne Vanrenterghem, Preliminary Review of US Ecology Safety Analysis Report, ProposedBoyd County, Nebraska Low-Level Waste Facility, prepared l
on behalf of the Boyd County Local Monitoring Committee, February 2,1992.
l Marvin Resnikoff, Radon Releasesfrom Uranium Tailings and Projected Health Efects, I'
prepared on behalf of Northwatch Coalition, February 17,1992.
RWMA, White Paper #5, Storage ofLow-Level Radioactive Waste, prepared on behalf of 6
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- 0 the Towns of East Windsor, Ellington and South Windsor, February 19,1992.
. Marvin Resnikoff, Scope: McArthur River and Cigar Lake Projects, Memo to Inter Church Uranium Council, February 27,1992.
Richard Leigh, Marvin Resnikoff and Anne Vanrenterghem, EnvironmentalImpacts of Elliot Lake Mill Tailings, prepared on behalf of Northwatch Coalition, March 30,1992.
Marvin Resnikoff, Canadian High-Level Waste Repository Costs, Memo to David Poch and David Argue, Coalition of Environmental Groups, April 2,1992.
Minard Hamilton, Low Level Waste Facilities in Canada and the U.S., prepared on behalf ofNorthwatch Coalition, April 22,1992.
Marvin Resnikoff, Comment on Midwest Joint Venture EIS, Memo to Inter Church Uranium Council, April 23,1992.
Benjamin A. Goldman, Review ofEnvironmental Report Social and Economic Impact Assessments: Proposed Low-Level Radioactive Waste Disposal Facility, prepared on behalf of Northwatch Coalition, June 25,1992.
Lee DiTullio and Marvin Resnikoff, Review ofSafety Analysis Report Part 1: Geology, l
. Hydrology Proposed Low-Level Waste Facility Butte, Nebraska, prepared on behalf of the Boyd County Local Monitoring Committee, June 29,1992.
Marvin Resnikoff, Mythbuster#8, " Low-Level" Radioactive Waste, for Safe Energy Communications Council, Summer 1992.
Marvin Resnikoff, Comments on Final Guidelinesfor the Preparation ofan Environmentalimpact Statement on the Nuclear Fuel Waste Management and Disposal Concept, July 22,1992.
Marvin Resnikoff, NMrs ProposedHydromet Project, Memo to Judy Scotnicki, Concerned Citizens of Concord, July 29,1992.
Marvin Resnikoff and Lee DiTullio, Review ofSafety Analysis Report Part 2: Risk Assessment Proposed Low-Level Waste Facility Butte, Nebraska, prepared on behalf of the Boyd County Local Monitoring Committee, August 7,1992.
RWMA, Comments on McClean Lake Project EIS, prepared on behalf of the Inter-7 a
i Uranium Coalition, June 30,1992.
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- Lee DiTullio and Karen Levine, Comments on Cluglake EIS, prepared on behalf of the
' Inter-Church Uranium Coalition, July 20,1992.
Marvin Resnikoff, Plut ~sium Ship AkatsuU Maru Consequences ofFire at the Pearl Harbor Naval Shipyard, prepared on behalf of Greenpeace, August 24,1992.
Marvin Resnikoff, Waste Impacts ofthe Nuclear Fuel Cycle, prepared on behalf of Coalition of Environmental Groups, November 1992.
Marvin Resnikoff, Declarations on the safety of shipping naval fuel from shipyards to Idaho before the Federal District Court, prepared on behalf of the Idaho Attomey 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.
Marvin Resnikoff, Talk at a Town Meeting in Grand Rapids, Michigan, June 22, l
regarding the safety of the VSC-24 storage container at the Palisades reactor.
l Marvin Resnikoff, Reports to two environmental assessment panels reviewing the l
environmental impact of proposed mining operations in Northern Saskatchewan, prepared l
on behalf of the Interchurch Uranium Coalition, May 12 and June 14,1993.
Marvin Resnikoff, Presentation before the Ohio Governor's Blue Ribbon Committee on siting a low-level waste facility in Ohio for the Midwest Compact, July *1993.
i Marvin Resnikoff, Report on the safety of processing and storing radium-contaminated wastes in the Tapscott district of Scarborough, Toronto, prepared on behalf of the Coalition Against Radioactive Tapscott, November 1,1993.
Marvin Resnikoff, Remarks before the Department of Energy meeting on the Multi-Purpose Canister, Washington, D.C., November 16,1993.
Marvin Resnikoff, Repon 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 on behalf of Algoma-Manitoulin Nuclear Awareness, December 15,1993.
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Resnikoff, M and Haaker, Py " 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 Fuchsman, P, " 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.
Leigh, RL and Resnikoff, M, " Estimated Exposure to Radiation and Metals Received by Lincoln Park Residents from Cotter Mill Operations," report prepared for the case J Dodge et al v. Commonwealth Edison, July 1,1994.
Resnikoff, M, Affidavit prepared on behalf of plaintiffs in the United States District Court for the Eastern District Of Tennessee at Knoxville, Euchee Marina & Campground, Inc. et al, plaintiffs, v Union Carbide Corporation, et al, defendants, July 15,1994.
Resnikoff, M and Knowlton, K, " 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, RL and Fuchsman, P, " 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 Located in the Town of Two Creeks, Manitowoc County, September 11,1994. Also Rebuttal Testimony, dated September 27, 1994 and Supplemental Testimony, dated October 3,1994.
Resnikoff, M, affidavit prepared on behalf of plaintiffs in the United States District Court for the District of Massachusetts, Citizens Awareness Network, Inc., plaintiff, v. United States Nuclear Regulatory Commission, defendant, October 4,1994.
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l Resnikoff, M, affidavit in opposition to motion of Westinghouse for summary judgment, prepared on behalf of plaintiffs in the United States District Court for the Westem 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, l
Nevada: unresolved safety issues," February 1,1995.
Resnikoff, M, " Ohio low-level waste legislation," Lobby Day, Ohio Environmental j
Council Border Opposes Nuclear Dump," February 22,1995.
Fuchsman, P, Hamilton, M, Knowlton, K, Levine, K and Resnikoff, M, " Wayne Health Survey," prepared for the Town of Wayne, April,1995.
Knowlton, K and Resnikiff, M, "A review of the phase Il field investigation and financial resources of NMI," report prepared for CREW, May 22,1995.
l Resnikoff, M, Knowlton, K and Fuchsman, P, " Low-level waste transponation in Texas,"
prepared for Alert Citizens for Environmental Safety, June 29,1995.
I Resnikoff, M and Knowlton, K, " Comments on ' Engineering evaluation / cost analysis for the cleanup of residential and municipal vicinity properties at the Maywood site, Bergen County, New Jersey,'" on behalf of Concerned Citizens of Maywood, August 11,1995, t
Resnikoff, M, Fuchsman, P and Knowlton, K, " Low-level waste transportation in North Carolina," prepared for the Chatham County Preferred Site Local Advisory Committee, l
August 13,1995.
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Edelman, G and Fuchsman, P, " Business survey on the Socioeconomic impact of the low-level radioactive waste facility proposed for North Carolina," prepared for Chatham County, August, 16,1995 Resnikoff, M, Knowlton, K and Fuchsman, P, " Comments on environmental impact statements for the Cigar Lake and Midwest Joint Ventures proposals," prepared for the Saskatchewan Uranium Coalition, October,27,1995.
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- All publications in the year 1995 have appeared since my Rule 26 statement in the Muzzey/ Bryan case.
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' 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.
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 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 21,19%.
Resnikoff, M, K Knowlton, and K Island, " Comments on Environmental Impact Statement for the McArthur River Proposal," prepared for Saskatchewan Uranium Coalition, March 1,1996.
Resnikoff, M, K Knowlton, P Fuchsman, and K Island, " Site Suitability and Impact of Proposed Radioactive Waste Facility, Wake /Chatham Counties, North Carolina,"
prepared for Chatham County Preferred Site Local Advisory Committee, March 20,1996.
Resnikoff, M, " Mississippi Oil and Gas Board Proposed Rule 69: Control of Oilfield NORM," 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.
RWMA, " Comments on the IRP Remedial Design Work Plan, Maxey Flats, Kentucky,"
prepared for Maxey Flats Concemed Citizens, August 2,1996.
Knowlton K, and M Resnikoff, " Review of the License Application for the Proposed i
LLRW Facility Near Sierra Blanca, Texas," prepared for Sierra Blanca Legal Defense Fund, updated August 14,1996,(original November 30,1995).
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Resnikoff, M, " Radiation Dose Exposure Received by Milt Vercher During Oil Pipe Cleaning Operations," September 27,1996.
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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.
Knowlton, K, M Medina, and M Resnikoff, "Conunents 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 on behalf of Concemed Citizens of Manitoba, January 1997.
Resnikoff, M., and Waligora, Jr., S.J., " 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, on behalf of the Prairie Island Indian Community, February 1997.
Resnikoff, M., " Comments on Environmental Management Advisory Board Report
' Report of a Stakeholder Process to Develop Guiding Principles for the Formerly Utilized Sites Remedial Action Project, Background Information Document, " prepared on behalf of Thorium Advisory Committee, Town of Wayne, New Jersey, March 7,1997.
Resnikoff, M., " Comments On ' Report of a Stakeholder Process to Deveiop Guiding Principles for the Formerly Utilized Sites Remedial Action Project ' Background l
Information Document, " prepared on behalf of Concemed 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.
Resnikoff, M., andChampion, A., " Transportation Accident of Ship Carrying Vitrified 12
High-Level Radioactive Waste: Part 1. Impact on the Federated S ates of Micronesia,"
prepared on behalf of Greenpeace Pacific, July 31,1997.
Resnikoff, 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.
Resnikoff, M., " Comments on the Depanment of Energy's Draft Feasibility Study and Draft Record of Decision for the Wayne Site," prepared on behalf of Thorium Advisory Committee, Town of Wayne, New Jersey, September 15,1997.
Resnikoff, M., " Presentation Before Panel on the Waste Management System, Nuclear Waste Technical Review Board," November 19,1997.
Fairlie, I., and Resnikoff, M., No Dose Too Low, anicle prepared for The Bulletin of The
' Atomic Scientists, November / December 1997.
Resnikoff, M., " Proposed Remediation Work at Maxey Flats," prepared on behalf of l
l Maxey Flats Concerned Citizens, January 1998, l
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Resnikoff, M., " Comments on the draft Safety Evaluation Report (DSER), Proposed l
LLRW Facility at Boyd County, Nebraska by the State of Nebraska," prepared on behalf of the Boyd County Monitoring Committee, Febmary 1998.
Resnikoff, M., " Comments on Draft PEIS for the Long-Term ' Management and Use of l
Depleted Uranium Hexafluoride," March 1998.
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Resnikoff, M., Affidavit prepared for Giordano, Halleran, & Ciesla, in the case Robert Kenny v. Shore Regional High School, et al., March 1998.
Resnikoff, M., " Comments on FOR No.13, Part I - Interim Version, Health Risks from i
Low-Level Environmental Exposure to Radionuclides," June 30,1998.
' Resnikoff, M., " Radioactive Waste Trends," prepared on behalf of the Chatham County PSLAC, June 1998.
Resnikoff, M., and Tsui, C., " Health Impacts of Oil Production in Brookhaven, Mis'sissippi," prepared on behalf of Sacks & Smith, July 30,1998.
Resnikoff, M., " Comments on Preliminary Safety Evaluation Report and Proposed 13
4 Certificate of Compliance H1-Star 100 Storage Cask," prepared on behalf of The State of Utah, Department of Environmental Quality, October 26,1998.
Resnikoff, M., " Calculation of Radiation Exposures Received by Rebekah Dassion,"
prepared on behalfof Hagens & Berman as part of a federal personal injury case, November 23,1998.
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Marvin Resnikoff, PhD: Court Proceedings Case Oficial Title, Case M.
PlaintyfAttorney Nature ofcase Court Adams v Dupont Anita Adams et al v El John Emerson Personal injury, U mining DuPont DeNemours et al, Whittington, vonSternberg, and milling US District Court, San Emerson Antonio, SA-98-CA.
2600 S Gessner, Ste 600 816(EP)
Houston,TX 77063 713.789.8850 Boeni y Stepan George L. Boeni v. Stepan David Tykulsker Worker's comp; thorium Chemical Chemical Co.;
Ball, Livingston & Tykulsker processing plant heard before Div. Of 108 Washington St.
Worker's Compensation, Newark, NJ 07102 Hackensack, NJ (201)622-4545 Carey v Kerr-McGee Jesse Carey et al v Kerr-Paul Weiss Personalinjury, thorium McGee Corp, US District Hagens & Berman processing plant Ct, Nonhern Dist of 1301 Fifth Ave, Ste 2900 lilinois, No. 96-C-8583 Seattle, WA 98101 206.623.7292 Case v Chevron Jarnes Edward Case et al.
Stuart Smith Dose reconstruction: oil j
- v. Chevron USA, Inc. et Sacks & Smith pipe scale al.; USDC; Southern 1615 Poydras St.
Miss.; Jackson District; Suite 860 Case #J92-0269(W)(N)
New Orleans, LA 70112 (504) 593-9600
]
Davis v Transelco Stuart Smith Thorium lens polishing Sacks & Smith compound; occupational 1615 Poydras St.
exposure l
Suite 860 i
New Orleans, LA 70112 l
(504) 593-9600 Dodge v Comm Edison Joseph Dodge et al. v. The Rebecca Lorenz Dose reconstruction; Cotter Corporation and Melat, Pressman, Ezell &
Cotter U mill Commonwealth Edison Higbic Co.; USDC; District of 711 South Tejon St.
Colorado; Civil Action Colorado Springs, CO, I
- 91 Z l861 80903-4059 (719)475-0304 Ferguson v Ashland Victor Ferguson v Ashland Pete Petroski, Esq NORM contamination inc, et al Fleming Hovenkamp&
Johnson Circuit Court, Grayson KY, No. 95-CI-124 1330 Post Oak Blvd Houston. TX 77056-3019
r Case Oficial Title, Case #,
PlaintifAttorney Nature ofcase Court Garza v Wyoming A Garza et al v Andrew Schirrmeister,2603 Personal injury case re.
Minerals Westinghouse Electric Augusta, Sie 1200, llouston, binh defects; parents Corporation, et al; UDC in TX 77057;(713) 781-0771 involved in U mining Corpus Christi, TX; Civ No. C-95-505 Kenny v Shore Robt Kenny v Shore Norm Hobbie, Esq, Personal injury, industrial Regional Regional Bd of Ed, et al Giordano,llalleran,125 Half accident Superior Court of NJ, Mile Rd, Middletown, NJ Monmouth Cry, MON-L-07748,(732)219-5484 6617-93 Idaho AG Public Service Co. of Larry Echohawk, Atty Federal Coun Colorado v. Cecil D General State ofIdaho; proceedings re impact of Andrus, individually and Office of the Attorney transportation of sub fuel as the Governor of the General; Boise,ID 83720-to Idaho State ofIdaho;UDC; 1000 District ofIdaho; Civil #
(208) 234-2400 91-0035-S-HLR Kennedy v Southern Joe Kennedy and Ellen Katy Jacobs, Esq Personalinjury at nuclear California Edison Marie Kennedy v Southern Howarth & Smith reactor California Edison, et al 700 So Flower St, Suite 2900 US District Ct, Southern Las Angeles,CA 90017 District of California 213/955 9400 Case No. 95 3769 J (RBB)
Longoria v URI Manuel T Longoria et al.
Ricardo DeAnda Propeny damage due to
- v. Uranium Resources, DeAnda Law Firm uranium solution mining Inc. et al.;in the District Plaza de San Augustin Court of Duval County, 212 Flores Ave.
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229* Judicial District, Laredo, TX 78040 l
Texas; Cause # 16264 (210) 726-0038 l
Marina Owners v MM Euchee Marina &
Wm Vines; Butler, Vines &
Federal Coun Campground, et al. v.
Babb; Suite 810, First proceedings, potential j
Martin Marietta Energy American Center; Knoxville, risk from Dak Ridge l
System, Inc. et al.; USDC; TN 379012649;(423) 637-releases East Dist; Nonh Div; 3531 Docket: CIV 3 91-0510 Radioactive Waste Louie Roselle; Waite, Fernald U exposures and Campaign Schneider, Bayless &
radiation doses to nearby l
Chesley; 1513 Central Trust residents Tower, Cincinnati, OH 45202;(513) 621-0267 Rock v Southern Joshua Rock v Southern Katy Jacobs, Esq Personal injury," hot" California Edison California Edison, et al, Howanh and Smith particles Case No. 95 3821 J (RBB) 700 S Flower St.
Suite 2900 Los Angeles,CA 90017 i
4216 l
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b Case Official Title, Case M, PlaintifAttorncy Nature ofcase l
Court Talitsch y Stepan Mathis Talitsch v. Stepan David Tykulsker.
Worker's comp; thorium Chemical Chemical Co.; Division of Ball, Livingston & Tykulikcr processing plant Worker's Compensation, 108 Washington St.
Hackensack, NJ; C.P. #91-Newark, NJ 07102 001800 (201) 622-4545 Vercher v intracoastal Stuart Smith; Sacks & Smith; Oilpipe scale 1615 Poydras St.
Suite 860; New Orleans, LA 70112;(504) 593-9600 West v Kerr-McGee Kristy Lee West et al. v.
Thomas Trinley Personalinjury cases re.
Kerr-McGee Chemical Patrick J Kenneally Ltd KMCC thorium Corp.;in USDC; Northern 2 North LaSalle St.
District ofIllinois; Eastern Suite 1950 Div.; Case # 92 C 4211 Chicago. ILL 60602 (312)236-2522 Muzzey/ Bryan v Kerr-Gary Muzzey et al. v.
Thomas Trinley Personal injury cases re.
McGee Kerr McGee Chemical Patrick J Kenneally ' td KMCC thorium Corp.;in USDC; Northern 2 North LaSalle St.
District ofIllinois; Eastern Suite 1950 Div.; Case # 93 C 3623 Chicago. ILL 60602 (312)236-2522 l
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