ML20206N597

From kanterella
Jump to navigation Jump to search
Declaration of M Resnikoff in Support of State of UT Opposition to Applicant Motion for Summary Disposition of Contention C.*
ML20206N597
Person / Time
Site: 07200022
Issue date: 05/11/1999
From: Resnikoff M
AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20206M879 List:
References
97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9905180005
Download: ML20206N597 (1)


Text

-

j i

)

i 1

UNITED STATES OF AMERICA i

BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION j

ATOMIC SAFETY AND LICENSING BOARD In the Matter of PRIVATE FUEL STOR AGE, LLC.

j (Independent Spent Fuel Docket No. 72-22-ISFSI Storage Installation)

May 11,1999 DECLARATION OF DR. MARVIN RESNIKOFF IN SUPPORT OF STATE OF UTAH'S OPPOSITION TO APPLICANT'S MOTION j

FOR

SUMMARY

DISPOSITION OF CONTENTION c l

1 I, Dr. Marvin Resnikoff, declare under penalty of perjury that:

1. I am the Senior Associate at Radioactive Waste Management Associates, a private consulting firm based j

in New York City. On November 20,1997 and January 16,1998, I prepared declarations which were submitted to l

the Licensing Board by the State of Utah ir, support ofits contentions regarding Private Fuel Storage, L.L.C.'s proposed Independent Fuel Storage Installation. A statement of my qualifications was attached to November 1997 1

declaration.

I l

2. I am familiar with Private fuel Storage's ("PFS's") license application and Safety Analysis Report in this proceeding, as well as the applications for the storage and transportation casks PFS plans to use. I am also familiar with NRC regulations, guidance documents, and environmental studies relating to he transportation, storage, and j

disposal of spent nuclear power plant fuel, and with NRC decommissioning require'ments.

i l

3. I assisted in the preparation of the State of Utah's Contention C, and r.m currently assisting the State in the preparation ofits position on Contentic n C, including the taking of discovery. I assisted in the preparation of, and have reviewed, the State of Utah's Opposition to Applicant's Motion for Summary Disposition of Contention C (May 11,1999). The technical facta regarding Contention C, which are presented in the State's Opposition and j

accompanying Statement of Materid Facts in Dispute Regarding Contention C, are true and correct to the best of my knowledge, and the conclusions drawn from tho facts are based on my best professional judgment.

. M'arvin Resn'ikoff

[/

l l

May 11,1999 I

I 1

4' I

'99051'80005 990511 1

PDR ADOCK 07200022 C

PDR

)

L

$