ML20206Q172

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State of UT Second Amended Responses & Suppl Responses to Applicant First Set of Formal Discovery Requests.* with Certificate of Svc.Related Correspondence
ML20206Q172
Person / Time
Site: 07200022
Issue date: 05/12/1999
From: Chancellor D
UTAH, STATE OF
To:
AFFILIATION NOT ASSIGNED
References
CON-#299-20391 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9905190073
Download: ML20206Q172 (20)


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USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 99 MY 18 P 3 :09 BEFORE THE ATOMIC SAFETY AND LICENSING BOARDUPfl. !

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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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May 12,1999 1

STATE OF UTAH'S SECOND AMENDED RESPONSES AND SUPPLEMENTAL RESPONSES TO APPLICANT'S FIRST SET OF FORMAL DISCOVERY REQUESTS The State of Utah amends and supplements its April 14,1999 and April 29, 1999 response to the Applicant's First Set of Formal Discovery Requests (" Applicant's Discovery Requests"). This response supplements the State's responses to General Interrogatories Nos. 3 and 4, and Document Requests for Utah Contention K (Inadequate Consideration of Credible Accidents) and Utah Contention M (Probable

- Maximum Flood); and amends Request for Admissions Nos.14,15, and 16 for Utah

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K; Request for Admissions Nos.1 and 4 and Interrogatories 1-6 for Utah M; and corrects pages 37 and 53 in the State's April 14,1999 Response to Applicant's i

Discovery Requests.

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STATE'S SUPPLEMENTAL REEPONSES TO GENERAL

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INTERROGATORIES GENERAL INTERROGATORY NO.1.

State the name, be,iness address, and job title of each person who was consulted and/or who supplied I

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i 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, pursuant to agreement with PFS, files declarations (included hereto as Exhibit 1) for each person who assisted in answering specific interrogatories and requests for admissions, specifically Denise Chancellor, Esq. (General Interrogatories),

David B. Cole (Utah Contention M), and David Larsen (Utah Contention K).

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.

i STATE'S SUPPLEMENTAL RESPON.SE TO GFNERAL INTERROG ATORY NO. 3.

t Attached as Exhibit 2 is Dane Finerfrock's resume. The State anticipates it will call Mr. Finerfrock as a witness for Contention K.

i 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 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 2

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preceding four years.

STATE'S SUPPLEMENTAL RESPONSE TO GENERAL INTERROGATORY NO. 4.

Attached as Exhibit 3 are lists of publications for Contention K witnesses John L

L. Matthews, Major General USAF (Ret), and Bronson Hawley.

II.

STATE'S SUPPLEMENTAL RESPONSES TO DOCUMENT PRODUCTION REQUESTS Additional documents in support of State's Contentions K and M have been assembled and are now available to the Applicant for inspection and copying at Ms.

Nakahara's office at the Department of Environmental Quality. With respect to Utah Contention K, the State recently obtained information relating to F-16 air crashes, the cruise missile mishap at Dugway and flight operations at Hill Air Force Base. For

. Contention M, calculations were recently prepared by David B. Cole, State's expert for Contention M.

III.

STATE'S AMENDED RESPC. JES A.

. Amended Responses to Requests for Admissions for Utah Contention K Inadequate Consideration of Credible Accidents In its April 14 response, the State qualified its responses to Contention K.

Response at 19-20. The State also filed a general objection to the Applicant's requests for Admissions. Response at 20 21. The State hereby incorporates the qualifications 3

and general objection into this amended response. Notwithstanding the qualifications

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1 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? -

STATE'S AMENDED RESPONSE TO REQUEST FOR ADMISSION NO.

14 - UTAH K:

The State admits that 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 objects to this request for admission on the basis that the phrase "no l

- more than approximately" is contradictory and thus, vague. Notwithstanding this objection, the State admits that the X-33 plans to make approximately seven landmgs i

at Michael Army Airfield over the course of the program.

j

- l REQUEST FOR ADMISSION NO.16-UTAH K:

Do you admit that -

as set forth at page 4-101 of the FEIS for the X 33 space plane - the seven flights for the i

X 33 to Michael Army Airfield are scheduled to be completed by mid 1999.

STATE'S AMENDED RESPONSE TO REQUEST FOR ADMISSION NO.

16 - UTAH K:

The State admits that the seven flights for the X-33 to Michael Army Airfield 4

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were originally scheduled to be completed by mid-1999. However, it is almost mid.

1999 and no space plan flights have occurred to date.

B.

Amended Responses to Requests for Admissions for Utah -

Contention M - Probable Maximum Flood REQUEST FOR ADMISSION NO.1 - UTAH M.

Do you admit that the 270 square mile drainage area used to calculate flooding in PFS's response to RAI Question 2-3 is an appropriate drainage area for calculating the potential for flooding at the PFS ISFSI?

STATE'S AMENDED RESPONSE TO REQUEST FOR ADMISSION NO.

1 - UTAH M:

The State admits that the 270 square mile drainage area is an appropriate drainage area for calculating the potential for flooding at the PFS ISFSI.

REQUEST FOR ADMISSION NO. 4 - UTAH M.

Do you admit that the lowest elevation of the PFS site as identified in the PFS Environmental Report at 2.5-3 and Response to RAI Question 2-3 at 3 is 4460 ft.?

STATE'S AMENDED RESPONSE TO REQUEST FOR ADMISSION NO.

4 - UTAH M:

Admit in part and deny in part. Admit that the PFS Environmental Report at 2.5-3 and Response to RAI Question 2-3 at 3 identify an " approximate" ISFSI site elevation low of 4460 feet. Deny that 4460 feet is the lowest elevation at the PFS site.

Other RAI responses by the Applicant use different lowest site elevation figures for the ISFSI site. See e.g., Enclosure to Commitment Resolution Information, PFS Response to RAI 2 3 (second round), Flooding Analysis, at 1 ("[t]he lowest corner of the PFSF site (elevation 4462 ft)"), submitted by PFS to NRC under cover letter dated March 25, 5

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j 1999. Further, the State does not have access to the ISFSI site and, thus, has not.

conducted a ground survey to verify PFS's claim that 4460 ft. is in fact the lowest elevation at the PFS site. In addition, the ER and the RAI responses do not contain the basis for PFS's estimation that the lowest elevation at the PFS site is 4460 ft.

C.

Amended Responses to Interrogatories - Utah Contention M INTERROGATORY NO.1 - UTAH M. Identify and fully explain each respect in which the State claims that PFS failed "to accurately estimate the Probable Maximum Flood (PMF) as required by 10 CFR $ 72.98" or the 100 Year Flood for the PFS ISFSI, taking into account PFS's response to RAI Question 2-3 as supplemented.

STATE'S AMENDED RESPONSE TO INTERROGATORY NO.1 -

UTAH M:

The State has reviewed PFS's responses to RAI Question 2-3, as last supplemented on March 25,1999', and has now re-calculated the Probable Maximum Flood based on the following parameters and a computer program developed by the State based on Soil Conservation Service (now called Natural Re:,surces Conservation Service) methods to generate a storm hydrograph, including peak flow rate. The inputs into this program include drainage area: 270 square miles area (see Admission No.1 above); time of concentration (T,) (based on the Army Corps of Engineers formula): 8.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; Infiltration rate (curve number): 0.15 inch per hour (State's PFS's Interrogatory asks that the State take into account PFS's response to 2

RAI Question 2 3 as supplemented. Since PFS's supplementation of this RAI question was sent to NRC under cover letter dated March 25,1999, it is inappropriate for PFS to complain that the State has had the supplemented answer "since mid-February." See Applicant's Motion to Compel dated April 22,1999 at 7.

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A original parameter based on the soil and vegetation in the drainage area). The storm hydrograph generated a peak flow rate of 64,500 cfs. After the State generated the storm hydrograph, it used the Corps of Engineers HEC RAS program and the cross sections describing the geometry of the flood channel from PFS recent calculations (p.

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17) to compute the probable maximum flood elevation at and near the PFS site.

INTERROGATORY NO. 2 - UTAH M. Identify and fully explain each respect in which the State claims that the facility's design does not adequately protect the access road or the site against adverse consequences from potential flooding as calculated by the State.

STATE'S AMENDED RESPONSE TO INTERROGATORY NO. 2 -

UTAH M:

In PFS's cross sections describing the geometry of the access road, PFS appears to assume that a vertical berm is in place to prevent the PMF flood discharge from spreading west along the access road and possibly flooding the site. There is not enough information shown to describe the geometry of the berm) and how the access road gets past the berm. It appears that without this berm or with an. inadequate berm

- the PFS site would be flooded by water backed up by the access road during the PMF 2 Zeng, V.N. and Liang, G.H.C. (Stone & Webster Engineering Corp.), March 22,1999, PFSFFlood Analysis with Larger Drainage Basin, Calculation No.

0599602G(B) 12, Rev.1, submitted by PFS to NRC under cover letter dated March 25, 1999, from John L. Donnell to Mark Delligatti, NRC.

3 See e.g., Figure 1, Hydraulic Model at Access Road Crossing (p. 6), Zeng, V.N.

and Liang, G.H.C. (Stone & Webster Engineering Corp.), March 10,1999, PFSFFlood A nalysis with Proposed A ccess Road and Railroad, Calculation No. 0599602G(B)-17, Rev. O, submitted by PFS to NRC under cover letter dated March 25,1999, from John

- L. Donnell to Mark Delligatti, NRC.

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4-flood. Additionally, the access road may be flooded or washed out, preventing necessary operations, personnel or emergency service providers access to the site.

Hence the Applicant would not be able to cope with emergencies as required by 10 CFR 72.24(k).

1 INTERROGATORY NO. 3 - UTAH M. Identify and fully explain each respect in which the State claims that the access road may be adversely impacted by potential flooding as calculated by the State and any resulting adverse safety consequences to the PFS ISFSI.

STATE'S AMENDED RESPONSE TO INTERROGATORY NO. 3 -

UTAH M:

See State's amended response to Interrogatory 2 - Utah M. Additionally, the State's present calculation shows that flooding would be approximately 3.5 feet deep where it crosses the access road. As stated in Response to Interrogatory No. 2, this would result in preventing necessary operations, personnel or emergency service providers access to the site.

INTERROGATORY NO. 4 - UTAH M. Identify and fully explain each respect in which the State claims that " consequences important to safety may occur because of flooding or an inadequate berm construction and location," based on potential flooding as calculated by the State.

STATE'S AMENDED RESPONSE TO INTERROGATORY NO&

UTAH M:

See State's amended response to Interrogatory 2 - Utah M.

INTERROGATORY NO. 5 - UTAH M. Identify and fully explain each other respect in which the State claims that the PFS ISFSI site may be adversely impacted by potential flooding as calculated by the State and the resulting adverse safety 8

consequences of such impacts.

STATE'S AMENDED RESPONSE TO INTERROGATORY NO. 5 -

UTAH M:

See State's amended response to Interrogatory 2 - Utah M.

l INTERROGATORY NO. 6 - UTAH M. If the State continues to claim an 1

adverse impact from potential flooding as calculated by the State on the " operation, I

maintenance of the ISFSI," the " washing out" of the access road, the " translation motion of the storage pad and building foundations," and the " transport (of) onsite chemical and radiological contaminants to offsite soils and ground and surface waters,"

identify and fully explain the scientific, technical, engineering and/or other bases on which the State bases these claims and any other claims of adverse impact and/or safety consequences identified in response to interrogatories 3 through 5 above.

STATE'S AMENDED RESPONSE TO INTERROGATORY NO. 6 -

UTAH M:

See State's amended response to Interrogatory 2 - Utah M. Furthermore, until the State can accurately ascertain the lowest elevation at the ISFSI site, it cannot fully respond to this interrogatory.

IV.

CORRECTIONS TO STATE'S RESPONSES DATED APRIL 14,1999, TO UTAH CONTENTIONS K AND N.

A.

State's Correction to Contention K, Response to Interrogatory No. 2:

Correction to page 37, fourth line of the response: Change the word " confine" to " confound."

B.

State's Correction to Contention N, Response to Request for Admission No.1:

Correction to the property description on page 53,1 ( b), which has three i

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references,instead of two, to "the SE 1/4 of" and should read as follows: "within the N1/2 of the SE1/4 of the SE1/4 of Section 12, Township T1S, Range R8W."

DATED this 12* day of May,1999.

Respectfully s

itted, STATE OF H

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Denise'C%n'cellor,1ssistant At%tGe W Fred G Nhlson, 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 10

DOCKETED USNPC CERTIFICATE OF SERVICE 3

18 P3:0 I hereby certify that a copy of STATE OF UTAH'S SECOND AMENDED RESPONSES AND SUPPLEMENTAL RESPONSES TO APPLICANT'S FI ADJUO:,

7-SET OF FORMAL DISCOVERY REQUESTS was served on the persons listed below by electronic mail (unless otherwise noted) with conforming copies by United States mail first class, this 12'h day of May,1999:

Rulemaking & Adjudication Staff Sherwin E. Turk, Esq.

Secretary of the Commission Catherine L. Marco, Esq.

U. S. Nuclear Regulatory Commission Office of the General Counsel Washington D.C. 20535 Mail Stop - 015 B18 E mail: hearingdocket@nrc. gov U.S. Nuclear Regulatory Commission (originaland two copies)

Washington, DC 20555 E Mail: set @nrc. gov G. Paul Bollwerk,III, Chairman E Mail: clm@nrc. gov I

Administrative Judge 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.

Administrative Judge Washington, DC 20037 8007 Atomic Safety and Licensing Board E-M ail: J ay_Silberg@shawpittm an.co m U. S. Nuclear Regulatory Commission E Mail: ernest _blake@shawpittman.com Washington, DC 20555 E-Mail: paul _gaukler@shawpittman.com E Mail: jrk2@nre. gov John Paul Kennedy, Sr., Esq.

Dr. Peter S. Lam 1385 Yale Avenue Administrative Judge Salt Lake City, Utah 84105 Atomic Safety and Licensing Board E-Mail: john @kennedys.org U. S. Nuclear Regulatory Commission Washington, DC 20555 E Mail: psl@nrc. gov 11

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 i

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Denise Chancellor Assistant Attorney General State of Utah 1

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UNITED STATES OF AMERICA L

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1

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l 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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l Storage Installation)

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May 12,1999 DECLARATION OF DENISE CHANCELLOR, ESQ.

I, Denise Chancellor, hereby declare under penalty of perjury and pursuant to 28 U.S.C. $ 1746, that the statements contained in State of Utah's Second Amended Responses and Supplemental Responses to Applicant's First Set of Formal Discovery Requests dated May 12,1999, as well as the State's April 29,1999 response to the Applicant's First Set of Formal Discovery Requests, with respect to General I

Interrogatories, are true and correct to the best of my knowledge, information and l

' belief.

j Executed this 12th day of May,1999.

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i By:

Jhfa# g Denise Chancellor, Esq.

Assistant Attorney General State of Utah l

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UNITED STATES OF AMERICA l

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. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of:

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Docket No. 72-22-ISFSI

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4 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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May 12,1999 DECLARATION OF DAVID B. COLE I, David B. Cole, hereby declare under penalty of perjury and pursuant to 28 U.S.C. 51746, that the statements contained in State of Utah's Second Amended Responses and Supplemental Responses to Applicant's First Set of Formal Discovery Requests dated May 12,1999, with respect to Utah Contention M (probable maximum flood), are true and correct to the best of my knowledge, information and belief.

Executed this 12th day of May,1999.

By:

I David B. Cole Senior Engineer Utah Division of Water Resources Utah Department of Natural Resources

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1

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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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May 10,1999 i

DECLARATION OF DAVID C. LARSEN 1, David C. Larsen hereby declare under penalty of perjury and pursuant to 28 U.S.C. { 1746, that the statements contained in State of Utah's Second Amend Responses to the Applicant' s First Set of Formal Discovery Requests, with respect to Utah Contention K, are true and correct to the best of my knowledge, infortnation and belief.

Executed this 10* day of May,1999.

By:

61 David C. Larsen Geologist Division of Solid and Hazardous Waste Department of Environmental Quality State ofUtah

4 Resume s

Dane L. Finerfrock 1732 East 1700 South Salt Lake City, UT 84108 EDUCATION B.S. in Meteorology 1970 B.S. in Biology 1974 University of Utah Salt Lake City, Utah EXPERIENCE Environmental Program Manager Division of Radiation Control, Utah Department of Environmental Quality April 1988 to present

  • Administrative responsibility for seven staff scientists / engineers. Duties include determining staff assignments; conducting performance evaluations; project budgeting and progress evaluations; preparing grant proposals; and management of other bureau contracts.

Technical responsibilities include statewide environmental radiation monitoring program; coordinator for State involvement for the inactive uranium mill tailings remedial action program; administration of the EPA State Indoor Radon Grant and Utah radon program; licensing and compliance activities involved with the low level radioactive waste disposal facility and other radioactive waste issues; the purchasing, maintenance and cz'": ration of State radiation detection instrumentation.

  • Rogers & Associates Eng.

Salt Lake City, Utah June / July 1993 StaffScientist Health Physicist Bureau of Radiation Control, Utah Department of Health May 1984 to April 1988 Duties included radioactive material license application review; compliance inspections of various radioactive materials licensees; sampling and radiologic analysis of~ environmental samples; development and implementation of a statewide radon program; quality assurance audits of the health physics program for Salt Lake UMTRA project; development and implementation of the health physics and radiation safety plan for the UMTRA Salt Lake City

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project.

Health Physics Section Leader l

Ford, Bacon, and Davis, Inc., Salt Lake City, Utah I

October 1981 to April 1984 Administrative responsibility for the management of three scientists and three technicians in support of government and industry contracts. Duties included marketing of Nuclear, Environmental and Geotechnical group services; participation in proposal preparation; direct projects in accordance with contract requirements; determine staff assignments; prepare and/or review staff reports.

Duties included responsibility for all health physics activities such as maintenance and calibration of radiation detection instrumentation; personnel dosimetry and bioassay programs for staff and subcentractors; environmental monitoring sampling and analysis for remedial action site characterizations; performed dose assessment and risk analysis for potential remedial sites; developed a radiologic control plan, health physics and safety plan and instrument use protocols for uranium mill tailings remedial action project.

Radiation Analyst University of Utah, Radiological Health Department Salt Lake City, Utah 1977-September 1979 Duties included radiation surveys oflaboratories throughout the University; performed analytical tests on personnel dosimeters; maintenance and calibration ofinstrumentation; assisted in the assessment of radiation doses received by personnel; advised laboratories on proper radiation safety. Other responsibilities included liquid scintillation counting, and air sampling and analysis. Also, radiation safety assessments and quality control analysis of diagnostic radiology equipment; radiation safety assessment of x-ray defraction units commercial and research microwave units.

Responsible for the University low-level radioactive waste disposal program, including collection, classification, packaging and shipment of wastes. Supervisor of one employee.

ADDITIONAL EXPERIENCE Research Technician University of Utah, Department of Anatomy Intemal Irradiation Research Project 1976-1977 2

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fd-Military Service United States Army 2nd Lt. Fort Jackson, South Carolina 1-1st Lt. U.S. Army Viet Nam August 1970-February 1972 Meteorologist Stone and Webster Engineering Co.

Boston, Massachusetts Summer 1969 Prepared climatic and meteorologic sections of environmental impact statement for clients.

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i PUBLICATIONS OF JOHN L. MATTHEWS MAJOR GENERAL USAF (RET)

Matthews, John L., Assessing Reserve Component Training, MILITARY REVIEW, US Army Command and General Staff College, (November 1989)

Responsible for a Presidents Message monthly from September 1992 to September 1994 in the j

National Guard Magazine, a publication of the National Guard Association of the United States, j

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Bronson W. Hawley L

PUBLICATIONS l

1.

1979, Qamar, A. and B. W. Hawley; Seismic Activity Near the Three Forks Basin, l

Montana; Bull. Seis. Soc. Amer., Vol. 69, pp.1917-1929.

2.

1980, Hawley, B.W., and R. B. Smith; Lateral Velocity Variations Within a Layered l

Model from Inversion of Local Earthquake Data; Seismo. Soc. Amer., Abstract.

3.

1981, Hawley, B.W., G. Zandt, and R.B. Smith; Simultaneous Inversion for Hypocenters

. and Lateral Velocity Variations: An Iterative Solution with a Layered Model; Jour.

Geophys. Res., pp. 7073-7086.

4.

1983, Hawley, B.W., and R.L. Bruhn; A Structural Model for the Evolution of the Southwest Kenai Peninsula, Alaska; Geol. Soc. Amer., Abstract.

5.

1984, Hawley, B.W., R.L. Bruhn and S.H. Evans, Jr.; Vertical Tectonics in a Forearc

- Region, Southern Alaska, Using Fission Track Dating of Apatite Grains and Flexural Beam Modeling; Geol. Soc. Amer., Abstract.

6.

1987, Hawley, B.W., The Application of Fission Track Dating to Uplift Ages of j

Mountains; Yearbook of Science and Technology, McGraw-Hill.

7.

- 1988, Gay, S.P. Jr., and B.W. Hawley, Field Examples form Utah, Wyoming and Nebraska of Two Causes of Non-controversial Intrasedimentary Magnetic Anomalies; Symposium on Intrasedimentary Magnetic Anomalies; Colorado School of Mines; April, 1988.

8.

1991, Gay, S. P. Jr., and B.W. Hawley, Syngenetic Magnetic Anomaly Sources: Three examples, Geophysics, Vol. 56, No. 7, July 1991.

9.

1991, Thompson, T.L., B.W. Hawley, S.P. Gay, Jr. and J.R. Howe; Utility of High Resolution Residual Aeromagnetics in the Structural Interpretation of the Ouachita Region of Southeast Oklahoma and Western Arkansas; Petroleum Reservoir Geology in the southern Mideontinent; Oklahoma Geol. Sury., March 1991.

10.

1992, Thompson, T.L., B.W. Hawley, J. Howe, and S.P. Gay, Jr.; Basement Influence on the Structural Geology of Southern Oklahoma Inferred from Residual-Aeromagnetic maps; Structural Styles in the Southern Midcontinent; Oklahoma Geological Survey; March 1992.

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1992, Hawley, B.W. Structural, Metamorphic and Geochemical Study of the Seldovia Bay Fault, Alaska: A Relict Cretaceous Subduction Zone; Ph.D. Dissertation, University of Utah, June' 1992.

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