ML20206R972
| ML20206R972 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 05/18/1999 |
| From: | Doris Lewis AFFILIATION NOT ASSIGNED, STONE & WEBSTER, INC. |
| To: | |
| Shared Package | |
| ML20206R953 | List: |
| References | |
| ISFSI, NUDOCS 9905210021 | |
| Download: ML20206R972 (15) | |
Text
MAY-18-1999 M. 03:2b Pd FRAlkth ISLAND PLANI lM NO. 6513305984 P. 02 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMI ISION l
l Before the Atomic Safety and Licensinn Board
)
l In the Matter of
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PRIVATE FUEL STORAGE L.L.C.
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Docket No. 72-22
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(Private Fuel Storage Facility)
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AFFIDAVIT OF DONALD WAVNE LEWIS CITY OF REDWING
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) SS:
1 STATE OF MINNESOTA
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1, Donald Wayne Lewis, being duly swom, states as follows:
1.
I am Lead Mechanical Engineer with Stone & Webster for the Private Fuel Storage Facility (PFSF) project. In that position I am responsible for ensuring that all mechanically related systems for the PFSF meet the principal design criteria as stated in Chapter 3 of the PFSF Safety Analysis Report (SAR), including the storage system's thermal performance. I am providing this affidavit, in support of a motion for partial summary disposition of Contention Utah H in the above captioned proceeding, to describe the revised thermal analysis performed by Private Fuel Storage, L.L.C.
2.
My pmfessional and educational experience is summarized in the curriculum vitae attached as Exhibit I to this affidavit. I have been assigned to severaljobs since 1991 that specifically involved the design of spent nuclear fuel storage and hrage packages, including the design of spent fuel storage systems at the Prairie Island Nuclear Generating Plant, Mainc Yankee Atomic Plant, Indian Point 2 Nuclear Plant, Yucca Mountain National Repository, and Goodhue County. I have specifically had to ensure the thermal performance of the storage systems on all the abovojobs except for Yucca Mountain.
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I am knowledgeable of the design of the spent fu storage casks to be used at the PFSF for the storage of spent nuclear fuel, their thermal charact stics, and their responses to high temperature thennal trraients. I am familiar with the orig L1 and revised thermal calculations for the spent fuel storage casks to be used at the PF 4.
On December 10,1998, the NRC Staff filed its s md round of safety Requests l
for Additional Information, including RAI 4-2, which asked PF. 31)" clarify the thermal J
cncrgy balance between the concrete pad, casks, and environmc ' and 2)"[d]emonstrate that j
the ' chimney effect' incorporated into the design of the TranStc nd HI-STORM casks is i
unaffected." In its response to RAI 4-2, dated February 10,199 PFS filed a revised thermal calculation to supplement the original vendor calculations.
5.
PFS asked Holtec Intemational to perform the revi ed calculation for the HI-STORM 100 spent fuel storage cask to show that the issues raisec by the Staffin RAI 4-2 do not affect PFS's conclusions that the thermal design of both storage e aks to be used at the PFSF are adequate. PFS had the calculation performed for the HI STORM 100 because it would experience the highest temperatures under the relevant conditiom RAI Resp. 4-2 at 3.
Specifically, the thermal perfonnance of the HI-Storm 100 result: in greater temperatures of the fuel cladding than those for TranStor under the same extemal con litions. 'Ihis is specifically due to storage system design and thermal modeling differences betwe :n the vendors. Therefore, all other conditions being equal, the calculated temperature of the sp nt fuel cladding from a fully loaded HI-Storm 100 cask will be greater than that from a fully it ided TranStor cask and therefore is bounding.
6.
A copy of PFS's responses to the second round RAls, including PFS's response to RAI 4-2, was sent to the State of Utah by ovemight mail on February 11,1999. A copy of the calculations and other backup to PFS's responses, including the bfu:kup calculation for PFS's responses to RAI 4-2, were sent to the State for next business day' delivery on February 13,1999.
7.
I have reviewed the State's bases underlying the three pertinent subparts of Utah H as well as the contention itself. The new thermal calculation described in PFS's response to 1
RAI 4-2, and described in greater detail in the Affidavit ofIndresh Rampall, addresses the issues raised in each of subparts 3,4, and 5 of Utah H.
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EXHIBIT 1
May 1999 LEWIS, DONALD WAYNE LEAD ENGINEER MECHANICAL DIVISION EDUCATION Montana State University - Bachelor of Science, Civil Engineering - 1980 Daniel International Corp. - Course in ASME Section 11I - 1982 Daniel Intemational Corp. - Course in Welding - 1983 REGISTRATIONS Professional Engineer - New York (1988)
Colorado (1997)
EXPERIENCE
SUMMARY
Mr. Lewis has 17 years of engineering experience in the power generation industry, and has participated in all phases of power plant engineering from design through constmetion, pre-operational testing to on-line modifications.
Mr. Lewis has experience on several nuclear facilities. Assignments include the design of spent nuclear fuel storage facilities, plant systems design modifications, and on-site engineering of mechanical systems installation. Spent fuel storage facility design involved preparation of the j
design of mechanical aspects and related licensing of the facilities, including an on-site assigmnent as project engineer for the client for construction of one of the facilities. Plant systems modification assignments involved resolving system design problems, preparing design changes and supporting analyses, revising drawings and preparing specifications. On-site engineering of mechanical systems installation involved resolving pipe and equipment installation conflicts, reviewing and revising design drawings, ensuring code compliance, procuring system components, and developing start-up procedures.
Mr. Lewis has experience on four coal-fired boiler plants. Assignments included the design of mechanical systems on a flue gas scrubber project, development of system descriptions and operating instructions; and the evaluation of a coal to natural gas conversion design. Work involved design of piping systems, component selection and sizing, preparing calculations and specifications, reviewing proposal submittals, initiating process flow and layout drawings; writing plant operation instructions; and preparing cost analyses.
Mr. Lewis is currently assigned to several projects: the Indian Pt 2 spent fuel conceptual design project where he is Project Engineer, the Maine Yankee Atomic Plant spent fuel storage project where he is Lead Mechanical Engineer, the Private Fuel Storage Project where he is Lead Mechanical Engineer, and the Northem States Power Prairie Island Generating Plant where he is Project Engineer, responsible for overseeing the High Energy Line Break Upgrade Project and spent fuel storage issues.
Lewis, D. W.
DETAILED EXPERIENCE RECORD LEWIS, DONALD WAYNE STONE & WEBSTER ENGINEERING CORPORATION, DENVER, COLORADO l
l (Apr 1988 - Present)
Appointments:
Lead Engineer, Mechanical Division - Jan 1998 Senior Mechanical Engineer, Mechanical Division - Nov 1990 Mechanical Engineer, Mechanical Division - Jan 1989 l
Indian Point 2 Nuclear Plant, Buchanan, NY - Consolidated Edison (January 1999 - Present)
As PROJECT ENGINEER responsible for the technical oversight of a study to provide a conceptual design to transfer fuel from the fuel storage building to an at plant storage site. The 1
work includes reviewing current plant drawings, calculations, and site to locate a suitable storage site, design the storage site layout, upgrade the fuel building crane and structural design, determine the fuel transfer operation, licensing, and cost requirements.
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- Maine Yankee Atomic Plant, Wiscasset, ME-Maine Yankee Power Company (November 1998 - Present)
As LEAD MECHANICAL ENGINEER responsible for mechanical work that is associated with the removal and storage of spent nuclear fuel at the Maine Yankee Atomic Plant. Work specifically involves oversight of the engineering and design work of the water supply system, sewage system, building HVAC, diesel generator, and crane upgrade for the storage facility.
Yuc'ca Mountain Proiect, Las Vegas, NV - U.S. Department of Energy i
(June 1998 - August 1998)
As SYSTEMS ENGINEER part of a specialized team responsible for evaluating the operability of the Yucca Mountain Geologic Repository facility design that will be used to store the Nation's high level waste and spent nuclear fuel. The work includes reviewing the facility design as it relates to operations, i.e. process efficiency, WITNESS model inputs, equipment maintenance, breakdown, and upset impacts, emplacement and retrieval equipment functions, ventilation functions, and the transition from startup to operation.
Rocky Flats Environ. Tech. Site. Golden CO - Rocky Flats Engineers & Contractors, L.L.C.
. (May 1998 - Sept 1998)
As RADIOLOGICAL CONSULTANT responsible for reviewing and providing the Professional Engineering approval of radiological calculations for the RFETS Transuranic (TRU)/ Transuranic 2
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Lewis, D. W.
l Mix (TRM) Waste Management Facility design. Specific calculations include Waste Management l
Facility Source Term Evaluation, Repackaging Area Shielding Evaluation and Occupational I
Radiation Exposures, Storage Area Radiation Levels and Shielding Evaluations, and l
Characterization Area and Shipping Area Operational Radiation Exposures, Radiation Levels and Shielding Evaluations.
l Prairie Island Generating Plant. Red Wing, MN - Northem States Power Company (Oct 1997 - Present)
As PROJECT ENGINEER responsible for the technical and administrative oversight of the plant's Iligh Energy Line Break (HELB) Upgrade Project and technical issues from loading and storing spent nuclear fuel. The HELB work includes reviewing current plant docun'entation records, updating existing or preparing new analyses for pipe break locations, steam exclusion zones, pressurization stresses, pipe whip restraints, and jet impingement barriers, verifying and identifying critical safety equipment, updating plant engineering procedures and design basis documents, and rewriting the HELB ponion of the plant Updated Safety Analysis Repon (USAR). The spent fuel work includes addressing storage cask design changes, fabrication nonconformance reports, and licensing issues and perfbrming the related NRC regul:d unreviewed safety questions.
National Wind Technology Center. Golden, CO - National Renewable Energy Laboratory (Oct 1997 - Apr 1998)
As SENIOR MECHANICAL ENGINEER responsible for providing machine design expertise to j
design a large movable test table for a new National Wind Technology Center. Work included oversight of the design, which consists oflayout of a 3500 hp motor and gear drive unit, machine screwjack lifts, table alignment wheel assemblies, support components, and cable carrier track system, preparing drawings showing component layouts, and preparation of purchase specifications and design calculations.
Rocky Flats Environmental Technology Site, Golden CO - BNFL (July 1997 - Oct1997)
As SENIOR MECHANICAL ENGINEER responsible for preparing a radiation shielding analysis for the Plutonium Stabilization and Packaging System. Work involved reviewing a time and motion study that revised the stabilization process, determining the impact e.nd required changes for the neutron and gamma source terms, workstation shielding, and whole body and extremity operational and downtime doses for stabilization process work stations, and preparing a revised radiation shielding analysis. The work included preparation of a ALARNOSHA report that provided dose combinations for operators working et multiple stations.
Private Fuel Storage Facility. Goshute Indian Res.. UT - Private Fuel Storage (Oct 1996 - Present)
As SENIOR MECHANICAL ENGINEER responsible for the mechanical design and engineering activities of the facility, including overhead cranes, fuel canister transfer facility, HVAC, water and 3
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Lewis, D. W.
sewage systems, and rail and truck fuel transport. Work included preparing drawings of the component layout, transfer facility, cranes, railroad spur, and highway tractor-trailer intermodal facility; preparing the design criteria and specifications for storage systems, cranes, HVAC systems, tractor-trailers, and infrastructure systems; and preparing licensing documents, which included the License Application, Safety Analysis Repon, Environmental Report, Emergency Plan, Decommissioning Plan, Technical Specifications, and Security Plan for submittal to the Nuclear Regulatory Commission.
Goodhue County ISFSI, Frontenac. MN - Northem States Power Company (Aug 1995 - Sept 1996)
As PROJECT ENGINEER responsible for the technical oversight of all engineering activities for 4
Northem States Power Company's proposed $49 million spent fuel storage facility project in Goodhue County. The state mandated project provides storage of spent nuclear fuel and replaces an on-site storage facility. Work includes preparing, reviewing and approving: designs of the site layout, buildings, crane and transfer equipment, rail road spur, and power supply; specifications for selection of the spent fuel storage and transportation technology; licensing documents for the Nuclear Regulatory Commission and State of Minnesota; and design criteria for civil / structural, electrical, mechanical, geotechnical, and radiological areas. Supervisor of up to 12 engineering personnel.
Navaio Generating Station. Page AZ - Salt River Project (Sept 1993 - Nov 1995)
As SENIOR MECHANICAL ENGINEER responsible for engineering mechanical systems required for the addition of wet limestone forced oxidation flue gas desulfurization scrubbers at three 700 MW coal fired plants. The project was initiated to reduce sulfur dioxide emissions in accordance with EPA requirements. Work included the design of the pipe support structure between buildings, compressed air system, flue gas system guillotine and louver dampers, and modifications to the bottom and fly ash removal systems. Responsibilities also included writing pipe rack, compressor, damper, and tank agitator specifications; initiating process flow (P&lD) drawings; evaluating the etTects of slurry piping modifications in the boiler ash removal system; designing a scrubber slurry removal system to allow scrubber maintenance; reviewing the technical portion of proposals submitted for the purchase of raw water pumps; and preparing a detailed cost analysis for the selection of air compressors.
Prairie Island Generating Plant, Red Wing. MN - Northem States Power Company (Jan 1992 - Aug 1993)
As SENIOR MECHANICAL ENGINEER, Project Engineer on site in Minnesota for Northern States Power Company's $10.7 million spent fuel storage facility project at the twin 500 MW nuclear plant. The project provides temporary storage of spent nuclear fuel to ensure the plant can continue operating until the Depanment of Energy can permanently store fuel. Responsible for ensuring technical adequacy is maintained by the A/E site design, vendor component designs and construction installations. Work included reviewing and approving A/E and vendor designs, 4
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Lewis, D. W.
l identifying project scope and schedule concems, providing instructions to craft to resolve l
installation problems, monitoring all construction activities, procuring project components, and l
maintaining project records. Work required knowledge of several types of engineering including:
mechanical for fuel container and container transport vehicle designs; civil for road and soil designs; structural for concrete and steel designs; and electrical for power, instrumentation and security system designs. Also maintained and updated the project safety analysis report required by the Nuclear Regulatory Commicion to ensure federal code requirements are met.
Neil Simpson Station, Gillette, WY - Black Hills Power Company (Sept 1991 - Dec 1991)
As SENIOR MECHANICAL ENGINEER responsible for preparing system descriptions and operating instructions for the plant personnel at the 80 MW coal fired power plant. Work included writing system descriptions which described the purpose, function, and components and wrote operating instructions which described the steps for startup, operation and shutdown for most of the plant's systems. Documents were prepared by reviewing plant system drawings, obtaining vendor data of the system components, and consulting plant operators.
North Omaha Station. Omaha, NE - Omaha Public Power District (July 1991 - Aug 1991)
As SENIOR MECHANICAL ENGINEER responsible for preparing system operation instructions for plant personnel at the five unit 550 MW coal fired boiler. Work included writing operating -
instructions which described the purpose, methods and steps for startup, operation and shutdown for the plant's steam systems. Documents were prepared by reviewing plant system drawings, system descriptions and consulting plant personnel.
Fort Calhoun Power Station, Ft Calhoun, NE - Omaha Public Power District (Apr 1988 - June 1990)(Nov 1990 - Aug 1991)
As SENIOR MECHANICAL ENGINEER (Nov 1990 - Aug 1991), and as MECHANICAL ENGINEER (Apr 1988 - June 1990), responsible for the disposition of station modification requests for the 488 MW pressurized water reactor fluid systems. Work included preparing design packages, specifications and calculations, revising or creating new drawings, assessing attemative solutions, j
analyzing system design problems, preparing safety evaluations, changing licensing documents and preparing installation and testing requirements. Major assignments included a new plant instrument i
air dryer installation, a diesel driven auxiliary feedwater pump addition, radiation monitor replacements, raw water valve replacements and diesel generator design bases determination analyses.
Prairie Island Generating Plant-Unit 2. Red Wing. MN - Northem States Power Company (July 1990 - Oct 1990)
As LEAD MECHANICAL ENGINEER, responsible for preparing a plant modification conceptual design to create access openings in the steam generator vault walls of the twin 550 MW pressurized 5
l Lewis, D. W.
l water reactors. The project was initiated to reduce radiation doses received by plant personnel.
l Work included reviewing original plant structural calculations, determining post loss-of-coolant accident loads, evaluating resulting radiation doses, identifying existing component interferences and analyzing modification costs. The project was terminated based on the cost analysis.
EG&G Rocky Flats Inc., Golden, CO - U. S. Department of Energy (July 1990)
As MECHANICAL ENGINEER, responsible for developing fastener specification procedures to be used for all repair, replacement or modification work involving any type of fastener for the plutonium operations resumption program.
U. S. Department of Energy, Hanford. WA (June 1990)
As MECHANICAL ENGINEER, responsible for reviewing low level radwaste process facility designs per DOE General Design Criteria 6430.l A to determine if the fluid system designs were ade-quate.
STONE & WEBSTER ENGINEERING CORP., CHERRY HILL, NEW JERSEY (Sept 1983 - Mar 1988)
Appointments:
Engineer, Mechanical Division - Aug 1987 Construction Engineer - Oct 1985 Senior Field Engineer-Oct 1984 Field Engineer-Sept 1983 Nine Mile Point Nuclear Station, Unit 2, Lycoming, NY - Niagara Mohawk Power Corporation (Sept 1983 - Mar 1988)
As ENGINEER in the Mechanical Division (Aug 1987 - Mar 1988), responsible for the resolving of plant operation problems, and preparing design documents for modification requests for the 1080 MW boiling water reactor plant. Work included reviewing, preparing and/or revising system design calculations, flow and pipe drawings, component specifications, safety evaluation reports and plant licensing documents. Major assignments included replacing eight 28 inch main steam isolation valves, evaluating the flow and heat balance of the turbine building closed loop cooling system and design of the nitrogen cryogenic system used for inerting the primary containment of the reactor.
As ENGINEER in the Construction Division (Sept 1983 - July 1987), responsible for evaluating and resolving system piping problems during construction of the plant. Work included monitoring construction work, preparing engineering and design change reports, reviewing and revising design 6
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l Lewis, D. W.
l drawings and specifications, procuring piping components, ensuring system complied with code requirements, and maintaining a good relationship with craft personnel. Also prepared a study on the use and effectiveness of flexible metal hoses used in the instrumentation and process systems.
Oswego Steam Station Units 5 & 6. Oswego, NY - Niagara Mohawk Power Corporation (Dec 1986)
As CONSTRUCTION ENGINEER, responsible for reviewing a coal to natural gas conversion design in the two 902 MW unit fossil fuel steam station. Work included inspecting the proposed design changes, evaluating the design to ensure A/E changes were appropriate, and developing a report of findings for the Client, i
DANIEL INTERNATIONAL CORPORATION, GREENVILLE,50UTH CAROLINA (June 1982 - Aug 1983)
Wolf Creek Nuclear Plant, New Strawn. KS - Kansas Gas & Electric l
l As CONSTRUCTION ENGINEER 11 responsible for providing engineering support for pipe installation in the 1150 MW nuclear pressurized water reactor. Work included resolving field installation problems and initiated documents such as weld control records and pipe installation records which provided craft instruction and documented work, maintaining material and documentation records for pipe systems personally responsible for, and as-builting and reviewing piping installations to ensure code compliance.
,I.A. JONES CONSTRUCTION COMPANY, CHARLOTI'E, NORTH CAROLINA (Oct 1981 - Apr 1982)
Washington Nuclear Plant No.1, Handford, WA - Washington Public Power Supply System As FIELD ENGINEER responsible for providing engineering support for pipe and pipe support steel installation in the 1259 MW nuclear pressurized water reactor. Work included preparing engineering change reports to resolve construction installation problems, establishing pipe pressure test boundaries and overseeing test activities by craft Supervisor of seven engineers.
WRIGHT SCHUCHART HARBOR-BOECON-GERI, RICHLAND, WASHINGTON 1
(Mar 1981 - Oct 1981)
Washington Nuclear Plant No. 2. Handford. WA - Washington Public Power Supply System As ASSOCIATE STRUCTURAL ENGINEER responsible for providing engineering support for i
I structural steel installation in the 1100 MW nuclear boiling water reactor. Work included preparing and reviewing design drawings, weld records, welding non-destruction examinations, and installation documents required to instruct craft in order to install large steel beams in the reactor containment. Also prepared a report in response to an NRC audit to determine acceptability of the structural steel design.
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Lewis, D. W.
1 MONTANA STATE HIGHWAY DEPARTMENT, HELENA, MONTANA (July 1979 - Sept 1979, July 1980 - Mar 1981) i As CIVIL ENGINEER I (Traffic Division, Jan 1981 - Mar 1981), responsible for intersection evaluations, traffic and capacity studies, and signal light installations (Highway Division, July 1980
- Dec 1980), responsible for storm drain project installation, highway project surveys, grade calculations and material evaluations.
As ENGINEER AIDE (July 1979.- Sept 1979), responsible for support in a survey crew and inspecting contractor installed asphalt.
Document #: 763996 v.I O
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USNPC UNITED STATES OF AMERICA 99 MAY 20 P4 :43 NUCLEAR REGULATORY COMMISSION Oh Before the Atomic Safety and Licensine Board ASIL In the Matter of
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PRIVATE FUEL STORAGE L.L.C.
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Docket No. 72-22
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(Private Fuel Storage Facility)
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C.EETIFICATE OF SERVICE I hereby certify that copies of the Applicant's Motion for Partial Summary Disposition Of Utah Contention H -Inadequate Thermal Design and the Affidavit of Donald Wayne Lewis were served on the persons listed below (unless otherwise noted) by e-mail with conforming copies by U.S. mail, first class, postage prepaid, this 19th day of May 1999. The Affidavit ofIndresh Rampall and its Exhibits contain proprietary information and are being served and filed only with the officials at the NRC and counsel for the State who have signed a confidentiality agreement covering such information.
Two of the four exhibits for the Rampall affidavit are not being filed by e-mail. They are the Holtec Calculation Package and the material from the Holtec HI-STORM 100 TSAR.
The Calculation Package was filed with PFS's response to RAI 4-2; the TSAR material was filed with PFS's response to the State's discovery request on May 14,1999. The Licensing Board, the NRC Staff, the NRC Office of the Secretary, the Licensing Board l
Panel Adjudicatory File, and the NRC Office of Nuclear Material Safety and Safeguards are being served conforming copies of all materials by hand.
G. Paul Bollwerk III, Esq., Chairman Dr. Jerry R. Kline 1
Administrative Judge Administrative Judge j
Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 e-mail: GPB@nrc. gov e-mail: JRK2@nrc.cov:kjerry@erols.com Dr. Peter S. Lam
- Susan F. Shankman Administrative Judge Deputy Director, Licensing & Inspection l
Atomic Safety and Licensing Board Panel Directorate, Spent Fuel Project Office U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety &
Washington, D.C. 20555-0001 Safeguards e-mail: PSL@nrc. gov U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of the Secretary
- Adjudicatory File U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Attention: Rulemakings and Adjudications Washington, D.C. 20555 N01 Staff e-mail: hearingdocket@nrc. gov (Original and two copies)
Catherine L. Marco, Esq.
Denise Chancellor, Esq.
Sherwin E. Turk, Esq.
Assistant Attomey General Office of the General Counsel Utah Attorney General's Office Mail Stop O-15 B18 160 East 300 South,5* Floor U.S. Nuclear Regulatory Commission P.O. Box 140873 Washington, D.C. 20555 Salt Lake City, Utah 84114-0873 e-mail: pfscase@nrc. gov e-mail: dchancel@ state.UT.US John Paul Kennedy, Sr., Esq.
Joro Walker, Esq.
Confederated Tribes of the Goshute Land and Water Fund of the Rockies Reservation and David Pete 165 South Main, Suite l' 1385 Yale Avenue Salt Lake City, UT 84111 Salt Lake City, Utah 84105 -
e-mail: joro61@inconnect.com e-mail: john @kennedys.org
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Diane Curran, Esq.
Danny Quintana, Esq.
l Harmon, Curran, Spielberg &
Skull Valley Band of Goshute Indians Eisenberg, L.L.P.
Danny Quintana & Associates, P.C.
l 2001 S Street, N.W.
50 West Broadway, Fourth Floor Washington, D.C. 20009 Salt Lake City, Utah 84101 e-mail:DCurran.HCSE@zzapp.org e-mail: quintana @xmission.com
- By U.S. mail only Paul A. Gaukler ~
Document #: 763937 v.!
Document #: 763957 v.1 3