ML20207A565
| ML20207A565 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 05/20/1999 |
| From: | Gaukler P AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| CON-#299-20431 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9905270033 | |
| Download: ML20207A565 (18) | |
Text
3O REUTED CORRESPONDENCE
,1 99 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFF-Before the Atomic Safety and Licensing Board nii ADJU; In the Matter of
)
)
PRIVATE FUEL STORAGE L.L.C.
)
Docket No. 72-22
)
(Private Fuel Storage Facility)
)
ASLBP No. 97-732-02-ISFSI APPLICANT'S OBJECTIONS AND RESPONSES TO SUWA'S FIRST REQUESTS FOR DISCOVERY Applicant Private Fuel Storage L.L.C. (" Applicant" or "PFS") files the following objections and responses to " Southern Utah Wilderness Alliance's (SUWA) First Set of Discovery Requests Directed to the Applicant"("SUWA's First Discovery Requests"), an electronic copy of which was served on the Applicant on Monday, May 10,1999.
Pursuant to Board Orders,' SUWA requested Applicant to answer Interrogatories within 10 days after service of the formal discovery request and produce documents within 15 days after service of the formal discovery request. SUWA's First Discovery Requests at 1.
I.
GENERAL OBJECTIONS These general objections apply to the Applicant's responses to all of SUWA's First
~
l Discovery Requests.
' See Board Orders dated April 22,1998, June 29,1998 and August 20,1998.
i 9905270033 990520 7
PDR ADOCK 07200022 J563 C
PDR L
]
1.
The Applicant objects to SUWA's instructions and definitions on the grounds and to the extent that they request or purport to impose upon the Applicant any l
obligation to respond in manner or scope beyond the requirements set forth in 10 C.F.R.
s 2.740,2.741 and 2.742.
2.
The Applicant objects to SUWA's Request for Production of Documents to the extent that it requests discovery ofinformation or documents protected under the attomey-client privilege, the attomey work product doctrine, and limitations on discovery of trial preparation materials and experts' knowledge or opinions set forth in 10 C.F.R. Q 2.740 or other protection provided by law. The Applicant will provide SUWA with a Privilege Log which identifies documents subject to these privileges and protections, which the Applicant reserves the right to supplement.
3.
The Applicant objects to SUWA's interrogatories and document requests to the extent they seek discovery beyond the scope of SUWA Contention B, as admitted by the Board in this proceeding. SUWA is only permitted to obtain discovery on matters that pertain to the subject matter with which SUWA is involved in this proceeding. 10 C.F.R. Q 2.740(b). The only SUWA contention admitted by the Board was SUWA B. In admitting the contention, the Board limited the scope of SUWA B to the issue of
" alignment alternatives to the proposed placement of the Low Junction rail spur." Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation), LBP-99-3,49 NRC slip op. at 21 (1999) (emphasis added). SUWA's discovery requests regarding conditions in the North Cedar Mountains generally and Skull Valley generally, rather than alignment attematives for the rail line from L ow to the Private Fuel Storage Facility ("PFSF"), are 2
c if
}
beyond the scope of SUWA B, as admitted by the Board, and therefore are not relevant to the subject matter to which SUWA is a party to this proceeding. PFS objects to any request by SUWA to obtain discovery on matters outside the scope ofits contention.
II.
INTERROGATORIES -
These interrogatories apply to SUWA Contention B, " Failure to Develop and Analyze a Meaningful Range of Alternatives to the Low Rail Spur."
l INTERROGATORY NO.1. Please state the name, business address, and job title of each person who was consulted and/or who supplied information for responding to -
these interrogatories and requests for the production of documents. Specifically note for which interrogatories 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 production of documents 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.
APPLICANT'S RESPONSE: In addition to counsel for PFS, the followmg i
persons were consulted and/or supplied information in responding to the OGD's First L
Discovery Requestsi John Donnell-Interrogatory Nos. 3, 5; Document Request Nos.1-10.
Project Director Private Fuel Storage L.L.C.
7677 East Berry Ave l
Englewood, CO 80111-2137 l
Jerry Cooper-Interrogatory No. 4 L
Project Engineer Stone & Webster L
7677 Berry Avenus j
Denver, CO 80111-2137 j
L l
l 3
i In response to whether the information or opinions of anyone who was consulted in connection with PFS's response to an interrogatcry or request for production of documents differs from the PFS's written answer to the discovery request, PFS is unaware of any such difference among those consulted.
INTER.ROG ATORY NO. 2. Please give the name, address, profession, employer, area of professional expertise, and educational and scientific experience of each person PFS expects to call as a witness or expen witness and the subject matter about which each witness or expert witness will testify at the hearing with regard to SUWA's admitted contention. For each expert witness, please include a list of all publications she or he authored within the preceding ten years and a list 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. Plexe describe the subject matter on which each of the witnesses is expected to testify at the.iearing by detailing the facts and opinions to which i
each witness is expected to testify, including a summary of the grounds for each opinion, and identifying the -documents (including all pertinent pages or pany thereof), data or other information which each witness has reviewed and considered, or is expected to consider or to rely on for her or his testimony.
APPLICANT'S RESPONSE: The Applicant has not selected the witness or l
witnesses that it expects to call at the hearing regarding SUWA Contention B and will supplement this response in accordance with 10 C.F.R. @ 2.740(e).
1 INTERROGATORY NO. 3. Please explain how and why PFS chose its current transportation alternatives (the Low Rail Spur and the Skull Valley Road Transportation Corridor), including the exact alignment for the Low Rail Spur and explain which l
transportation altematives relative to the proposed storage facility were considered and l
rejected and why.
l APPLICANT'S RESPONSE: The present local transportation p!an for moving a transportation cask from the mainline railroad to the PFSF site includes two modes of transportation and two distinct routes. The primary mode and route, sg SAR 1.4, is based on direct rail access to the facility from Low, Utah on a new corridor located solely on Bureau of Land Management ("BLM") land. The altemate mode and route utilizes a 4
o
gj heavy-haul transportation and the existing Skull Valley Road corridor from an Intermodal
. Transfer Point ("ITP") located 1.8 miles east of Timpie, Utah to the facility.~
~ The Skull Valley Road corridor is the only existing transportation route servicing
- the Skull Valley Indian Reservation. This route was surveyed for technical and environmental viability in February 1997 prior to the submittal of the PFS License Application to the Nuclear Regulatory Commission ("NRC") in June 1997. The survey
. found that the existing corridor was suitable for use as a heavy-haul route and that rail access could be added as an alternative.
Following the submittal of the PFS License Application to the NRC in June 1997, PFS commissioned, in September 1997, a Transportation Infrastructure Study to further evaluate and assess transponation altematives for moving shipping casks between the
. mainline railroad and the PFSF. This study included a review of the entire Skull Valley rather thanjust the more direct approach of using the existing Skull Valley Road corridor.
This study postulated six ITP heavy-haul options and five Direct Rail options for transportation from the railroad mainline to the PFSF as follows:
Direct Rail Options e Option DR-1 Rail Line from Timpie, Utah
. Option DR-2 Rail Line from West of Timpie, Utah
- Option DR-3 Rail Line and Flyover Bridge East of Timpie, Utah
. Option DR-d Rail Line from Dolomite, Utah e Option DR-5 Rail Line from Low, Utah
-5
T, 4
ITP (Heavy-Haul) Options e Option IT-1 Intermodal Transfer at Timpie, Utah e Option IT-2 Intermodal Transfer 0.9-mile West of Timple, Utah e Option IT-3 Intermodal Transfer 1.75-miles West of Timpie, Utah e Option IT-4 Intermodal Transfer at Delle Junction, Utah e Option IT-5 Intermodal Transfer at Dolomite, Utah e Option IT-6 Intermodal Transfer at Low, Utah These options are addressed in the Transportation Study report, which will be included in the documents made available at Parsons, Behle and Latimer in Salt Lake City. See Response to Document Request No. 2. From the above options, the study concluded that the Direct Rail option originating at Low, Utah (DR-5) and the Heavy-Haul option for an ITP 1.75 (1.8) miles west of Timpie, Utah (IT-3) were the recommended routes. PFS then reviewed these suggested routes in a final detennination of the preferred mode and route for the transportation casks from the railroad mainline to the PFSF, In June 1998, PFS declared that Direct Rail access (DR-5) to the PFSF from i
. Low, Utah was the preferred mode of transportation and route. Heavy-Haul access (IT-3) utilizing an ITP located 1.75 miles (1.8) west of Timpie, Utah was declared as the attemate mode and route.
The selection of Direct Rail over Heavy-Haul access to the PFS is based on the elimination of a cask handling operation at the ITP if direct rail access is provided. In tum, this eliminates the need for an additional gantry crane and weather enclosure necessitated by intermodal transfer.
i 6
4
f 1
l
(
For Direct Rail access, the Low Corridor was selected based on four principal characteristics:
1 - a location away from other established ranches and vehicular traffic associated with the existing Skull Valley Road corridor.
2 - access to the mainline rail south ofInterstate 80.
3 - a location on land controlled by a single owner (BLM) as opposed to other direct rail options using the Skull Valley Road corridor to PFS where mixed private and BLM land ownership issues exist.
4 - fewer environmental impacts relative to other mainline access options local to the Timpie, Utah area.
The Low Corridor alignment is principally located on a north-south line at the foot of the Cedar Mountains and away from the more environmentally sensitive mid-valley areas. The PFS Environmental Report, Figures 3.2-2, sheets I through 4 identify the location of the alignment.
J
'Ine selection of the IT-3 as the location for the ITP was based on three principle characteristics:
1 - a location away from the Skull Valley Road / Interstate 80 interchange.
2 - a location on land controlled by a single owner (BLM) as opposed to other Heavy Haul access options encumbered with mixed land ownership.
3 - fewer environmental impacts relative to other Intermodal Transfer options local to the Timpie, Utah area.
7
r~,
Neither of the selected options for Direct Rail (DR-5) or Intermodal Transfer (IT-
- 3) was the least expensive. In aggregate, IT-3 was the fourth least expensive and DR-5 was ninth least expensive out of a total of eleven options considered.
INTERROGATORY NO. 4. Please explain whether, to what extent and in what manner PFS examined the wilderness and/or roadless and/or primitive character of the North Cedar Mountains roadless area, as depicted by exhibi. 2 attached to SUWA's Request for Hearing and Petition to Intervene (November 18,1998) (the " North Cedar Mountains roadless area"), when it determined the current alignment of the Low Rail Spur and/or altematives to that alignment or means of transporting casks to the proposed storage site.
APPLICANT'S RESPONSE: PFS objects to this interrogatory in that it is vague and ambiguous as to what it means by "wildemess[,] roadless [,] or primitive character." PFS did evaluate the environmental resources on the site and surrounding area of the Low Corridor rail line, including that section that crosses S'UWA's self-described "Ncrth Cedar Mountains roadless area." The findings of the environmental resources evaluation for the Low Corridor rail line, including that section that crosses SUWA's self-described " roadless area," are presented in Chapter 2 of the PFSF Environmental Report. Environmental resource issues evaluated include: geography; land use and demography; ecology; climatology and meteorology; hydrology; geology and seismology; socioeconomics; noise and traffic; and regional historic, scenic, cultural, and natural features.
Ecological resources were specifically evaluated and described for a 0.5-mile zone along both sides of the entire Low Corridor rail line. S_ce ER, Q 2.3. Ecological resources evaluated include: vegetation; wildlife; aquatic resources; threatened and endangered species; animals; and notable ecological communities. The effects of construction and 8
l l
t I
b?
operation of the Low Corridor rail line on the surrounding environment were also I
evaluated and are presented in PFSF Environmental Report. See ER, { 4.4.
Any areas of the SUWA's self-described " North Cedar Mountains roadless area" 1
that are within the 0.5-mile zone along both sides of the Low Corridor rail line were
. examined as discussed above.
INTERROGATORY NO. 5. You state that "[I]t is anticipated that the low [ sic]
corridor rail spur will be utilized by others in the Skull Valley and will not be dismantled and removed." ER at 4.6.4. Please explain the basis for this statement and discuss your assessment of the future uses of the rail spur and provide your opinion of th; likelihood that these uses willindeed occur.
APPLICANT'S RESPONSE: PFS does not have an agreement with any other party for "other" uses of the Low Corridor rail line during operation of the PFSF or future use of the rail line after the PFS's license from the NRC expires. The Low Comdor rail line, as defined in the PFS License Application, is a single purpose transportation corridor i
for the sole benefit of PFS. The statement in Environmental Report Section 4.6.4, referenced by SUWA, was an acknowledgment that the possibility exists in the future that others could find a use for the rail corridor unrelated to PFSF. Any such use, whatever that might be, would be defined, implemented and licensed, as necessary, by others. PFS -
has no plan or intent to develop any other use.
III.
DOCUMENT REQUESTS SUWA requests the Applicant to produce the following documents directly or indirectly _ within its possession, custody, and/or control:
L
. R' QUEST NO.1. All documents that are identified, referred to or used in any way in responding to any of the above interrogatories.
1 9
l.
p,
)
APPLICANT'S RESPONSE: Relevant documents used in responding to the above interrogatories will be provided in accordance with Applicant's Response to Request No. 2.
REQUEST NO. 2. All documents pertaining to SUWA's admitted contention.
APPLICANT'S RESPONSE: The documents requested will be provided during the week of May 24,1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
REQUEST NO. 3. All documents (including experts' opinions, workpapers, affidavits, and other materials used to render such opinion) supporting or otherwise relating to testimony or evidence that you intend to use or rely upon at the hearing on SUWA's admitted contention.
APPLICANT'S RESPONSE: Applicant objects to this Request as being overly broad, vague, unduly burdensome and seeking privileged material. Applicant will provide documents with respect to its witnesses as agreed to with respect to other parties.
i See Applicant's Objections and Non-Proprietary Responses to State's First Requests for Discovery, Response to General Interrogatory No. 5 (Apr. 21,1999); see also Response to Interrogatory No. 2.
REQUEST NO. 4. All docunents pertaining to and/or that were relied upon to prepare Chapter 4, section 4 (4.4) rad section 5 (4.5) of the PFS Environmental Report, including documents that substantiate the following claims made in that document: 1) there are no known wetlands or other environmentally sensitive areas along the 32 mile rail spur (4.4.1); 2) there are no unique vegetation habitat features in areas proposed for vegetation removal (4.4.2); 3) that a smvey for wildlife within 0.5 mile of the rail spur is sufficient to protect relevant wildlife (4.4.2); 4) the impact to the local population oflarge animal species from corstruction and operation of the Low Rail Spur is expected to be minimal (4.4.2); and,5) that there is a low level of recreational use of the area around the proposed Low Rail Spur (4.4.8).
10
E APPLICANT'S RESPONSE: Applicant objects to this Request as it is overly broad and requests information that is beyond the scope of SUWA Contention B as admitted by the Board. See General Objection 3. Without waiving this objection, the documents requested will be provided during the week of May 24,1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
REQUEST NO. 5. All documents pertaining to the need for, impacts of and potential success of the 40 ft wide rail spur corridor, to be constructed around the Low Rail Spur and cleared of vegetation for the purposes of preventing fires.
APPLICANT'S RESPONSE: Applicant objects to this Request as it is overly broad and requests information that is beyond the scope of SUWA Contention B as admitted by the Board. See General Objection 3. Without waiving this objection, the documents requested will be provided during the week of May 24,1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
REQUEST NO. 6. All documents pertaining to the condition or health of the public land within Skull Valley generally and over which the Low Rail Spur will traverse spect. ' ally, particularly with regard to the impacts of grazing on this land and any cumulative impacts of the PFS proposal on wildlife.
APPLICANT'S RESPONSE: Applicant objects to this Request as it is overly broad and requests infentation that is beyond the scope of SUWA Contention B as admitted by the Board. See General Objection 3. Without waiving this objection, the documents requested will be provided during the week of May 24,1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
REQUEST NO. 7. Any documents pertaining to the vegetative composition of the land within Skull Valley generally and the land over which the Low Rail Spur will traverse.
Il
L, 4
APPLICANT'S RESPONSE: Applicant objects to this Request as it is overly i
broad and requests information that is beyond the scope of SUWA Contention B as admitted by the Board. See General Objection 3. Without waiving this objection, the documents requested will be provided during the week of May 24.1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
REQUEST NO. 8. Any documents pertaining to any mitigation measures which will be implemented if and when kit fox, burrowing owl, northern hanier or ferruginous hawk nests or dens are discovered within the construction zone of the rail spur and the likelihood of success of these mitigation measures.
l APPLICANT'S RESPONSE: Applicant objects to this Request as it is overly broad and requests information that is beyond the scope of SUWA Contention B as j
admitted by the Board. See General Objection 3. Without waiving this objection, the documents requested will be provided during the week of May 24,1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
REOUEST NO. 9. Any documents pertaining to the impact of fugitive dust emissions during construction on visibility, wildlife, recreation, plant life and wildlife habitat.
APPLICANT'S RESPONSE: Applicant objects to this Request as it is overly broad and requests information that is beyond the scope of SUWA Contention B as admitted by the Board. See General Objection 3. Without waiving this objection, the documents requested will be provided during the week of May 24,1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
REOUEST NO.10. Any documents pertaining to fugitive dust emissions from the construction and operation of the fire buffer zone to be maintained in conjunction with the Low Rail Spur.
12 L
ep ie c
APPLICANT'S RESPONSE: Applicant objects to this Request as it is overly
' broad and requests information that is beyond the scope of SUWA Contention B as -
admitted by the Board. See General Objection 3. Without waiving this objection, the
. documents requested will be provided during the week of May 24,1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
REOUEST NO.11. Any documents pertaining to the impact of noise from operation and construction of the Low Rail Spur on wildlife and humans within the North Cedar Mountains roadless area.
APPLICANT'S RESPONSE: The documents requested will be provided during j
the week' of May 24,1999 to PFS's document repository at Parsons, Behle and Latimer in Salt Lake City.
Res tfully submitted, aaEbwk Jay E. Silberg Ernest L. Blake, Jr.
j Paul A.Gaukler SHAW, PITTMAN, POTTS &.
TROWBRIDGE 2300 N Street, N.W.
Washington,DC 20037 (202) 663-8000 ~
DatediMay 20,1999 Counsel for Private Fuel Storage L.L.C.
l a
13
o 00CggyED gsHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 9 N iN Before the Atomic Safety and Licensing Board Og i'
ADM In the Matter of
)
)
PRIVATE FUEL STORAGE L.L.C.
)
Docket No. 72-22
)
(Private Fuel Storage Facility)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the Applicant's Objections and Responses to SUWA's First Requests For Discovery and the Affidavits of Paul A. Gaukler, John Donnell, and Jerry Cooper 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 20th day of May 1999.
G. Paul Bollwerk III, Esq., Chairman Dr. Jerry R. Kline Administrative Judge Administrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
' Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 i
e-mail: GPB@nrc. gov e-mail: JRK2@nrc. gov and kjerry@erols.com Dr. Peter S. Lam
- Susan F. Shankman Administrative Judge Deputy Director, Licensing & Inspection 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 i
L
rq OfTice 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. 20555-0001 i
Staff e-mail: hearingdocket@nrc. gov (Original and two copies)
Catherine L. Marco, Esq.
Denise Chancellor, Esq.
Sherwin E. Turk, Esq.
Assistant Attorney General Office of the General Counsel Utah Attorney General's Office Mail Stop O-15 B18 160 East 300 South,5th 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 1 1385 Yale Avenue Salt Lake City, UT 84111 Salt Lake City, Utah 84105 e-mail: joro61@inconnect.com e-mail: john @kennedys.org Diane Curran, Esq.
Danny Quintana, Esq.
Harmon, Curran, Spielberg &
Skull Valley Band of Goshute Indians Eisenberg, L.L.P.
Danny Quintana & Associates, P.C.
1726 M Street, N.W., Suite 600 50 West Broadway, Fourth Floor Washington, D.C. 20036 Salt Lake City, Utah 84101 e-mail: deurran@harmoncurran.com e-mail: quintana @xmission.com
- By U.S. mail only O
Y Paul A.Gaukler 2
J' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety And Licensing Board In the Matter of
)
)
PRIVATE FUEL STORAGE L.L.C.
)
Docket No. 72-22
)
(Private Fuel Storage Facility)
)
ASLBP No. 97-732-02-ISFSI AFFIDAVIT OF PAUL A. GAUKLER 1, Paul A. Gaukler, being duly sworn, state as follows:
1.
I am counsel with Shaw Pittman Potts & Trowbridge in Washington, D.C.
2.
I am duly authorized to verify Private Fuel Storage's Responses to SUWA's First Requests for Discovery to Applicant Private Fuel Storage; specifically, those responses to Interrogatory Nos. I and 2.
i 3.
I certify that the statements in such responses are true and correct to the best of my personal knowledge and belief.
OM (111 Plul A.Gaukler Sworn to and subscribed before me this.1o Mday of'hfaa,1999.
Gnw&
Notary Public F
My commission expires:
f-/bloco
6 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensine Board In the Matter of
)
)
PRIVATE FUEL STORAGE L.L.C.
)
Docket No. 72-22
)
(Private Fuel Storage Facility)
)
AFFIDAVIT OF JOHN DONNELL CITY OF ENGLEWOOD
)
) SS:
STATE OF COLORADO
)
I, John Donnell, being duty sworn, states as follows:
l I am Project Director for Private Fuel Storage, L.L.C. ("PFS"). I report directly to John Parkyn, the Chairman of the Board of PFS. In my capacity as Project Director, I am responsible for the execution and integration of the legal and technical activities of the Private Fuel Storage Facility ("PFSF") project. I have read the responses to Interrogatory Nos. 3 and 5 of the Responses to SUWA's First Requests for Discovery to Applicant PFS and certify that the statem' nts in such responses are true and correct to the best of my personal k.nowledge and e
belief.
[
Jo onnell Sworn to and subscribed before me thisM day of #f4y.1999.
bk nw-Motary Public My commission expires:
ov-a/.7eod
- -_:::3
(
ll JOANNE G. MOON 3
3 NOTARY PUBUC L
ll _ _ _ STATE OF COLORAD0__ j;
~~ a.E ~..e s,. o vaimaas
_ - - ~. -
- c. a 2
g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
Before the Atomic Safety and Licentino Board
)
l l-In the Matter of
)
l
)
- PRIVATE FUEL STORAGE L.L.C.
)
Docket No. 72-22
)
(Private Fuel Storage Facility)
)
l AFFIDAVIT OF JERRY COOPER CITY OF ENGLEWOOD
)
l
) SS:
STATE OF COLORADO
)
I, Jerry Cooper, being duly sworn, states as follows:
l l
I am the Project Engineer with Stone & Webster Engineering Corporation (Stone &
Webster) for the Private Fuel Storage Facility ("PFSF'i project. Stone & Webster is the architect-engineer for the PFSF. I report to John Donnell, the Project Director for Private Feel Storage, L.L.C ("PFS"). As Project Engineer for the PFSF, I am responsible for the execution and integration of the technical activities for the project. I have read the response to Interrogatory No. 4 of the Responses to SUWA's First Requests for Discovery to Applicant PFS and certify that the statements in such response are true and correct to the best of my personal knowledge and belief.
1 lAhAU Sworn to and subscribed before me this Jo E day of Aldu 1999.
e On
. h. n
[ Notary Public
_ :_ - _.nm tre5' D M. J / - 2 AS) p NOTARY PUBLIC 3
d STATE OFCOLORADO
+
- - _ : : : : _- : :3 E, and
.s C.ed.sme Ad P'189FWG L