ML20209A817
| ML20209A817 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 06/30/1999 |
| From: | Braxton J UTAH, STATE OF |
| To: | Julian E NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20209A821 | List: |
| References | |
| CON-#399-20612 ISFSI, NUDOCS 9907060155 | |
| Download: ML20209A817 (1) | |
Text
PELATED CORRFSPONDENCE 28Mp S TATE OF UTAH OFFICE OF rHE ATTORNEY GENER AL
"=.
USNRC l
i g
'99 JUL -2 P2 36
- * <..... /
OFFh' JAN G R A ll A M R1; ATTORNEY GENER AL ADAD
'F JAMES R. SOPER REED RicHARDS PALMER DEPAutts Soknar General Clut Deputy Aftomey General Dwactor of Pubic Polcy & Commutucatons June 30,1999 1
Emile L.Julian, Assistant for Rulemakings and Adjudications Rulemakings and Adjudications Staff Office of the Secretary U.S. Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint North Mail Stop: 016G15 Washington, D.C. 20555 Re: In the Matter of Private Fuel Storage, LLC, Docket 72 I sFS I l
Dear Mr.Julian; l
Enclosed are original signed documents (plus two copies of each) which had not been l
available at the time certam State's pleadings were filed. They are:
l l
1.
Declaration of Dr. Marvin Resnikoff, dated June 22,1999, the faxed version of which was filed with the State of Utah's Request for Admission of Late-Filed Amended Utah Contention C, dated June 23,1999; and 2.
Declaration of Dr. Marvin Resnikoff, dated June 24,1999, the faxed version of which was filed with the State of Utah's Objections and Responses to Applicant's Second Set of Discovery Requests with Respect to Groups II and III Contentions, dated June 28,1999.
Please replace the faxed version of these documents with the enclosed original signed documents into the corresponding pleadings as listed above.
Please contact me with any questions at (801) 366-0287.
Thank you.
Yours truly,
Enclosures:
as stated
. _ _ 2 eLa v '7#[)
t Jean Braxton, t
cc: Service List without enclosures Legal Assistant 1
9907060155 990630 PDR ADOCK 07200022 3,
C PDR
')$0 1
160 East 300 South. 5th Flocs. P.o. Box 140873. Salt Lake City. Utah 84114 0873 Telephone: (80 ) 366 0290 Facsimile: (801) 366 0292
1 l
l l!
UNITED h.TATES OF AMERICA l
BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION l
ATOMIC SAFETY AND LICENSING BOARD in the Matter of PRIVATE FUEL STORAGE L.L.C.
(Independent Spent Fuel Doche No. 72 22 ISFSI Storage Installation)
June 22.1999 DECLARATION OF DR. MARVIN RESNIKOFF IN SUPPORT OF STATE OF UTAH'S AMENDED CONTENTION C
- 1. Dr. Marvin Resnikoff, declare under penalty of perjury that:
- l. I am the Senior' Associate at Radioactive Waste Management Associates. a private consulting firm based in New York City. On November 20.1997 and January 16.1998. I prepared declarations which were submitted to the
]
Licensi. g Board by the State of Utah in support of its contentions regarding Private Fuel Storage. L.L.C.'s proposed i
Independent Fuel Storage Installation. A statement of my qualifications was attached to November 1997 declaration.
- 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 casha PFS plans to use. I am also familiar with NRC regulations, guidance documents, and environmental studies relating to the transportation, storage, and disposal of spent nuclear power plant fuel, and with NRC decommissioning requirements.
- 3. I assisted in the preparation of the State of Utah's Amended Contention C. The technical facts presented in Amended Contention C are true and correct to the best of my knowledge, and the conclusions drawn from those itets are based on my best professional jud n ent.
s
/
{/
N
~5r. Marvin'itesnitiofV//
1 June 22.1999 1