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Category:AFFIDAVITS
MONTHYEARML20217B6861999-10-0404 October 1999 Declaration of M Resnikoff in Support of State of Utah Amended Contention V.* Declaration of M Resnikoff Re Inadequacy of Table S-4 in 10CFR51 to Address Environ Impacts of Transporting Sf.With Certificate of Svc ML20212B3661999-09-13013 September 1999 Reply Declaration of M Resnikoff in Support of State of UT Second Amended Contention Q.* Statement of Qualications Was Filed on 971120,as an Exhibit to State of UT Contentions in Proceeding ML20211M2021999-08-31031 August 1999 Declaration of Jc Pechman.* Declaration of Jc Pechman Supporting Factual Statements Contained in State of Utah Supplemental Response to Applicant Second Discovery Request (Contention L),Filed on 990831 ML20211M2121999-08-20020 August 1999 Declaration of M Resnikoff in Support of State of Utah Second Amended Contention Q.* ML20211C0091999-08-20020 August 1999 Declaration of M Resnikoff in Support of State of Utah Second Amended Contention Q.* ML20211B8581999-08-20020 August 1999 Affidavit of B Sagar.* Affidavit of B Sagar Re NRC Staff Objections & Responses to State of Utah Second Set of Discovery Requests Directed to NRC Staff Re Utah Contention K ML20211B8411999-08-20020 August 1999 Supplemental Affidavit of a Ghosh.* Supplemental Affidavit of a Ghosh Re NRC Staff Objections & Responses to State of UT Second Set of Discovery Requests Directed to NRC Staff, Pertaining to Utah Contention K ML20210S3501999-08-12012 August 1999 Errata to 990720 Declaration of Major General J Matthews, Us Air Force (Retired),Re Matl Facts in Dispute with Respect to Contention K.* Submits Errata Notification Re Paragraph 16 of 990720 Declaration.With Certificate of Svc ML20210Q6981999-08-0909 August 1999 Declaration of M Resnikoff in Support of State Response to Applicant Motion for Partial Summary Disposition of Utah Contention R.* ML20210H8111999-07-30030 July 1999 Declaration of DA Ostler.* Declaration of DA Ostler Re Review of State 990730 Response to Applicant Motion to Compel Answers to Interrogatories for Utah Contention O & Declaring That Statements Contained Herein True & Correct ML20216D6471999-07-28028 July 1999 Affidavit of Rl Sullivan Re Utah Contention R (Emergency Planning).* Affidavit Concerns Issues Related to Emergency Plan,Revised on 990519,re Private Fuels Storage ISFSI License Application.With Certificate of Svc ML20216D6411999-07-28028 July 1999 Affidavit of Pw Lain Re Utah Contention R (Emergency Planning).* Affidavit Relates to Applicant SAR & Emergency Plan,As Revised on 990519,re Fire Protection Equipment & Firefighting Capabilities ML20210C6801999-07-22022 July 1999 Affidavit of P Lain Re Contention Utah K & Confederated Tribes Contention B.* Affidavit Addresses Issues Pertaining to Wildfires as Admitted by Board with Respect to Contention.With Certificate of Svc ML20210C6761999-07-22022 July 1999 Affidavit of J Guttmann Re Contention Utah K & Confederated Tribes Contention B.* Affidavit Addresses Issues Pertaining to Wildfires as Admitted by Board with Respect to Contention ML20210E5031999-07-22022 July 1999 Declaration of MD Gray Regarding Matl Facts in Dispute with Respect to Contention K.* ML20210E4971999-07-22022 July 1999 Supplemental Declaration of Major General J Matthews,Us Air Force,(Retired) Regarding Matl Facts in Dispute with Contention K.* Submits Addl Info Relevant to Applicant Motion for Partial Summary Disposition ML20210E4771999-07-22022 July 1999 Declaration of M Resnikoff Regarding Matl Facts in Dispute with Respect to Contention K.* Addresses Risks from Private & Commercial Aircraft & Risks of Aircraft Parts or Munitions Being Dropped on Private Fuel Storage ML20210E3561999-07-22022 July 1999 Declaration of J Braxton in Support of State of Utah Amended Contention Q.* Informs That ISG-12 Was Placed on NRC Webpage on 990618.Related Correspondence ML20210E3451999-07-22022 July 1999 Declaration of M Resnikoff in Support of State of Utah Amended Contention Q.* Contention Related to Private Fuel Storage Proposed Isfsi.Related Correspondence ML20210C6701999-07-22022 July 1999 Affidavit of a Ghosh Re Contention Utah K & Confederated Tribes Contention B.* Affidavit Addresses Applicant Motion as Motion Relates to Issues Pertaining to Whether Credible Hazard to Proposed ISFSI Posed by Events or Conditions ML20210E4901999-07-20020 July 1999 Declaration of Major General J Matthews,Us Air Force, (Retired) Regarding Matl Facts in Dispute with Respect to Contention K.* ML20209H7041999-07-19019 July 1999 Affidavit of to Matula Concerning Contention UT G (Qa).* Responds to Applicant Motion for Summary Disposition of Utah G, Filed on 990628 by Private Fuel Storage.With Certificate of Svc ML20210M4251999-07-19019 July 1999 Declaration of J Cooper.* Declaration of J Cooper Verifying Applicant Amended Response to State Second Requests for Discovery (Group I),Specifically Utah Contention M Interrogatory 1 ML20210B3601999-07-19019 July 1999 Affidavit of Jd Parkyn,Per 10CFR2.790 Re State Proprietary Responses to Applicant Second Set of Discovery Requests for Groups II & III Contentions.* ML20209H7351999-07-19019 July 1999 Affidavit of SR Abt Concerning Contention Utah M.* Affidavit Re Application Motion for Summary Disposition of Utah Contention M & Statement of Matl Facts on Which No Genuine Dispute Exists. with Certificate of Svc ML20209G7291999-07-16016 July 1999 Affidavit of EP Easton Concerning Contention Utah B.* Applicant Motion Reviewed.Statement of Material Facts Attached to Motion Correct.With Certificate of Svc ML20210B1661999-07-16016 July 1999 Declaration of Bw Hawley.* Declaration of Bw Hawley with Respect to Documents in Exhibit A,Which Consists of Memo from Hill Air Force Base to D Downs,Div of Solid & Hazardous Waste, ML20210B1411999-07-16016 July 1999 Declaration of M Resnikoff.* Declaration of M Resnikoff on Utah Contention B Re License Needed for Intermodal Transfer Facility ML20209E4621999-07-0707 July 1999 Declaration of J Donnell.* Declaration of J Donnell Verifying Applicant Supplemental Response to Ogd First Set of Discovery Requests,Specifically,Response to Interrogatory 3 ML20212J5871999-07-0101 July 1999 Affidavit of CE Gaskin Re Contentions UT Security A,B & C.* Affidavit Prepared in Response to Applicant Motion for Summary Disposition of Contentions Utah Security a & B & Partial Summary Disposition for C.With Certificate of Svc ML20196G1131999-06-28028 June 1999 Declaration of J Johns.* Provides Declaration in Support of Motion for Partial Summary Disposition of Contention UT R in Listed Proceeding ML20196G5541999-06-28028 June 1999 Declaration of Jg Thorgersen.* Supports Motion of Summary Disposition of Utah G.With Certificate of Svc ML20196K5251999-06-28028 June 1999 Declaration of Davis.* Declaration of Davis Verifying Applicant Response to State Second Requests for Discovery, Specifically,Response to Interrogatory 5 with Respect to Utah Contention DD ML20196K5321999-06-28028 June 1999 Declaration of Jd Parkyn.* Declaration of Jd Parkyn Verifying Applicant Response to State Second Requests for Discovery,Specifically,Responses to Request for Admission 2 with Respect to Utah Contention E & ML20196K5351999-06-28028 June 1999 Declaration of E Supko.* Declaration of E Supko Verifying Applicant Response to State Second Requests for Discovery, Specifically,Responses to Request for Admission 3 with Respect to Utah Contention E ML20196K5401999-06-28028 June 1999 Declaration of J Cooper.* Declaration of J Cooper Verifying Applicant Response to State Third Requests for Discovery, Specifically,Response to Request for Admissions 14-15 with Respect to Utah Contention ML20196K5461999-06-28028 June 1999 Declaration of B Ebbeson.* Declaration of B Ebbeson Verifying Applicant Response to State Third Requests for Discovery,Specifically,Response to Interrogatories 5 (Last Paragraph only),8 & 9 with Respect to Utah Contention L ML20196K5491999-06-28028 June 1999 Declaration of Jd Parkyn.* Declaration of Jd Parkyn Verifying Applicant Response to State Third Requests for Discovery,Specifically,Responses to Request for Admission 1- 6 with Respect to Contention E & Admission 2-4 & 7-13 ML20196K5571999-06-28028 June 1999 Declaration of P Trudeau.* Declaration of P Trudeau Verfying Applicant Response to State Third Requests for Discovery, Specifically,Response to Request for Admission 1,3 (Paragraph 2),6-21,23-24 & Interrogatories 4 & 6 ML20196K5661999-06-28028 June 1999 Declaration of RR Youngs.* Declaration of RR Youngs Verifying Applicant Response to State Third Requests for Discovery,Specifically,Response to Request for Admissions 2- 5 & Interrogatories 5,7,10-13 Re Utah Contention L ML20196K5791999-06-28028 June 1999 Affidavit of Jd Parkyn Pursuant to 10CFR2.790 Re Applicant Objections & Proprietary Responses to State Second & Third Requests for Discovery.* ML20196G0071999-06-28028 June 1999 Declaration of J Cooper.* Provides Support of Motion for Partial Summary Disposition of Contention ML20196F9811999-06-28028 June 1999 Declaration of Gh Liang.* Provides Support of Motion for Summary Disposition of Contention Utah M in Listed Proceeding ML20196F1481999-06-25025 June 1999 Affidavit of J Guttmann Re Contention UT H (Inadequate Thermal Design).* Affidavit Prepared in Response to Applicant Motion for Partial Summary Disposition of UT Contention H.With Certificate of Svc ML20196G0651999-06-24024 June 1999 Declaration of R Srinivasan.* Provides Support of Motion for Partial Summary Disposition of Contention UT R in Listed Proceeding Re Ability of Transstor Sf Storage Cask ML20209A8361999-06-24024 June 1999 Declaration of M Resnikoff.* Declares That Statements Contained in State of UT Objections & Response to Applicant Second Set of Discovery Requests,Are True & Correct ML20196G0481999-06-22022 June 1999 Declaration of M Resnikoff in Support of State of Utah Amended Contention C.* Declaration of M Resnikoff Re Preparation of State of Utah Amended Contention C ML20196A9191999-06-14014 June 1999 Declaration of J Johns.* Declaration of J Johns in Support of Motion for Partial Summary Disposition of Contention Utah K to Show That Smoke from Distant Fire or Explosion Would Pose No Significant Hazard to Pfsf ML20195G3911999-06-11011 June 1999 Declaration of Ja Vincent.* Declaration of Ja Vincent in Support of Pfs Motion for Summary Disposition of Contention Utah B to Show That There Exists No Genuine Issue as to Any Matl Fact Relevent to Contention ML20195F5451999-06-11011 June 1999 Declaration of M Ladd.* Declaration of M Ladd in Support of Motion for Summary Disposition of Contentions Utah F & P to Show That Pfs Training & Certification Program for Pfs Facility Satisfies Requirements of Subpart I of 10CFR72 1999-09-13
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217J9611999-10-22022 October 1999 Order (Granting Motion for Leave to File Reply).* State 991021 Motion for Leave to File Reply to 991018 Pfs & Staff Responses Re Admission of late-filed,amend Contention Utah V Granted.With Certificate of Svc.Served on 991022 ML20217L8541999-10-21021 October 1999 State of Utah Motion for Leave to Reply to Applicant & Staff Responses to State of Utah Request for Admission of late- Filed Amended Utah Contention V.* NRC Staff Do Not Oppose Motion.With Certificate of Svc ML20217E9281999-10-18018 October 1999 NRC Staff Response to State of Utah Request for Admission of late-filed Amended Utah Contention V.* Staff Submits That Contention V Should Be Rejected on Grounds That Contention Untimely Filed Without Good Cause.With Certificate of Svc ML20217E9691999-10-18018 October 1999 Applicant Response to State of Utah Request for Admission late-filed Amended Utah Contention V.* Recommends That State of Utah Request Should Be Denied as Untimely.With Certificate of Svc ML20212M0201999-10-0707 October 1999 Order (Schedule for Responses to Request for Admission of late-filed,amended Contention).* Responses to Amended Utah Contention V Shall Be Filed on or Before 991018. with Certificate of Svc.Served on 991007 ML20217B6741999-10-0404 October 1999 State of Utah Request for Admission of late-filed Amended Utah Contention V.* Amended Contention V Both Admissible & Meets Commission Standard for Late Filed Contentions & Should Be Admitted ML20217B6821999-10-0404 October 1999 Notice of Change of Address.* Submits Listed Address Change for C Nakahara ML20217B6861999-10-0404 October 1999 Declaration of M Resnikoff in Support of State of Utah Amended Contention V.* Declaration of M Resnikoff Re Inadequacy of Table S-4 in 10CFR51 to Address Environ Impacts of Transporting Sf.With Certificate of Svc ML20217B6921999-10-0404 October 1999 Notice of Withdrawal.* Informs That DG Moquin No Longer Represents State of UT in Proceeding & Notice of Appearance Withdrawn Effectively Immediately ML20212C1701999-09-20020 September 1999 Memorandum & Order (Revised General Schedule).* Orders That Parties Should Provide Board with Joint Rept That Outlines Suggested Schedule for Estimated One to Two Day Evidentiary Hearing.With Certificate of Svc.Served on 990920 ML20212B8351999-09-20020 September 1999 Memorandum & Order (Summary disposition-related Rulings).* Applicant 990903 Motion for Reconsideration &/Or Clarification of LBP-99-35 Denied.With Certificate of Svc. Served on 990920 ML20212B8271999-09-20020 September 1999 NRC Staff Correction to NRC Staff Objections & Responses to State of UT Second Set of Discovery Requests Directed to NRC Staff.* No Affidavit Being Provided in Support of Legal Change.With Certificate of Svc.Related Correspondence ML20212B3661999-09-13013 September 1999 Reply Declaration of M Resnikoff in Support of State of UT Second Amended Contention Q.* Statement of Qualications Was Filed on 971120,as an Exhibit to State of UT Contentions in Proceeding ML20212B3491999-09-13013 September 1999 State of UT Reply to Application & Staff Oppositions Ot late-filed Second Amended UT Contention Q.* Applicants Objections to Admission of Second Amended Contention Q Without Merit & Should Be Admitted.With Certificate of Svc ML20212B8451999-09-13013 September 1999 State of UT Response to Applicant Motion for Reconsideration & Clarification of Ruling on Applicant Motion for Summary Disposition of Contention Utah K/Confederated Tribe B.* State Requests Denial of Motion.With Certificate of Svc ML20211N4821999-09-0909 September 1999 NRC Staff Response to Applicant Motion for Reconsideration & Clarification of Ruling on Applicant Motion for Summary Disposition of Contention Utah K/Confederated Tribes B.* with Certificate of Svc ML20211N4651999-09-0909 September 1999 Order (Granting Motion for Leave to File Reply).* State of Utah 990909 Motion for Leave to File Reply Granted in That State Reply to 990903 Pfs & Staff Responses Shall Be Filed by 990913.With Certificate of Svc.Served on 990909 ML20211Q9211999-09-0909 September 1999 State of Utah Motion for Leave to Reply to Applicant & Staff Response to Second Amended Contention Q.* Neither Applicant Nor Staff Oppose Subj Motion.With Certificate of Svc ML20212A4521999-09-0808 September 1999 Transcript of 990908 Prehearing Conference Private Fuel Storage,Inc in Rockville,Md.Pp 1168-1215 ML20211M5571999-09-0707 September 1999 Order (Schedule for Responses to Reconsideration/ Clarification Motion).* Orders That Party Responses Be Filed on or Before 990913.With Certificate of Svc.Served on 990907 ML20211M4051999-09-0707 September 1999 NRC Staff Position Regarding Impact of LBP-99-34 on Other Contentions.* Staff Submits That Remaining ITP-related Contentions (or Portions of Contentions) Should Be Dismissed.With Certificate of Svc ML20211M3151999-09-0707 September 1999 Joint Rept to Aslb.* Authorizes Applicant to Submit Joint Rept Re Scheduling of Nov 1999 Evidentiary Hearing,Estimate of Time Trial & Security-C Hearings in Response to 990830 Memorandum & Order.With Certificate of Svc ML20211M5691999-09-0707 September 1999 Applicant Position on Dismissal of ITP-related Contentions.* Requests That ITP-related Portions of Contentions Be Dismissed.With Certificate of Svc ML20211Q9301999-09-0707 September 1999 State of Utah Response to Impact of Board Ruling in LBP-99-34 (Utah Contention B) as Ruling May Relate to Other Admitted Contentions.* Maintains That Relevant Parts of Contentions R & Not Be Dismissed.With Certificate of Svc ML20211N4901999-09-0303 September 1999 Applicant Motion for Reconsideration & Clarification of Ruling on Applicant Motion for Summary Disposition of Contention Utah K/Confederated Tribes B.* with Certificate of Svc ML20211M5421999-09-0303 September 1999 Applicant Response to State of Utah Request for Admission of late-filed Second Amended Utah Contention Q.* Applicant Requests That Board Deny Utah Request.With Certificate of Svc ML20211M2411999-09-0303 September 1999 NRC Staff Response to State of Utah Request for Admission of late-filed Second Amended Utah Contention Q.* Recommends for Reasons Stated,That State Second late-filed Contention Q Be Rejected.With Certificate of Svc ML20211J8341999-08-31031 August 1999 State of UT Supplement Response to Applicant Second Discovery Request (Contention L).* State of UT Acceded to Applicant Request to Suppl State 990628 Discovery Request. with Certificate of Svc.Related Correspondence ML20211M2021999-08-31031 August 1999 Declaration of Jc Pechman.* Declaration of Jc Pechman Supporting Factual Statements Contained in State of Utah Supplemental Response to Applicant Second Discovery Request (Contention L),Filed on 990831 ML20211G9001999-08-30030 August 1999 Memorandum & Order (Administrative & Scheduling Matters).* Board Will Hold Telcon with Parties to Discuss Number of Administrative & Scheduling Matters Re Three Group I Issues for Litigation.With Certificate of Svc.Served on 990830 ML20211G8941999-08-30030 August 1999 Memorandum & Order (Granting Motion for Summary Disposition Re Contention Utah B).* Grants 990611 Motion for Summary Disposition of Pfs & Rendors Decision Re Contention Utah B in Favor of Pfs.With Certificate of Svc.Served on 990830 ML20211G8141999-08-30030 August 1999 Memorandum & Order (Granting in Part & Denying in Part Motion for Partial Summary Disposition Re Contention Utah K/Confederated Tribes B).* Decision Rendered in Favor of Pfs.With Certificate of Svc.Served on 990830 ML20211G8381999-08-30030 August 1999 Memorandum & Order (Denying Motion for Partial Summary Disposition of Contention Utah R).* Pfs Requests for Partial Summary Disposition on Part of Contention Utah R Denied. with Certificate of Svc.Served on 990830 ML20211E7411999-08-27027 August 1999 Memorandum & Order (Granting Motion for Summary Disposition Re Contentions security-A & security-B & Partial Summary Disposition Re Contention security-C).* Pfs Motion Granted. with Certificate of Svc.Served on 990827 ML20211E8231999-08-27027 August 1999 Memorandum & Order (Granting Motion for Summary Disposition Re Contention Utah G).* Order Granted for Reasons Given in Memo.Decision Regarding Contention Rendered in Favor of Pfs.With Certificate of Svc.Served on 990827 ML20211F0221999-08-27027 August 1999 Memorandum & Order (Granting Motion for Summary Disposition Re Contention Utah M).* Pfs Established No Genuine Issue as to Any Matl Fact & Is Entitled to Judgement in Favor as Matter of Law.W/Certificate of Svc.Served on 990827 ML20211G9031999-08-26026 August 1999 Applicant Second Supplement Response to State First Requests for Discovery.* Applicant Files Suppl Response,Per 10CFR2.740(e),to Name Addl Witness to Be Called at Hearing. with Certificate of Svc.Related Correspondence ML20211A6691999-08-23023 August 1999 Order (Schedule for Responses to Request for Admission of late-filed Second Amended Contention Utah Q).* Orders That Party Responses to State 990820 Request Be Filed on or Before 990903.With Certificate Svc.Served on 990823 ML20211B8411999-08-20020 August 1999 Supplemental Affidavit of a Ghosh.* Supplemental Affidavit of a Ghosh Re NRC Staff Objections & Responses to State of UT Second Set of Discovery Requests Directed to NRC Staff, Pertaining to Utah Contention K ML20211B8581999-08-20020 August 1999 Affidavit of B Sagar.* Affidavit of B Sagar Re NRC Staff Objections & Responses to State of Utah Second Set of Discovery Requests Directed to NRC Staff Re Utah Contention K ML20211B9701999-08-20020 August 1999 State of Utah Request for Admission of late-filed Second Amended Utah Contention Q.* for Stated Reasons,Second Contention Q Should Be Admitted.With Certificate of Svc. Related Correspondence ML20211C0091999-08-20020 August 1999 Declaration of M Resnikoff in Support of State of Utah Second Amended Contention Q.* ML20211A5701999-08-20020 August 1999 NRC Staff Objections & Responses to State of UT Second Set of Discovery Requests Directed to NRC Staff.* Staff Objects to State Discovery Requests.State Has Not Complied with NRC Regulations.With Certificate of Svc.Related Correspondence ML20211A5821999-08-20020 August 1999 NRC Staff Second Suppl Response to State of UT First Set of Discovery Requests Directed to NRC Staff.* Staff Reiterates & Renews Each Objection to State Discovery Requests.Related Correspondence ML20211M2121999-08-20020 August 1999 Declaration of M Resnikoff in Support of State of Utah Second Amended Contention Q.* ML20210S4791999-08-17017 August 1999 Order (Granting Motion for Leave to File Reply Pleading).* State 990816 Motion to File Reply to Pfs 990806 Response Granted in That State Has Up to 990818 to File Reply.With Certificate of Svc.Served on 990817 ML20210U3061999-08-16016 August 1999 State of Utah Motion for Leave to Reply to Applicant Response to Amended Contention Q.* Moves for Leave to Reply to Applicant 990806 Response to Request for Admission of late-filed Amended Contention Q.With Certificate of Svc ML20210S3501999-08-12012 August 1999 Errata to 990720 Declaration of Major General J Matthews, Us Air Force (Retired),Re Matl Facts in Dispute with Respect to Contention K.* Submits Errata Notification Re Paragraph 16 of 990720 Declaration.With Certificate of Svc ML20210Q6721999-08-10010 August 1999 State of Utah Supplemental Answers to Applicants General Interrogatories (Utah Contention R).* State Suppls Discovery Responses to General Interrogatories 3,4 & 5.With Certificate of Svc.Related Correspondence ML20210M4511999-08-0909 August 1999 Order (Granting Motion for Leave to File Reply to Response).* Grants State of Utah 990806 Motion for Leave to File Reply to NRC Staff 990805 Response.With Certificate of Svc.Served on 990809 1999-09-09
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July 22,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PRIVATE FUEL STORAGE, LLC ) Docket No. 72-22-ISFSI
)
(Independent Spent )
Fuel Storage Installation) )-
AFFIDAVIT OF PAUL LAIN CONCERNING CONTENTION UTAH K AND CONFEDERATED TRIBES CONTENTION B I, Paul Lain, having first been duly sworn, do hereby state as follows:
- 1. My name is Paul Lain. I am employed as a Fire Protection Engineer in the
' Licensing and International Safeguards Branch, Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Materials Safety and Safeguards, U.S. Nuclear Regulatory Commission (NRC), )
in Washington, D.C. A statement of my professional qualifications is attached hereto.
- 2. This Affidavit is prepared in response to " Applicant's Motion for Partial Summary ;
i Disposition of Utah Contention K and Confederated Tribes Contention B" (Motion), filed on
- June 7,1999, by Private Fuel Storage L.L.C. (Applicant or PFS), and the " Statement of Material Facts" attached thereto. In particular, this Affidavit addresses issues pertaining to wildfires as I admitted by the Board with respect to this contention.
- 3. I have reviewed the portion of the Applicant's Motion which pertains to wildfires (Motion at 18-20), the Affidavits of Carlton Britton (and his Febmary 8,1999 report), Jerry Cooper, Krishna Singh, and Ram Srinivasan, filed with the Applicant's motion. I have also 9907270008 990722 PDR '
l ADOCK 07200022
,. PDR
,4 reviewed those portions of the Statement of Material Facts which pertain to wildfires (11 El-Ell).
I have also reviewed peninent sections of the Applicant's Safety Analysis Report, and the NRC Staff's Position Concerning Group I Contentions, dated June 15, 1999, with respect to fires external to the facility (Id. at 16). In addition, I have read and am familiar with the Affidavit of Jack Guttmann, attached hereto.
- 4. Based on my review of the Applicant's Motion and documents attached thereto, and the Affidavit of Jack Guttmann, I am satisfied that the Applicant's Statement of Material Facts with respect to wildfires (ji El-E10) is correct. I do not agree with Material Fact TEll (which states, "the threat a fire might pose to systems at the PFSF other than those important to safety -
is irrelevant to the licensing of the PFSF"). However, I do agree that the threat a wildfire might pose to systems at the PFSF other than those important to safety would not pose a significant hazard to the facility that would rer. ult in a release of radioactive material. In this regard, while the SAR should be revised to reflect the Applicant's evaluation of wildfires pursuant to 10 C.F.R.
f 72.92, I am satisfied that wildfires are bounded by the design basis fire discuned in Safety Analysis Report { 8.2.5 and that wildfires do not pose a threat to the safe operation of the facility.
I i
=
,o .
- 5. I hereby certify that the foregoing is true and correct to the best of my knowledge, information and belief.
~
/. _" ._.
Paul Lain Subrcribed and sworn to before me this 22nd day of July,1999.
NOTA NML eu ,
Notary Public '
My commission expires: Awk l. [O9 3 1
i i
l l
a = ..
I Paul W. Lain, P.E.
Statement of Professional Qualifications Mr. Lain is a board certified professional engineer with more than 15 years of experience in fire protection -
engineering. He has held technical and project management positions for the U.S. Navy, Department of Energy (DOE), and the Nuclear Regulatory Commission (NRC). He has conducted inspections on aircraft carriers, battleships, plutonium and uranium manufacturing facilities, and a nuclear waste storage facility.
He has conducted over 100 shipboard fire tests to test the effectiveness of smoke control systems onboard naval vessels. - He was the fire protection expert on multiple Operational Readiness Reviews for DOE nuclear facilities. Mr. lain authored the Fire Protection Chapter of the Standard Review Plan for NRC fuel cycle facilities, and conducted the fire protection review for the re-licensing of the Nuclear Fuel Services facility in Tennessee. Currently, Mr. Lain currently conducts all fire protection licensing reviews for fuel fabrication facilities licensed by the NRC.
j EDUCATION Bachelor of Science in Fire Protection Engineering from the University of Maryland,1983 Master of Science in Fire Protection Engineering from Worcester Polytechnic Institute,1996 PROFESSIONAL EXPERIENCE From 1983 to 1991, Mr. Lain was a fire protection engineer for the Fire Protection Systems Branch of the Naval Sea Systems Command. He was the project manager for many research projects pertaining to fire protection onboard U.S. naval ships and submarines. He conducted over 100 large scale fire tests onboard the navy's test vessel USSX Shadwell, to determine the feasibility of active smoke control utilizing the existing shipboard ventilation system. He performed fire protection inspections and design reviews on a variety of naval vessels.
- From 1991 to 1997, Mr. Lain was a fire protection engineer for the Division of Nuclear Material and .
Facility Stabilization at DOE. Mr. Lain was the fire protection subject matter expert for reviews of Safety .
Analysis Reports (SARs) at Rocky Flats Environmental Technology Site and Idaho National Engineering Laboratory, for Operational Readiness Reviews of F-Canyon, FB-Line, and the Inter Tank Processing facilities at the Savanna River Site, and the Fire Protection Vulnerability Review of Y12 and K25 facihues ;
at Oak Ridge. j Since May of 1997, Mr. Lain has been a fire protection engineer for the NRC Office of Nuclear Materials Safety and Safeguards, in the Licensing and International Safeguards Branch. He conducts fire safety reviews for fuel cycle facilities licensed by the NRC and is the NRC project manager for the Siemens Power Corporation facility in Richland, Washington. Additional duties have included the development
, of the Fire Safety Chapter of the Standard Review Plan for fuel cycle facilities, inspection of Oak Ridge
. National Laboratory's Research and Engineering Development Center for the DOE Pilot Study, and l inspection of the Gaseous Diffusion Plant at Paducah, KY.
MEMBERSHIPS l
Mr. Lain is a member of the National Fire Protection Association (NFPA) and has served on several standards committees of the NFPA. He is a licensed professional engineer in the State of Maryland. i
DOCKETED UNITED STATES OF AMERICA US4RC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND 1.ICENSING BOAS JUL 23 P2 :01 In the Matter of ) ons
) Rm ,
y PRIVATE FUEL STORAGE L.L.C. ) Docket No. 72 /22 ISFSI
)
(Independent Spent )
Fuel Storage Installation) )
CERTIFICATE OF SERVICE I hereby certify that copies of the "NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR ' PARTIAL
SUMMARY
DISPOSITION OF UTAH CONTENTION K AND CONFEDERATED TRIBES CONTENTION B" in the above captioned proceeding have been served on the following through deposit in the Nuclear Regulatory Commission's internal mail system, or by deposit in the United States mail, first class, as indicated by an asterisk, with copics by electronic mail as indicated, this 22nd day of July,1999:
G. Paul Bollwerk, III, Chairman Atomic Safety and Licensing Board Panel Administrative Judge -
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Secretary (E-mail copy to GPB@NRC. GOV) ATTN: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline Washington, DC 20555 Administrative Judge (E-mail copy to:
Atomic Safety and Licensing Board HEARINGDOCKET@NRC. GOV)
U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Cemmission Appellate
- (E-mail copy to JRK2@NRC. GOV) Adjudication Mail Stop: 16-C-1 OWFN Dr. Peter S. Lam U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555
. Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission James M. Cutchin, V Washington, DC 20555 Atomic Safety and Licensing Board l
(E-mail copy to PSL@NRC. GOV) U.S. Nuclear Regulatory Commission
- l. Washington, DC 20555
- (by E-mail to JMC3@NRC. GOV) l l
l
Danny Quintana, Esq.* Diane Curran, Esq.*
'Danny Quintana & Associates, P.C. Harmon, Curran, Spielberg 68 South Main Street, Suite 600 & Eisenberg, L.L. P.
Salt Lake City, UT 84101 1726 M. Street N.W., Suite 600 (E-mail copy to quintana @Xmission.com) Washington, D.C. 20036 (E-mail copy to 1 Jay l E. Silberg, Esq.* deurran@harmoncurran.com)
Ernest Blake, Esq.* '
Paul A.' Gaukler, Esq.* John Paul Kennedy, Sr., Esq.*
SHAW, PITTMAN, POTTS & 1385 Yale Ave.
TROWBRIDGE -
Salt Lake City, UT 84105
- 2300 N Street, N.W. (E-mail copy to john @kennedys.org)
Washington, DC 20037-8007-(E-mail copies to . jay _silberg, Joro Walker, Esq.*
paul _gaukler, and ernest _blake Land and Water Fund of the Rockies
@shawpittman.com) 2056 East 3300 South, Suite 1 Salt Lake City, UT 84109 Denise Chancellor, Esq.* - (E-mail copy to joro61@inconnect.com)
. Fred G. Nelson, Esq.-
' Utah Attorney General's Office , Richard E. Condit, Esq.
160 East 300 South,5th Floor Land and Water Fund of the Rockies P.O. Box 140873- 2260 Baseline Road, Suite 200 Salt Lake City, UT 84114-0873 Boulder, CO 80302 (E-mail copy to dchancel@ State.UT.US) (E-mail copy to rcondit@lawfund.org)
Connie Nakahara, Esq.*
Utah Dept. of Environmental Quality 168 North 1950 West -
P. O. Box 144810
' Salt Lake City, UT 84114-4810 (E-mail copy to cnakahar@ state.UT.US)
$W .Wanza Catherine L. Marco Counsel for NRC Staff