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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
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
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
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
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
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.*
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
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
ML20210B1411999-07-16016 July 1999
Declaration of M Resnikoff.* Declaration of M Resnikoff on Utah Contention B Re License Needed for Intermodal Transfer Facility
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,
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
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
ML20196G5541999-06-28028 June 1999
Declaration of Jg Thorgersen.* Supports Motion of Summary Disposition of Utah G.With Certificate of Svc
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
1999-09-09
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Text
f l
D UNITED STATES OF AMERICA BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION :
AJOMIC SAFETY AND LICENSING BOARD I
) l In the Matter of )
) Docket No. 72-22-ISFSI l PRIVATE FUEL STORAGE, L.L.C. ) ,
(Independent Spent Fuel )
Storage Installation ) September 13,1999
)
REPLY DECLARATION OF DR. MARVIN RESNIKOFF IN SUPPORT OF STATE OF UTAII'S SECOND AMENDED CONTENTION Q l
1, Dr. Marvin Resnikoff, declare under penalty of perjury that:
- 1. I am the Senior Associate at Radioactive Waste Management Associates, a privatnonsulting firm based in New York City. I am an expert in the field of nuclear wde ransportation, storage, and disposal. A copy of my statement of qualifications was filed on November 20,1997, as an exhibit to the State of Utah's contentions in this proceeding.
- 2. I am familiar with Private Fuel Storage's ("PFS's") license application and l Safety Analysis Report in this proceeding, as well as the applications for the storage and transportation casks 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 decorrunissioning requirements.
- 3. On August 20,1999, I prepared a declaration which was submitted in support of the State of Utah's Request for Admission of Late-Filed Second Amended Contention Q (August 20,1999). The declaration attested to the fact that the technical facts presented in the contention are true and correct to the best of my knowledge, and that the opinions expressed therein are based on my best professionaljudgment.
- 4. I also assisted in the preparation of the State of Utah's Reply to the Applicant's and NRC Staf1's Responses to Late-Filed Second Amended Contention Q. The technical l
9909200067 990913 PDR ADOCK 07200022 C PDR
r facts presented in that pleading are true and correct to the best of my knowledge, and the conclusions drawn from those facts are based on my best professionaljudgment. 1 i
l l
- Dr. Marvin Resnikoff September 13,1999 i i
- Dr. Resnikoffis traveling and unavailable to send his signed Declaration for filing ;
toady. The original will be filed on Dr. Resnikoffs retum. l l
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,