ML20212G046
| ML20212G046 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 09/20/1999 |
| From: | Braxton J UTAH, STATE OF |
| To: | Julian E NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#399-20847 ISFSI, NUDOCS 9909290063 | |
| Download: ML20212G046 (3) | |
Text
J AN GR AH AM ATTORNEY GENER AL j
JAMES R. SoPER REED RcHARDs PALMER DEPAuus Sohenar General Chief Deputy Atterney General Drector of Pubhc Pokey & Commutucations September 20,1999 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: Ol6G15 Washington, D.C. 20555 Re: In the Matter of Private Fuel Storage, LLC, Docket 72-22 Dear Mr.Julian; I
Enclosed is the original signed Reply Declaration ofDr. Marvin Resnileoffin Support ofState ofUtah's Second Amended Contention Q (plus two copies of each), dated September 13,1999, which was not available at the time State of Utah's September 13,1999 Reply to Applicant and Staff Oppositions to Late-filed Second Amended Utah Contention Q was filed by the State in the above mentioned proceeding.
Please replace the unsigned version of this declaration with the enclosed original declaration.
Please contact me with any questions at (801) 366-0287. Thank you.
urs truly, gd stant
Enclosures:
as stated j
cc: PFS Docket 72-22 ISFSI Service List, without enclosures 9909290063 990920 PDR-ADOCK 0720007 C
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160 East 300 South,5;h Floor. P.o. Box 140873, Salt Lake C6ty, utsih 84114 0873 Telephone: ;601) 366 0290 Facsimile: (801) 366-0292
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BEFORE THE U.S. NUCLRAR REGULATORT ATOMIC SAFETY AND LICENSING BOARD l
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1 In the Matter of
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Docket No. 72-22-ISFSI PRIVATE FUEL STORAGE, LLC.)
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(Independent Spent Fuel
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j Storage Installation
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September 13,1999 1
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l REPLY DECLARATION OF DR. MARVIN RESNIKOFF IN SUPPORT OF STATE OF UTAH'S SECOND AMENDED CONTENTION Q 1, Dr. Marvir. Resnikoff, declare under penalty of perjury that:
- 1. I am the Senior Associate at Radioactive Waste Management Associates, a private consulting firm based in New York City. I am an expert in the field of nuclear waste transportation, storage, and disposal. A copy of my statement of qualifications was filed on November 20,1997, e 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 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 regulaticas, guidance documents, and environmental studies relating to the transportation, storage, and disposal of spent nuclear power plant fuel, and with NRC decommissioning 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 professional judgment.
- 4. I also assisted in the preparation of the State of Utah's Reply to the Applicant's and NRC c.ff's Responses to Late-Filed Second Amended Contention Q. The technical 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 professional judgment.
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- r. Marvin Resnikoff[7 September 13,1999
- Dr. Resnikoffis traveling and unavailable to send his signed Declaration for filing toady.
The original will be filed on Dr. Resnikoff's return.