ML20216C972

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Forwards Original Declarations Which Had Not Been Available at Time State of Utah Reply to NRC Staff & Applicant Response to State of Utah Contentions a Through DD Was Filed on 980116
ML20216C972
Person / Time
Site: 07200022
Issue date: 03/10/1998
From: Braxton J
UTAH, STATE OF
To:
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20216C977 List:
References
CON-#198-18871 ISFSI, NUDOCS 9803160253
Download: ML20216C972 (2)


Text

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STATE OF UTAH OF FICE OF.TH E ATTOR N EY GEN ER AL iCKETED l

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ATTORNEY GENER AL R1 i

CAnot CLAWSON REED RicHARDS PALMER DEPAutis Sonctor General Chet Deputy Aitomey General Chelof Staff March 10,1998 Attn: Docketing & Services Branch Office of the Secretary U.S. Nuclear Regulatory Commission Mail Stop: 016G15 11555 Rockville Pike, One White Flint North Rockville, MD 20852-2738 Re: In the Matter of Private Fuel Storage, LLC, Docket 72-22 Dear Madam / Sir; Enclosed are original Declarations which had not been available at the time " State of Utah's Reply to the NRC Staff's and Applicant's Response to State of Utah's Contentions A through DD" was filed on January 16,1998. The Declarations accompanying that original pleading were faxed versions by Lawrence A. White, PE, Exhibit 1 to the pleading, and by Dr.

Marvin Resnikcff, Exhibit 2.

Please replace the faxed versions of those Declarations with the enclosed original Declarations.

Enclosed also is a copy of the first page of this pleading for your convenience. Many thanks for your assistance.

Yours truly, i

an,0 1xton, Legal Assistant l

Enclosures:

as stated

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9903160253 900310 PDR ADOCK 07200022 C

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160 East 300 South,5th Floor, P.o. Box 140873, Salt Lake City, Utah 84114-0873 Telephone: (801) 366 0290 Facsimile: (801) 366 0292 g3

2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of:

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Docket No. 72-22 ISFSI

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PRIVATE FUEL STORAGE, LLC

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ASLBP No. 97-732-02-ISFSI (independent Spent Fuel

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Storage Installation)

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January 16,1998 STATE OF UTAH'S REPLY TO THE NRC STAFF'S AND APPLICANT'S RESPONSE TO STATE OF UTAH'S CONTENTIONS A THROUGH DD In accordance with the Licensing Board's Memorandum and Order of January 6,1998, the State of Utah heieby replies to the Responses filed by the Staff and the Applicant on December 24,1997, and the supplemental response filed by the Applicant on January 6,1998, with respect to State of Utah Contentions A through DD. With respect to contentions regarding general NEPA issues, the intermodal transfer site, l

financial assurance, and ISFSI design, this Reply is supported by the Declaration of Lawrence A. White, PE, Executive Vice-President and Senior Project Manage, of

. Versar, Inc., attached hereto as Exhibit 1. With respect to Contentions regarding fdlure to comply with NRC dose limits; insdequate facditation of decommissioning; inadequate thermal design; inadequate inspection and mai'ntenance safety components, such as canisters and cladding; inadequate training; inadequate quality assurance l

program; lack of a procedure for verifying presence of helium in canisters; and failure -

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