ML20217B686

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

ML20217B686
Person / Time
Site:	07200022
Issue date:	10/04/1999
From:	Resnikoff M RADIOACTIVE WASTE MANAGEMENT ASSOCIATES, UTAH, STATE OF
To:
Shared Package
ML20217B679	List: ML20217B674 ML20217B686
References
ISFSI, NUDOCS 9910130026
Download: ML20217B686 (4)

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UNITED STATES OF AMERICA BEFORE THE U.S. NUCLEAR REG ULA'IORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of

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PRIVATE FUEL STORM 3E, LLC.

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(Independent Spent Puel

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Docket No. "12 22-ISFSI Stonge InstaBadon

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October 4,1999 DACI.ARATION OF DR. MARVIN RESNIKOFF IN SUPPORT OF STATE OF UTAH'S AMENDED CONTENTION V 1, Dr. Marvin Resnikoff, declare ureder penalty of perjury that

1. I am the Senior Associate at Radioactive Waste Mana6cment Associates, a private

_ consulting Gem based in New York City. On November 20,1997 andJanuary 16,1998,1 prepa desdne which were submitted to the Licensing Board by the State of Utah in support ofits contentions regarding Privaw Puel Storage, LLC.'s proposed Independent Spent Puel Storage Ins **%%. I assisted in the preparation of State of Utah's original Contention V, which was submitted on November 23,1997. A statement ofmy qualrfications was attached to the November 1997 declatstion.

2. I am famdiar with Pnvate Fuel Stomge's ("PFS's") license application and Safety Analysis Report in this proceeding, as well as the applications for the storsge 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 decommissioning requirements. I have extensive professional experience in the areas of nuclear waste storage, transportation, and disposal.

3. I assisted in the preparation of the State of Utah's Amended Contention V. 'Ihe technical facts presented in Amended Contention V are true and correct to the best ofmy knowledge, and the conclusions drawn from those facts are based on my best professional judgment.

4. If Amended Contention V is admitted for litigation, I would testify regarding my opinion of the inadequacy of Table S-4 in 10 C.F.R. Part 51 to address the environmental impacts l

of tunsporting spent nuclear power plant fuel through the Wuatch Front, including Salt Imke City, i

Amended Contention V provides a summary of the testimony I would give, based on the inforsnation that has been prended to date. Iwould expect to be able to expand upon and refine my ttstimony, after having an opportunity to review materials produced by the Applicant and the NRC Staffin discovery.

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O CERTIFICATE OF SERVICE OCT -^ 81 E

I hereby cenify that copies of STATE OF UTAH'S REQUE ADMISSION OF LATE-FILED AMENDED UTAH CONTENTION OTIC q

OF WITHDRAWAL, and NOTICE OF CHANGE OF ADDRESS were serve on.

the persons listed below by electronic mail (unless otherwise noted) with conforming copies by United States mail first class, this 4'h day of October,1999:

Rulemaking & Adjudication Staff Sherwin E. Turk, Esq.

Secretary of the Commission -

Catherine L. Marco, Esq.

U. S. Nuclear Regulatory Commission Office of the General Counsel Washington D.C. 20555 Mail Stop 15 B18 E-mail: hearingdocket@nrc. gov U.S. Nuclear Regulatory Commission (originaland two copies)

Washington, DC 20555 E-Mail: set @nrc. gov G. Paul Bollwerk, III, Chairman E-Mail: clm@nrc. gov Administrative Judge E-Mail: pfscase@nrc. gov

- Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Jay E. Silberg, Esq.

Washington, DC 20555 Ernest L. Blake,Jr.

E-Mail: gpb@nrc. gov Shaw, Pittman, Potts & Trowbridge 2300 N Street, N. W.

Dr. Jerry R. Kline Washington, DC 20037-8007 Administrative Judge E-Mail: Jay _Silberg@shawpittman.com Atomic Safety and Licensing Board E-Mail: ernest _blake@shawpittman.com U. S. Nuclear Regulatory Commission E-Mail: paul _gaukler@shawpittman.com Washington, DC 20555 E-Mail: jrk2@nrc. gov John Paul Kennedy, Sr., Esq.

E-Mail: kjerry@erols.com

. Salt Lake City, Utah 84105 1385 Yale Avenue Dr. Peter S. Lam E-Mail: john @kennedys.org Administrative Judge Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, DC 20555 E Mail: psl@nrc. gov

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Joro Walker, Esq.

James M. Cutchin Land and Water Fund of the Rockies Atomic Safety and Licensing Board 2056 East 3300 South Street, Suite 1 Panel Salt Lake City, Utah 84109 U.S. Nuclear Regulatory Commission E-Mail: joro61@inconnect.com Washington, D.C. 20555-0001 E-Mail: jmc3@nrc. gov Danny Quintana, Esq.

(electronic copy only)

Danny Quintana & Associates, P.C.

68 South Main Street, Suite 600 Office of the Commission Appellate Salt Lake City, Utah 84101 Adjudication E-Mail: quintana @xmission.com Mail Stop: 16-G-15 OWFN U. S. Nuclear Regulatory Commission Washington, DC 20555 (United States mailonly) aa40 Laurl Lockhartr-Assistant Attorney General State of Utah 15 t