ML20217E066
| ML20217E066 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 10/12/1999 |
| From: | Braxton J UTAH, STATE OF |
| To: | Julian E NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#499-20905 ISFSI, NUDOCS 9910190065 | |
| Download: ML20217E066 (1) | |
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-stM S'T A T E O F -.U T A H O
cE OF THE ATTORNEY GENER A!,
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' ATTORNEY GENER AL ADJU-JAMES R. SOPER REED RcHARos PALMER DEPauus Schenor General CluolDem AmomeyGeneral
,ector of PutAc Pohey & C: _
October 12,1999
. Emile L.Julian, Assistant for Rulemakings and Adjudications Rulemakings and Adjudications Staff Office of the Secretary U.S. Nuclear Regulatory Commission 11555 Rockville Pike, Or.e 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; Enclosed is the original Declaration ofDr. Marvin Resnikoffin Support ofState ofUtah 's Amended Contention V(plus two copies of each), dated October 4,1999, which was not available at the time State of Utah's October 4,1999 Request for Admisdon of Late-Filed Amended Utah Contention V was filed by the State in the above mentioned proceeding.
Please replace the faxed version of this declaration with the enclosed original declaration.
e Please contact me with any questions at (801) 366-0287. Thank you.
Yo rs truly, y
Br gal Assistant
Enclosures:
as stated cc: PFS Docket 72-22-ISFSI Service List, without enclosures v?t0190065 991012 d)
PDA ADOCK 07200022 C
PDR 160 East 300 South,5th Floor, P.o. Box 140873, Salt Lake City, Utah 84114 0873
. Telephone: (801) 366 0290 Facsimile: (801) 366 0292
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UNITED STATES OF AMERICA j
BEFORE THE U.S. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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PRIVATE FUEL STORAGE, L.L.C.
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(Independent Spent Fuel
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Docket No. 72-22-ISFSI i
Storage Installation
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1 October 4,1999 DECLARATION OF DR. MARVIN RESNIKOFF IN SUPPORT OF STATE OF UTAH'S AMENDED CONTENTION V 1, Dr. Marvin Resnikoff, declare under penalty of perjury that:
- 1. I on the Senior Associate at Radioactive Waste Management Associates, a private consulting firm based in New York City. On November 20,1997 andJanuary 16,1998,1 prepared declarations which were submitted to the Licensing Board by the State of Utah in support ofits contentions regarding Private Fuel Storage, LLC.'s proposed Independent Spent Fuel Storage Installation. I assisted in the preparation of State of Utah's original Contention V, which was submitted on November 23,1997. A statement of my qualifications was attached to the November 1997 declaration.
- 2. I am familiarwith 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 regulations, guidance documents, and environmental
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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. The technical facts presented in Amended Contention V are true and correct to the best of my 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 of transporting spent nuclear power plant fuel through the Wasatch Front, including Salt Lake City.
Amended Contention V provides a summary of the testimony I would give, based on the information that has been provided to date. hmuld expect to be able to expand upon and refine my testimony, after having an opportunity to review materials produced by the Applicant and the NRC Staffin discovery.
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. Marvin ns'nikdk'
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October 4,1999
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